Harris County Community Services Department Office of Transit Services TITLE VI "STATEMENT OF POLICY"

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1 Harris County Community Services Department Office of Transit Services TITLE VI "STATEMENT OF POLICY" Harris County Community Services Department, Office of Transit Services is committed to a policy of non-discrimination in the conduct of its business, including its Title VI responsibilities - the delivery of equitable and accessible transportation services. Harris County CSD recognizes its responsibilities to the communities in which it operates and to the society it serves. It is the County s policy to utilize its best efforts to assure 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 under its program of transit service delivery and related benefits. Toward this end, it is the County s objective to: A. Ensure that the level and quality of transportation service is provided without regard to race, color, or national origin; B. Identify and address, as appropriate, disproportionately high and adverse human health and environmental effects, including social and economic effects of programs and activities on minority populations and low-income populations; C. Promote the full and fair participation of all affected populations in transportation decision making by providing meaningful access to these activities; D. Prevent the denial, reduction, or delay in benefits related to programs and activities that benefit minority populations or low-income populations and to notify beneficiaries of protections available under Title VI; E. Ensure meaningful access to programs and activities by persons with limited English proficiency. F. Adhere to the Title VI reporting requirements of the Federal Transit Administration through the annual Certification and Assurance module in TEAM and provide written Title VI policy documentation every three years as required in as required in FTA circular A. G. Provide public notification of Title VI protections in all buses and public places were Harris County Transit Services conducts business or operations. The responsibility for carrying out Harris County's commitment to this program has been delegated to the Harris County Office of Transit Services. Harris County CSD has a Title VI Compliance Officer who will receive and investigate Title VI complaints which come through the complaint procedure. However, all managers, supervisors and employees share in the responsibility for making Harris County's Title VI Program a success. Additional information concerning Harris County s Title VI obligations and the complaint procedure can be found on the Harris County web site or by calling

2 LIMITED ENGLISH PROFICIENCY POLICY STATEMENT AND AVAILABLE RESOURCES Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq., provides that no person shall be subjected to discrimination on the basis of race, color, or national origin under any program or activity that receives Federal financial assistance. Title VI and its implementing regulations require that FTA recipients take responsible steps to ensure meaningful access to the benefits, services, information, and other important portions of their programs and activities for individuals who are Limited English Proficient (LEP). To that end, Harris County CSD provides translation and interpretation services free of charge upon request by calling (713) Harris County CSD contracts with Language Line Services, a language translation firm, to provide phone interpretation. The firm provides realtime phone interpretation in 140 different languages and is available 24 hours a day, 7 days per week. Since the 2010 Census demographic data is unavailable, Harris County has chosen to use the most current American Community Survey (ACS) Forecast data to identify LEP needs within the county. As of the ACS data, 1,448,542 (40%) of the residents of Harris County listed a language other than English as the language spoken at home. Of the above 1,448,542 residents, 1, (81%) listed Spanish as the language spoken at home which is the largest non-english speaking segment of the County. Harris County Transit provides services to the cities of Baytown, Pasadena and La Porte and the unincorporated communities of McNair, Barrett Station, The Highlands, and Crosby. According to the above ACS Forecast Data the total approximate population of the service area is 262,900 people. Of that amount, an estimated 50,990 individuals are identified as speaking English less than very well. Of the 50,990 individuals mentioned above, 48,441or 95% who speak English less than very well are identified as Spanish. As such, all publications, communications and advertising are published in English and Spanish. Translations into other languages are available upon request. PUBLIC PARTICIPATION Harris County Community Services Department, Office of Transit Services (HCCSD) is responsible for preparing and utilizing a Public Participation Plan (PPP) that is developed in consultation with interested parties pursuant to the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU). The participation procedures outlined below are intended to afford an expanded list of interested parties with an opportunity to comment on transportation plans and programs. HCCSD strives to provide timely information to the public and opportunities for public participation. Key objectives of the public participation process are to: Provide opportunities for citizens to help shape the region s future through a public comment process that is open and accessible to the public, stakeholders, and policymakers.

3 Work with community groups to create opportunities for all segments of the public to learn and become informed about issues and proposals under consideration that may impact their neighborhoods. Look for opportunities to seek comment from low-income, elderly/disabled, and minority communities that may not typically participate in the regional planning process. Disseminate clear, concise, and timely information to citizens, affected agencies, and interested parties. Make information on transportation projects and programs available in a variety of formats, mediums, and languages to reach a larger audience. Provide timely responses to concerns and comments raised by the public regarding the development and implementation of regional transportation plans, programs, and projects. Ensure that the comments received are considered and incorporated into the deliberation regarding proposed plans and programs. COLLECTION OF DEMOGRAPHIC DATA In order to comply with 49 CFR Section 21.9(b), the Harris County Community Services Department, Transit Services Division (HCCSD) shall collect and analyze racial and ethnic data showing the extent to which members of minority groups are beneficiaries of programs receiving Federal financial assistance. HCCSD collects customer demographic and travel pattern questioners on a frequent basis. Those questioners collect the following information: the riders race, color and national origin; Language spoken at home and whether the passenger understands English; Rider income information; modes of transit uses; availability of an automobile; and frequency of transit use. In addition to the above, HCCSD also conducts planning by preparing demographic and service profile maps and charts displaying such information as major streets, highways, major activity centers or trip generators. In addition the maps should reflect the census tracts where the percentage of the total minority and low-income population residing in these areas exceeds the average minority and low income population for the service area as a whole

4 Harris County Community Services Department Office of Transit Services Title VI Complaint and Investigation Procedures These procedures cover all complaints filed under Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act of 1990, for alleged discrimination in any program or activity administered by the Harris County Community Services Department, Office of Transit Services (HCCSD). These procedures do not deny the right of the complainant to file formal complaints with other State or Federal agencies or to seek private counsel for complaints alleging discrimination. Every effort will be made to obtain early resolution of complaints at the lowest level possible. The option of informal mediation meeting(s) between the affected parties and the HCCSD may be utilized for resolution. Any individual, group of individuals or entity that believes they have been subjected to discrimination prohibited under Title VI and related statutes may file a complaint. The following measures will be taken to resolve Title VI complaints: 1.) A formal complaint must be filed within 180 days of the alleged occurrence. Complaints shall be in writing and signed by the individual or his/her representative, and will include the complainant s name, address and telephone number; name of alleged discriminating official, basis of complaint (race, color, national origin, sex, disability, age, limited English), and the date of alleged act(s). A statement detailing the facts and circumstances of the alleged discrimination must accompany all complaints. 2.) In the case where a complainant is unable or incapable of providing a written statement, a verbal complaint of discrimination may be made to the HCCSD Title VI Coordinator. Under these circumstances, the complainant will be interviewed, and the HCCSD Title VI Coordinator will assist the Complainant in converting the verbal allegations to writing. 3.) When a complaint is received, the Title VI Coordinator will provide written acknowledgment to the Complainant, within ten (10) days by registered mail. 4.) If a complaint is deemed incomplete, additional information will be requested, and the Complainant will be provided 60 business days to submit the required information. Failure to do so may be considered good cause for a determination of no investigative merit. 5.) Within 15 business days from receipt of a complete complaint, the HCCSD will determine its jurisdiction in pursuing the matter and whether the complaint has sufficient merit to warrant investigation. Within five (5) days of this decision, the Department Director or his/her authorized designee will notify the Complainant and Respondent, by registered mail, informing them of the disposition. a. If the decision is not to investigate the complaint, the notification shall specifically state the reason for the decision. b. If the complaint is to be investigated, the notification shall state the grounds of HCCSD s jurisdiction, while informing the parties that their full cooperation will be required in gathering additional information and assisting the investigator.

5 6.) When the HCCSD does not have sufficient jurisdiction, the Department Director or his/her authorized designee will refer the complaint to the appropriate State or Federal agency holding such jurisdiction. 7.) If the complaint has investigative merit, the Executive Director or his/her authorized designee will instruct the Title VI Compliance Officer to fully investigate the complaint. A complete investigation will be conducted, and an investigative report will be submitted to the Department Director within 60 days from receipt of the complaint. The report will include a narrative description of the incident, summaries of all persons interviewed, and a finding with recommendations and conciliatory measures where appropriate. If the investigation is delayed for any reason, the Title VI Compliance Officer will notify the appropriate authorities, and an extension will be requested. 8.) The Department Director or his/her authorized designee will issue letters of finding to the Complainant and Respondent within 90 days from receipt of the complaint. 9.) If the Complainant is dissatisfied with the HCCSD s resolution of the complaint, he/she has the right to file a complaint with the Federal Transit Administration within 180 days of the alleged occurrence to the following address: Federal Transit Administration s Office of Civil Rights 819 Taylor Street, Room 8A36 Fort Worth, TX 7610 Telephone: (817)

6 Title VI Complaint Form Complaint Form Instructions: If you would like to submit a Title VI complaint to the Harris County Community Services Department Office of Transit Services (HCCSD), please fill out the form below and send it to: Office of Transit Services, Attn: Director, 8410 Lantern Point Drive, Houston, Texas For questions or a full copy of HCCSD s Title VI policy and complaint procedures call , visit or transit@csd.hctx.net 1. Name (Complainant): 2. Phone: 3. Home address (street no., city, state, zip: 4. If applicable, name of person(s) who allegedly discriminated against you: 5. Location and position of person (s) if known: 6. Date of incident: 7. Discrimination because of: Race / Color Sex (includes sexual harassment) Vietnam Era Veteran National Origin Sexual Orientation Disabled Veterans Creed / religion Marital Status Retaliation Disability Age Limited English 8. Explain as briefly and clearly as possible what happened and how you believe you were discriminated against. Indicate who was involved. Be sure to include how you feel other persons were treated differently than you. Also, attach any written material pertaining to your case. 9. Why do you believe these events occurred?

7 10. What other information do you think is relevant to the investigation? 11. How can this/these issue(s) be resolved to your satisfaction? 12. Please list below any person(s) we may contact for additional information to support or clarify your complaint (witnesses): Name: Address: Phone Number: 13. Have you filed this complaint with any other federal, state, or local agency; or with any federal or state court? Yes No If yes, check all that apply: Federal agency Federal Court State court Local agency State agency If filed at an agency and/or court, please provide information about a contact person at the agency/court where the complaint was filed. Agency/Court: Contact s Name: Address: Phone number: Signature (Complainant) Date of filing:

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