Columbia County, FL | Title Six Policy

LOCAL ASSISTANCE PROGRAM
TITLE VI/NONDISCRIMINATION POLICY STATEMENT
INCLUDING 504 AND ADA REQUIREMENTS

The Columbia County adopted the Title 6 policy on June 23rd, 2016. (PDF) Signed Title 6 Policy

In order to plan for efficient, effective, safe, equitable and reliable transportation systems, the County must have the input of its public. The County spends extensive staff and financial resources in furtherance of this goal and strongly encourages the participation of the entire community. Any person may attend any Board of County Commissioner (BOCC) Meeting including Committee Meetings and speak during the Public Comment portion of the agenda concerning a matter of the BOCC business or concern of the person. Persons should check the BOCC's website at www.columbiacountyfla.com for a list of scheduled meetings and agendas. Persons may also call the County Manager's Office to receive a calendar of upcoming meetings. Meeting location is accessible to the disabled.

The BOCC and/or staff members also attend other Community meetings as necessary or when invited.

The Columbia County Board of County Commissioners (County) values diversity and welcomes input from all interested parties, regardless of cultural identity, background or income level. Moreover, the County believes that the best programs and services result from careful consideration of the needs of all of its communities and when those communities are involved in the transportation decision making process. Thus, the County does not tolerate discrimination in any of its programs, services or activities. Pursuant to Title VI of the Civil Rights Act of 1964 and other federal and state authorities, the County will not exclude from participation in, deny the benefits of, or subject to discrimination anyone on the grounds of race, color, national origin, sex, age, disability, religion, income or family status.

Section 504 of the Rehabilitation Act of 1973 (Section 504), the Americans with Disabilities Act of 1990 (ADA) and related federal and state laws and regulations forbid discrimination against those who have disabilities. Furthermore, these laws require federal aid recipients and other government entities to take affirmative steps to reasonably accommodate the disabled and ensure that their needs are equitably represented in transportation programs, services and activities.

REFERENCE

Americans with Disabilities Act of 1990 (ADA)

POLICY

1. Title VI/Nondiscrimination Coordinator Designated:

   1. The coordinator tasked with ensuring the County 's compliance with this policy shall be the Human Resource Director. The Director's contact information is listed below:

      Name: Lisa Roberts , Human Resources Director Title VI/Nondiscrimination Coordinator

      Address: P.O. Box 1529 Lake City, FL 32056-1529 Email: lisa roberts@columbiacountyfla.com Phone: 386-758-1006

2. Complaint Procedures:

   1. The County has established a discrimination complaint procedure and will take prompt and reasonable action to investigate and eliminate discrimination when found. Any person who believes that he or she has been subjected to discrimination based upon race, color, national origin, sex, religion, age, disability, family or income status in any of the County's programs, services or activities may file a complaint with the County Title VI/Nondiscrimination Coordinator. Likewise, any person who feels that he or she has been retaliated against for having made such a complaint or for having testified on behalf of another who has made such a complaint may file a complaint with the County Title VI/Nondiscrimination Coordinator.

   2. If possible, the complaint should be submitted in writing and contain the identity of the complainant; the basis for the allegations (i.e., race , color, national origin, sex, religion, age, disability or family status); and a complete description of the alleged discrimination. If the complaint cannot be submitted in writing , the complainant should contact the Title VI/Nondiscrimination Coordinator for assistance.

   3. The Title VI/Nondiscrimination Coordinator will respond to the complaint within thirty (30) calendar days and will take reasonable steps to resolve the matter.

      1. Should the County receive a complaint related to the administration of a federally or state funded project, the County will forward the complaint, along with a record of its disposition to the appropriate state agency for assistance/documentation purposes. For example, complaints of discrimination related to Florida Department of Transportation (FOOT) funded projects can be forwarded to the following address:

         Florida Department of Transportation

         Equal Opportunity Office

         ATTN: Title VI Complaint Processing 605 Suwannee Street MS 65

         Tallahassee, FL 32399

      2. Should the complainant be unable or unwilling to complain to the County, the written complaint may be submitted directly to the assisting state agency.

   4. The County 's Title VI/Nondiscrimination Coordinator has "easy access" to the County Manager and is not required to obtain management or other approval to discuss discrimination issues with the County Manager.

3. ADA/504 Statement:

   1. The County will make every effort to ensure that its facilities, programs, services, and activities are accessible to those with disabilities. The County encourages participation on its advisory committees, public involvement activities and all other programs, services and activities by the disabled community and disability service groups.

   2. The County encourages the public to report any facility, program, service or activity that appears inaccessible to those who are disabled. Furthermore, the County will provide reasonable accommodation to all individuals who wish to participate in public involvement events or who require special assistance to access facilities, programs, services or activities. Because providing reasonable accommodation may require outside assistance, organization or resources, the County asks that requests be made at least ten (10) calendar days prior to the need for accommodation. Questions, concerns, comments or requests for accommodation should be made to the County 's Title VI/Nondiscrimination Coordinator.

4. Limited English Proficiency (LEP) Guidance:

   1. Title VI of the Civil Rights Act of 1964, Executive Order 13166, and various directives from the US Department of Justice (DOJ) and US Department of Transportation (DOT) require federal aid recipients to take reasonable steps to ensure meaningful access to programs, services and activities by those who do not speak English proficiently. To determine the extent to which LEP services are required and in which languages , the law requires the analysis of four factors:

      1. The number or proportion of LEP persons eligible to be served or likely to be encountered by the County's programs, services or activities.

      2. The frequency with which LEP individuals come in contact with these programs, services or activities.

      3. The nature and importance of the program, service, or activity to people's lives and;

      4. The resources available to the County and the likely costs of the LEP services.

   2. The County understands that its community profile is changing and the four factor analysis may reveal the need for more or varied LEP services in the future. Persons requiring special language services should contact the County's Title VI/Nondiscrimination Coordinator.

   Columbia County Limited English Proficiency Plan

   (PDF) Adopted Columbia County Limited English Proficiency Plan

    

   Columbia County has assessed its programs and services using the following four (4) factor analysis.

   1. Factor 1: the number or proportion or LEP persons eligible to be served or likely to be encountered by Columbia County's programs, services or activities.

      Columbia County conducts regular Board meetings and advisory committee meetings throughout the year. Additionally there will be public hearings and community outreach conducted. Although the County Board meetings and advisory committee meetings are open to the public, the primary source of contact with citizens is through the webpage and community outreach. Therefore, it stands to reason that the most likely encounter avenue with LEP individuals would be through community outreach, and on the Columbia County webpage.

      Data from Census Table B16001: Language Spoke at Home by ability to Speak English for the Populations 5 Years and Over, from the U.S. Census Bureau 2015-2019 American Community Survey 5-Year Estimates, was gathered. It should be noted that for our planning purposes, people that speak English "less than very well" are included in the analysis. Further, only the top four language groups are examined.

      The table below is derived from the U.S. Census Bureau's 2015-2019 American Community Survey. It shows the number and percent of LEP persons 5 years and over, in total and by language in Columbia County. (LEP person: Person that speaks English "less than very well".)

      Table 1: The Top Four Languages Spoken at Home in Columbia County By LEP Persons {US Census Bureau's 2015-2019 American Community Survey)
      Population 5 years and older	Number of LEP Persons	Percentage of LEP Persons	LEP Persons who speak Spanish		LEP Persons who speak other Inda-European Languages		LEP Persons who Speak Asian and Pacific Island Languages		LEP Persons who speak other Languages
      Total	Total	Percent	Total	Percent	Total	Percent	Total	Percent	Total	Total
      65,754	3,259	4.96%	925	.28%	74	.02%	194	.06%	26	.008%

      Table 1 shows that of the LEP persons within the Columbia County area, only .28% speak Spanish at home, making this the most significant language group as a percentage of population. The next most common language of the area's LEP population is Asian and Pacific Island language, which makes up just .06%, followed by Other Inda-European Languages at just .02% and other languages at .008%.

      Results from Factor I Analysis: Although the percentage of LEP persons in Columbia County is not significant enough to trigger a responsibility to provide services in languages other than English, Columbia County is committed to the principles of Title VI.

   2. Factor 2. The frequency with which LEP individuals come in contact with these programs, services or activities.

      The four-factor analysis identified Spanish as the most significant language spoken by the LEP population in the area covered by Columbia County. The size of the LEP population in this region is relatively small. However, to date, no requests for language assistance services have been made by LEP individuals or groups with the exception of Fire Services and 911 Communication (emergency dispatch} Services as in Factor 3 below. We will continue to monitor the requests for language assistance.

      Results from Factor 2 Analysis: Based on this information, it is likely very infrequently that Columbia County staff will come into contact with LEP populations.

   3. Factor 3: The nature and importance of the program, service, or activity to people's lives.

      The largest concentration of LEP individuals in Columbia County is Spanish. In terms of importance, Columbia County provides Fire services and 911 Communication Services (emergency dispatch} are deemed the most important. Adequate procedures are in place to ensure service to LEP individuals.

   4. Factor 4: The resources available and the overall cost to Columbia County.

      Although there is a very low percentage of LEP individuals in Columbia County, that is, persons who speak English "less than very well" the County will strive to offer the following measures:

      1. The Columbia County staff will take reasonable steps to provide the opportunity for meaningful access to LEP clients who have difficulty communicating English.
      2. The following resources will be available to accommodate LEP persons: Language interpretation may be accessed for all languages through a telephone interpretation service such as the Language Line and Florida Relay 711.

       

      Results from Factor 4 Analysis: Although the percentage of LEP persons in Columbia County is not significant enough to trigger a responsibility to provide services in languages other than English, Columbia County is committed to the principles of Title VI and will provide, with reasonable notice, translation services when needed upon request.

5. Public Involvement:

   1. Persons wishing to request special presentations by the County; volunteer in any of its activities or offer suggestions for improvement of County public involvement may contact the Title VI/Nondiscrimination Coordinator identified above.

6. Data Collection for Specific Programs:

   1. Federal Highway Administration (FHWA) regulations require federal-aid recipients to collect racial, ethnic and other similar demographic data on beneficiaries of or those affected by transportation programs, services and activities. The County accomplishes this through the use of census data, and other methods. From time to time, the County may find it necessary to request voluntary identification of certain racial, ethnic or other data from those who participate in its public involvement events . This information assists the County with improving its targeted outreach and measures of effectiveness.

7. Assurances for Specific Programs:

   1. Every three years the County must certify to FHWA and FOOT that its programs, services and activities are being conducted in a nondiscriminatory manner. These certifications are termed "assurances".