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Title VI Complaint Policy and Procedures & Limited English Proficiency Plan Notification
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of color, race or national origin. Pomona Valley Transportation Authority (PVTA) is committed to providing non-discriminatory services to ensure that no person is excluded from participation in, or is denied the benefits of services on the basis of race, color, national origin, or income. PVTA also takes steps to ensure meaningful access to the benefits, services, information and other important portions of their programs and activities for Limited English Proficient ("LEP") persons.

LEP persons include those individuals whose primary language is not English and who have a limited ability to read, write, speak or understand English and have reported to the U.S. Census that they do not speak English well or do not speak English at all. A link to the PVTA LEP Plan and the Title VI Procedures is included on the PVTA website.

Any person or agency with internet access will be able to access and download the plan from the PVTA 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 transition which PVTA will provide, if feasible.

Questions or comments regarding the LEP Plan may be submitted to the Pomona Valley Transportation Authority, Administrator:
2120 Foothill Blvd., Ste. #116
La Verne, CA 91750
(909) 596-7664
Fax: (909) 596-7399
Email: glspvta@gmail.com (PVTA Administrator)

PROCEDURE FOR FILING A COMPLAINT
If you believe you have been discriminated against, or that there has been a violation of any laws or regulations, or if you have a problem regarding services received, you have the right to file a grievance.

When a complaint or grievance is filed, the following will happen:

  • PVTA staff will contact you to meet to resolve the situation.
  • Meeting will be documented in writing and all parties will receive a copy of the meeting notes.
  • If the issue is resolved, no further actions will be taken.
  • If no resolution is apparent, a formal, written complaint may be filed with:

    George L. Sparks, PVTA Administrator
    Pomona Valley Transportation Authority
    2120 Foothill Blvd. Ste. 116
    La Verne, CA 91750
    (909) 596-7664 (phone)
    (909) 596-7399 (Fax)
    glspvta@gmail.com (e-mail)

If a resolution of the situation is not apparent in a reasonable time, the complaint or grievance may be forwarded to: U.S. Department of Transportation, Federal Transit Administration, Office of Civil Rights. The regional office is located at Federal Transportation, Region IX 201 Mission Street, Suite 1650, San Francisco CA 94105-1839

LIMITED ENGLISH PROFICIENCY (LEP) PLAN
Pomona Valley Transportation Authority

Introduction
This Limited English Proficiency (LEP) Plan has been prepared to address Pomona Valley Transportation Authority responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, Federal Transit Administration Circular 4702.1A dated May 13, 2007, which state that no person shall be subjected to discrimination on the basis of race, color or national origin.

Executive Order 13166, titled Improving Access to Services for Persons with Limited English Proficiency, indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to all state and local agencies which receive federal funds.

Plan Summary
PVTA is the operator of Get About transportation and other local transportation services. PVTA has developed this LEP Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency who wish to access services provided by PVTA. 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, and the ways in which assistance may be provided.

In order to prepare this plan, PVTA undertook the U.S. Department of Transportation (U.S. DOT) four-factor LEP analysis which considers the following factors:

  1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a PVTA program, activity or service.

  2. The frequency with which LEP persons come in contact with PVTA programs, activities or services.

  3. The nature and importance of programs, activities or services provided by PVTA to the LEP population.

  4. The resources available to PVTA and overall cost to provide LEP assistance.

LEP Assistance
PVTA 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 PVTA could partner with for outreach and translation efforts. The amount of staff and vehicle operating training that might be needed was also considered.

Based on the four-factor analysis, PVTA developed its LEP Plan as outlined in the following section.

Limited English Proficiency (LEP) Plan

Limited English Proficiency (LEP) Plan Outline
How PVTA and staff may identify an LEP person who needs language assistance:

  1. Examine records to see if requests for language assistance have been received in the past, either at meetings or over the phone, to determine whether language assistance might be needed at future events or meetings.

  2. Have a staff person greet participants as they arrive to PVTA sponsored events. By informally engaging participants in conversation it is possible to gauge each attendee’s ability to speak and understand English.

  3. Have Census Bureau Language Identification Flashcards available at PVTA meetings. This will assist PVTA in identifying language assistance needs for future events and meetings.

  4. Have Census Bureau Language Identification Flashcards on all transit vehicles to assist vehicle operators in identifying specific language assistance needs of passengers. If such individuals are encountered, vehicle operators will be instructed to try to obtain contact information to give to PVTA’s management for follow-up.

  5. Vehicle operators and other front-line staff, like dispatchers, dial-a-ride schedulers, and service development planners, will be surveyed on their experience concerning any contacts with LEP persons during the previous year.

Language Assistance Measures
There are numerous language assistance measures available to LEP persons, including both oral and written language services. There are also various ways in which PVTA staff responds to LEP persons, whether in person, by telephone or in writing.

  • Network with local human service organizations that provide services to LEP individuals and seek opportunities to provide information on PVTA programs and services;

  • Provide a bilingual staff at community events, public hearings and Board of Director meetings and on the Get About reservation and customer service phone lines.

  • To the extent feasible assign bilingual drivers to vehicle runs serving groups with a high concentration of LEP riders.

  • Placement of statements in notices and publications that interpreter services are available for these meetings, with seven day advance notice;

  • Survey bus drivers and other front-line staff, like dispatchers, dial-a-ride schedulers, and service development planners, annually on their experience concerning any contacts with LEP persons during the previous year;

  • Post the PVTA Title VI Policy and LEP Plan on the agency website, www.pvtrans.org;

  • Include language “Spanish a plus” on bus driver recruitment flyers and onboard recruitment posters;

  • When an interpreter is needed, for a language other than Spanish, in person or on the telephone, staff will attempt to access language assistance services from a professional translation service or qualified community volunteers. A list of volunteers will need to be developed.

Staff Training
The following training will be provided to PVTA staff:

  1. Information on the PVTA Title VI Procedures and LEP responsibilities

  2. Description of language assistance services offered to the public

  3. Use of Language Identification Flashcards

  4. Documentation of language assistance requests

  5. 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 will be available as needed.

Monitoring and Updating the LEP Plan
PVTA will update the LEP as required by U.S. DOT. At minimum, the plan will be reviewed and updated when data from the 2010 U.S. Census is available, or when it is clear that higher concentrations of LEP individuals are present in the PVTA service area. Updates will include the following:

  • The number of documented LEP person contacts encountered annually

  • How the needs of LEP persons have been addressed

  • Determination of the current LEP population in the service area

  • Determination as to whether the need for translation services has changed

  • Determine whether local language assistance programs have been effective and sufficient to meet the need

  • Determine whether PVTA’s financial resources are sufficient to fund language assistance resources needed

  • Determine whether PVTA has fully complied with the goals of this LEP Plan

  • Determine whether complaints have been received concerning PVTA’s failure to meet the needs of LEP individuals

Dissemination of the PVTA LEP Plan
A link to the PVTA LEP Plan and the Title VI Procedures is included on the PVTA website.

Any person or agency with internet access will be able to access and download the plan from the PVTA 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 PVTA will provide, if feasible.

Questions or comments regarding the LEP Plan may be submitted to the Pomona Valley Transportation Authority, Administrator:

Pomona Valley Transportation Authority
2120 Foothill Blvd., Ste. 116
La Verne, CA 91750
Phone: 909-596-7664
Fax: 909-596-7664
Email: glspvta@gmail.com (PVTA Administrator)