HomeMy WebLinkAboutE-5 Staff Report - Title VI Program UpdateCONSENT ITEM
E-5
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
VIA: DON PENMAN, INTERIM CITY MANAGER
FROM: DANIEL BOBADILLA, P.E., DIRECTOR OF PUBLIC WORKS/CITY ENGINEER
DATE: FEBRUARY 5, 2018
SUBJECT: RESOLUTION TO APPROVE THE UPDATED CITY OF AZUSA TITLE VI
PROGRAM
SUMMARY:
As a sub-recipient of grant funds from the Federal Transit Administration (FTA) for the intermodal
transit facility, the City of Azusa Public Works Department, responsible for the planning and operations
of the Dial-A-Ride and Gold-Line Shuttle, is required to comply with Title VI of the Civil Rights Act of
1964 which provides 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 subjected to discrimination
under any program or activity receiving federal financial assistance.” The City of Azusa adopted a Title
VI Program on September 2, 2014, which was subsequently approved by Caltrans on October 1, 2014.
The Title VI Program must be updated and approved every three years by the City Council, Los Angeles
County Metropolitan Transit Authority (LACMTA) and Caltrans.
RECOMMENDATION:
Staff recommends the City Council take the following action:
1) Adopt Resolution No. 2018-C13 approving the updated City of Azusa Title VI Program, a
requirement to comply with the Civil Rights Act of 1964 for all agencies receiving Federal
Transit Administration grant funds.
DISCUSSION:
Triggered by FTA grant funding utilized in the construction of the intermodal transit facility, the City of
Azusa Dial-A-Ride program is required to adopt a Title VI Program. A Title VI Program provides that
no person shall be discriminated against on the basis of race, color, and national origin.
APPROVED
CITY COUNCIL
2/5/2018
Title VI Plan Update
February 5, 2018
Page 2
The City of Azusa complied with FTA Circular 4702.1B – Title Guidelines for FTA Recipients, and
approved and submitted their original Title VI Program on September 2, 2014. LACMTA requested
some minor modifications to the Program, which were approved in an amendment on April 20, 2015.
The Title VI Program requires updating every three years.
The Title VI Program includes documents that will be posted and/or available on the Public Works
Department webpage and on all transit vehicles operated by the City of Azusa. These documents
include, but are not limited to, a Title VI Notice to Beneficiaries, Title VI Complaint Procedures, Title
VI Complaint Form. In addition, the Title VI Plan includes a Limited English Proficiency (LEP) Plan
and Public Participation Plan.
For purposes of determining the number of LEP persons eligible to be served by Transit Division
services, an analysis was conducted that focused on those who speak English “less than very well,” in
accordance with the formal definition of LEP persons from the FTA. The analysis results showed that
of the various languages spoken in Azusa, the Spanish language has 11,025 speakers who could speak
English “less than very well,” thus falling under the FTA’s “Safe Harbor Provision” threshold (over
1,000). Based on the results from the survey, the language of Spanish meets the LEP “Safe Harbor”
threshold and therefore notifications and forms must also be provided in Spanish.
This updated Title VI Plan has minor modifications, which primarily include updated names of
individuals who hold legislative offices. A few graphics have also been added.
FISCAL IMPACT:
There is no fiscal impact associated with the proposed action.
Prepared by: Reviewed and Approved:
Nikki Rosales Daniel Bobadilla
Senior Management Analyst Director of Public Works/City Engineer
Reviewed and Approved: Reviewed and Approved:
Louie F. Lacasella Don Penman
Senior Management Analyst Interim City Manager
Attachments:
1)Title VI Program
2)Resolution No. 2018-C13
City of Azusa
TITLE VI PROGRAM
Developed: July, 2014
Approved by Azusa City Council: September 2, 2014
Amended by Azusa City Council: April 20, 2015
Updated by Azusa City Council: February 5, 2018
213 East Foothill Blvd.
Azusa, California 91702
www.ci.azusa.ca.us
Attachment 1
City of Azusa Title VI Program
Updated: 2/5/2018 2
INTRODUCTION
This document was prepared by the City of Azusa to comply with Title VI of the Civil Rights
Act of 1964, including new provisions detailed in U.S. Department of Transportation’s FTA
Circular 4702.1B, “Title VI Requirement and Guidelines for Federal Transit Administration
Recipients.”
Table of Contents
Introduction Pg. 3
Title VI Notice to the Public Pg. 5
Title VI Complaint Procedures Pg. 6
Public Participation Plan Pg. 14
Language Assistance Plan Pg. 16
Safe Harbor Provision Pg. 21
Determination of Site of Location of Facilities Pg. 21
City of Azusa Title VI Program
Updated: 2/5/2018 3
Introduction:
The City of Azusa: Transit Division’s Pledge to Fair and Equal Access
The City of Azusa is deeply committed to protecting the rights of its residents. Per Title VI of
the Civil Rights Act of 1964, the City has reexamined its Transit Division to ensure that no
citizen eligible for Dial-A-Ride is excluded from its services due to race, color, or national
origin.
Since its inception, the primary goal of Azusa Dial-A-Ride has been to provide the highest level
of service. This manual has been prepared with that same level of service in mind. The rights
afforded to the residents of the City of Azusa Dial-A-Ride patrons in regards to race, color, or
national origin, are outlined in this manual as well as the legal actions that may be pursued to
protect the residents from said discrimination.
This manual allows the Transit Division and its customers to work together to maintain and build
a better Division. The City of Azusa regards this issue and others pertaining to customer service
very highly and is dedicated to working to improve and maintain exceptional service. Thus, the
City, along with the Transit Division, encourages the residents to read through this manual and
utilize any tools and resources provided to them.
City of Azusa Title VI Program
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The City of Azusa, in accordance with the Civil Rights Act of 1964, and as a federally funded
entity, of Federal Transit Administration (FTA) of the U.S. Department of Transportation (US
DOT), is obligated to offer its residents the following:
• The benefits of services are shared equitably throughout the City
• The quality of services are adequate to provide equal access to all patrons
• No one is excluded from contributing to Azusa’s Dial-A-Ride planning and development
process
• Process and procedures are implemented which prohibit discrimination of any kind, both
intentional and unintentional
The Azusa Transit Division worked to compile this manual which best reflects the City, its
residents, and the Dial-A-Ride service. The program has been redesigned and updated to meet
federal regulations and provide the utmost in customer service.
City of Azusa Title VI Program
Updated: 2/5/2018 5
City of Azusa Title VI Notice to the Public
The following public notice is posted in all operating Dial-A-Ride vehicles, City Hall, and on the
City of Azusa’s website.
Per Title VI of the Civil Rights Act of 1964, the residents of the City of Azusa cannot be denied
access to programs and services based on race, color, or national origin. The City of Azusa
pledges to protect these rights and has taken the necessary precautions. Residents are assured the
following:
• Equal access to Dial-A-Ride services
• Proper notification on modifications pertaining to the services
• Encouraged public participation regarding issues pertaining to Dial-A-Ride
• Easy access to information regarding Dial-A-Ride
• Ability to easily file a complaint with the City of Azusa should an incident occur
pertaining to Title VI Rights
Residents are encouraged to utilize the resources afforded to them by Title VI Rights. Should a
patron or resident have issues or concerns regarding these or any other rights, they should contact
the Transit Division at 626-812-5206 or City Hall at 626-812-5229.
Spanish Notice
Según el Título VI de la Ley de Derechos Civiles de 1964, no se puede negar a los residentes de
la Ciudad de Azusa el acceso a programas y servicios basados en la raza, el color o el país de
origen. La Ciudad de Azusa se compromete a proteger estos derechos y ha tomado las
precauciones necesarias. Los residentes tienen la seguridad de lo siguiente:
• • Igual acceso a los servicios de Dial-A-Ride
• • Notificación adecuada sobre las modificaciones relacionadas con los servicios
• • Fomentó la participación del público en relación con cuestiones relacionadas con Dial-
A-Ride
• • Fácil acceso a la información sobre Dial-A-Ride
• • Posibilidad de presentar una queja fácilmente ante la Ciudad de Azusa en caso de que
ocurra un incidente relacionado con los Derechos del Título VI
Se alienta a los residentes a utilizar los recursos que se les otorgan mediante los Derechos del
Título VI. Si un usuario o residente tiene problemas o inquietudes con respecto a estos u otros
derechos, debe comunicarse con la División de Tránsito al 626-812-5206 o al Ayuntamiento al
626-812-5229.
City of Azusa Title VI Program
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Title VI Complaint Procedures
As a recipient of federal dollars, the City of Azusa is required to comply with Title VI of the
Civil Rights Act of 1964 and ensure that services and benefits are provided on a non-
discriminatory basis. The City of Azusa has in place a Title VI Complaint Procedure, which
outlines a process for local disposition of Title VI complaints and is consistent with guidelines
found in the Federal Transit Administration Circular 4702.1B, dated October 1, 2012.
Any person who believes she or he has been discriminated against on the basis of race, color, or
national origin by the City of Azusa may file a Title VI complaint by completing and submitting
the agency’s Title VI Complaint Form. The City of Azusa investigates complaints received no
more than 180 days after the alleged incident. The City of Azusa will only process complaints
that are complete.
Within 10 business days of receiving the complaint, the City of Azusa will review it to determine
if our office has jurisdiction. The complainant will receive an acknowledgement letter informing
her/him whether the complaint will be investigated by our office. The City of Azusa has 30 days
to investigate the complaint. The complainant will be notified in writing of the cause to any
planned extension to the 30-day rule.
If more information is needed to resolve the case, the City of Azusa may contact the
complainant. The complainant has 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 10 business days the City of
Azusa can administratively close the case.
A case can be administratively closed also 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 a 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. An
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 complainant wishes to appeal the decision, she/he has 10 business days after the
date of the letter or the LOF to do so.
A person may also file a complaint directly with the Federal Transit Administration, at FTA
Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC 20590.
Below is a general outline of our process and procedures:
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Complaint is received by Transit
Division.
City reviews for determination of
jurisdiction and sends acknowledgement
letter within 10 business days.
City has 30 days to investigate and
determine if a violation took place.
If determined no Title VI violation
took place, a closure letter will be
issued.
If a Title VI violation did take place, a
Letter of Finding will be sent out
summarizing the allegations and the
interviews regarding the alleged
incident, and explaining whether any
disciplinary action, additional training
of the staff member, or other action
will occur.
Complainant has 10 days to appeal the
decision.
City of Azusa Title VI Program
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City of Azusa Title VI Complaint Form
COMPLAINT FORM
Section I: Please write legibly
1. Name:
2. Address:
3. Telephone: 3.a. Secondary Phone (Optional):
4. Email Address:
5. Accessible Format
Requirements?
[ ] Large Print [ ] Audio Tape
[ ] TDD [ ] Other
Section II:
6. Are your filing this complaint on your own behalf? YES* NO
*If you answered “yes” to #6, go to Section III.
7. If you answered “no” to #6, what is the name of the person for whom you are filing this complaint? Name:
8. What is your relationship with this individual:
9. Please explain why you have filed for a third party:
10. Please confirm that you have obtained permission of the
aggrieved party to file on their behalf. YES NO
Section III:
11. I believe the discrimination I experienced was based on (check all that apply):
[ ] Race [ ] Color [ ] National
Origin
12. Date of alleged discrimination: (mm/dd/yyyy)
13. 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 is needed, please attach additional sheets of paper.
City of Azusa Title VI Program
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City of Azusa Title VI Complaint Form, Page 2
COMPLAINT FORM
You may attach any written materials or other information that you think is relevant to your
complaint.
Signature and date are required below to complete form:
Signature_____________________________________ Date________________
Please submit this form in person or mail this form to the address below:
Director of Public Works, Title VI Coordinator
213 East Foothill Blvd.
Azusa, CA 91702
Section IV:
14. Have you previously filed a Title VI complaint with
your agency name here? YES NO
Section V:
15. 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 __________________________ [ ] State Agency
__________________
[ ] Federal Court ___________________________ [ ] Local Agency
__________________
[ ] State Court ______________________________
16. If you answered “yes” to #15, provide information about a contact person at the agency/court
where the complaint was filed.
Name:
Title:
Agency:
Address:
Telephone: Email:
Section VI:
Name of Transit Agency complaint is against:
Contact Person:
Telephone:
City of Azusa Title VI Program
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Titulo VI Procedimiento de Queja Como un receptor de dólares federales, la Ciudad de Azusa. tiene que cumplir con lo dispuesto en el Titulo VI de la ley de los derechos civiles de 1964 y asegúrese de que los servicios y los beneficios se proporcionen sobre una base no discriminatoria. La Ciudad de Azusa ha puesto en marcha un procedimiento de queja Titulo VI, que emboza un proceso de disposición local de quejas del Titulo VI y es consistente con las pautas de Administración Federal de Transito Circular 4702.1B, de Octubre 1, 2012. Cualquier persona que cree que ha sido objeto de discriminación por motives de raza, color, u origen nacional por la Ciudad de Azusa puede presentar al Titulo VI su denuncia. La Ciudad de Azusa investiga las quejas no mas de 180 días después del incidente. La ciudad solo tramitara las quejas que están completas. En un periodo de 10 días de haber recibido la demanda, la Cuidad de Azusa revisara para determinar si nuestra oficina tiene la jurisdicción. El autor de la queja, recibirá un acuse de recibo informándole al denunciante que será notificado por escrito si el caso de él/ella el será investigado por nuestra oficina. La Cuidad the Azusa tiene 30 días para investigar la queja. Si necesita mas información para resolver el caso, la Cuidad de Azusa puede contactar al autor de la queja. El autor de la queja tiene 10 días de la fecha que recibió la carta para solicitar un investigador que sea asignado al caso. El caso se puede cerrar también si el autor de la queja no desea proseguir con el caso. Después de que el investigador analice la queja, el / ella emitirá una de las dos cartas a la denunciante.
City of Azusa Title VI Program
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FORMA DE QUEJA – CIUDAD DE AZUSA
Seccion I: Escribir en forma legible 1. Nombre: 2. Direccion: 3. Telefono: 3.a. Telefono secundario(opcional): 4. Direccion de correo electronico: 5.Reuistos de forma accesible? [ ] Impresion grande [ ] Cinta de audio [ ] TDD [ ] Otros Seccion II: 6.Esta presentando esta queja en su propio nombre? Si No *Si usted contesto “Si” to #6, vaya a la Seccion III. 7. If you answered “no” to #6, what is the name of the person for whom you are filing this complaint? Name: 8. Cual es su relacion con este individuo: 9. Por favor, explique por que han presentado para una tercera parte: 10. Por favor, confirme que ha obtenido el permiso de la parte agraviada en el archivo en su nombre. Si No Seccion III: 11.Creo que la discriminacion que he experimentado fue basado en (marqu todas las que
correspondan): [ ] Raza [ ] Color [ ] Origin nacional 12. Fecha de supuesta discriminacion: (mm/dd/aaaa) 13.Explica lo mas claramente posible lo que ocurrio y por que usted cree que son objeto discriminacion. Describir todas las personas que han participado. Incluir el nombre y la informacion de contacto de la(s) persona(s) que discrimina contra usted (si se conoce), asi como los nombres y la informacion de contacto de los testigos. Si se necesita mas espacio, por favor adjunte hojas adicionales de papel.
City of Azusa Title VI Program
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FORMA DE QUEJA – CIUDAD DE AZUSA – PAGINA 2
Seccion IV: 14. 14. Anteriormente ha presentado un Titulo VI denuncia con la **************. Si No Seccion V: 15. Ha presentado esta queja con cualquier otro local, estato o federal, o con cualquier Federal o Estato? [ ] Si* [ ] No si la respuesta es si Marque todo lo que apliqua [ ] Agencia Federal _____________________ [ ] Agencia Estatal __________________ [ ] Federal Tribunal ____________________ [ ] Agencia Local____________________ [ ] Tribunal Estatal ______________________________ 16. Si usted contesto "si" a la posicion #15, proporcionan informacion acerca de una persona de contacto en la agencia/tribunal donde se presento la denuncia. Nombre: Titulo: Organismo: Direccion: Telefono: Correo electronico: Seccion VI: Nombre de organizacion Transito denuncia es contra: Persona de contacto: Telefono:
City of Azusa Title VI Program
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List of Transit-Related Title VI Investigations, Complaints, and
Lawsuits
The City of Azusa has not been involved in any transportation-related Title VI investigations,
lawsuits or complaints.
City of Azusa List of Investigations, Lawsuits and Complaints
Type of Process Date Summary (including
basis of complaint)
Status Action(s) Taken
Investigations
1. None
2.
Lawsuits
1. None
2.
Complaints
1. None
2.
City of Azusa Title VI Program
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Public Participation Plan
About City of Azusa
The City of Azusa was founded in 1887 and incorporated as a general law city on December 29,
1898. The City is located in the County of Los Angeles, situated 27 miles northeast of the City of
Los Angeles, and nestled against the San Gabriel Mountain foothills. The City of Azusa
encompasses 9.13 square miles and has a population of approximately 46,361. Educational
facilities include nine public elementary / middle schools, two public high schools, one private
school, and one private university. In the California State Legislature, Azusa is located in the
22nd Senate District, represented by Democrat Ed Hernandez, and in the 48th Assembly District,
represented by Democrat Blanca Rubio. Federally, Azusa is located in California's 32nd
congressional district, and is represented by Democrat Grace Napolitano.
Purposes of this Plan
Public participation is the process through which stakeholders can partake directly in agency
decision-making, and express their concerns, desires, and values. It is the mission of this agency
to "improve the lives of people with disabilities by creating opportunities to maximize their
independence." At every opportunity through prescribed methods the agency will solicit input
from stakeholders in order to best support persons served without creating disproportionately
high and adverse human health or environmental effects on minority and/or low-income
populations.
Summary of Outreach Efforts
The following is a summary of outreach efforts conducted by the City of Azusa as they relate to
Title VI requirements under the Public Participation Plan. Many of our activities are conducted
in partnership or ad hoc outreach with other service organizations and non-profit agencies within
the community. This is in no way a complete list but rather documents the agency's outreach
efforts as they relate specifically to minority and low-income populations.
City Council and Commission Meetings - Open to the Public
City Council and Advisory Commission meetings are open to the public and announced on the
agency's website. When public meetings are held they are held in ADA accessible buildings.
Meetings to discuss changes or additions to the transportation program are publicized by posting
the agenda at the City Clerk’s office, the Police Department, the Library, in front of The
Auditorium, Light & Water, and on the City’s web-page.
Los Angeles County Office of Emergency Services
The City of Azusa previously worked in conjunction with the Los Angeles County Office of
Emergency Services in the development of the Los Angeles County Evacuation Plan. This plan
specifically addresses the needs of populations at risk including disabled, minority and low-
income. This partnership also includes a coordinated plan in which this agency will provide
vehicles, transportation, and shelter during evacuation emergencies.
City of Azusa Title VI Program
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Food, Clothing, and Toy Drives
Annually, the City of Azusa conducts food, clothing, and toy drives to connect with and benefit
low-income populations. These events are publicized through press releases to various media
outlets and flyers.
The City of Azusa Website
Currently, the City of Azusa posts notices and announcement on the agency's website. Additional
public input can be obtained by the Title VI Complaint Form, which is available as a download
in English and Spanish.
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Language Assistance Plan
Overview
The first section in this document describes the purpose of the Language Assistance Plan
(LAP). The second section in this document provides the four-factor Limited English
Proficient (LEP) analysis (as outlined by the Department of Transportation (DOT) used to
identify LEP needs and assistance measures. The four-factor LEP analysis includes:
Factor 1: The number or proportion of LEP persons in the service area who may be
s erved or are likely to encounter the Life Skills Learning Center program, activity or
service.
Factor 2: The frequency with which LEP persons come in contact with the Life Skills
Learning Center program, activit y or service.
Factor 3: The nature and importance of programs, activities or services provided by Life
Skills Learning Center to the LEP population.
Factor 4: The resources available to the City of Azusa and overall cost to provide LEP
assistance.
The third and final section discusses the implementation of the Language Assistance Plan ,
which includes methodologies for identifying LEP individuals, providing services, establishing
policies, monitoring the LAP, and recommendations for future LAP implementations.
City of Azusa Title VI Program
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Purpose of the Language Assistance Plan
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and
national origin in programs and activities receiving federal financial assistance. One critical
concern addressed by Title VI is the language barrier that Limited English Proficiency (LEP)
persons face with respect to accessing information about and using transit service. Transit
operators must ensure that this group has adequate access to the agency’s programs and
activities, including public participation opportunities.
Executive Order 13166, titled “Improving Access to Services for Persons with Limited
English Proficiency,” forbids funding recipients from “restricting an individual in any way in
the enjoyment of any advantage or privilege enjoyed by others receiving any service, financial
aid, or other benefit under the program,” or from “utilize[ing] criteria or methods of
administration which have the effect of subjecting individuals to discrimination because of their
race, color, or national origin, or have the effect of defeating or substantially impairing
accomplishment of the objectives of the program as respects to individuals of a particular race,
color, or national origin.”
FTA Circular 4702.1B was developed by the Federal Transit Administration (FTA) and
details the administrative and reporting requirements for recipients of FTA financial assistance
to comply with Title VI and related executive orders including on LEP.
The United States Department of Transportation (DOT) published guidance that directed its
recipients to ensure meaningful access to the benefits, services, information, and other important
portions of their programs and activities for LEP customers. The City of Azusa language
assistance plan (LAP) includes a four factor analysis and implementation plan that complies with
the requirements of DOT LEP guidance.
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Four Factor Analysis
Factor 1: The number or proportion of LEP persons eligible to be served or likely to be
encountered by the program or recipient.
To determine this number, the City of Azusa referred to demographic information provided by
the U.S. Census Bureau. Data from the Census Bureau’s American Community Survey (2007-
11) indicates that the population of the City of Azusa above 5 years of age is 40,299. From this
total, residents were divided by language into those who can speak English “very well” or “less
than very well.” For the purposes of determining the number of LEP persons eligible to be
served by Azusa Transit services, this analysis focuses on those who speak English “less than
very well,” in accordance with the formal definition of LEP persons from the FTA. The analysis
results showed that of the various languages spoken in Azusa, three languages had over 1,000
speakers who could speak English “less than very well,” thus falling under the FTA’s “Safe
Harbor Provision” threshold. Based on the results from the American Community Survey, the
language of Spanish meets the LEP “Safe Harbor” threshold, as shown in the table below:
Total Azusa Population 5 yrs. And Older 40,299
Languages Total
Speak English
"Less Than
Very Well"
% of Total
Population
Spanish 19,946 11,025 27.36%
Indo-European 751 285 0.71%
Asian and PI 1,741 730 1.81%
The City of Azusa then determined, based on the numbers provided by the Census, the
appropriate level of language assistance needed for each safe harbor group. A higher number of
LEP persons per language generally means a higher level of assistance needs to be provided.
City staff will continue working with other City departments, as well as agencies that often come
into direct contact with these populations, in order to ascertain the appropriate level of language
assistance needed.
Factor 2: The frequency with which LEP persons come into contact with the program.
The City of Azusa recognizes that additional LEP groups require a unique mix of
communication, both written and oral, in order to be effectively informed of service changes and
other customer information. As required, the City has and/or will conduct a language assessment
based on the following methods:
1. Analyze updated census data to identify the percentage of LEP persons in the service area.
2. Utilize ridership surveys from transit planning or marketing studies to identify the percent of
transit users that are LEP persons.
3. Survey staff members who interact with the public, such as drivers and workers at the transit
counter, about their experience concerning any contacts with LEP persons during the previous
year.
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Factor 3: The nature and importance of the program, activity, or service provided by the
program to people’s lives.
Transit services operated by the City of Azusa play a vital role in the lives of many residents of
the service area. City transit services include connections to the Los Angeles regional transit
network via Metro Gold Line, Metro bus lines, and Foothill Transit bus lines. These services
reach most major job centers in Southern California. In addition, seniors rely on transit services
for trips to shopping areas, doctor appointments, and many other destinations in the City.
Factor 4: The resources available to the recipient for LEP outreach, as well as the costs
associated with that outreach.
The City of Azusa currently provides resources to each LEP group while maintaining cost
efficiency for taxpayers. Resources may include, but are not limited to:
1. Bilingual or multi-lingual staff members (the City’s Transit Division currently has staff
members who are fluent in Spanish)
2. Professional translation services (can be implemented quickly with minimal cost)
3. On-call translation services (can be implemented quickly)
4. Input by various community organizations that regularly interact with LEP populations
(ongoing basis)
5. Printing services for vital documents, brochures, and other media. Essential documents such as
Title VI forms, Dial-a-Ride applications, proposed service/fare changes, and certain scheduling
information will be made available in the identified languages per the LEP analysis. The City
will attempt to use universal symbols such as pictures, maps, and diagrams when feasible to
streamline communication among all language groups.
6. Documents, brochures, and other media of less-essential importance shall be translated into
the identified languages per the LEP analysis upon request. (available upon request)
7. Multi-lingual services and resources offered and utilized by other City departments (available
upon request)
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Language Assistance Implementation Plan
Language Assistance Measures
Language measures currently used or planned to be used by the City of Azusa to address the
needs of LEP persons include the following:
• Vital documents including the Civil Rights Notice, Title VI Complaint Form, and Title
VI Complaint Procedures translated into the identified LEP languages
• Translating marketing materials into Spanish
• If needed, arranging for availability of oral translators depending on availability
• Interactive meeting materials to engage LEP individuals in the planning process
• Posting notices in appropriate languages informing LEP persons of available transit
services, routes, and amenities; and during the Station Square planning process,
opportunities for LEP persons to provide input
Azusa will continue to seek ways to add notices to the City website to inform LEP populations of
opportunities for input and project construction
Staff Training
To ensure effective implementation of this plan, the City of Azusa will schedule training at
orientations for new City staff and relevant employees on an annual basis to review:
• Azusa’s Language Assistance Plan
• Demographic data about the local LEP populations
• Printed LEP persons’ materials
Notice to LEP Persons about Available Language Assistance
The City of Azusa is working toward being able to notify LEP persons in their own language
about the language assistance available to them without cost by using the following methods:
• Webpage notices
• Information at local events, City Hall, Community Center, and Azusa Public Library
• Flyers and brochures
• Sending information to local organizations
Monitoring, Evaluating, and Updating Plan
The Language Assistance Plan has been evaluated since the Metro Gold Line service began in
December of 2016 and is still considered to be applicable. On an ongoing basis, monitoring
activities may identify changes that should be made to the Language Assistance Plan. Monitoring
activities will include evaluation of the following information:
• Needs identified by the community or LEP populations during outreach activities
• New data related to LEP populations and Metro Gold Line ridership numbers
• Assessing the sufficiency of staff training and budget for language assistance
Equity Analysis - Determination of Site or Location of Facilities
None of our FTA funded construction projects required land acquisition and the displacement of
persons from their residences and businesses, therefore we did not need to conduct a Title VI
equity analysis.
Minority Representation on Planning and Advisory Bodies
Azusa does not have a transit related planning advisory board.
City of Azusa Title VI Program
Updated: 2/5/2018 21
Safe Harbor Provision
The Federal Transit Authority Circular 4702.1B states:
"DOT has adopted DOJ’s Safe Harbor Provision, which outlines
circumstances that can provide a “safe harbor” for recipients regarding
translation of written materials for LEP populations. The Safe Harbor
Provision stipulates that, if a recipient provides written translation of
vital documents for each eligible LEP language group that constitutes
five percent (5%) or 1,000 persons, whichever is less, of the total
population of persons eligible to be served or likely to be affected or
encountered, then such action will be considered strong evidence of
compliance with the recipient’s written translation obligations.
Translation of non-vital documents, if needed, can be provided orally. If
there are fewer than 50 persons in a language group that reaches the five
percent (5%) trigger, the recipient is not required to translate vital
written materials but should provide written notice in the primary
language of the LEP language group of the right to receive competent
oral interpretation of those written materials, free of cost.
These safe harbor provisions apply to the translation of written
documents only. They do not affect the requirement to provide
meaningful access to LEP individuals through competent oral
interpreters where oral language services are needed and are
reasonable. A recipient may determine, based on the Four Factor
Analysis, that even though a language group meets the threshold
specified by the Safe Harbor Provision, written translation may not be an
effective means to provide language assistance measures. For example, a
recipient may determine that a large number of persons in that language
group have low literacy skills in their native language and therefore
require oral interpretation. In such cases, background documentation
regarding the determination shall be provided to FTA in the Title VI
Program."
Some of Azusa Transit Dial-a-Ride customers have very limited English literacy skills and are
unable to read or write in English. The City of Azusa has a bi-lingual incentive program, where it
certifies then provides additional compensation to staff that can adequately read and write in
Spanish. Azusa Transit has bi-lingual dispatchers and drivers that can assist our native Spanish
speaking population with minor translation services.
Determination of Site of Location of Facilities
Section 13 of the Title VI Requirements and Guidelines for Federal Transit Administration
Recipients defines transit facilities as storage facilities, maintenance facilities, and operations
centers. No FTA funds have been used to construct a transit facility and therefore this
requirement does not apply. FTA were used to construct a transit station, however, per Title 49,
“facilities” does not include transit stations.
RESOLUTION NO. 2018-C13
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF AZUSA
ADOPTING THE UPDATED TITILE VI PROGRAM
WHEREAS, the City of Azusa desires to comply with Title VI of the Civil
Rights Act of 1964, including new provisions detailed in U.S. Department of
Transportation’s FTA Circular 4702.1B, “Title VI Requirement and Guidelines for
Federal Transit Administration Recipients,” and
WHEREAS, the City of Azusa adopted a Title VI Program on September 2,
2014, which was approved by Caltrans on October 1, 2014, and
WHEREAS, the Title VI Program requires updating every three (3) years, and
WHEREAS, the City Council wishes to approve the updated compliance plan
developed by staff to comply with the necessary provisions of the Civil Rights Act.
NOW, THEREFORE BE IT RESOLVED, by the City Council as follows:
1.The City Manager is authorized to implement any components of the updated
plan in order to meet Federal requirements.
2.The City Manager is authorized to implement policies that may be necessary
to comply with subsequent revisions or interpretations to the Civil Rights Act.
PASSED AND APPROVED this 5th day of February, 2018.
Joseph Romero Rocha, Mayor
ATTEST:
Jeffrey Lawrence Cornejo, Jr., City Clerk
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss.
CITY OF AZUSA )
Attachment 2
I HEREBY CERTIFY that the foregoing Resolution No. 2018-C13 was duly
adopted by the City Council of the City of Azusa at a regular meeting thereof, held on the
5th day of February, 2018, by the following vote of Council:
AYES: COUNCILMEMBERS
NOES: COUNCILMEMBERS
ABSENT: COUNCILMEMBERS
Jeffrey Lawrence Cornejo, Jr., City Clerk