Title VI Program FINAL - Seagull · Title VI plan including complaint\rforms uploaded to Seagull website\r Title VI training for van operators\rand front office staff 9/11/15 8/28/15

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Title VI Program

Adopted 1/13/15

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Seagull Services

Title VI Program Activity Log

Date Activity Concerned Person Remarks (Review/ Update/ Addendum/ (Signature)

Adoption/ Distribut ion)

4/28/2015 Administrative review and update 1~-ft FOOT /"~AJ'v~u- recommendations

Rachel WatermanTypewritten Text
















Rachel WatermanTypewritten Text9/15/15

Rachel WatermanTypewritten TextTitle VI plan including complaintforms uploaded to Seagull website






Rachel WatermanTypewritten TextTitle VI training for van operatorsand front office staff




Rachel WatermanTypewritten TextDOT concurrence letter insertedinto Title VI Plan


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Table of Contents

1.0 Title VI/Nondiscrimination Policy Statement & Management Commitment to Title VI Program1‐1

2.0 Introduction & Description of Services ..................................................................................... 2‐1

2.1 Annual Certifications and Assurances .................................................................................... 2‐2 2.2 Title VI Program Concurrence and Adoption ......................................................................... 2‐2

3.0 Title VI Notice to the Public ...................................................................................................... 3‐1

3.1 Notice to Public ...................................................................................................................... 3‐9

4.0 Title VI Procedures and Compliance.......................................................................................... 4‐1

4.1 Complaint Procedure .............................................................................................................. 4‐1 4.2 Complaint Form ...................................................................................................................... 4‐2 4.3 Record Retention and Reporting Policy ............................................................................... 4‐18

5.0 Title VI Investigations, Complaints, and Lawsuits ...................................................................... 5‐1

6.0 Public Participation Plan ........................................................................................................... 6‐1

7.0 Language Assistance Plan ......................................................................................................... 7‐1

7.1 Overview ................................................................................................................................. 7‐1 7.2 Four Factor Analysis ............................................................................................................... 7‐2 7.3 Language Assistance Plan ....................................................................................................... 7‐4

8.0 Transit Planning and Advisory Bodies ....................................................................................... 8‐1

9.0 Title VI Equity Analysis ............................................................................................................. 9‐1

10.0 System‐Wide Service Standards and Service Policies .............................................................. 10‐1

10.1 Service Standards ................................................................................................................. 10‐1

11.0 Appendices ............................................................................................................................ 11‐1

APPENDIX A FTA CIRCULAR 4702.1B REPORTING REQUIREMENTS FOR TRANSIT PROVIDERS APPENDIX B TITLE VI PROGRAM ADOPTION MEETING MINUTES AND FDOT CONCURRENCE LETTER APPENDIX C OPERATING AREA LANGUAGE DATA: SEAGULL SERVICES’ SERVICE AREA APPENDIX D DEMOGRAPHIC MAPS APPENDIX E TITLE VI EQUITY ANALYSIS

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2.0 Introduction & Description of Services

Seagull Services submits this Title VI Program in compliance with Title VI of the Civil Rights Act of 1964, 49 CFR Part 21, and the guidelines of FTA Circular 4702.1B, published October 1, 2012.

Seagull Services is a sub‐recipient of FTA funds and provides service in Palm Beach County, FL.

Seagull Services’ mission is to assist people with intellectual and developmental disabilities to live in dignity and realize their life potential through education, vocational training, employment and other support services and advocacy. We believe every person has the right to the opportunity to live a satisfying, productive life, to fully participate in the community, and to live as independently as possible, while having the support and resources necessary to pursue their dreams and fulfill their aspirations.

Seagull serves more than 300 families each year through our programs: the Seagull Achievement Center, Seagull Place residential facilities, our Work Makes Cents employment support and placement services, and our public charter school, Seagull Academy for Independent Living (SAIL).

Seagull Services is a Florida‐based nonprofit governed by an 11‐member volunteer Board of Directors and President and CEO. The board employs the agency’s President and CEO, Barbara Nurenberg, who in turn employs a staff of fourteen full‐time and five part‐time people dedicated to serving our program participants. On average 80 dedicated individuals volunteer regularly.

Seagull Services maintains policies and procedures for employees, clients and students. There are Standard Operating Procedures in place that relates to the safety and welfare of each group while engaged in Seagull activities. An on‐site designated Safety Officer handles the DOT safety plan.

Seagull’s Vice President of Finance is responsible for insurance policies. She is responsible for annual renewal of all liability insurance for all vehicles, handles vehicle registration renewal, and maintains all titles, registration forms and warranty information. Our Chief Vocational Specialist oversees scheduling, supervision of drivers and general oversight duties. The Director of Human Resources is responsible to ensure each driver has a DOT physical as required and directs employees in quarterly random drug tests. Palm Tran (Palm Beach County) regularly monitors Seagull’s fleet to ensure that vehicles are properly maintained. The Chief Operating Officer, Facilities Director and the Director of Human Resources share miscellaneous administrative responsibilities in this area.

Maintenance of the vehicles and the updating of each vehicle’s service files are handled by our mechanic, a veteran of more than sixteen years with Seagull Services. There are some repairs that

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require that we use an outside mechanic. All maintenance is performed using the Edwards Preventative Maintenance Plan, which conforms to the State Vehicle Maintenance Guidelines set forth in the FDOT Preventative Maintenance Guidelines document. Palm Tran (Palm Beach County) regularly monitors our fleet to ensure that vehicles are properly maintained. All vehicle files and driver files are kept on‐site at our operations base located at 3879 Byron Drive, West Palm Beach, FL 33407 and are maintained by the Transportation Manager. All records are maintained and retained for a minimum of four (4) years.

Our transportation department has a total of 21 employees that include: 17 part‐time drivers, 2 administrators and 2 support staff. Only transportation employees that have completed all of the required safety and drivers training requirements will be allowed to drive the agency vehicles. Currently no vehicles in our fleet require Commercial Driver’s licensure. Within Seagull are forty employees that comply with DOT requirements to transport our program participants

These are the transportation routes for our adults and youth:

Route 1 Riviera Beach, FL transporting round‐trip to Seagull Work Center (11 passengers each way)

Route 2 Downtown West Palm Beach, FL transporting round‐trip to Seagull Work Center (11 passengers each way)

Route 3 West Palm Beach (West of I‐95) transporting round‐trip to Seagull Work Center (10 passengers each way)

Route 4 Jupiter to Haverhill (including Palm Beach Gardens) transporting round‐trip to Seagull Work Center (11 passengers each way)

Route 5 Wellington (including West Palm Beach County) transporting round‐trip to Seagull Work Center (8 passengers each way)

Route 6 Boynton Beach and Lantana area transporting round‐trip to Seagull Work Center (10 passengers each way)

Route 7 Singer Island, assisted living facility to Seagull Work Center (9 passengers each way)

Route 8 Singer Island, assisted living facility to Seagull Work Center (9 passengers each way) Route 9 Singer Island, assisted living facility to Seagull Work Center (9 passengers each way) Route 10 North to Jupiter and south to include, but not limited to, Singer Island, and Bear Lake

Country Club area off 45th St. to Seagull Academy (7 passengers in morning/9 in afternoon)

Route 11 Military Trail from M.L.K. Blvd. in Riviera Beach to Southern Blvd on the west side of I‐95; east of 95 to Flagler Blvd. north of Southern to Seagull Academy (7 passengers each way)

Route 12 South county to Boynton Beach to include Lantana, Lake Worth, Palm Springs, and Greenacres to Seagull Academy (8 passengers each way)

Route 13 Central and Western Palm Beach County to include, but not limited to, Royal Palm Beach, Wellington, and Belle Glade to Seagull Academy (8 passengers each way)

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Seagull Service must designate a liaison for Title VI issues and complaints within the organization. The liaison is the focal point for Title VI implementation and monitoring of activities receiving fed‐eral financial assistance. Key responsibilities of the Title VI Liaison include: Maintain knowledge of Title VI requirements. Attend training on Title VI and other nondiscrimination authorities when offered by FDOT or

any other regulatory agency. Disseminate Title VI information to the public including in languages other than English, when

necessary. Develop a 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 processing of Title VI complaints.

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FTA Circular 4702.1B, Chapter III, Paragraph 2: Every application for financial assistance from FTA must be accompanied by an assurance that the applicant will carry out the program in compliance with the Title VI regulations.

2.1 Annual Certifications and Assurances In accordance with 49 CFR Section 21.7(a), every application for financial assistance from FTA must be accompanied by an assurance that the applicant will carry out the program in compliance with Title VI regulations. This requirement shall be fulfilled when the applicant/recipient submits its an‐nual certifications and assurances. Primary recipients will collect Title VI assurances from sub‐recipients prior to passing through FTA funds.

Seagull Services will remain in compliance with this requirement by annual submission of certifica‐tions and assurances as required by FDOT.

2.2 Title VI Program Concurrence and Adoption This Title VI Program received FDOT concurrence on July 21, 2015. The Program was approved and adopted by Seagull Services’ Board of Directors during a meeting held on January 13, 2015. A copy of the meeting minutes and FDOT concurrence letter is included in Appendix B of this document.

Title VI Liaison Linda Moore Chief Operating Officer (561) 842‐5814 3879 Byron Drive West Palm Beach, FL 33404

Alternate Title VI Contact Ellen Hoffacker Vice President of Finance (561) 842‐5814 3879 Byron Drive West Palm Beach, FL 33404

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3.0 Title VI Notice to the Public

3.1 Notice to Public

Recipients must notify the public of its rights under Title VI and include the notice and where it is posted in the Title VI Program. The notice must include:

A statement that the agency operates programs without regard to race, color and national origin

A description of the procedures members of the public should follow in order to request additional information on the grantee’s nondiscrimination obligations

A description of the procedure members of the public should follow in order to file a discrimination complaint against the grantee

The following is Seagull Services’ Title VI notice to the public:

Seagull Services operates its transportation programs and services without regard to race, color, and 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 Title VI may file a complaint with Seagull Services.

For more information on Seagull Services’ civil rights program, and the procedures to file a com‐plaint, contact Linda Moore at 561‐842‐5814,email [email protected] or visit our administrative office at 3879 Byron Dr., West Palm Beach, FL 33404 or seagull.org.

A complainant may file a complaint directly with the Florida Department of Transportation by filing a complaint with the District 4 Title VI Coordinator Adrienne Brown at [email protected]

A complainant may also file a complaint directly with Federal Transit Administration by filing a com‐plaint with the Office of Civil Rights, Attention: Complaint Team, East Building, 5th Floor‐TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.

If information is needed in another language, contact Linda Moore, Chief Operating Officer at 561‐842‐5814.

FTA Circular 4702.1B, Chapter III, Paragraph 5: Title 49 CFR 21.9(d) requires recipients to provide information to the public regarding the recipient’s obligations under DOT’s Title VI regulations and apprise members of the public of the protections against discrimination afforded to them by Title VI.

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3.1 Notice to Public (Spanish)

Aviso al público:

Seagull Services desarrolla sus programas y servicios de transporte sin hacer distinción de raza, color y nacionalidad, de acuerdo con lo establecido en el Título VI de la Ley de Derechos Civiles. Toda persona que considere que ha sido agraviada por alguna práctica discriminatoria ilegal conforme el Título VI puede presentar su queja ante Seagull Services.

Para más información sobre el programa de derechos civiles de Seagull Services y para conocer los procedimientos de presentación de quejas, comuníquese con Linda Moore al 561‐842‐5814, correo electrónico: [email protected] o visite nuestra oficina administrativa en 3879 Byron Dr., West Palm Beach, FL 33404 o seagull.org.

Puede presentar una queja directamente ante el Departamento de Transporte de Florida, con la Coordinadora del Título VI para el Distrito 4, Adrienne Brown, escribiendo a: [email protected]

También puede presentar su queja directamente en la Administración Federal de Transporte, escribiendo a la Oficina de Derechos Civiles, a la atención de: Complaint Team, East Building, 5th Floor‐TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.

Si necesita recibir información en otro idioma, comuníquese con Linda Moore, Directora de Operaciones, al 561‐842‐5814.

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3.1 Notice to Public (French)

Avis au public :

Seagull Services exploite ses programmes et services de tranport sans distinction de race, de couleur ni d'origine conformément au titre VI de la loi sur les droits civiques. Toute personne qui croit avoir été lésée par n'importe quelle pratique discriminatoire illégale en vertu du titre VI peut déposer une plainte auprès de Seagull Services.

Pour plus d'information sur le programme des droits civiques de Seagull Services, et les procédures à suivre pour déposer une plainte, contactez Linda Moore au 561‐842‐5814, ou envoyez un courriel à l’adresse : [email protected] ou rendez‐vous à notre bureau administratif au 3879 Byron Dr., West Palm Beach, FL33404 ou visitez notre site www.seagull.org.

Un plaignant peut déposer une plainte directement auprès du Florida Département of Transportation (Département des transports de la Floride), attention Coordonnateur du District 4 Titre VI, Adrienne Brown àl’ adresse: [email protected]

Le plaignant peut également déposer une plainte directement auprès de la Federal Transit Administration (Administration fédérale des transports des États‐Unis) en la déposant auprès du bureau des droits civiques, attention : Complaint Team, East Building, 5th Floor‐TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.

Si vous avez besoin d'information dans une autre langue, contactez Linda Moore, Chef des opérations au 561‐842‐5814.

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3.1 Notice to Public (French Creole)

Anons Pou Piblik La:

Seagull Services opere pwogram transpòtasyon ak sèvis li yo san gade sou ras, koulè, ak peyi orijin moun konfòmeman ak Tit VI nan Lwa Dwa Sil la. Nenpòt moun ki kwè yo te fè yon pratik diskriminasyon ilegal kont li sou Tiv VI kapab depoze yon plent ak Seagull Services.

Pou plis enfòmasyon sou pwogram dwa sivil Seagull Services la, ak pwosedi pou depoze yon plent, kontakte Linda Moore nan 561‐842‐5814, imèl [email protected] oswa vizite biwo administratif nou nan 3879 Byron Dr., West Palm Beach, FL 33404 or seagull.org.

Yon moun k ap depoze yon plent kapab voye li dirèkteman bay Depatman Edikasyon Florida. Pou fè sa depoze plent la ak Kòdonatris Distri 4 Tit VI Adrienne Brown nan [email protected]

Yon moun k ap depoze yon plent kapab fè li dirèkteman ak Office of Civil Rights, Attention: Complaint Team, East Building, 5th Floor-TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.

Si ou bezwen enfòmasyon nan yon lòt lang, kontakte Linda Moore, Operatè Operasyon Prensipal nan 561-842-5814.

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3.1 Notice to Public (Italian)

Avviso al pubblico La Seagull Services elabora i propri programmi e servizi di trasporto senza considerare la razza, il colore e le origini, in ottemperanza al Titolo VI della Dichiarazione dei Diritti Civili. Ciascun individuo ritenga di essere stato leso da qualsiasi pratica discriminatoria illegale, ai sensi del Titolo VI di tale Dichiarazione, può presentarne denuncia alla Seagull Services. Per maggiori informazioni sul programma in materia di diritti civili di Seagull Services e sulle procedure per presentare una denuncia, si prega di contattare Linda Moore al numero di telefono561‐842‐5814 oppure via e‐mail all’indirizzo [email protected].

Il ricorrente può presentare una denuncia direttamente al Dipartimento dei Trasporti della Florida all’attenzione della Coordinatrice della sezione Titolo VI del Distretto 4,AdrienneBrown,all’indirizzo di posta [email protected]

Un ricorrente può, inoltre, presentare una denuncia direttamente all’Amministrazione Federale dei Trasporti tramite l’Ufficio Diritti Civili, alla c.a. della Sezione Denunce, Edificio Est, V piano‐TCR, 1200 New Jersey Ave., SE, Washington, DC 20590. Se si necessitano informazioni in un’altra lingua, contattare Linda Moore, Coordinatrice Operativa,al numero di telefono 561‐842‐5814.

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3.1 Notice to Public (Portuguese)

Aviso ao público:

A Seagull Services opera seus programas e serviços de transporte sem considerar raça, cor e nacionalidade, em conformidade com o Título VI da Lei de Direitos Civis. Qualquer pessoa que considerar ter sido lesada por qualquer prática discriminatória ilegal nos termos do Título VI poderá apresentar uma denúncia junto à Seagull Services.

Para obter mais informações sobre o programa de direitos civis da Seagull Services, e sobre os procedimentos para apresentar uma denúncia, entre em contato com Linda Moore, pelo telefone 561‐842‐5814, pelo e‐mail [email protected], ou visite nosso escritório administrativo em 3879 Byron Dr., West Palm Beach, FL 33404 ou nosso site seagull.org.

Qualquer pessoa pode apresentar uma denúncia diretamente na Florida Department of Transportation (Secretaria de Transportes da Flórida) mediante preenchimento de uma denúncia enviada à Coordenadora do Título VI do Distrito 4, Adrienne Brown, pelo e‐mail [email protected]

O denunciante também pode apresentar uma denúncia diretamente junto à Federal Transit Administration (Administração Federal de Trânsito) mediante preenchimento de uma denúncia endereçada à Office of Civil Rights (Secretaria de Direitos Civis), aos cuidados de: Complaint Team, East Building, 5th Floor-TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.

Se houver necessidade de informações em outro idioma, entre em contato com Linda Moore, Diretora de Operações pelo telefone 561-842-5814.

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3.1 Notice to Public (Chinese)

公眾通告：

根據民權法案的第六章,海鷗服務運營其運輸計劃和服務,不區分種族，膚色和國籍。任何

人確信他或她由於任何非法的歧視性做法被傷害,根據民權法案第六章可向海鷗服務投

訴。

有關海鷗服務“公民權利計劃和程序的詳細信息，並提出申訴的程序，請聯繫琳達·穆爾.

電話561‐842‐5814，電子郵件[email protected];

或訪問我們的行政辦公室在3879號拜倫路，西棕櫚灘，佛羅里達州33404; 或seagull.org。

申訴人可直接提交投訴佛羅里達運輸部,提交申訴給4區民權法案第六章協調員艾德麗安·

布朗; 電子郵件:[email protected].

申訴人可直接與聯邦運輸管理局人權辦公室投訴;投訴提交給: 投诉小组,東方大廈5樓‐

TCR，1200东南新澤西大道，SE，華盛頓特區，20590。

如果需要另一種語言資訊，請聯繫琳達·穆爾，首席運營官, 電話561‐842‐5814。

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3.1 Notice to Public (Vietnamese)

Thông báo đến công chúng:

Seagull Services cung cấp các chương trình và dịch vụ vận chuyển của họ mà không quan tâm đến chủng tộc, màu da và nguồn gốc quốc gia tuân theo Tiêu đề VI của Đạo luật Quyền Dân sự. Tất cả những cá nhân tin rằng họ đang bị gây phiền nhiễu bởi bất cứ hành vi kỳ thị trái phép nào theo Tiêu đề VI đều có thể gửi khiếu nại đối với Seagull Services.

Để biết thêm thông tin về chương trình quyền dân sự của Seagull Services, và thủ tục gửi khiếu nại, quý vị vui lòng liên hệ với Linda Moore theo số 561‐842‐5814, gửi email đến [email protected] hoặc ghé thăm văn phòng hành chính của chúng tôi tại 3879 Byron Dr., West Palm Beach, FL 33404 hay truy cập seagull.org.

Người khiếu nại có thể nộp đơn khiếu nại trực tiếp với Bộ Giao thông Vận tải Florida, thông qua Điều phối viên Adrienne Brown phụ trách Tiêu đề VI của Quận 4 tại địa chỉ [email protected]

Người khiếu nại cũng có thể nộp đơn khiếu nại trực tiếp với Ban Quản lý Giao thông Vận tải Liên bang, thông qua Văn phòng Quyền Dân sự, địa chỉ Attention: Complaint Team, East Building, 5th Floor-TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.

Nếu quý vị cần thông tin bằng một ngôn ngữ khác, hãy liên hệ với Linda Moore, Giám đốc Điều hành theo số 561-842-5814.

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3.2 Notice Posting Locations

The Notice to Public will be posted at many locations to apprise the public of Seagull Services’ obligations under 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 Seagull Services’ administrative offices in all vehicles.

Seagull Services’ notice to the public will be posted at the following locations:

The Title VI notice and program information will also be provided on Seagull Services’ website at www.seagull.org

LocationName Address City Seagull Admin. Office 3879 Byron Dr. West Palm Beach Vehicles 3879 Byron Dr. West Palm Beach

SAIL Front Office 6250 N. Military Trail Riviera Beach

Seagull Place 1233 Island Rd. Riviera Beach

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4.0 Title VI Procedures and Compliance

4.1 Complaint Procedure

Any person who believes he or she has been discriminated against on the basis of race, color or na‐tional origin by Seagull Services may file a Title VI complaint by completing and submitting the agency’s Title VI Complaint Form. Complaints can also be submitted by phone at 561‐842‐5814, ext. 107 or via the web at www.seagull.org. Seagull Services investigates complaints received no more than 180 days after the alleged incident. Seagull Services will only process complaints that are com‐plete. To be considered complete, complainants must, at a minimum, include their name, contact information, date of alleged incident, and a description of the incident.

Once the complaint is received, Seagull Services will review it to determine if our office has jurisdic‐tion. The complainant will receive an acknowledgement letter informing him/her whether the com‐plaint will be investigated by our office.

Seagull Services has ninety (90) days to investigate the complaint. If more information is needed to resolve the case, Seagull Services may contact the complainant. The complainant has ten (10) busi‐ness 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 ten (10) business days, Seagull Services 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 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. A LOF summarizes the allegations and the interviews regarding the alleged incident, and explains whether any disciplinary action, addi‐tional training of the staff member or other action will occur. If the complainant wishes to appeal the decision, she/he has seven (7) days to do so from the time he/she receives the closure letter or the LOF.

The complaint procedures and forms will be made available to the public on Seagull Services’ website www.seagull.org. The forms are also available in other formats upon request.

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 member of the public.

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4.2 Complaint Form

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4.2 Complaint Form

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4.2 Complaint Form (Spanish)

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4.2 Complaint Form (Spanish)

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4.2 Complaint Form (French)

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4.2 Complaint Form (French)

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4.2 Complaint Form (French Creole)

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4.2 Complaint Form (French Creole)

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4.2 Complaint Form (Italian)

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4.2 Complaint Form (Portuguese)

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4.2 Complaint Form (Portuguese)

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4.2 Complaint Form (Chinese)

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4.2 Complaint Form (Chinese)

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4.2 Complaint Form (Vietnamese)

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4.2 Complaint Form (Vietnamese)

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4.3 Record Retention and Reporting Policy FTA requires that all direct and primary recipients document their compliance by submitting a Title VI Program to their FTA regional civil rights officer once every three (3) years. Seagull Services will submit Title VI Programs to FDOT for concurrence on an annual basis or any time a major change in the Program occurs.

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

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5.0 Title VI Investigations, Complaints, and Lawsuits

In accordance with 49 CFR 21.9(b), Seagull Services 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 Seagull Services in response; and final findings related to the investigation, lawsuit, or complaint. The records for the previous three (3) years shall be included in the Title VI Program when it is submitted to FDOT.

Seagull Services has had no investigations, complaints, or lawsuits involving allegations of discrimination on the basis of race, color, or national origin over the past three (3) years.

Table 1: Summary of Investigations, Lawsuits and Complaints

FTA Circular 4702.1B, Chapter III, Paragraph 7: In order to comply with the reporting requirements of 49 CFR 21.9(b), FTA requires all recipients to prepare and maintain a list of any of the following that allege discrimination on the basis of race, color, or national origin: active investigations….; lawsuits, and complaints naming the recipient.

Date (Month, Day,

Year)

Summary (include basis of complaint: race,

color, or national origin)

Status Action(s) Taken

Investigations 1. 2. Lawsuits 1. 2. Complaints 1. 2.

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6.0 Public Participation Plan

Introduction

The Public Participation Plan (PPP) for Seagull Services 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 Seagull Services. 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 Seagull Services’ services and to provide a variety of efficient and convenient methods for receiving and considering public comment prior to implementing changes to services. Seagull Services also recognizes the importance of many types of stakeholders in the decision‐making process, including other units of government, metropolitan area agencies, 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 Seagull Services and its operations. The goals for this PPP include:

Inclusion and Diversity: Seagull Services will proactively reach out and engage low‐income, minority, and LEP populations for Seagull Services’ 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.

Responsive: Seagull Services will strive to respond to and incorporate, when possible, appropriate public comments into transportation decisions.

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

FTA Circular 4702.1B, Chapter III, Paragraph 4.a.4: Every Title VI Plan shall include the following in‐formation: A public participation plan that includes an outreach plan to engage minority and limited English proficient populations, as well as a summary of outreach efforts made since the last Title VI Plan submission. A recipient’s targeted public participation plan of minority populations may be part of efforts that extend more broadly to include constituencies that are traditionally underserved, such as people with disabilities, low‐income populations, and others.

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Public Participation Methods

The methods of public participation included in this PPP were developed based upon best practices in conjunction with the needs and capabilities of Seagull Services. Seagull Services intends to achieve meaningful public participation by a variety of methods with respect to service and any changes to service.

The public will be invited to provide feedback on Seagull Services website (www.seagull.org) and all feedback on the site will be recorded and passed on to Seagull Services’ management. The public will also be able to call Seagull Services’ office at 561‐842‐5814 during its hours of operation. Feedback collected over the phone will be recorded and passed on to Seagull Services’ management

Seagull Services’ monthly board meetings are open to the public and each offers a public input opportunity during the public comments section. For all board meetings, the venue will be a facility that is accessible for persons with disabilities and, preferably, is served by public transit.

For other important information, Seagull Services will use a variety of means to make riders and citizens aware, including some or all of the following methods:

Posting of information on the website

Written communication to each rider

Phone communication to each rider

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

Seagull Services is not required to perform public hearings.

Current Outreach Efforts

The following is a list of Seagull Services’ outreach activities.

Every year Seagull Services participates in 5‐6 community fairs to highlight all Seagull Services’ programs. This includes Indiantown Green Market; Honda 5K; Disabilities Day.

BOAT Bash – participation 2013, 2014, 2015

Back to School Bash – 3 locations in Palm Beach County, 2012, 2013, 2014

Bowling event for People with Disabilities – 2013, 2014, 2015 (June)

Partnership with Best Buddies at two local Palm Beach County high schools – 2013, 2014

Monthly board meetings which are open to the public.

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FTA Circular 4702.1B, Chapter III, Paragraph 9: Recipients shall take reasonable steps to ensure meaningful access to benefits, services, information, and other important portions of their programs and activities for individuals who are limited English proficient (LEP).

7.0 Language Assistance Plan

7.1 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 used to identify LEP needs and assistance measures.

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.

Safe Harbor Provision, DOT has adopted the Department of Justice’s Safe Harbor Provision, which outlines circumstances that can provide a “safe harbor” for recipients regarding translation of written materials for LEP population. 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

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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.

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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. Seagull Services’ language assistance plan (LAP) includes a four factor analysis and implementation plan that complies with the requirements of DOT LEP guidance.

7.2 Four Factor Analysis

The analysis provided in this report has been developed to identify LEP populations that may use Seagull Services’ 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) Persons, dated April 13, 2007, 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 Seagull Services’ program, activity or service. Of the 1,268,614 residents in Seagull Services’ service area Spanish speakers are the primary LEP persons likely to utilize Seagull Services’ services. Appendix C contains a table which lists the languages spoken at home by the ability to speak English for the population within the Seagull Services’ service area. In Seagull Services' service area there are 164,920 residents or 13% who describe themselves as not able to communicate in English “very well” (Source: US Census 2012 ACS 5 Year). The following table shows the exact number and percentages of individuals who self‐identify as speaking English "less than very well" which meet the safe harbor threshold. These languages include: Spanish or Spanish Creole (8.24%), French (.27%), French Creole (2.54%), Italian (.16%), Portuguese or Portuguese Creole (.37%), Chinese (.22%) and Vietnamese (.18%).

2. The frequency with which LEP persons come into contact with the program. Every day individuals from a variety of backgrounds attend SAIL Academy, participate at the Achievement Center of the Palm Beaches and use our transportation throughout the day.

3. The nature and importance of the program, activity, or service provided by the program to people’s lives. Seagull Services helps adults and youth with a developmental disability or people with barriers to employment training and education to increase their independence and help them become self‐sustaining. Seagull provides twenty‐four hour residential care for vulnerable adults

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with disabilities and enhances their lives with various social and recreational activities. Seagull has helped more than 10,000 individuals and families, assisting people to live in dignity and realize their life potential through education, vocational training, employment, transportation, residential and other support services and referrals. This can only happen through coordinated transportation and the vans used by Seagull are integral. Without the ability to transport these people, self‐sufficiency could not be achieved by many.

4. The resources available to the recipient for LEP outreach, as well as the costs associated with that outreach. Seagull Services employs a diverse staff, including those who speak Spanish as well as French Creole and sign language for the hearing impaired. The complaint form has been translated into each the LEP population languages. Through this Four Factor Analysis, Seagull Services has determined outreach services are reasonable and necessary and will be provided throughout the year.

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Palm Beach County Language Data Tables - US Census 2013

ACS 5 Year

Palm Beach County

Percent of Popula-tion

Total Population 1,268,614 100.00% Speak only English 907,740 71.55%

Spanish or Spanish Creole: 213,688 16.84%

Speak English less than "very well" 104,551 8.24%

French (incl. Patois, Cajun): 12,362 0.97%

Speak English less than "very well" 3474 0.27%

French Creole: 61,203 4.82%


Italian: 6,341 0.50%


Portuguese or Portuguese Creole: 10,612 0.84%


Chinese: 5,041 0.40%


Vietnamese: 3,955 0.31%


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7.3 Language Assistance Plan

In developing a Language Assistance Plan, FTA guidance recommends the analysis of the following five elements:

1. Identifying LEP individuals who need language assistance

2. Providing language assistance measures

3. Training staff

4. Providing notice to LEP persons

5. Monitoring and updating the plan

The five elements are addressed below.

Element 1: Identifying LEP Individuals Who Need Language Assistance

Federal guidance provides that there should be an assessment of the number or proportion of LEP individuals eligible to be serviced or encountered and the frequency of encounters pursuant to the first two factors in the four‐factor analysis.

Seagull Services has identified the number and proportion of LEP individuals within its service area using United States Census data (see Appendix C). As presented earlier, 71.55% of the service area population speaks English only. The largest non‐English spoken language in the service area is Spanish or Spanish Creole (16.84%). Of the general population in Palm Beach County, 8.24% are Spanish or Spanish Creole speakers who identify themselves as speaking English less than “very well”. Seven languages are spoken by groups of at least 1,000 residents in Palm Beach County who identify themselves as speaking English less than "very well": Spanish or Spanish Creole (8.24%), French (.27%), French Creole (2.54%), Italian (.16%), Portuguese or Portuguese Creole (.37%), Chinese (.22%) and Vietnamese (.18%).

Seagull Services may identify language assistance need for an LEP group by:

1. Examining 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. Vehicle operators and front‐line staff will be surveyed on their experience concerning any contacts with LEP persons during the previous year.

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Element 2: Language Assistance Measures

Federal guidance suggests that an effective LAP should include information about the ways in which language assistance will be provided. This refers to listing the different language services an agency provides and how staff can access this information.

For this task Federal guidance recommends that transit agencies consider developing strategies that train staff as to how to effectively deal with LEP individuals when they either call agency centers or otherwise interact with the agency.

Seagull Services has undertaken the following actions to improve access to information and services for LEP individuals:

1. Provide bilingual staff at community events, and board meetings as requested. 2. Survey transit drivers and other front‐line staff annually on their experience concerning any

contacts with LEP persons during the previous year. 3. When an interpreter is needed in person or on the telephone, staff will attempt to access language

assistance services from a professional translation service, qualified community volunteer or when related to Palm Beach County district school children, access services of the school district.

Seagull Services will utilize the demographic maps provided in Appendix D in order to better provide the above efforts to the LEP persons within the service area. Element 3: Training Staff

Federal guidance states staff members of an agency should know their obligations to provide meaningful access to information and services for LEP persons and that all employees in public contact positions should be properly trained.

Suggestions for implementing Element 3 of the Language Assistance Plan, involve: (1) identifying agency staff likely to come into contact with LEP individuals; (2) identifying existing staff training opportunities; (3) providing regular re‐training for staff dealing with LEP individual needs; and (4) designing and implementing LEP training for agency staff.

In the case of Seagull Services the most important staff training is for administrators and drivers. Several staff members are bilingual in Spanish or Creole.

The following training will be provided to administrative assistants and drivers:

1. Information on Title VI Procedures and LEP responsibilities 2. Documentation of language assistance requests 3. How to handle a potential Title VI/LEP complaint

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Element 4: Providing Notice to LEP Persons

Seagull Services will make Title VI information available in English, Spanish, French, French Creole, Italian, Portuguese, Chinese and Vietnamese on the Agency’s website. Notices are also posted in Seagull Services’ office, on vehicles, at Seagull Place and Seagull Academy for Independent Living.

Element 5: Monitoring and Updating the Plan

The plan will be reviewed and updated annually. Updates will consider 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 Segull Services’ financial resources are sufficient to fund language assistance

resources needed Seagull Services understands the value that its service plays in the lives of individuals who rely on this service, and the importance of any measures undertaken to make the use of system easier. Seagull Services is open to suggestions from all sources, including customers, Seagull Services staff, other transportation agencies with similar experiences with LEP communities, and the general public, regarding additional methods to improve their accessibility to LEP communities.

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8.0 Transit Planning and Advisory Bodies

Seagull Services does not have a transit‐related committee or board, therefore this requirement does not apply.

FTA Circular 4702.1B, Chapter III, Paragraph 10: Recipients that have transit‐related, non‐elected planning boards, advisory councils or committees, or similar committees, the membership of which is selected by the recipient, must provide a table depicting the racial breakdown of the membership of those committees, and a description of efforts made to encourage the participation of minorities on such committees.

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9.0 Title VI Equity Analysis

Title 49 CFR, Appendix C, Section (3)(iv) requires that “the location of projects requiring land acquisition and the displacement of persons from their residences and business may not be determined on the basis of race, color, or national origin.” For purposes of this requirement, “facilities” does not include bus shelters, as they are considered transit amenities. It also does not include transit stations, power substations, or any other project evaluated by the National Environmental Policy Act (NEPA) process. Facilities included in the provision include, but are not limited to, storage facilities, maintenance facilities, operations centers, etc. In order to comply with the regulations, Seagull Services will ensure the following:

1. Seagull Services will complete a Title VI equity analysis for any facility during the planning stage with regard to where a project is located or sited to ensure the location is selected without regard to race, color, or national origin. Seagull Services will engage in outreach to persons potentially impacted by the siting of the facility. The Title VI equity analysis must compare the equity impacts of various siting alternatives, and the analysis must occur before the selection of the preferred site.

2. When evaluating locations of facilities, Seagull Services will give attention to other facilities with similar impacts in the area to determine if any cumulative adverse impacts might result. Analysis should be done at the Census tract or block group level where appropriate to ensure that proper perspective is given to localized impacts.

3. If Seagull Services determines that the location of the project will result in a disparate impact on the basis of race, color, or national origin, Seagull Services may only locate the project in that location if there is a substantial legitimate justification for locating the project there, and where there are no alternative locations that would have a less disparate impact on the basis of race, color, or national origin. Seagull Services must demonstrate and document how both tests are met. Seagull Services will consider and analyze alternatives to determine whether those alternatives would have less of a disparate impact on the basis of race, color, or national origin, and then implement the least discriminatory alternative.

Seagull Services has not recently constructed any facilities nor does it currently have any facilities in the planning stage. Therefore, Seagull Services does not have any Title VI Equity Analysis reports to submit with this Program. Seagull Services will utilize the demographic maps included in Appendix D for future Title VI analysis.

FTA Circular 4702.1B, Chapter III, Paragraph 4.a.8: If the recipient has constructed a facility, such as vehicle storage, maintenance facility, operation center, etc., the recipient shall include a copy of the Title VI equity analysis conducted during the planning stage with regard to the location of the facility.

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FTA Circular 4702.1B, Chapter III, Paragraph 10: All fixed route transit providers shall set service standards and policies for each specific fixed route mode of service they provide.

10.0 System‐Wide Service Standards and Service Policies

Seagull Services is not a fixed route service provider.

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11.0 Appendices

APPENDIX A FTA CIRCULAR 4702.1B REPORTING REQUIREMENTS FOR TRANSIT PROVIDERS APPENDIX B TITLE VI PROGRAM ADOPTION MEETING MINUTES AND FDOT CONCURRENCE LETTER APPENDIX C OPERATING AREA LANGUAGE DATA: SEAGULL SERVICES’ SERVICE AREA APPENDIX D DEMOGRAPHIC MAPS APPENDIX E TITLE VI EQUITY ANALYSIS

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AppendixA

FTACircular4702.1BReportingRequirementsforTransitProviders

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Every three 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 (the entity from whom the sub‐recipient receives funds directly), on a schedule to be determined by the primary recipient.

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 Procedures (i.e., instructions to the public regarding how to file a Title VI discrimination complaint)

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 a summary of outreach efforts made since the last Title VI Program submission

Language Assistance Plan for providing language assistance to persons with limited English proficiency (LEP), based on the DOT LEP Guidance

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

Primary recipients shall include a description of how the agency monitors its sub‐recipients for compliance with Title VI, and a schedule of sub‐recipient Title VI Program 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 board meeting minutes, resolution, or other appropriate documentation showing the board of directors or appropriate governing entity or official(s) responsible for policy decisions reviewed and approved the Title VI Program. For State DOTs, the appropriate governing entity is the State’s Secretary of Transportation or equivalent. The approval must occur prior to submission to FTA.

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AppendixB

TitleVIProgramAdoptionMeetingMinutesandFDOTConcurrenceLetter

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S_[gull S_rvi]_s Titl_ VI Prog

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AppendixC

OperatingAreaLanguageData:SeagullServices’ServiceArea

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AppendixDDemographicMaps

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AppendixETitleVIEquityAnalysis

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Seagull Services is not required to perform a Title VI Equity Analysis.

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Documents

Title VI Program FINAL - Seagull · Title VI plan including complaint\rforms uploaded to Seagull website\r Title VI training for van operators\rand front office staff 9/11/15 8/28/15