Title VI Policy
It is the policy of the San Luis Obispo Council of Governments (SLOCOG) that no person shall on the grounds of race, color, or national origin be excluded from participation in, be denied the benefits of, or be subjected to discrimination in any agency operation, as provided by Title VI of the Civil Rights Act of 1964 and related statutes. This policy also prohibits discrimination on the basis of sex, disability, or age, as provided by the Older Americans Act of 1965, Federal-Aid Highway Act of 1973, and Rehabilitation Act of 1973. Similarly, Executive Orders 12898 and 13166 clarify nondiscrimination under Title VI to articulate protections for minority and low-income populations, as well as individuals with limited English proficiency.
As the metropolitan planning organization (MPO) for the San Luis Obispo region, SLOCOG is committed to making Title VI and Environmental Justice a part of our planning process, integrated in all our programs and plans, and a guide for our public participation efforts. This document establishes a framework for SLOCOG’s efforts to ensure compliance with Title VI and related statutes regarding nondiscrimination and Environmental Justice.
Póliza del Título VI
El Título VI de la Ley de Derechos Civiles de 1964 prohíbe la discriminación por motivos de raza, color u origen nacional en los programas y actividades que reciben asistencia financiera federal. Específicamente, el Título VI establece que “ninguna persona en los Estados Unidos será excluida, por motivos de raza, color u origen nacional, de la participación en, se le negarán los beneficios de, o será objeto de discriminación en cualquier programa o actividad que reciba asistencia financiera federal” (42 U.S.C. Sección 2000d).
San Luis Obispo Council of Governments se ha comprometido a garantizar que ninguna persona quede excluida de la participación en sus servicios o se le nieguen los beneficios de estos por motivos de raza, color, origen nacional, sexo, edad o discapacidad, según lo dispuesto en el Título VI y los reglamentos de aplicación conexos.
Formulario De Queja Del Título VI
El Título VI de la Ley de Derechos Civiles de 1964 exige que “Ninguna persona en los Estados Unidos será excluida, por motivos de raza, color, origen nacional, sexo, edad o discapacidad, de la participación en, se le negarán los beneficios de, o será objeto de discriminación en cualquier programa o actividad que reciba asistencia financiera federal”. Si siente que ha sido discriminado en los servicios de la San Luis Obispo Council of Governments (SLOCOG por sus siglas en inglés), por favor proporcione la siguiente información para ayudarnos a procesar su queja
Procedure For Filing a Complaint
How do I file a Title VI Complaint?
If you believe that you have been discriminated against because of your race, color, national origin, sex, age, or disability, you may file a signed written complaint up to thirty (30) days from the date of the alleged discrimination.
The complaint should include the following information:
- Your name, mailing address, and how to contact you (i.e., telephone number, email address).
- How, when, where, and why you believe you were discriminated against, including location as well as the names and contact information of any witnesses.
- Other information that you deem significant.
Complaints may be filed with SLOCOG’s Title VI Officer using the Title VI Complaint Form at the following address:
Title VI Coordinator
San Luis Obispo Council of Governments
1114 Marsh Street
San Luis Obispo, CA 93401
What happens to the complaint after it is submitted?
To ensure compliance with both FHWA’s and FTA’s implementation of Title VI, all complaints received will be forwarded to the Caltrans Office of Civil Rights (OCR) and investigated internally. Copies of complaints will be forwarded to Caltrans OCR via email ([email protected]) within one business day of receipt by SLOCOG. Caltrans OCR will coordinate with the local FHWA division office as needed to conduct an independent investigation.
During its concurrent internal investigation, SLOCOG will provide appropriate assistance to complainants, including persons with disabilities and people who need language assistance. SLOCOG will make every effort to address all complaints in an expeditious and thorough manner. SLOCOG’s internal investigation may also result in the complaint being forwarded to the FTA Office of Civil Rights. A letter acknowledging receipt of the complaint will be mailed within thirty (30) days. Please note that complainants must respond to requests for additional information. Failure to do so may result in SLOCOG’s closure of the complaint.
How will the complainant be notified about the outcome of the complaint?
SLOCOG will send a final written response letter to the complainant. If the complaint is not substantiated, the letter will advise them of his or her right to: 1) appeal of the final written decision SLOCOG, and/or 2) file a complaint externally with the U.S. Department of Transportation and/or FTA. Every effort will be made to respond to Title VI complaints within 60 working days of receipt.
In addition to the complaint process described above, a complainant may file a Title VI complaint with the following offices:
Federal Transit Administration Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5th Floor – TCR
1200 New Jersey Ave., SE
Washington, DC 20590
Limited English Proficiency (LEP) Plan Introduction
SLOCOG is committed to upholding the principles and intentions of the Civil Rights Act of 1964 and related nondiscrimination mandates in all of its work, including: publications, products, communica-tions, public input, and decision-making processes. Executive Order 13166 modifies the Civil Rights Act of 1964 to address language barriers that may prohibit people who are limited in English proficient-cy (also known as LEP persons) from obtaining services, information, or participating in public plan-ning processes. To better identify LEP populations and thoroughly evaluate our agency’s efforts to provide meaningful access, SLOCOG has produced this Limited English Proficiency Plan.
Plan Summary
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, SLOCOG undertook the U.S. Department of Transportation (U.S. DOT) four-factor LEP analysis which considers the following factors:
- The number or proportion of LEP persons in the service area who may be served or are likely to encounter a SLOCOG program, activity or service
- The frequency with which LEP persons comes in contact withSLOCOG programs, activities or services
- The nature and importance of programs, activities or services provided by SLOCOG to the LEP population
- The resources available to SLOCOG and overall cost to provide LEP assistance
LEP Assistance
SLOCOG assessed its available resources that could be used for providing LEP assistance, including determining how much a professional interpreter and translation service would cost on an as needed basis, which of its documents would be the most valuable to be translated if the need should arise, and taking an inventory of available organizations that SLOCOG could partner with for outreach and translation efforts.
Based on the four-factor analysis, SLOCOG developed its LEP Plan as outlined in the following section.
Language Assistance Measures
Based on the results of the four-factor analysis and safe harbor thresholds, SLOCOG provides proactive language assistance measures in Spanish only. Future requests for assistance measures in other languages will be addressed on a case-by-case basis, in a timely manner and at no cost to the requestor. As discussed below, SLOCOG will continue to monitor LEP requests, regional demographics, and will reevaluate and adjust language assistance measures as appropriate.
SLOCOG provides language assistance measures on a program-specific basis, depending on the nature of the service provided as identified in the four-factor analysis. In the case of 511, Spanish-language phone assistance is provided by RTA during business hours through a contractual arrangement. This service may be accessed through the 511 phone tree, or via direct transfer by SLOCOG staff. For Call Box roadside assistance, a third-party answering center responds to callers in both English and Spanish 24/7. In the absence of a physical Call Box, callers may also access the Call Box answering center for roadside assistance through the 511 phone tree. The majority of tow truck operators employed by SLOCOG’s FSP contactor are bilingual in English and Spanish, although this is not a requirement. When responding to an LEP motorist, FSP operators communicate directly with the motorist when possible, or enlist interpretation assistance from contractor staff over the phone as needed. The Travel Trainer Know How to Go guide is published and maintained in both English and Spanish, and written outreach efforts for the program is translated into Spanish when needed or requested. Spanish versions of written materials (including posters, fliers, applications, forms, surveys, webpages, etc.) are provided for all Regional Rideshare programs, including Safe Routes to School, the Commuter club, vanpool subsidy. When appropriate or by request, SLOCOG will arrange in advance to provide in-person interpretation services during public events.
Outside of SLOCOG’s public-facing programs and services, appropriate translation and/or interpretation services will be made available upon request on a case-by-case-basis. Public hearing notices are published in both English and Spanish, and public meeting agendas include information, in both English and Spanish, informing readers of their right to request language assistance services and other accommodations .
For all language assistance measures, SLOCOG will ensure appropriate competency of language service providers. While SLOCOG does not require formal certifications or assessments for in-house or third-party providers, self-identification as bilingual is not sufficient. Providers must demonstrate proficient and accurate communication in both English and the target language, and must have sufficient conceptual understanding of relevant subject matter and associated vocabulary in each language.
Employee Training
As part of SLOCOG’s training on Title VI, all staff are informed of their obligation to provide meaningful access for LEP persons and trained on SLOCOG’s language assistance measures. New employees are introduced to SLOCOG’s Title VI Plan during their orientation and are required to sign an Acknowledgement of Receipt (Appendix B). Annual Title VI training is provided to all staff, and includes LEP policies and procedures, such as how staff can utilize the 511 Spanish-language line
The following training will be provided to SLOCOG staff:
- Information on the SLOCOG Title VI Procedures and LEP responsibilities
- Description of language assistance services offered to the public
- Documentation of language assistance requests
- How to handle a potential Title VI/LEP complaint
Outreach Techniques
When staff prepares a document or schedules a meeting, for which the target audience is expected to include LEP individuals, then documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population. Interpreters may be available on an as needed or requested basis. To achieve greater participation by LEP persons, SLOCOG partners with community-based organizations to connect with LEP populations.
Data Collection, Monitoring, and Updates to the LEP Plan
As part of SLOCOG’s broader Title VI Plan, this LEP plan will be reviewed and updated concurrently with Title VI processes. Relevant LEP data will be reviewed annually during development of the Title VI Goals and Accomplishments report, including reporting from frontline staff on LEP interactions during the previous year. As part of each triennial Title VI Plan update, SLOCOG will reassess this LEP plan using the four-factor analysis and revise planned language assistance measures as needed.
During this process, staff will collect and analyze relevant data required for the four-factor analysis and safe harbor provision, including (but not limited to): Latest demographic data from the American Community Survey (ACS) for assessing regional LEP populations by language group, current frequency of LEP interactions, changes to SLOCOG programs and services, current resources available for language assistance, and any LEP requests or complaints received during the prior plan period. SLOCOG may also reassess this LEP plan in response to significant changes to SLOCOG services, volume of LEP interactions, or regional demographics.
Dissemination of the SLOCOG LEP Plan
Any person or agency with internet access will be able to access and download the plan from the SLOCOG website. Alternatively, any person or agency may request a copy of the plan via telephone, fax, mail, or in person and shall be provided a copy of the plan at no cost. LEP individuals may request copies of the plan in translation which SLOCOG will provide, if feasible.
Questions or comments regarding the LEP Plan may be submitted to the San Luis Obispo Council of Governments, Title VI Coordinator:
San Luis Obispo Council of Governments
Title VI Coordinator
1114 Marsh St.
San Luis Obispo, CA 93401
Phone: 805-781-1385
Fax: 805-781-5703
[email protected]
Limited English Proficiency (LEP) Plan
Title VI Complaint Procedures (English)