Title VI Program & Complaint Procedure

Title VI Program Effective January 29, 2020

Notice to the Public

The Greene County Transit Board, D.B.A. Greene CATS Public Transit, operates its programs and services without regard to race, color, or national origin in accordance with Title VI of the Civil Rights Act of 1964. Any person who believes he or she has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with Greene County Transit Board.

For more information on the Greene County Transit Board civil rights program visit our website at www.greenecountyohio.gov/GreeneCATS; email [email protected]; or call (937) 708-8322. If information is needed in another language, contact (937) 708-8313.

You may file a Title VI complaint by completing a Title VI Complaint Form and mailing to the Executive Director at 2380 Bellbrook Avenue, Suite A, Xenia, Ohio 45385.

You may also file a Title VI complaint directly with the Federal Transit Administration by completing a Title VI Complaint Form and mailing it to: FTA Office of Civil Rights, Attention: Title VI Program Coordinator, 1200 New Jersey Ave., SE, Washington, DC 20590.

The preceding notification is available on the website, in the administrative offices, and in the passenger guide.

Title VI Complaint Procedure

Any person who believes she or he has been discriminated against on the basis of race, color, or national origin by the Greene County Transit Board (GCTB) may file a complaint by completing and submitting the agency’s Title VI Complaint Form. The GCTB investigates complaints received no more than 180 days after the alleged incident. GCTB will process all fully completed and signed complaint forms. All Title VI complaints shall be logged and tracked throughout the process in a spreadsheet. 

Once the complaint form is received, the GCTB will review it to determine if our office has jurisdiction. An acknowledgement letter will be sent out within 30 days of the date the complaint is received informing the complainant whether the complaint will be investigated by our office. The GCTB has 30 days to investigate the complaint. If more information is needed to resolve the case, the GCTB may contact the complainant. The complainant has 30 days from the date of the contact 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 30 days, the GCTB will decide the case with the information already received in the complaint. A case can be closed if the complainant withdraws 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 30 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, Attention: Title VI Program Coordinator, 1200 New Jersey Avenue SE, Washington, DC 20590.

List of Investigations, Lawsuits and Complaints

There have been no Title VI investigations, complaints, or lawsuits since the Greene County Transit Board’s last submission June 2018.

Public Participation Plan

The GCTB shall solicit public input for its Program of Projects annually as well as needed for other general matters such as the Language Assistance Plan, raising fares, or carrying out a major service change or reduction using variety of means to communicate to the public these and other proposed activities. Notices will include how the public can obtain information and make comments, where meetings are to take place, and other applicable information.  The notices for public input will be posted 30 days in advance so the public has time to consider proposals and make comments. The notice methods include:  

1. Press releases to local media
2. Newsletter (print and e-mail)
3. Website links and articles
4. Posting notices on social media platforms
5. On Greene CATS Public Transit flex route vehicles advertising with flyers
6. Posting of flyers at social service agencies
7. Distribution of flyers to minority, low income, and Limited English Proficiency communities

The GCTB meets with the public in locations that have convenient access to transit and are centrally located so that anyone, including minorities, low income, and Limited English Proficiency riders, in its service area can attend meetings and receive information about the GCTB activities that will impact them. Meetings are held at different times of the day in coordination with route schedules for easier access. All public meeting locations will be accessible to those with disabilities. If notified five (5) days prior to the meeting, language or hearing interpreters will be made available. 

The GCTB staff will accept written comments and record oral comments if needed. Meetings will have sign-up sheets available and if no one is in attendance, staff will wait 30 minutes and then announce the reason for the meeting, a statement that no one is in attendance and close the meeting.  The public are also able to submit comments by letter or e-mail until the time of the public hearing is scheduled to end.  Public comments are presented to the appropriate Transit Board committee as part of the decision making process. 

Language Assistance Plan

The intent of the plan is to ensure that Limited English Proficiency (LEP) individuals have access to published information and transportation services in Greene County. The production of multilingual publications and documents and/or interpretation at meetings and events will be provided to the degree that funding permits based on current laws and regulations

The GCTB will keep a running log of requests for language assistance to monitor the need of language assistant. Also, every ten years the GCTB will assess the magnitude and nature of any significantly large groups of people with Limited English Proficiency, and any problems that they may have, due to such proficiency limits, of obtaining information about and using the GCTB public transit services. The GCTB will use relevant local, State and Federal demographic data to locate and quantify the number of people, within Greene County, that have limited English proficiency. Significant concentrations or numbers of identified persons or locations will be identified, if any do exist. The language(s) spoken will be identified. The plan will be reviewed and updated as needed every three years. GCTB staff who interact with riders will be trained initial upon hire and as new assistance tools are made available.

Four-Factor Analysis 2018

Factor 1: The number and proportion of LEP persons served or encountered in the eligible Service Population:

1. Geographical Boundaries of the GCTB service area: Greene County, Ohio

2. Analysis of U.S. Census Data: According the 2018 American Community Survey (ACS) the total population in Greene County was 167,995.  Of the 158,711 persons five years of age or older 149,755 (94,4%) of them speak English only, 8,956 (5.6%) speak a language other than English and 2,262 (1.4%) speak English less than “very well”. The next categories that show significant language usage other than English are the populations of Other Indo-European language speakers (3,071 – 1.9%), Spanish speaking persons (2,479 - 1.6%), Asian and Pacific Island language speakers (2,282 – 1.4%). Of these three groups the number of individuals that speak English less than “very well” were Spanish (881 or 0.6%), Asian and Pacific Island (685 or 0.4%), and Other Indo-European language speakers (524 or 0.3%) of the total population.

3. Concentrations of LEP Persons within the GCTB service area: The ACS demonstrates that no LEP population group that speaks English less than “very well” meets the Safe Harbor threshold of 5% of the total population or 1,000 persons whichever is less indicating that the GCTB service area is populated by a small LEP population.

Factor 2: The frequency with which individuals with Limited English Proficiency come in contact with GCTB services:

1. GCTB prior experiences with LEP individuals: From 2016 to 2019 there has been no individuals that sought the use of GCTB services that did not speak English.

Factor 3: The importance of GCTB Services to LEP persons:

1. Accessing Services: GCTB provides traditional demand response service and flex routes that circulate and connect neighboring communities of Greene County and to the adjoining transit system (Greater Dayton RTA) in Montgomery County. The service provides rides to individuals with developmental and physical disabilities to adult day services and work, students who attend local universities, and Medicaid eligible and elderly individuals for medical appointments.  The general public also uses the service to access local social service agencies, retail stores, medical appointments, and work.  Most of our riders are transportation disadvantaged and require specialized transportation due to intellectual or physical disabilities and/or are elderly and/or cannot afford to operate their own vehicle. Other transportation options in Greene County are limited to private non-profit or public senior centers, and adult day service providers with limited number of vehicles serving specific populations and private cab companies. This makes Greene CATS Public Transit a vital service to these populations. Interaction with local human service agencies and participating in coordinating committees have informed GCTB that the need for accessible low cost transportation is just as great among the LEP population as the general and specialized populations we serve.

Factor 4: The Resources Available to the Recipient and Costs:

1. Assessing Services: Currently the GCTB employees are instructed to refer language assistant requests to the Mobility Manager.  The Mobility Manager will maintain a current listing of collaborative partners that can assist in communicating with Limited English Proficient individuals and develop language specific materials. There is also a feature on the Greene County Public Transit website that allows individuals to translate and view all content into multiple languages.
2. Additional Services needed to provide meaningful access: The Mobility Manager is working on establishing agreements with translation service providers, developing computer applications that can assist schedulers, obtaining language card for drivers to better communicate with individuals who have LEP.
3. Accessing Budgetary Constraints: The GCTB will continue to look for low cost ways to improve the accessibility of our services through the community collaborations, computer operations, and limited copies of printed material since the number of LEP individuals in Greene County is such a small portion of the population. 

Membership of non-elected Committees

The GCTB seeks to include members on its committees that are representative of the various communities and populations of Greene County and can provide the expertise needed to advise the Transit Board. Members are recruited through social service agencies, community organizations, and public institutions that include minority professionals and provide service to minorities, private businesses and the public at large.  In addition, both Staff and Board members personally contact potential Board and Committee members including minority candidates.

Subrecipient Monitoring

The GCTB has no Subrecipients that receive Federal financial assistance therefore is the monitoring requirements are not applicable.

Facility Equity Analysis

The GCTB has not constructed a facility therefore the requirement to provide a Title VI Equity Analysis is not applicable.

Fixed Route Service Standards and Policies

The GCTB does not operate Fixed Route Service therefore additional information required is not applicable.