Okaloosa County BOCC — March 4, 2014 — Title VI and Nondiscrimination Policy and Limited English Proficiency (LEP) Plan

TITLE VI PLAN Okaloosa County Board of County Commissioners August 2011 March 2014 Update  Title VI and Nondiscrimination Policy and Plan Including Limited English Proficiency (LEP) This Title VI Plan has been developed pursuant to Title VI of the Civil Rights Act of 1964, FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients”. Section 601 of Title VI of the Civil Rights Act of 1964 states the following: No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance. Prepared by Okaloosa County Board of County Commissioners Updated March 4, 2014 1 I. Title VI Policy Statement Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI of the Civil Rights Act of 1964, as amended, “protects any person in the United States on the ground of race, color, or national origin from being excluded from participation, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity receiving Federal financial assistance from the Department of Transportation” (42 U.S.C. Section 2000d). Okaloosa County Board of County Commissioners (BCC) is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et. seq. This plan was developed to guide the BCC in its administration and management of Title VI related activities. Title VI Coordinator Contact Information: Okaloosa County Board of County Commissioners Transit Coordinator & Grants Manager 600 Transit Way Fort Walton Beach, FL 32547 Okaloosa County Board of County Commissioners County Administrator Growth Management Director Transit Coordinator & Grants Manager 2 II. Compliance Plan – General Requirements: A. Title VI Notice to the Public, including a list of locations where the notice is posted: Title VI of the Civil Rights Act of 1964 and supplemental legislation prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that "no person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance" (42 U.S.C. Section 2000d). The Okaloosa County Board of County Commissioners will not discriminate on the basis of race, color, national origin, sex, age, handicap/ disability or income status. No person may be treated unfavorably, excluded from participating in or denied the benefits of any County program or activity because of their race, color, national origin, age, sex, handicap/ disability or income status. If you feel you are being denied participation in or being denied benefits of the transit services provided by OCT, or otherwise being discriminated against because of your race, color, or national origin, you may contact our office at 850-833-9173 or complete below Title VI Complaint form and forward via fax (833-9168) or mail (Attn: Title VI Officer, 600 Transit Way, Fort Walton Beach, FL 32547). Okaloosa County BCC/Okaloosa County Transit Provider displays this Title VI Notice on our website, www.rideoct.org, and in the public areas of the Okaloosa County BCC/Okaloosa County Transit Provider office(s) including the reception desk and meeting rooms. Our Okaloosa County BCC/Okaloosa County Transit Provider brochure and user guide also has the Title VI notice in it. The Title VI Notice is also displayed on the transit vehicles and Ride Guide. Appendix A – Okaloosa County BCC/Okaloosa County Transit Provider brochures, with schedule. Title VI statement is included. B. Title VI Complaint Procedures (i.e. instructions to the public regarding how to file a Title VI discrimination complaint) How to file a Title VI Complaint The complaint shall be submitted in writing and contain the identity of the complainant; basis for the allegations (i.e., race, color, or national origin); and a description of the alleged discrimination with the date of occurrence. If the complaint cannot be submitted in writing, the complainant will contact the Title VI Office for assistance. The complete complaint should include the following information: • Your name, mailing address, and how to contact you (i.e., telephone number, email address, etc.). 3  • How, when, where and why you believe you were discriminated against. • Include the location, names and contact information of any witnesses. • Other information that you deem significant The Title VI Complaint Form (see Appendix B) may be used to submit the complaint information. The complaint may be filed in writing at the following address: Okaloosa County Board of County Commissioners Okaloosa County Transit Building Attn: Title VI Officer 600 Transit Way Fort Walton Beach, FL 32547 NOTE: It is encouraged that all complainants certify all mail that is sent through the U.S. Postal Service and/or ensure that all written correspondence can be tracked easily. For complaints originally submitted by facsimile, an original, signed copy of the complaint must be mailed to the Title VI Coordinator as soon as possible. A Spanish complaint form has also been developed. Follow up coordination for LEP individuals will be verbal correspondence with a volunteer interpreter. What happens to the complaint after it is submitted? The Title VI Officer will respond to the complaint within thirty (30) days and will take reasonable steps to resolve the matter. Should the BCC be unable to resolve the complaint, the Title VI Officer will forward the complaint, along with a record of its disposition to the Statewide Title VI Coordinator at the Equal Opportunity Office of the Florida Department of Transportation (FDOT). FDOT will assume jurisdiction over the complaint for continued processing. FDOT will inform the BCC of all results pertaining to the complaint. How will the complainant be notified of the outcome of the complaint? The Transit Coordinator & Grants Manager will send an acknowledgement letter (Appendix C). A final written response letter to the complainant will be provided notifying complainant that the complaint has been substantiated (Appendix D) or not substantiated (Appendix E). If the complaint is not substantiated the letter advises the complainant his or her right to 1) appeal within seven calendar days of receipt of the final written decision from OCT, and/or 2) file a complaint externally with the U.S. Department of Transportation. Every effort will be made to respond to Title VI complaints within 60 working days of receipt of such complaints, if not sooner. C. Title VI Complaint Form Okaloosa County BCC/Okaloosa County Transit Provider has a Complaint Form developed in compliance with FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients”. This Form is included in Appendix B. The complaint form is available on our website and is also available at the Okaloosa County BCC/Okaloosa County Transit Provider office at the Okaloosa County Transit Building, 600 Transit Way, Fort Walton Beach, FL 32547. 4 D. List of Transit-related Title VI investigations, complaints, and lawsuits There have not been any investigations, complaints, or lawsuits that pertain to allegations of discrimination on the basis of race, color, and/or national origin in transit-related activities. If there is a Title VI complaint in the future, Okaloosa County BCC/Okaloosa County Transit Provider will follow the Complaint Procedure in Section B. In addition, this complaint will be properly reported. This report shall include the date that the investigation, lawsuit, or complaint was filed; a summary of the allegation(s); the status of the investigation, lawsuit, or complaint; and actions taken by the recipient in response, or final findings related to, the investigation, lawsuit, or complaint. E. Public Participation Plan As an agency receiving federal financial assistance, the BCC has engaged the public in its planning and decision-making processes, as well as its marketing and community outreach activities. The purpose of a Public Involvement Plan is to document these public outreach efforts. Outreach efforts are an essential part of gaining input into the functionality of the local transit system. The public involvement process is a multi-pronged process that includes stakeholder meetings, household telephone surveys, an on-board transit survey, and other efforts. A detailed description of these public involvement efforts is found below. As part of this plan major outreach efforts are either done annually (when possible) or once every 5 years. Major Public Involvement Efforts (Outreach) Public outreach and solicitation of input regarding public transit in Okaloosa County is crucial to crafting a plan that is relevant and accurately reflects the performance of Okaloosa County Transit (OCT). The objective of the public involvement efforts proposed is to utilize multiple forms of outreach in order to effectively reach the target audience, which includes OCT current and potential users and operators. To meet this objective, the following efforts will be undertaken: Ø Stakeholder Meetings: Conduct stakeholder meetings in a group setting with the Transportation Disadvantaged Local Coordinating Board, senior citizens who use OCT, and other groups such as key local officials and community leaders through the Transportation Planning Organization roster. (Every 5th year) Ø Household Telephone Survey: A random household telephone survey will be conducted of Okaloosa/Walton/Santa Rosa County residents to determine their existing awareness, opinions, and needs regarding public transportation services. At least 300 surveys will be completed. (Every 5th year) Ø On-Board Transit Survey: OCT riders will have an on-board survey administered to assist in identifying transit needs, desires, issues & concerns. The survey will collect detailed demographic information & travel information about OCT bus riders, and also assess their level of satisfaction with aspects of the transit service provided. The survey will cover all bus routes and a minimum of 100 surveys will be completed. (Annually) 5 Ø Survey of OCT Staff & Bus Operators: OCT staff & bus operators will also be surveyed regarding their perception of needs, issues, and concerns with the Sunshine Bus system. (Annually) Ø Origin / Destination Analysis: An origin-destination analysis of a sampling of trips will be conducted to determine travel patterns and peak travel times. (Annually) Outreach to Low Income and Minority Communities Outreach to low-income and minority communities are addressed in the following ways. 1. Outreach to low-income and minority population will be identified through the Local Coordinating Board for the Transportation Disadvantaged. This 15 member board consisting of members from local agencies who work with the local disadvantaged population, can disseminate Title VI information through their daily contact with the low-income and minority populations they serve. 2. The placement of information items such as brochures will target areas where low-income and minority populations congregate. Local churches, community centers, the County Health Department, Work Force Development, Department of Children and Families, and public libraries are areas that have been identified for this purpose. 3. In the event a public meeting concerning OCT, at least one location will be within the area of the low-income/minority community. The meeting will also be held where those who wish to attend can use transit. Additional Outreach (The outlined outreach opportunities are in addition to the Transit Public Involvement Plan and are used for Transit program development and planning) As an agency receiving federal financial assistance, OCT has engaged the public in its planning and decision-making processes, as well as its marketing and community outreach activities. The public has been invited to participate in these activities: Transit Improvement Plan (TIP). The TIP is a fiscally constrained three-year planning document that addresses transportation projects and programs including: federal, state and local highways, transit, ridesharing, bike paths and pedestrian facilities. If an item we wish to purchase is not in the TIP, it cannot be funded. The TIP process includes public hearings and public comment periods. Communities are contacted by the TPO directly; newspaper announcements are published in the local newspaper of all meetings. Community outreach is conducted in areas where minorities and/or low-income individuals are available. OCT advertises on their revenue buses meetings and will work the clients to meetings that are outside service areas. Sign in sheets are always furnished to document attendees, information is collected to have the ability to contact individuals for future meetings. Notices always display the following “The Okaloosa-Walton TPO adheres to the Americans with Disabilities Act and will make reasonable modification for access to their meetings upon request. Please call Ms. Dorothy McKenzie at 1-800-226-8914 Ext. 230 to make a request. Requests must be received at least 48 hours in advance of any meeting in order to allow the TPO time to provide requested services.” 6  Okaloosa County Board of County Commissioners Board Meetings. The BCC holds two meetings monthly and the public is invited to attend. The meetings are advertised and can be streamed live via the internet. Public Meetings. When new service is proposed information is disseminated to the neighborhoods affected and public meetings are scheduled. Funding Applications. We submit to the Florida Department of Transportation annually an application for funding. The application requests funding for operating assistance. Should capital purchases be considered a public notice is required, which includes a 30-day public comment period. Transit Development Service Plan (TDSP). The Okaloosa County Transportation Disadvantaged Service Plan (TDSP) addresses the needs of elderly, disabled or economically disadvantaged people in Okaloosa County, and reflects a careful review of various data, travel patterns, policies, agency responsibilities and funding to define a five-year detailed implementation plan to help meet those needs. Meetings are conducted at facilities where public transit routes operate. Job Access and Reverse Commute Program (Section 5316), and New Freedom Program (Section 5317) be derived from a coordinated plan. Local entities were recruited to attend a workshop hosted by the TPO on the Section 5316 and 5317 programs. The workshop was publicly advertised in the local newspaper and community leaders were contacted individually. The BCC/ OCT also work with the Okaloosa-Walton TPO extensively to engage the public. As stated by the TPO, in order to plan for efficient, effective, safe, equitable, and reliable transportations systems, the TPO must have the input of its public. The TPO spends extensive staff and financial resources in furtherance of this goal and strongly encourages the participation of the entire community. The TPO offers a number of volunteer roles for those wishing to become more involved in the planning process. The TPO also holds a number of transportation meetings, workshops, and other events designed to gather public input on planning activities. Further, the TPO attends and participates in other community events to promote its programs and improve its name recognition in the public. F. Language Assistance Plan for providing language assistance to persons with limited English proficiency (LEP), based on the DOT LEP Guidance: Okaloosa County BCC/Okaloosa County Transit Provider Limited English Proficiency (LEP) Plan is included as Appendix F. G. Non-Elected Committees and Councils, broken down by race, and agency Okaloosa County Board of County Commission is a direct recipient of federal funding. The BCC does not have a designated transportation non-elected board at this time. 7 H. Primary Recipients shall include a description of how the agency monitors its sub recipients for compliance with Title VI, and a schedule of sub recipient Title VI Program submissions Okaloosa County Board of County Commissioners/ Okaloosa County Transit does not have sub recipients, however if that changes, they will submit an agreement to follow Okaloosa County Board of County Commissioners/ Okaloosa County Transit Title VI Plan. I. A Title VI equity analysis if the recipient has constructed a facility, such as a vehicle storage facility, maintenance facility, operation center, etc. Currently, no construction projects using FTA funds are underway and none are scheduled in the near or distant future. In the event that a construction project is programs, prior to the start of the project a Categorical Exclusion will be completed and approved by the Federal Transit Administration. A copy of the FTA’s standard CE checklist is kept on file along with the NFPA 1600 document. Prior to any future projects that may come about the following will be integrated into any required analysis: • A description of the low-income and minority population within the study area affected by the project • A discussion of all adverse effects of the project both during and after construction that would affect the identified low-income and minority population • A discussion of all positive effects that would affect the identified low-income and minority population, such as an improvement in transit service, mobility, or accessibility • A description of all mitigation and environmental enhancement actions incorporated into the project to address any adverse effects • A discussion of remaining effects, if any, and why further mitigation is not proposed • A comparison of mitigation and environmental enhancement actions that effect predominantly low-income and minority areas J. Board Minutes, Resolution, and other appropriate documentation showing the Board of Directors reviews and approved the Title VI Program This Plan was approved and the Assurances signed on March 4, 2014. Please see Appendix G. 8 III. System-wide Standards and Policies A. System-Wide Standards 1. Vehicle load for each mode: Vehicle load on average is 37% on a 14 passenger bus. 2. Vehicle Headway for each mode: Vehicle headway on average is 30 minutes. 3. On Time Performance for each mode: On time performance on average is 97% - 98%. 4. Service Availability for each mode: We provide 9 deviated fixed routes in Okaloosa County. We serve the medical community, shopping centers, banks, restaurants and other businesses in Okaloosa County. B. System-Wide Policies 1. Distribution of transit amenities for each mode: The amenities provided on the routes. As of February 2014 there are 220 total stops in the transit system. The fixed route in Okaloosa County is considered small and the number of stops, routes and amenities reflect the small size. We currently have 180 stops with bus stop signs, 5 with benches. There are 40 with missing signs that are in the process of being replaced. Okaloosa County conducted a complete bus stop accessibility compliance study in 2013 and are in the process of securing funding to make all bus stops ADA compliant or to change routes to accommodate ADA access. It is the desire of the transit provider to install more benches in the future. 2. Vehicle Assignment for each mode: Amenities are the same for all Okaloosa County Transit vehicles. All vehicles provide temperature control (heat/AC) and wheelchair lifts. There are no other available amenities. 9 IV. Conclusion Okaloosa County BCC is committed to a policy of non-discrimination in the conduct of its business, including its Title VI responsibilities, and to the delivery of equitable and accessible transportation services. Okaloosa County BCC recognizes its responsibilities to the community in which it serves and to the citizens of the county. It is the Okaloosa County BCC policy to utilize its best efforts to assure that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by Title VI. Okaloosa County BCC/Okaloosa County Transit Provider will continue to work with our community to offer services equitably and assist our customers to the extent our budget allows. 10 Appendix A Title VI of the Civil Rights Act of 1964 and supplemental legislation prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that "no person in the United States shall, on the ground of race, color, or nationall origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance" (42 U.S.C. Section 2000d). English: The Okaloosa County Board of County Commis Commissioners sioners will not discriminate on the basis of race, color, national origin, sex, age, handicap/ disability or income status. No person may be treated unfavorably, excluded from participating in or denied the benefits of any County program or activity because se of their race, color, national origin, age, sex, handicap/ disability or income status. If you feel you are being denied participation in or being denied benefits of the transit services provided by OCT,, or otherwise being discriminated against because of your race, color, or national origin, you may contact our office at 850-833-9173. Spanish La Junta de Comisionados del Condado de Okaloosa no discrimina por motivos de raza, color, origen nacional, sexo, edad, incapacidades / discapacidades o nivel de ingresos. Ninguna persona puede ser tratada desfavorablemente, excluida de participar o ser negado de los beneficios de cualquier programa o actividad Condado debido a su raza, color, origen nacional, edad, sexo, discapacidades / incapacidades o nivel de ingresos. Si usted piensa que le han negado participación o acceso a los beneficios y servicios proveídos por el Departamento de Tránsito del Condado de Okaloosa, o que ha sido discriminado por motivos de raza, color, u origen nacional, usted debe comunicarse al 850-833-9173. 9173.  Appendix B Okaloosa County Board of County Commissioners Title VI / Nondiscrimination Program Complaint of Discrimination Complainant(s) Name: Complainant(s) Address: Complainant(s) Phone Number: Complainant's Representative's Name, Address, Phone Number and Relationship (e.g. friend, attorney, parent, etc): Name and Address of Agency, Institution, or Department Whom You Allege Discriminated Against You: Names of the Individual(s) Whom You Allege Discriminated Against You (If Known): o Race o Color o National Origin Discrimination o Sex o Age o Handicap/Disability Date of Alleged Discrimination: Because Of: o Income o Retaliation o Other Status Please list the name(s) and phone number(s) of any person, if known, that the Okaloosa Board of County Commissioners could contact for additional information to support or clarify your allegation(s). Please explain as clearly as possible how, why, when and where you believe you were discriminated against. Include as much background information as possible about the alleged acts of discrimination. Additional pages may be attached if needed. Complainant(s) or Complainant(s) Representatives Date of Signature: Signature: Mail or Fax Completed Form to: Okaloosa County Transit 850-833-9173 ph Attn: Title VI Officer 850-833-9168 fax 600 Transit Way Fort Walton Beach, FL 32547  Okaloosa County Board of County Commissioners Title VI / Programa Antidiscriminatorio Querella de Discriminacion Nombre del querellante: Dirección: Número de teléfono: Nombre, dirección, teléfono y relación (ej. amigo, abogado, pariente, etc.) del Representante del querellante: Nombre y dirección de la Agencia, Institución, o Departamento que usted alega discrimino en su contra: Nombre(s) del Individuo(s) Quien(es) Usted Allega Discrimino (naron) Contra Usted Si lo(s) Conoce: o Raza o Color o Origen Nacional Fecha de la o Incapacidad/Impedimento alegada Razón de la o Sexo o Edad discriminación: Físico discriminación: o Status oRepresali o Otro de Ingreso a Favor de indicar el nombre (s) y número(s) de teléfono(s) de alguna persona(s) que La Junta de Comisionados del Condado de Okaloosa puede comunicarse para información adicional que clarifique o respalde su alegación o alegaciones. Favor de explicar tan claro como sea posible, como, porque, cuando y donde usted cree que fue discriminado. Incluya suficiente información acerca de los antecedentes según le sea posible, de los alegados actos de discrimen. Puede añadir paginas adicionales, si es necesario. Firma del Querellante(s) o su Representante: Fecha: Favor de mandar por correo electrónico o fax a: Okaloosa County Transit 850-833-9173 ph Attn: Title VI Officer 850-833-9168 fax 600 Transit Way Fort Walton Beach, FL 32547 Appendix C Letter Acknowledging Receipt of Complaint Today’s Date Mr. John Doe 123 Oak St. Fort Walton Beach, FL 32548 Dear Mr. Doe: This letter is to acknowledge receipt of your complaint against Okaloosa County Transit alleging ________________________________________________. An investigation will begin shortly. If you have additional information you wish to convey or questions concerning this matter, please feel free to contact this office by telephoning 850-833-9173, or write to me at 600 Transit Way, Fort Walton Beach, FL 32547. Sincerely, Name Title VI Coordinator Appendix D Letter Notifying Complainant that the Complaint Is Substantiated Today’s Date Mr. John Doe 123 Oak St. Fort Walton Beach, FL 32548 Dear Mr. Doe: The matter referenced in your letter of ______________ (date) against Okaloosa County Transit alleging Title VI violation has been investigated. (An/Several) apparent violation(s) of Title VI of the Civil Rights Act of 1964, including those mentioned in your letter (was/were) identified. Efforts are underway to correct these deficiencies. Thank you for calling this important matter to our attention. You were extremely helpful during our review of the program. You may be hearing from this office, or from federal authorities, if your services should be needed during the administrative hearing process. Sincerely, Name Title VI Coordinator Appendix E Letter Notifying Complainant that the Complaint Is Not Substantiated Today’s Date Mr. John Doe 123 Oak St. Fort Walton Beach, FL 32548 Dear Mr. Doe: The matter referenced in your complaint of ______________ (date) against Okaloosa County Transit (OCT) alleging _______________________________ has been investigated. The results of the investigation did not indicate that the provisions of Title VI of the Civil Rights Act of 1964, had in fact been violated. As you know, Title VI prohibits discrimination based on race, color, or national origin in any program receiving federal financial assistance. Okaloosa County Transit has analyzed the materials and facts pertaining to your case for evidence of OCT’s failure to comply with any of the civil rights laws. There was no evidence found that any of these laws have been violated. I therefore advise you that your complaint has not been substantiated, and that I am closing this matter in our files. You have the right to 1) appeal within seven calendar days of receipt of this final written decision from OCT, and/or 2) file a complaint externally with the Florida Department of Transportation: FDOT - Equal Opportunity Office Title VI/Nondiscrimination Program John Smith, Title VI Coordinator District Three – Chipley 605 Suwannee Street, M.S. 65 Tallahassee, Florida 32399 john.smith@dot.state.fl.us Phone: 850-414-4747 Fax: 850-414-4879 Thank you for taking the time to contact us. If I can be of assistance to you in the future, do not hesitate to call me. Sincerely, Name Title VI Coordinator Appendix F LIMITED ENGLISH PROFICIENCY (LEP) PLAN OKALOOSA COUNTY BOARD OF COUNTY COMMISSIONERS OKALOOSA COUNTY TRANSIT Introduction This Limited English Proficiency (LEP) Plan has been prepared to address Okaloosa County Board of County Commissioners (Okaloosa BCC) responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, Federal Transit Administration Circular 4702.1A dated May 13, 2007, which state that no person shall be subjected to discrimination on the basis of race, color or national origin. Executive Order 13166, titled “Improving Access to Services for Persons with Limited English Proficiency”, indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to all state and local agencies which receive federal funds. Plan Summary The Okaloosa County Board of County Commissioners is the recipient of FTA 5307 funding and has developed this LEP Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency who wish to access services provided by Okaloosa County Transit (OCT). OCT is a contractor to the Okaloosa County Board of County Commissioners. As defined in Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write or understand English. This plan outlines how to identify a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how to notify LEP persons that assistance is available. In order to prepare this plan, the BCC undertook the U.S. Department of Transportation (U.S. DOT) four-factor LEP analysis which considers the following factors: 1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter the BCC program, activity or service. 2. The frequency with which LEP persons come in contact with BCC programs, activities or services. 3. The nature and importance of programs, activities or services provided by the BCC to the LEP population.  4. The resources available to BCC and overall costs to provide LEP assistance. Factor 1: The Number and Proportion of LEP Persons Served or Encountered in the Eligible Service Population. Task 1, Step 1: Examine prior experiences with LEP individuals The Transit Coordinator & Grants Manager for Okaloosa County Board of County Commissioners interviewed the Okaloosa County Transit Program Manager, Operations Manager (supervisor to all field staff), and Administrative Assistant (supervisor to all administrative staff) regarding either their personal interactions with LEP Persons, or reports by their employees of daily interactions between LEPs and staff. The Administrative Assistant stated that she has worked with 2 LEPs in the last several years, one client was French who utilized her own resources to provide an interpreter and one client that spoke English, not very well, but enough to communicate. This client’s native language was Spanish. The Operations Manager acknowledged that during the summer, the local tourist area experiences an influx of foreign workers. These foreign workers use public transportation during their temporary stay in Okaloosa County. Their LEP does not emerge as a deterrent to accesses the public transit service available and many utilize the service with great ease. Okaloosa County also provides maps along with written information in their Ride Guide and OCT website. The maps can provide LEPs and individuals with limited reading capabilities where and when the routes operate (Fig. 1 and Fig. 2). Fig.1  Fig.2 Attendees of Okaloosa County Transit (OCT) affiliated community meetings and/or public hearings are requested to sign an attendance sheet. No attendees have displayed signs of LEP nor has any special accommodations been requested. OCT provides deviated fixed route service rather than ADA complementary paratransit service. Task 1, Step 2: Become familiar with the data from the U.S. Census Task 1, Step 2A: Identify the geographic boundaries of the area that your agency serves Okaloosa County provides demand response/paratransit door-to-door service to all of Okaloosa County. Fixed route service is provided in the most densely populated areas of Okaloosa County. Okaloosa County’s geography is divided by the largest Air Force Base in the world, Eglin AFB. Thus the service is divided in Northern and Southern regions with Eglin AFB in the center of the county. No fixed-route service is provided on Eglin AFB at this time. Task 1, Step 2B: Obtain Census data on the LEP population in your service area Okaloosa County, Florida Percent Subject Margin of Estimate Percent Margin of Error Error LANGUAGE SPOKEN AT HOME Population 5 years and over 171,333 +/-110 171,333 (X) English only 154,058 +/-951 89.90% +/-0.6 Language other than English 17,275 +/-953 10.10% +/-0.6 Speak English less than "very well" 6,078 +/-745 3.50% +/-0.4 Spanish 9,443 +/-598 5.50% +/-0.3 Speak English less than "very well" 3,013 +/-432 1.80% +/-0.3 Other Indo-European languages 3,694 +/-673 2.20% +/-0.4 Speak English less than "very well" 1,206 +/-373 0.70% +/-0.2 Asian and Pacific Islander 3,666 +/-451 2.10% +/-0.3 languages Speak English less than "very well" 1,672 +/-379 1.00% +/-0.2 Other languages 472 +/-196 0.30% +/-0.1 Speak English less than "very well" 187 +/-97 0.10% +/-0.1 Source: U.S. Census Bureau, 2008-2012 American Community Survey 2010 Census - Florida, Okaloosa County Population Total Population 180,822 Population by Ethnicity Hispanic or Latino 12,296 Non Hispanic or Latino 168,526 Population by Race White 146,582 African American 16,797 Asian 5,328 American Indian and Alaska Native 1,068 Native Hawaiian and Pacific Islander 354 Other 3,592 Identified by two or more 7,101 Source: Census.gov 2010 Census Data Task 1, Step 2C: Analyze the data you have collected Staff reviewed the 2010 U.S. Census Report and the U.S. Census Bureau 2008-2012 American Community Survey and determined that 17,275 persons in Okaloosa County (10 % of the population) speak a language other than English. In Okaloosa County, 6,078 persons have limited English proficiency; that is, they speak English “not well” or “not at all.” Of those persons with Limited English Proficiency, 3,013 speak Spanish, 1,206 speak one of the Indo-European languages, 1,672 speak one of the Asian and Pacific Island languages and 187 speak a language classified as other. Only the Spanish speaking LEP population reached the DOJ’s Safe Harbor Provision of 1,000 persons or 5%. Task 1, Step 2D: Identify any concentrations of LEP persons within your service area. The 2010 Census block group with the greatest concentration of LEPs is located on Eglin Air Force Base. This can be explained by the higher number of military spouses that are natives of the United States. OCT does not service Eglin Air Force Base at this time. The highest concentration area serviced is in the southern end of the county. This area, at most, has 8.5% recorded as LEPs. Task 1, Step 3: Consult state and local sources of data We consulted with the Okaloosa County School District which offers ESOL or “English for Speakers of Other Languages” programs. Total enrollment of all students in Okaloosa County in 2013-14 is 34,345. The predominant language spoken at home is English (96% of all students). 2.6% of the student population are enrolled in the ESOL program. There are 36 languages other than English reported as the predominant language spoken at home by ESOL students. Of the 2.6% ESOL students, the largest primary language reported is Spanish at 594 students or 1.9% of the total student population. Task 1, Step 4: Reach out to community organizations that serve LEP persons Task 1, Step 4A: Identify community organizations Northwest Florida State College (NWFSC) Workforce Development Board/Jobs Plus Task 1, Step 4B: Contact relevant community organizations Ms. Nancy Ordonia, Coordinator for the Adult Education Program for Northwest Florida State College was contacted Ms. Linda Sumblin, Executive Director of CareerSource Okaloosa Walton was contacted. Task 1, Step 4C: Obtain information Suggested that NWFSC utilize the OCT’s Ride Guide as part of the ESL (English as Second Language) curriculum. NWFSC, as part of their current instruction, provides lessons on public transit use. Our goal is to formulate a plan to work with NWFSC in partnership to provide classroom instruction on the local transit service. Ms. Linda Sumblin, Executive Director of CareerSource Okaloosa Walton was contacted. There is currently no demand for dual language services for clients. OCT and CareerSource (formerly JobsPlus) currently work in partnership to provide transportation to individuals who are unemployed and need transportation. There has never been a request for special accommodations from a CareerSource client. Factor 2: The Frequency with Which LEP Individuals Come into Contact with your programs, activities, and services Task 2, Step 1: Review the relevant programs, activities, and services you provide OCT provides demand response and fixed route transportation. Rarely do staff come in contact with LEP individuals, contact when made, will be made once to twice a year at which time staff is able to communicate with them by spending time and having patience to work with clients. We have not had to turn clients away due to language barriers. Should we come in contact with LEP individuals that staff cannot communicate with we will refer them to agency volunteers. If they speak an uncommon language a commercial telephonic interpretation service may be used. Task 2, Step 3: Consult directly with LEP persons The LEP persons that we are in contact with have not demonstrated a need for special accommodations. The LEPs that currently use the system are entirely self-sufficient and do not appear to have any problems with acquiring transit service. It is our goal to work with Northwest Florida State College’s ESL program to make contact with additional LEP persons regarding public transit in Okaloosa County. Factor 3: The Importance to LEP Persons of Your Program, Activities and Services Task 3, Step 1: Identify your agency’s most critical services Fixed Route service is the most critical service provided to persons with LEP. As stated earlier in this plan, Okaloosa County experiences an influx of Eastern European student workers during the summer season. These people live and work on the beach and they rely on fixed route service. We have interviewed several of them and their command of the English language is limited, but sufficient for them to be heavy users of public transportation. We do not see a need for special accommodations at this time. Task 3, Step 2: Review input from community organizations and LEP persons Over the years we have spoken with LEP persons that use our service. Though they are not native English speakers, their proficiency is enough to use public transportation in Okaloosa County. We have witnessed them at bus stops navigating the maps to determine how the system works independently. We do not see a need for special accommodations at this time. Factor 4: The Resources Available to the Recipient and Costs Task 4, Step 1: Inventory language assistance measures currently being provided, along with associated costs. Should the occasion arise that an interpreter is required agency volunteers will be utilized. There is no cost associated with this service Task 4, Step 2: Determine what, if any, additional services are needed to provide meaningful access Documents that are considered vital, such as the Title VI complaint form, notice of a person’s rights under Title VI, fare structure modifications and application forms will be printed in-house at minimal cost and made available to the LEP population. Okaloosa County BCC will also ensure the Title VI Coordinator and Chairman have reviewed the most up-to-date Title VI training available from the Federal Highway Administration and/or the Federal Transit Administration to ensure we are informed of our responsibilities. Task 4, Step 3: Analyze your budget Documents that are considered vital, such as the Title VI complaint form, notice of a person’s rights under Title VI, fare structure modifications and application forms will be printed in-house at minimal cost and made available to the LEP population. As additional funding currently is not available, printing in-house will be the most economical means of transmitting the information. Task 4, Step 4: Consider cost effective practices for providing language services Should the occasion arise, translation services would be solicited by agency volunteers. Conclusion: Developing the Right Mix of LEP Services At this time, the Okaloosa County Board of County Commissioners and Okaloosa County Transit does not see a need for LEP services beyond the translation services provided by agency volunteers and the general public transportation lessons provided in NWFSC ESL classes. We will continue to document the needs of Okaloosa County’s LEP population. Should major population fluctuations occur, we will amend our Title VI LEP Plan accordingly. Appendix G FEDERAL TRANSIT ADMINISTRATION CIVIL RIGHTS ASSURANCE THE OKALOOSA COUNTY BOARD OF COUNTY COMMISSIONERS HEREBY CERTIFIES THAT; as a condition of receiving Federal financial assistance under the Federal Transit Act of 1964, as amended, it will ensure that: 1. No person on the basis of race, color, or national origin will be subjected to discrimination in the level and quality of transportation services and transit-related benefits. 2. Okaloosa County Board of County Commissioners will compile, maintain, and submit in a timely manner Title VI information required by the most current FTA Circular and in compliance with the Department of Transportation’s Title VI regulation, 49 CFR Part 21.9. 3. Okaloosa County Board of County Commissioners will make it known to the public that those person or persons alleging discrimination on the basis of race, color, or national origin as it relates to the provision of transportation services and transit-related benefits may file a complaint with the Federal Transit Administration and/or the U.S. Department of Transportation. The person or persons whose signature appears below are authorized to sign this assurance on behalf of the grant applicant or recipient. March 4, 2014 Date______________ ______________________________________________ Charles K. Windes, Jr – Chairman Appendix H TITLE VI/ NONDISCRIMINATION POLICY STATEMENT Okaloosa County Board of County Commissioners assures the Florida Department of Transportation that no person shall on the basis of race, color, national origin, sex, age, disability, family or religious status, as provided by Title VI of the Civil Rights Act of 1964, the Civil Rights Restoration Act of 1987 and the Florida Civil Rights Act of 1992 be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination or retaliation under any program or activity. Okaloosa County Board of County Commissioners further agrees to the following responsibilities with respect to its programs and activities: 1. Designate a Title VI Liaison that has a responsible position within the organization and access to the Recipient’s Chief Executive Officer/Chairman. 2. Issue a policy statement signed by the Chief Executive Officer/Chairman, which expresses its commitment to the nondiscrimination provisions of Title VI. The policy statement shall be circulated throughout the Recipient’s organization and to the general public. Such information shall be published where appropriate in languages other than English. 3. Insert the clauses of Appendix I of this agreement in every contract subject to the Acts and the Regulations 4. Develop a complaint process and attempt to resolve complaints of discrimination against sub-recipients. Complaints against the Recipient shall immediately be forwarded to the FDOT District Title VI Coordinator. 5. Participate in training offered on Title VI and other nondiscrimination requirements. 6. If reviewed by FDOT or USDOT, take affirmative action to correct any deficiencies found within a reasonable time period, not to exceed ninety (90) calendar days. 7. Have a process to collect racial and ethnic data on persons impacted by your agency’s programs. THIS ASSURANCE is given in consideration of and for the purpose of obtaining any and all federal funds, grants, loans, contracts, properties, discounts or other federal financial assistance under all programs and activities and is binding. The person whose signature appears below is authorized to sign this assurance on behalf of the Recipient. Dated ________________ by ___________________, Chairman Appendix I POLICY STATEMENT During the performance of this contract, the contractor, for itself, its assignees and successors in interest (hereinafter referred to as the “Contractor”) agrees as follows: (1.) Compliance with Regulations: The Contractor shall comply with the Regulations relative to nondiscrimination in Federally-assisted programs of the U.S. Department of Transportation (hereinafter, “USDOT”) Title 49, Code of Federal Regulations, Part 21, as they may be amended from time to time, (hereinafter referred to as the Regulations), which are herein incorporated by reference and made a part of this Agreement. (2.) Nondiscrimination: The Contractor, with regard to the work performed during the contract, shall not discriminate on the basis of race, color, national origin, sex, age, disability, religion or family status in the selection and retention of subcontractors, including procurements of materials and leases of equipment. The Contractor shall not participate either directly or indirectly in the discrimination prohibited by section 21.5 of the Regulations, including employment practices when the contract covers a program set forth in Appendix B of the Regulations. (3.) Solicitations for Subcontractors, including Procurements of Materials and Equipment: In all solicitations made by the Contractor, either by competitive bidding or negotiation for work to be performed under a subcontract, including procurements of materials or leases of equipment; each potential subcontractor or supplier shall be notified by the Contractor of the Contractor’s obligations under this contract and the Regulations relative to nondiscrimination on the basis of race, color, national origin, sex, age, disability, religion or family status. (4.) Information and Reports: The Contractor shall provide all information and reports required by the Regulations or directives issued pursuant thereto, and shall permit access to its books, records, accounts, other sources of information, and its facilities as may be determined by the Florida Department of Transportation, the Federal Highway Administration, Federal Transit Administration, Federal Aviation Administration, and/or the Federal Motor Carrier Safety Administration to be pertinent to ascertain compliance with such Regulations, orders and instructions. Where any information required of a Contractor is in the exclusive possession of another who fails or refuses to furnish this information the Contractor shall so certify to the Florida Department of Transportation, the Federal Highway Administration, Federal Transit Administration, Federal Aviation Administration, and/or the Federal Motor Carrier Safety Administration as appropriate, and shall set forth what efforts it has made to obtain the information. (5.) Sanctions for Noncompliance: In the event of the Contractor’s noncompliance with the nondiscrimination provisions of this contract, the Florida Department of Transportation shall impose such contract sanctions as it or the Federal Highway Administration, Federal Transit Administration, Federal Aviation Administration, and/or the Federal Motor Carrier Safety Administration may determine to be appropriate, including, but not limited to: a. withholding of payments to the Contractor under the contract until the Contractor complies, and/or b. cancellation, termination or suspension of the contract, in whole or in part. (6.) Incorporation of Provisions: The Contractor shall include the provisions of paragraphs (1) through (6) in every subcontract, including procurements of materials and leases of equipment, unless exempt by the Regulations, or directives issued pursuant thereto. The Contractor shall take such action with respect to any subcontract or procurement as the Florida Department of Transportation, the Federal Highway Administration, Federal Transit Administration, Federal Aviation Administration, and/or the Federal Motor Carrier Safety Administration may direct as a means of enforcing such provisions including sanctions for noncompliance. In the event a Contractor becomes involved in, or is threatened with, litigation with a sub-contractor or supplier as a result of such direction, the Contractor may request the Florida Department of Transportation to enter into such litigation to protect the interests of the Florida Department of Transportation, and, in addition, the Contractor may request the United States to enter into such litigation to protect the interests of the United States.