TITLE VI COMPLIANCE PLAN

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TITLE VI

COMPLIANCE PLAN

 

OXFORD UNIVERSITY TRANSIT

 

January 2015

 

 

Revised

January 2021

 

 

 

Table of Contents

 

Nondiscrimination Policy Statement

Introduction and Description of Services

Notice to the Public

Procedure and Compliance

Complaint Form

Record Retention and Reporting Policy

Sub-recipient Assistance and Monitoring

Investigations, Complaints, and Lawsuits

Public Participation Plan

Current Outreach Efforts

Language Assistance Plan

Transit Planning and Advisory Board

System-Wide Service Standard and Service Policies

  • Service Standards

  • Service Policy

Appendices

  • FTA Circular 4702.18 Reporting Requirements For Transit Providers

  • Description of Services

  • Title VI Complain Form

  • Title VI Sample Notice to Public

  • Summary of Investigations, Lawsuits, and Complaints

  • Public Participation Plan

  • Language Assistance Plan

 

 

 

Nondiscrimination Policy Statement

Oxford University Transit assures the Mississippi Department of Transportation that no person is excluded from participation in, or denied the benefits of, or be otherwise subjected to discrimination or retaliation under any program or activity undertaken by the agency based on race, color, or national origin, as protected by Title VI of the Civil Rights Act of 1946, 49 CFR, part 21; dated October 1, 2012 and related statues and regulations.

Oxford University Transit further agrees to the following responsibilities with respect to its programs and activities:

  • Designated a Title VI Liaison that has a responsible position with the organization and access to the recipient’s Chief Executive Officer or authorized representative.

  • Issue a policy statement signed by the Executive Officer or authorized representative, with expresses its commitment to the nondiscrimination provisions of Title VI.   The policy statement shall be circulated throughout the Recipient’s organization and to the public.  Such information shall be published where appropriate in language other than English

  • Insert the clauses of Section 2.5 of this plan into every contract subjected to the Acts and the Regulations.

  • Develop a complain process and attempts to resolve complaints of discrimination against Oxford University Transit.

  • Participate in training offered on the Title VI and other nondiscrimination requirements.

  • If reviewed by MDOT or any other state or federal regulatory agency, take affirmative actions to correct any deficiencies found within reasonable time period, not to exceed ninety (90) days.

  • Have a process to collect racial and ethnic data on persons impacted by the agency’s programs.

  • Submit the information required by FTA Circular 2702.1B to the primary recipients (refer to Appendix A of this plan)

The 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 Agency.

 

 

_____________________________________                                  ______________________

Donna Zampella, General Manager Date

Introduction and Description of Services

Oxford University Transit submits this Title VI Plan in Compliance with the Title IV of the Civil Rights Act of 1964, 49 CFR 21, and the guidelines of FTA Circular 4702.18, published October 1, 2012.

Oxford University Transit is a sub-recipient of FTA funds and provides services in the City of Oxford and Lafayette County, MS.    A description of the current Oxford University Transit system is included in Appendix B.

 

Title VI Liaison

Carol Pringle – Operations Manager

Oxford University Transit

409 McElroy Drive

Oxford, MS  38655

662-234-3540

 

Oxford University Transit must designate a liaison for the Title VI issues and complaints within the organization.   The liaison is the focal point for the Title VI implantation and monitoring of activities receiving federal financial assistance.    Key responsivities of the Title VI liaison include:

 

  • Maintain knowledge of Title VI requirements

  • Attend training on Title VI and other nondiscrimination authorities when offered by MDOT or any other regulatory agency.

  • Disseminate Title VI information to the public including in languages other than English, when necessary.

  • Develop process to collect data related to race, gender, and national origin of service area population to ensure low income, minorities, and other underserved groups are included and not discriminated against.

  • Implement procedures for the prompt procession of Title VI complaints.

 

 

 

 

 

 

 

 

 

 

 

 

 

Notice to the Public

 

FTA Circular 4702.18 Chapter 11, Paragraph 5: Title 49 CFR 21.9(d) requires recipients to provide information to the public regarding the recipient’s obligation under DIT’s Title VI regulations and apprize members of the public of the protection against discrimination afforded to them by the Title VI.

 

The Notice to the Public will be posted at many locations to apprise the public of Oxford University Transit’s obligations under the Title VI and to inform them of the protections afforded them under Title VI.   At a minimum, the notice will be posted in public areas of Oxford University Transit Office including reception desk and meeting rooms, and on the Oxford University Transit website outransit.com.    Additionally, Oxford University Transit will post the notice on all transit vehicles.

 

A sample version of this notice is included in Appendix D of this Plan.

 

 

 

 

 

 

 

 

 

 

 

Procedures and Compliance

 

 

FTA Circular 4702.1B, Chapter III, Paragraph 6; All Recipients shall develop procedures for investigating and tracking Title VI complaints filed against them and make their procedures for filing a complaint available to members of the public.

 

Any person who believes he or she has been discriminated against based on race, color or national origin by Oxford University Transit may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint form, included as Appendix C.   Oxford University Transit investigates complaints received no more than 180 days after the alleged incident.   Oxford University Transit will process complaints that are complete.

 

Once the complaint is received, Oxford University Transit will review it to determine if our office has jurisdiction.   The complaint will receive and acknowledgement letter informing him/her whether the complaint will be investigated by our office.

 

Oxford University Transit has ninety (90) days to investigate the complaint.   If more information is needed to resolve the case, Oxford University Transit may contact the complainant.   The complainant has ten (10) business days from the date of the letter to send requested information to the investigator assigned to the case.   If the investigator is not contacted by the complainant or does not receive the additional information within the (10) business days, Oxford University Transit can administratively close the case.   A case can also be administratively closed if the complainant no longer wishes to pursue their case.

 

After the investigator reviews the complaint, she/he will issue one of two letters to the complainant:  a closure letter or letter of finding (LOF).  A closure letter summarizes the allegations and states that there was not a Title VI violation and that the case will be closed.   A LOF summarizes the allegations and the interviews regarding the alleged incident, and explains whether any disciplinary action, additional training of the staff member or other action will occur.  If the complaint wishes to appeal the decision, she/he was seven (7) days to do so from the time he/she receives the closure letter of the LOF.

 

The complaint procedure will be made available to the public on outransit.com.

 

Complaint Form

 

A copy of the complaint form in English and Spanish is provided in Appendix C and on our website outransit.com.

 

 

 

 

 

Record Retention and Reporting Policy

 

Oxford University Transit will submit Title VI plans to MDOT for concurrences on an annual basis or anytime a major change in the plan occurs.

 

Compliance records and all Title VI related documents will be retained for a minimum of three (3) years and reported to the primary recipient annually.

 

Sub-recipient Assistance and Monitoring

 

Oxford University Transit does not have any sub-recipients to provide monitoring and assistance.   As a sub-recipient to MDOT, Oxford University Transit utilizes the sub-recipient assistance and monitoring provided by MDOT, as needed.   In the future, if Oxford University Transit has a sub-recipient, it will provide assistance and monitoring as required by FTA Circular 2720.1B.

 

Oxford University Transit is required by FTA to ensure that sub-recipients of federal funds comply with all Title VI requirements.    To meet this mandate, MDOT monitoring consist of collecting data through site visits, day-to-day technical assistance, and report/forms.    MDOT uses reports and site visits to determine if the sub-recipients are complying with the Title VI requirements as outlined in FTA Circular 4702.1B and their Title VI Plan.

 

Title VI Complaint Procedures, Title VI Complaint Form, and sample Title VI notice have been developed and distributed by MDOT to its sub-recipients.    MDOT also assists the sub-recipients with demographic maps for Title VI purposes upon request.

 

Contractor and Subcontractors

 

Oxford University Transit is responsible for ensuring that contractors are in compliance with Title VI requirements.  Contractors may not discriminate in the section and retention of any subcontractors.

 

Subcontractors also may no discriminate in the section and retention of any subcontractors.

 

Oxford University Transit Contractors, and subcontractors may not discriminate in their employment practices in connection with federally assisted projects.   Contractors and subcontractors are not required to prepare or submit a Title VI Plan.    However, the nondiscrimination clauses will be inserted into every contract with contractors and subcontractors subject to Title VI regulations.

 

 

 

 

 

Title VI Investigations, Complaints and Lawsuits

 

In accordance with 49 CFR 21.9 (b), Oxford University Transit must record and report any investigations, complaints, or lawsuits involving allegations of discrimination.   The records of these events shall include the date the investigation, lawsuit, or complaint was filed; a summary of the allegations; the status of the investigation, lawsuit, or complaint; and actions taken by Oxford University Transit.   In response, the final findings related to the investigation, lawsuit, or complaint.   The records for the previous three (3) years shall be included in the Title VI Plan when it is submitted to MDOT.

 

Oxford University Transit has had no investigations, complaints, or lawsuits involving allegations of discrimination based on race, color, or national origin over the past three (3) years.   A

summary of these incidents is recorded on the form as seen on Appendix E, included in this plan.

 

Public Participation Plan

The public Participation Plan (PPP) for Oxford University Transit was developed to ensure that all members of the public, including minorities and Limited English Proficient (LEP) populations, are encouraged to participate in the decision-making process for Oxford University Transit.   Policy and service delivery decisions need to take into consideration community sentiment and public opinion based upon well-executed outreach efforts.   The public outreach strategies described in the PPP are designated to provide the public with effective access to information about Oxford University Transit services and to provide a variety of efficient and convenient method for receiving and considering public comment prior to implementing changes to services.    The PPP is included as Appendix G to this Title VI Plan.

 

Current Outreach Efforts

Oxford University Transit is required to submit a summary of public outreach efforts made over the last three (3) years.   The following is a list and short description of Oxford University Transit recent current and planned outreach activities.

 

  • On-going – regular monthly meeting with the Transit Commissioners that is open to the public to attend as we discuss upcoming events, changes in services, monthly reports etc.

  • April 2019 – Double Decker Arts Festival – we handed out maps and information concerning transit.     Allowed the public to tour our new bus and explained how to ride the bus.

  • June 2019 – The Mayor of Oxford signed a proclamation for June 19, 2019 as Transit Day – we set up at the Farmers Market and let the public tour our bus and handed out information concerning riding the bus along with maps.

  • August 2019 – handed out flyers concerning transit to all Freshman at the University of Mississippi.

  • On-Going - Update our website concerning changes in routes, and have live tracking of buses along with pertinent information concerning the buses.

 

Language Assistance Plan

 

Oxford University Transit Commission Board consist of six (6) members.    Three (3) from the City appointed by the Mayor and Three (3) from the University of Mississippi appointed by the University.

City Members University Members

Mike Black Sam Patterson

Tim Akers Jean Robinson

Rus McNees John Adrian

System-Wide Service Standards and Service Policies

Oxford University Transit is fixed route service provider.

FTA Circular 4702.1B required that all fixed route service providers prepare and summit system wide service standards and service policies as a part of their Title VI Plan.  These standards and policies must address how service is distribution across users access to these assets.

Oxford University Transit has adopted the following system-wide standards and policies to ensure service designed and operation practices do not result in discrimination on the basis of race, color, or national origin.   Service policies differ from service standards in that they are not necessarily based on a quantitative threshold.

Service Policies

The following is the policies for Oxford University Transit System:

  • Distribution of Transit Amenities – Installation of transit amenities along bus and routes based on the number of passengers boarding at stops and stations along those routes.

  • Vehicle Assignment –  Low floor buses will be used on frequent service and other high- ridership lines, so these buses carry a higher share of ridership than their numerical proportion of the overall bus fleet.     Low floor buses are also equipped with air conditioning, automated stop announcement system, Wi-Fi and Visual aid for stops.

 

Bus assignments considers the operating characteristics of buses of various lengths, which are matched to the operating characteristics of the route.  Local routes with lower ridership may be assigned small buses rather than the 30–40-foot buses.  Some routes, requiring tight turns on narrow streets are operated with 30 foot rather than 40-foot buses.

 

 

 

 

 

 

 

 

 

 

 

Appendices

 

 

  • FTA Circular 4702.1B Reporting Requirements for Transit Providers

 

  • Description of Services

 

  • Complaint Form

 

  • Sample Notice to Public

 

  • Summary of Investigations, Lawsuits, and Complaints

 

  • Nondiscrimination Poster Placed in All Vehicles

 

  • Public Participation Plan

 

  • Language Assistance Plan

 

 

 

 

 

 

Appendix A

FTA Circular 4702.1B Reporting Requirements for Transit Providers

 

Every three (3) years, on a date determined by FTA. Each recipient is required to submit the following information to the Federal Transit Administration (FTA) as part of their Title VI Program.   Sub-recipients shall submit the information below to their primary recipient, MDOT, on a schedule to be determined by MDOT.

 

General Requirements

All recipients must submit:

 

  • Title VI Notice to the Public, including a list of locations where the notice is posted.

  • Title VI Complaint Form

  • List of transit-related Title VI investigations, complaints, and lawsuits

  • Public Participation Plan, including information about outreach methods to engage minority and limited English proficient populations (LEP), as well as summary of outreach efforts made since last Title VI Program Submission.

  • Language Assistance Plan for providing language assistance to persons with limited English Proficiency (LEP), based on the MDOT LEP Guidelines

  • A table depicting the membership of non-elected committee and councils, the membership of which is selected by the recipient, broken down by race, and description of the process the agency uses to encourage the participation of minorities on such committees.

  • Primary recipients shall include a description of how they agency monitors it’s sub-recipients for compliance with Title VI, and a schedule of sub-recipient Title VI programs submissions.

  • A Title VI equity analysis if the recipient has constructed a facility, such as a vehicle storage facility, maintenance facility, operation center, etc.

  • A copy of the board meeting minutes, resolution, or other appropriate documentation showing the board of directors or appropriate governing entity of officials responsible for policy decisions reviewed and approved the Title VI Program.

  • Additional information as specified in Chapters IV, V and VI depending on whether the recipient is a transit provider, a State or planning entity.

 

Requirements of Transit Providers

All fixed route transit providers must submit:

 

  • All requirements set out in Chapter III (General Requirements)

  • Service Standards

  • Vehicle load for each mode

  • Vehicle headway for each mode

  • On Time Performance for each mode

  • Service availability for each mode

  • Service Policies

  • Transit amenities for each mode

  • Vehicle assignment for each mode

Transit Providers that operate 50 or more fixed route vehicles in peck service and are located in Urbanized Area (UZA) of 200,000 or more people must submit:

 

  • Demographic and service profile maps and charts

  • Demographic ridership and travel patterns, collected by surveys

  • Results of their monitoring program, and report, including evidence that the board or other governing entity or official(s) considered, was aware of the results, and approved the analysis.

  • A description of the public engagement process for setting the “major service change policy”, desperate impact policy, and disproportionate burden policy.

  • Result of service and/or fare equity analyses conducted since the last Title VI Program submission, including evidence that the board or other governing entity or official(s) considered, was aware of, and approved the results of the analysis.

 

 

 

 

 

 

 

 

 

 

 

 

Appendix B

Current System Description

 

  • An overview of the organization including its mission, program goals and objective.

Oxford University Transit current and long-term focus as a transportation provider is on maintaining the best-coordinated transportation system possible for our community.   Our goal is to create a coordinated system with the objective of providing safe, reliable, timely and efficient transportation services to the Lafayette County, City of Oxford, and University residents.

  • Organization structure, type of operation, number of employees, service hours, staffing plan, and safety and security plan.

 

Oxford University Transit is a 5311-recipient organization.   Our organization is made up of 65 full time employees and 3 part-time employees.   Our General Manager is responsible for all day-to-day operations of our organization and reports directly to our Board of Alderman.

 

  • Number of current transportation related employees

  • 1 General Manager

  • 1 Operations Manager

  • 1 Assistant Manager

  • 1 Safety Manager

  • 1 Maintenance Manager

  • 1 Transit Coordinator

  • 1 Office Manager

  • 50 Full Time Transit Operators

  • 3 Part Time Transit Operators

  • 4 Mechanics

  • 3 Maintenance Crew

  • 1 Janitor

 

  • A detailed description of service routes and service area

 

Oxford University Transit is available to all residence with the City Limits of Oxford Mississippi.  We provide a wide range of trip purposes that include, medical, nutrition, shopping, social services, training, employment, education, social and recreational.

 

Appendix C

Complaint Form

Section I:

Name:__________________________________________________________________

Address:________________________________________________________________

Phone:____________________________ Phone Work:__________________________

Section II:

Are you filing this complaint on your behalf?      _______ YES      ______NO

*If yes, go to Section III.

If not, please supply the name and relationship of the person for whom you are complaining:

_________________________________________________________________________

Please explain why you have filed for a third party:________________________________

_________________________________________________________________________

Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a third party.        ________ YES           ________ NO

Section III:

I believe the discrimination I experienced was based on:   

______ Race  ______Color _______ National Origin

Date of the alleged discrimination (Month, Day, Year): _______________________

Explain as clearly as possible what happened and why you believe you were discriminated against.  Describe all persons who were involved.   Include the name and contact information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses.    If more space ins needed, please use the back of this form.

 

 

 

Section IV:

Have you previously filed a Title VI complaint with this agency?    ______YES   ______NO

Section V:

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 Agency ________________________________   

____State Court__________________________________

____Local Agency ________________________________

Please provide information about a contact person at the agency/court where the complaint was filed:

Name:____________________________________________ Title________________________

Agency____________________________________________

Address____________________________________________ Phone:_____________________

Section VI:

Name of Agency complaint is against:

Contact Name:_____________________________________ Title________________________

Address____________________________________________ Phone:_____________________

You may attach any written materials or other information that you think is relevant to your complaint.

 

____________________________________ ____________________________

Signature (Required) Date (Required)

 

Please submit this form in person the address below, or mail this form to:

Oxford University Transit, Attn:   Carol Pringle

409 McElroy

Oxford, MS  38655

 

Appendix D

Public Rights under Title VI

 

OXFORD UNIVERSITY TRANSIT

  • Oxford University Transit operates its program and services without regard to race, color, or national origin in accordance with Title VI of the Civil Rights Act.  Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under the Title VI may file a complaint with Oxford University Transit.

  • For more information on Oxford University civil rights program, and the procedures to file a complaint, contact (662) 234-3540, email dzampella@outransit.com or visit our website at outransit.com or our location at 409 McElroy Drive Oxford, MS  38655

Derechos Públicos bajo el Título VI

 

OXFORD UNIVERSITY TRANSIT

  • Oxford University Transit opera su programa y servicios sin tener en cuenta la raza, el color o el origen nacional de acuerdo con el Título VI de la Ley de Derechos Civiles.  Cualquier persona que crea que ha sido agraviada por cualquier práctica discriminatoria ilegal bajo el Título VI puede presentar una queja ante Oxford University Transit.

  • Para obtener más información sobre el programa de derechos civiles de la Universidad de Oxford y los procedimientos para presentar una queja, comuníquese con (662) 234-3540, envíe un correo electrónico dzampella@outransit.com  o visite nuestro sitio web en outransit.com o nuestra ubicación en 409 McElroy Drive Oxford, MS 38655

 

 

 

 

 

 

 

 

 

 

 

 

Public Rights under Title VI

 

OXFORD UNIVERSITY TRANSIT

  • Oxford University Transit operates its program and services without regard to race, color, or national origin in accordance with Title VI of the Civil Rights Act.  Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under the Title VI may file a complaint with Oxford University Transit.

  • For more information on Oxford University civil rights program, and the procedures to file a complaint, contact (662) 234-3540, email dzampella@outransit.com or visit our website at outransit.com or our location at 409 McElroy Drive Oxford, MS  38655

Derechos Públicos bajo el Título VI

 

OXFORD UNIVERSITY TRANSIT

  • Oxford University Transit opera su programa y servicios sin tener en cuenta la raza, el color o el origen nacional de acuerdo con el Título VI de la Ley de Derechos Civiles.  Cualquier persona que crea que ha sido agraviada por cualquier práctica discriminatoria ilegal bajo el Título VI puede presentar una queja ante Oxford University Transit.

  • Para obtener más información sobre el programa de derechos civiles de la Universidad de Oxford y los procedimientos para presentar una queja, comuníquese con (662) 234-3540, envíe un correo electrónico dzampella@outransit.com  o visite nuestro sitio web en outransit.com o nuestra ubicación en 409 McElroy Drive Oxford, MS 38655

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix E

Summary of Investigations, Lawsuits, and Complaints

 

 

 

Complaint

Date

Summary

Status

Actions

Type

Month/Day/Year

Basic Complaint

 

Taken

 

 

Race, Color,

 

 

 

 

National Origin

 

 

Investigations

None in the past 3 years

 

 

 

1

 

 

 

 

2

 

 

 

 

Lawsuits

None in the past 3 years

 

 

 

1

 

 

 

 

2

 

 

 

 

Investigations

None in the past 3 years

 

 

 

1

 

 

 

 

2

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix F

Nondiscrimination Policy

 

Oxford University Transit is committed to operate our programs and services without regard to race, color, and national origin in accordance with Title VI of the Civil Rights Act of 1964.    Any person who believes she or he has bee aggrieved by any unlawful discriminatory practice under the Title VI may file a complaint by contacting the General Manager:

 

Donna Zampella, General Manager

409 McElroy Drive

Oxford, MS  38655

662-234-3540

dzampella@outransit.com

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix G

Public Participation Plan (PPP)

 

The Public Participation Plan (PPP) for Oxford University Transit was developed to ensure all members of the public, including minorities and Limited English Proficient (LEP) populations, are encouraged to participate in the decision-making process for Oxford University Transit.    Policy and service delivery decisions need to take into consideration community sentiment and public opinion based upon well-executed outreach efforts.   The public outreach strategies described in the PPP are designed to provide the public with effective access to information about Oxford University Transit also recognizes the important of many types of stakeholders in the decision-making process, including other units of government, metropolitan area agencies, and community-based organizations, major employers, passengers and the general public, including low-income, minority, LEP and other traditionally underserved communities.

 

Public Participation Goals

The main goal of the PPP is to offer meaningful opportunities for all interested segments of the public, including, but not limited to, low-income, minority and LEP groups, to comment, about Oxford University Transit and its operations.   The goal for this PPP is included:

 

  • Inclusion and Diversity:  Oxford University will proactively reach out and engage low-income, minority, and LEP populations for the Oxford University Transit service area so these groups will have an opportunity to participate.

  • Accessibility:  All legal requirements for accessibility will be met.  Efforts will be made to enhance the accessibility of the public’s participation -physically, geographically, temporally, linguistically, and culturally.

  • Clarity and Relevance:  Issues will be framed in public meetings, in such a way that the significance and potential effect of proposed decisions is understood by participants.   Proposed adjustments to fares or services will be described in language that is clear and easy to understand.

  • Responsive:  Oxford University Transit will strive to respond to and incorporate, when possible, appropriate public comments into transportation decisions.

  • Tailored:  Public participation methods will be tailored to match local and cultural preferences as much as possible.

  • Flexible:  The public participation process will accommodate participation in a variety of ways and will be adjusted over time as needed.

 

 

 

 

 

Public Participation Methods

 

This method of public participation included in this PPP were developed based upon best practices in conjunction with the needs and capabilities of Oxford University Transit.   We intend to achieve meaningful public participation by a variety of methods with respect to service and any changes to service.

 

Oxford University Transit will conduct community meetings and listening sessions as appropriate with passengers, employers, community-based organizations, and advisory committees to gather public input and distribute information about service quality, proposed changes or new service options.

 

The public will be invited to provide feedback on the Oxford University Transit website at outransit.com and all feedback on the site will be recorded and passed on to Oxford University Transit management.   The public will also be able to call the Oxford University Transit office at 662-234-3540 during its hours of operation.    Feedback collected over the phone will be recorded and passed on to Oxford University Transit management.   Formal customer surveys to measure performance, and listening sessions to solicit input, will be conducted periodically.   The comments recorded as part of these participation methods will be responded to as appropriate.

 

Meeting formats will be tailored to help achieve specific public participation goals that very by projector the nature of the prosed adjustment of service.   Some meetings will be designed to share information and answer questions.   Some will be designed to engage the public an provide input, establishing priorities, and helping to achieve consensus on a specific recommendation.   Others will be conducted to solicit and consider public comments before implementing proposed adjustments to services.   In each case, an agenda for the meetings will be created that work to achieve the stated goals and is relevant to the subject and not overwhelming for the public.

 

For all public meetings, the venue will be a facility that is accessible for person with disabilities and, preferably, is served by public transit.  If a series of meetings are schedule on a topic, different meeting locations may be used, since no one location is usually convenient to all participants.

 

For community meetings and other important information Oxford University Transit will use a variety of means to make riders and citizens aware, including some of all the following methods”

 

  • In-vehicle advertisement

  • Posters or flyers in transit center

  • Posting information on the website

  • Press release and briefings to media outlets

  • Multilingual flyer distribution to community-based organizations, particularly those that target LEP population

  • Flyers and information distribution through various libraries, and other civic locations that currently help distribute timetables and other information

  • Communications to relevant elected officials

  • Other methods required by local or state laws or agreements

All information and materials communicating proposed and actual service adjustments will be provided in English and any other language that meets the “safe harbor” criteria.

 

Public Hearing

Oxford University Transit is not required to perform public hearings.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Appendix H

Language Assistance Plan (LAP)

 

Introduction

 

Oxford University Transit operates a transit system within the City of Oxford, MS.   The Language Assistance Plan (LAP) has been prepared to address Oxford University Transit’s responsibilities as they relate to the needs of individuals with Limited English Proficiency (LEP).  Individuals, who have a limited ability to read, write, speak, or understand English are LEP.   Oxford University Transit is federally mandated to take responsible steps to ensure meaningful access to the benefits, services, information and other important portions of its programs and activities for individuals who are LEP.   Oxford University Transit has utilized the U.S. Department of Transportation (USDOT) LEP Guidance Handbook and performed a four-factor analysis to develop its LAP.

The U.S. Department of Transportation Handbook, titled “Implementing the Department of Transportation’s Policy Guidance concerning Recipient’s Responsibilities to Limited English Proficient (LEP) persons: a Handbook for Public Transportation Providers, (April 13,2007) (hereinafter handbook), states that Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq., and its implementing regulations provide that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity that receives Federal financial assistance (Handbook page 5).

Executive Order 13166 of August 6, 2000 states that recipients of Federal Financial Assistance must take responsible steps to ensure meaningful access to their program and activities by LEP persons (Handbook, page 6).   Additionally, recipients should use the MDOT LEP Guidance to determine how best to comply with statutory and regulatory obligations to provide meaningful access to the benefits, services, information and other important portions of their programs and activities for individuals who are LEP (Handbook, page 6).    These provisions are included in the FTA Circular 4702.18 in Paragraph 9 of Chapter III (pages 111-6 to 111-9).

For many LEP individuals, public transit is the principle transportation mode available.   It is important for Oxford University Transit be able to communicate effectively with all its riders.  When Oxford University Transit can communicate effectively with all its riders, the service provided is safer, more reliable, convenient, and accessible for all within its service area.   Oxford University Transit is committed to taking reasonable steps to ensure meaningful access for LEP individuals to this agency’s services in accordance with Title VI.   Currently Oxford University Transit can communicate through QRyde Services, webpage, social media, and newspaper.

 

This plan will demonstrate the efforts that Oxford University Transit undertakes to make its service accessible to all persons without regard to their ability to communicate in English.   The plan address how service will be provided through general guidelines and procedures including the following:

  • Identification – identifying LEP populations in service areas.

  • Notification – providing notice to LEP individuals about their right to language services

  • Interpretation – offering timely interpretation to LEP individuals upon request

  • Translation – Providing timely translation of important documents

  • Staffing – identifying Oxford University Transit staff to assist LEP customers

  • Training – Providing training on LAP to responsible employees

Four Factor Analysis

The analysis provided in this report has been developed to identify LEP population that may use Oxford University Transit services and identify needs for language assistance.   This analysis is based on the “Four Factor Analysis” presented in the implementing the Department of Transportation’s Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP) Person, dated April 13, 2007, which considers the following factor:

  • The number and proportion of LEP persons in the service area who may e served or are likely to encounter and Oxford University Transit Program, activity, or service.

  • The frequency with which LEP persons meet Oxford University Transit programs, activities, or services.

  • The nature and importance of programs, activities, or services provided by Oxford University Transit to LEP population.

  • The resources available to Oxford University Transit and overall cost to provide LEP assistance.

  • Factor 1:  The number and proportion of LEP person services or encountered in the eligible service population of the 24,528 residents in the City of Oxford 92.7% speak English very well.    7.27% speak another language and 3.09 speak Spanish per the US Census Bureau of 2017.

 

  • Factor 2: The frequency with which LEP individuals come into contact with your programs, activities and services.

The federal guidance for this factor recommends that agencies should access the frequency with which they have contact with LEP language group, the more likely enhanced services will be needed.