Title VI

COLUMBIA COUNTY PUBLIC TRANSPORTATION
TITLE VI POLICY STATEMENT AND MISSION

Columbia County Public Transportation is committed to ensuring that no person is excluded from participation in, or denied the benefits of, or be subject to discrimination in receipt of its services or programs on the basis of race, color, national origin, or any other characteristic protected by law, including Title VI of the Civil Rights Act of 1964, as amended. Further, under the Americans with Disabilities Act (ADA) of 1990, no entity shall discriminate against an individual with a physical or mental disability in connection with the provision of transportation services.

Columbia County Public Transportation’s primary goal is to ensure all management, staff, contractors, local agencies, and service beneficiaries are aware of the provisions of, and responsibilities derived from Title VI of the Civil Rights Act of 1964 and the Federal Transit Administration (FTA) Circular 4702.1B of 2012.

Columbia County Public Transportation’s Title VI policy is responsible for providing leadership, direction, and policy to ensure compliance with Title VI, Environmental Justice, and Limited English Proficiency principles. This policy also ensures that social impacts to communities and people are recognized and considered throughout the transportation planning, and decision-making process.

To obtain more information on Columbia County Public Transportation’s nondiscrimination obligations or to file a Title VI complaint, contact Columbia County Public Transportation at:

Columbia County Public Transportation                                         Email: info@ccptransit.org

507 Cameron Street                                                                             By phone: 509-382-1647

Dayton, WA 99328                                                                              By Fax: 509-382-3004

You may file a written complaint no later than 180 days after the date of the alleged discrimination. Information on non-English alternative formats may be obtained from our office 509-382-1647.

La informaci6n sobre formatos altemativos que no estån en inglés se puede obtener en nuestra oficina al
509-382-1647

David Ocampo,
General Manager

Phone: 509-382-1647 – Fax: 509-382-3004

Any person who believes they have been aggrieved by an unlawful discriminatory practice under Title VI has a right to file a formal complaint with Columbia County Public Transportation. Any such complaint must be in writing and filed with Columbia County Public Transportation within one hundred, eighty (180) days following the date of the alleged discriminatory occurrence. Title VI Discrimination Complaint Forms may be obtained from the Columbia County Public Transportation office at:  507 W Cameron Street Dayton Washington 99328 (at no cost to the complainant), on the WEBSITE  at ccptransit.org, by calling 509-382-1647 or by faxing 509-382-3004. Columbia County Public Transportation’s website includes the Title VI policy and complaint form. Please contact our office if information is needed in another language at 509-382-1647.


TITLE VI COMPLAINT PROCEDURE:

How to file a Title VI Complaint:
Any person who believes they have been discriminated against on basis of race, color, or national origin by Columbia County Public Transportation may file a Title VI complaint by completing and submitting a signed Title VI Complaint Form which can be accessed at www.ccptransit.org or by requesting a copy from Columbia County Public Transportation staff at:

507 W Cameron street
Dayton, Washington 99328
or by calling (509)-382-1647

The complaint should include the following information:

• Your name, mailing address, and how to contact you (i.e., telephone number, email address, etc.)
• 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 complaint may be filed in writing at the following address:    

Columbia County Public Transportation

507 West Cameron
Dayton Washington 99328

By Phone: (509) 382-1647

By Fax: (509) 382-3004

An original, signed copy must be mailed to Columbia County Public Transportation as soon as possible, but no later than 180 days from the alleged date of discrimination if you submit through this format. Email: info@ccptransit.org

NOTE: Columbia County Public Transportation encourages all complainants to certify all mail that is sent through the U.S. Postal Service and/or ensure that all written correspondence can be tracked easily.

What happens to your complaint after it is submitted?:
All complaints alleging discrimination based on race, color or national origin in a service or benefit provided by Columbia County Public Transportation will be directly addressed by Columbia County Public Transportation staff who will review it to determine the jurisdiction of the complaint. Columbia County Public Transportation shall also provide appropriate assistance to complainants, including those persons with disabilities, or who are limited in their ability to communicate in English.

Additionally, Columbia County Public Transportation shall make every effort to address all complaints in an expeditious and thorough manner. In instances where additional information is needed for investigation of the complaint, Columbia County Public Transportation will in writing ask for additional information that will help in the investigation of the complaint. Once sufficient information for investigating the complaint is received by Columbia County Public Transportation, a written response will be drafted subject to review by the transit’s attorney. If appropriate, Columbia County Public Transportation attorney may administratively close the complaint. In this case, Columbia County Public Transportation will notify the complainant of the action as soon as possible.

How vou will be notified of the outcome of your complaint:
Columbia County Public Transportation will send a final written response letter by the transit’s attorney and advise you (complainant) of your right to:

1)     Appeal within seven calendar days of receipt of the final written decision to the Board of The Columbia County Public Transportation and/or:

2)             File a complaint externally with the U.S. Department of Transportation and/or the Federal Transit Administration. Every effort will be made to respond to Title VI complaints within seven working days of receipt of such complaints, if not sooner.

In addition to the complaint process described above, a complainant may file a Title VI complaint with the following offices:

Washington State Department of Transportation
Public Transportation Division
Attn: Title VI Coordinator
PO Box 47387
Olympia, WA 98504-7387
WSDOT TITLE VI ONLINE COMPLAINT FORM

Federal Transit Administration Office of Civil Rights
Attention: Title VI Program Coordinator East Building, 5^th Floor— TCR
1200 New Jersey Ave., SE
Washington, DC 20590
FTA ONLINE TITLE VI COMPLAINT FORM

United States Department of Justice
Civil Rights Division
Coordination and Review Section — NWB
950 Pennsylvania Avenue NW
Washington DC, 20530
DOJ ONLINE COMPLAINT FORM

RECORD OF TITLE VI OR OTHER CIVIL RIGHTS INVESTIGATIONS,
COMPLAINTS, OR LAWSUITS:
To date, there have been no Title VI investigations, complaints, or lawsuits at Columbia County Public Transportation.

PUBLIC PARTICIPATION PLAN AND SUMMARY OF EFFORTS:
Purpose:  The purpose of this Public Participation Plan (PPP) is to establish procedures that encourage the full participation of all citizens in the Columbia County Public Transportation service area, including but not limited to, low-income and minority individuals, and those with limited English proficiency.  While traditional means of soliciting public involvement may not reach such individuals, or might not allow for meaningful avenues of input, the intent of this effort is to take reasonable actions throughout the planning process to provide opportunities for historically under-served populations to participate.  Additionally, as members of the Palouse Regional Transportation Planning Organization (PRTPO), Columbia County Public Transportation closely partners with them on their established Transportation Improvement Plan (TIP), and Public Participation Plan (PPP) which satisfies our requirements as part of serving the same community.

This document will lay out procedures to provide opportunities for all area citizens to participate in the development of short and long term plans for Columbia County Public Transportation. Where appropriate, Columbia County Public Transportation will make improvements to its public participation system.

A notice will be posted in the local newspapers and on the Columbia County Public
Transportation website noting the existence of this PPP and a copy will be sent, at a minimum, to stakeholders identified in this document.

Goals and Objectives:
The goal of the PPP is to offer opportunities for the engagement of all citizens of Columbia County Public Transportation’s Service Area to participate in the development of short and long term plans.

In support of this goal, our objectives are to determine what non-English languages, and other cultural barriers exist to public participation within Columbia County Public Transportation’s Service Area.  To provide a general notification of meetings, particularly forums for public input, in a manner that is understandable to all populations in the area;

•        To hold meetings in locations which are accessible and reasonably welcoming to all area residents, including, but not limited to, low-income and minority members of the public; o To provide avenues for a two-way flow of information and input from populations that are not likely to attend meetings;

•        To provide a framework of actions to encourage public participation in the development of various types of plans and programs, as well as amendments or alterations to any such plan or program;

•  And to use various illustrative visualization techniques to convey the information including, but not limited to, charts, graphs, photos, maps, and the internet.

Identification of Stakeholders:

Columbia County Public Transportation stakeholders are those who are either directly or indirectly affected by a plan, or the recommendations of that plan. Those who may be adversely affected, or who may be denied the benefits of a plan’s recommendation(s) are of particular interest in the identification of specific stakeholders. Stakeholders are broken down into several groups: general citizens, minority and low-income persons, public agencies, private organizations and businesses.

Columbia County Public Transportation Service Area:

When accessing data from the 2020 census, unfortunately for Columbia County it shows 0% of our population use public transportation. Columbia County Public Transportation collects data through Shah dispatch software. This software has been used by Columbia County Public Transportation since January 12^th of 2008. Since Columbia County Public Transportation operates under demand-response, the need to collect additional information from the passenger is presented, therefore, creating detailed data from the population that is served.

General Citizens:

According to our Shah dispatch software data there are 1,044 residents in Columbia County Public Transportation Benefit Area using our services. 2020 Census Bureau data indicates that 94.8% of the population speaks English at home, 4.2% speaks Spanish and most other languages account for less than 1% or less of the remainder. While the most current data indicates that the entire Service Area averages to lower than the Title VI threshold, there are 10 census tracts over the threshold, with some having as much as 25% of their population speaking Spanish as their first language. Because of this, Columbia County Public Transportation maintains that providing materials in Spanish will remain a priority.

Some of the techniques that can be used to engage the general population are public notices of meetings in the local newspaper, via social media channels, and on the radio. These meetings can be held as open house format public information meetings in locations such as the public library or the Columbia County Public Transportation facilities. Staff will also continue to utilize on-board surveys, focus groups, and use of local media and the internet to encourage participation from the public.

Minorities:

Columbia County’s total population according to 2020 census is 3,952, Columbia County Public Transportation serves 1,044 of that population. In accordance to the 2020 Census Data for Columbia County, the population by race is as follows, White 3,652, Black 15, American Indian/Alaskan 59, Asian 43, Pacific Islander 55, and Hispanic 286.Engaging minority and low-English proficiency populations can be a challenge. Language and cultural differences may not be compatible with the more traditional means of engaging the public in the planning process. Currently, the General Manager is fluent in Spanish and offers translation services if needed. Participation in the Palouse Regional Transportation Planning Organization and meetings with representatives from local human services organizations allows us to garner input from specific segments of the population. Columbia County Public Transportation provides in-house translation services and utilizes the services of a telephone language line.

Low-Income:
The 2020 Census Bureau data listed the per capita income for Columbia County as $57,249, which was well below the state’s per capita income of $67,126. Median household income in Columbia County was $57,249, well below the state’s $77,006. The percentage of persons living at or below the Federal Poverty Level in Columbia County was 12.6% compared to 9.5% for the state and 11.4% in the nation.

While low-income individuals may have access to all of the traditional means of public involvement discussed earlier in the section of “general citizens,” they may be less likely to become involved or offer input. Some methods of gathering input either directly or indirectly from this population includes on-board surveys and the involvement of agencies such as the local employment offices, housing groups, and public assistance providers that work with low-income individuals and families.

Public Agencies:
Public agencies can provide valuable input in the planning process. Pertinent public agencies include those that have clients who fall into the under-represented populations, including but not limited to minorities, low-income, and limited English proficiency households. All of these agencies have insight into the transportation needs of their clients and are useful partners in overcoming barriers that may not be understood by professionals dealing more directly with the provision of services.

Private Organizations and Businesses:
Private organizations and businesses offer several perspectives that are valuable to our planning processes. Columbia County Public Transportation has extensive contact with service providers who work closely with the developmentally disabled and elderly populations who often cross over into the low-income, minority, and limited English proficiency demographic(s).

Outreach Efforts:
Columbia County Public Transportation board approved public participation/public notification policies. In addition to the processes set out in this policy, staff may use the following techniques during its planning studies as deemed appropriate:

1.     Presentations to professional, citizen, and other organizations.

2.     Articles in community newspapers.

3.    Press releases and meetings with local media representatives.

4.    Informational conversations with individuals and small groups.

5.     Interviews with individuals who are or may be affected by proposed plans.  User and non-user surveys.

6.     Use of illustrative visualization techniques to convey the information including, but not limited to, charts, graphs, photos, maps, and the internet.

During any planning process the public is invited to contact Columbia County Public  Transportation with comments and/or to request additional information. Requests can be made via telephone by contacting:  Columbia County Public Transportation Customer Service at 509-382-1647, through the CONTACT FORM at ccptransit.org, or through email to info@ccptransit.org. Comments will be collected, documented, and presented to the Columbia County Public Transportation Board of Directors.  Columbia County Public Transportation does not record social media interactions as part of the formal public comment process but does maintain an archive of all interactions on their social media channels.

SUMMARY OF PUBLIC PARTICIPATION EFFORTS:
Community Outreach is a requirement of Title VI. Recipients and sub-recipients shall seek out and consider the viewpoints of minority and low-income populations in the course of conducting public outreach. Recipients have wide latitude to determine what specific measures are most appropriate and should make this determination based on the composition of the affected population, the public involvement process, and the resources of Columbia County Public Transportation.  Columbia County Public Transportation has engaged the public in its planning and decision-making processes, as well as its marketing and outreach activities.

Transit Development Plan (TDP):
The Transit Development Plan is a requirement of the Washington State Legislature, (RCW 35.58.2795). The Plan is prepared by the independent transit properties and turned into WSDOT. A summary document is prepared which shows the size of the fleet, costs, revenue, service revenue hours, revenue miles, expense, and capital expenditures. Public hearings are held to obtain comments from the public on the TDP Community Outreach is a requirement of Title VI. Recipients and sub-recipients shall seek out and consider the viewpoints of minority and low-income populations in the course of conducting public outreach. Recipients have wide latitude to determine what specific measures are most appropriate and should make this determination based on the composition of the affected population, the public involvement process, and the resources of Columbia County Public Transportation.

Transit Improvement Plan (TIP):
Another document called the Transit Improvement Plan is prepared and is used by cities and counties. The TIP is a planning document that only addresses capital projects and improvement projects in cities and counties. All TIPS from local jurisdictions (counties and cities) as well as the transits feed into a Regional TIP which is required by the federal government. If an item we wish to purchase is not in the TIP, it cannot be funded. TIP is only for capital projects and represents the capital section of the Transit Development Plan. Although TIP is a federal requirement, it goes through the region and the state. Public hearings are held to obtain comments from the public on the TIP.

Board Meetings:
Board meetings are held every two months on the 3^rd  Thursday of the month. The meetings are posted on our web site www.ccptransit.org, advertised in the local newspaper and posted at our administration offices located at 507 Cameron Street, Dayton Washington.

Public Meetings:
Public meetings are held when necessary and are advertised in the local newspaper, on our web site ccptransit.org and posted at our administration offices located at 507 Cameron Street, Dayton Washington.

Major Service Change:
Same as Public meetings.

Fare Increase:
Same as Public meetings.

Staff Training:
Columbia County Public Transportation’s staff has experience communicating in an ethnically diverse environment. Several employees come to the job with multi-lingual skills.  Agency training and internal planning will continue to note the need to consider persons with limited English proficiency in communicating transportation information and providing or partnering for language assistance for LEP persons to support and encourage their participation in the planning activities.

Given the proliferation of smart phone and expansion of Internet access, even among low-income populations, Columbia County Public Transportation is also exploring the potential to use more online community education and engagement tools that allow people to participate in the planning process without having to physically attend workshops or meetings, and whether those tools can be cost-effectively translated to Spanish or other non-English languages.

Customer Comment Process:
Those residing in the Columbia County Public Transportation Benefit Area may call our Office at 509-382-1647 to lodge a complaint, compliment, or comment. All complaints, compliments, and comments are entered into a database and distributed to the relevant department manager. The manager researches the complaint and if appropriate responds back to the citizen (if valid contact information is given). This database allows complaints to be sorted by type and maintains a separate log for Title VI and ADA complaints.

Columbia County Public Transportation tracks complaint type, the date of the complaint, the investigation, any legal action taken, a summary of the allegation(s), the status of the complaint, and a summary of any actions taken in response to the complaint.

All information is tracked until the complaint, investigation, and/or legal action has been closed. The records are then stored according to state and federal records retention requirements. Tracked information (such as Title VI or ADA) will be reported to the FTA and/or WSDOT as the grantors of public funds.

General Awareness and Phone Surveys:
Columbia County Public Transportation conducts bilingual (English and Spanish) onboard rider and general awareness surveys in conjunction with updates to the Transit Improvement Plan. These personal one-on-one surveys allow riders to convey any concerns or comments they have regarding services.

Bilingual Outreach:
Columbia County Public Transportation provides Spanish speaking clients with bilingual information on public transit services. Staff assistance is utilized in outreach programs and offered for programs and public meetings.

Community Events: Columbia County Public Transportation participates in community or civic events, as appropriate, to raise awareness of its Demand Response services.

Senior Center: Columbia County Public Transportation participates in senior center events, as appropriate, to ensure participants are aware of our Demand Response services.

LIMITED ENGLISH PROFICIENCY OUTREACH PLAN:
Columbia County Public Transportation is committed to breaking down language barriers by implementing consistent standards of language assistance across its service area.

Census:
The United States is home to millions of national origin minority individuals who are Limited English Proficiency (LEP). That is, their primary language is not English and they cannot speak, read, write or understand the English language at a level that permits them to interact effectively with recipients of Federal financial assistance. Because of language differences and the inability to effectively speak or understand English, persons with LEP may be subject to exclusion from programs or activities, experience delays or denials of services. These individuals may be entitled to language assistance with respect to a particular type of service. The federal government and those receiving assistance from the federal government must take reasonable steps to ensure that LEP persons have meaningful access to the programs, services, and information those entities provide. This will require agencies to establish creative solutions to address the needs of this ever-growing population of individuals, for whom English is not their primary language. To determine the need to provide language assistance for non-English speaking individuals, information was gathered from ridership surveys, social service agencies, and local school districts.

ANALYSIS OF FACTORS:
Factor No. 1: The number or proportion of LEP persons in the service area.  Most of the population with which we do business (individuals wishing to ride transit) are proficient in English, so intensive LEP services are not normally required. According to the 2020 Census Data for Columbia County, English is spoken by 94.8% of Columbia County. Spanish speaking in the household represents 5.2% of the non-English speaking in Columbia County.

Factor No. 2: The frequency with which LEP individuals come into contact with the service.

(All) contacts with Columbia County Public Transportation are made through our dispatching services. We serve LEP persons via our on-call Demand Response and Rideshare services. The Customer Service representatives speak and translate in person or over the phone a total of approximately one to two times a year. Columbia County Public Transportation also provides  ^“Language Line” services and uses Google Translate to communicate as needed.  Language assistances and document translation services are also available upon request.

Factor No. 3: The nature and importance of service provided by Columbia County Public Transportation.

Columbia County Public Transportation provides important transit services to the public through our on-call Demand Response and Rideshare services. Our system is a demand response service which means that customers call in to us and we provide transportation to and from the destination that they request within our guidelines.

Factor No. 4: The resources available to the recipient of the federal funds to assure meaningful access to the service by LEP persons.

Columbia County Public Transportation’s current in-house language capabilities are  Spanish. Experienced staff are fluent in Spanish. Currently, Columbia County Public Transportation teaches our Spanish-speaking passengers how to ride the bus through training and one on one assistance with a staff person who can speak their language. Columbia County Public Transportation makes all documents, publications, and special notices of public meetings available in Spanish. If the language is something other than Spanish, the following guidelines will be followed:

1.     Columbia County Public Transportation will have the Census Bureau’s “I Speak Cards” available at the Columbia County Public Transportation operations building. Although staff may not be able to provide immediate translation assistance, we will utilize the cards to identify language needs.

2.     If an interpreter is needed immediately, in person or on the telephone, staff will use “l Speak Cards” to help determine what language assistance is needed. Staff shall then contact Language Line for assistance. On the Language Line webpage, staff will select the Need an Interpreter Now link and follow the directions to receive an access code.

3.     Columbia County Public Transportation will add to our webpage the Title VI Policy and Complaint Procedures.

4.     Columbia County Public Transportation will educate our staff on the following procedures.

a.     Understanding the Title VI Policy and LEP responsibilities.

b.     How to access language assistant services via Language Line.

c.     Document language assistance requests.

d.     The procedure if a Tile VI and or LEP complaint is filed.

IMPLEMENTATION PLAN:
Columbia County Public Transportation currently has implemented its plan and will review it on a triennial basis unless a Title VI complaint necessitates reviewing it sooner. Columbia County Public Transportation will continue to identify LEP persons in the service area by ridership, telephone contact counts, neighborhood demographics, general awareness surveys, and board surveys. Per CFR 21.9(d) Columbia County Public Transportation maintains postings of statements of rights, and a policy statement, for Title VI beneficiaries.

DISPARATE IMPACT AND DISPROPORTIONATE BURDEN POLICY:
In the course of performing an analysis of a Major Service Change, Columbia County Public Transportation must consider how proposed actions will impact minority (as compared to non-minority) populations. In the event that proposed action(s) have a negative impact that affects minorities more than non-minorities with a disparity that exceeds 20% compared to the same impacts borne by non-minority populations. Columbia County Public Transportation must evaluate whether there is an alternative that may result in a more equitable impact. Otherwise, Columbia County Public Transportation must take measures to mitigate the impact of the proposed action on the affected minority population and demonstrate that a legitimate business purpose can not otherwise be accomplished and that the proposed change is the least discriminatory alternative.

This policy also establishes a threshold for determining whether a given action has a disproportionate burden on low-income populations versus non-low-income populations. The Disparate Impact and Disproportionate Burden Policy apply only to low-income populations that are not also minority populations. The threshold for Columbia County Public Transportation to determine Disproportionate Burden impacts of a Major Service Change borne by the low-income population is 20% compared to the same impacts borne by non-low-income populations.

MINORITY REPRESENTATION TABLE

MINORITY REPRESENTATION ON COMMITTEES:
Columbia County Public Transportation does not currently have non-elected citizen committees, but holds open public meetings once every two months, agenda and publishing additional special notices when any policy or practice changes are being discussed are always posted on our website, buses and available at our facilities.

CONSTRUCTION PROJECT EQUITY ANALYSIS:
Over the last three years Columbia County Public Transportation has not completed a construction project requiring an environmental assessment (EA) or environmental impact statement (EIS) but is aware of the Title VI requirements to conduct equity analyses for all facility construction projects, during the planning state. Columbia County Public Transportation will follow all requirements under the National Environmental Policy Act and other overarching planning processes to guide equitable consideration of facility sites and their impacts. A facility that results in Disparate Treatment may have substantial legitimate justification and lack of other alternatives. If so, both must be demonstrated in the planning process.

PASSED AND ADOPTED by the Board of Columbia County Public Transportation Authority, State of Washington, on this 20^th day of April 2023.