Kalkaska Public Transit Authority

Kalkaska Public Transit Authority 1251 Island Lake Rd, PO Box 1046, Kalkaska, Michigan 49646

Date Adopted:           August 20, 2020                    

I. Kalkaska Public Transit Authority (KPTA) Title VI Plan Statement:

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that; “no person in the United States of America shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits or be subjected to discrimination under any program or activity receiving Federal financial assistance” (42 U.S.C. Section 2000d).

Kalkaska Public Transit Authority is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by the Title VI in the Federal Transit Administration Circular 4702.1B.

This Plan was developed as a guide for the Kalkaska Public Transit Authority in its administration and management of Title VI related activities.

Kalkaska Public Transit Authority Coordinator contact information:

Tracy Fisher

1251 Island Lake Road, PO Box 1046

Kalkaska, Michigan 49646

Phone Number 231-258-6808. Email to kpta@att.net.

II. Title VI KPTA Plan Information Dissemination:

Title VI information posters and brochures shall be prominently and publicly displayed at the Kalkaska Public Transit Authority facility and in their revenue vehicles. Title VI information will be posted on the KPTA website, kalkaskatransit.com. Any additional information relating to nondiscrimination can be obtained from KPTA Title VI Coordinator.

Title VI information shall be given to each KPTA employee along with their W-2 form each year in the form of the Employee Education form (Appendix A).

All KPTA employees shall be provided a copy of KPTA Title VI Plan and are required to sign the Acknowledgement of Receipt (Appendix B). New employees during their initial training period will be given a copy of this plan and required to sign that they have read and understand the Plan. This signed copy of the Acknowledgement of Receipt will become part of the individual’s records.

III. Subcontracts and Vendors:

All subcontractors and vendors we receive payments from Kalkaska Public Transit Authority where funding originates from any Federal Assistance are subject to the provisions of Title VI of the Civil Rights Act of 1964 as amended.

Written contracts shall contain non-discrimination language, either directly or through the bid specification package which becomes an associated component of the contract.

IV. Record Keeping:

The Title VI coordinator will maintain permanent records which include, but are not limited to, signed acknowledgements of the receipt from the employees indication the receipt of the Kalkaska Public Transit Authority Title VI Plan, copies of the Title VI complaints or lawsuits and complainants, and the Title VI investigations.

V. Title VI Complaint Procedures:

How to file a Title VI Complaint.

The complainant must file a signed, written complaint within one hundred and eighty (180) days from the date of the alleged discrimination. The complaint should include the following information;

1. The complainant name, mailing address, and how they may be contacted i.e. telephone number, mailing address, etc.
2. How, when, where and why they believe they were discriminated against including the location, names and contact information of any witnesses.
3. Any and all other information that you deem significant.

The Title VI complaint form (Appendix C) may be used to submit the complaint information. This form is available from the KPTA Title VI Coordinator. Any complaint may be filled in writing with the Kalkaska Public Transit Authority, 1251 Island Lake Road, PO Box 1046, Kalkaska, Michigan 49646.

KPTA encourages all complainants to either mail it certified or hand deliver it to the KPTA Title VI Coordinator at which time they will receive a signed receipt.

What happens to the complaint after it is submitted?

1. The KPTA Title VI Coordinator will address all complaints alleging discrimination based on race, color, or national origin in a service provided by KPTA. 
2. KPTA will provide appropriate assistance to the complainants, including those persons with disabilities, or who are limited in their ability to communicate in English.
3. KPTA will address all complaints in an expeditious and thorough manner.
4. KPTA will provide a letter of acknowledging the receipt (Appendix D) within seven (7) days of receiving a Title VI complaint.

How will the complainant be notified of the outcome of the complaint?

1. KPTA will send a final written response letter (Appendix E or F) to the complainant notifying the complainant as to whether the complaint was or was not substantiated. The complainant is also advised of their right to:
   1. Appeal within seven (7) calendar days of receipt of the final written   decision from KPTA or.
   2. File a complaint externally with the US Department of Transportation and/or FTA.
2. KPTA will make every effort to respond to the Title VI complaint within Sixty (60) working days of receipt.

In addition to the KPTA complaint process described above, a complainant may file a Title VI Complaint with the following office:

           Federal Transit Administration Office of Civil Rights 

            Attention: Title VI Program Coordinator 

            East Building, 5th Floor-TCR

            1200 New Jersey Ave., SE

            Washington, DC 20590

VI. Transit related Title VI Investigations, Complaints, and Lawsuits.

Kalkaska Public Transit Authority has had no Investigations, Complaints, or Lawsuits related to Title VI.

VII. Four Factor Analysis

1. The number or proportion of LEP persons eligible in the Kalkaska Public Transit Authority service area who may be served or likely to encounter a Kalkaska Public Transit Authority program, activity, or service. The Kalkaska Public Transit Authority examined the US Census report from 2010 and was able to determine that approximately 2.5% or 410 people within the Kalkaska Public Transit Authority service area over the age of 5 spoke a language other than English.
2. The Kalkaska Public Transit Authority assessed the frequency at which staff and drivers have or could possibly have contact with LEP persons, via verbally surveying drivers and dispatchers. Since 1984 the Kalkaska Public Transit Authority has not had any requests for interpreters and/or translated KPTA documents. The staff and drivers have very little to no contact with LEP individuals.
3. The nature and importance of the program, activity, or service provided by the Kalkaska Public Transit Authority to the LEP Community. There are no large geographic concentrations of any one type of LEP individuals in the KPTA service area. The overwhelming majority of the population over the age of 5, 97.5% or 15,881 speak only English.
4. The resources available to the Kalkaska Public Transit Authority and overall costs. The Kalkaska Public Transit Authority assessed the available resources that could be used for providing LEP assistance. This included a interpreter and/or translation service that would be used on a as needed basis and updating our website to include language translation.

After analyzing the four factors, the KPTA does not feel that an LEP plan is needed at this time.

VIII. Language Assistance Plan (LAP).

Although we do not feel that a LAP plan is needed at this time, The Kalkaska Public Transit Authority will use the following guidelines to assist persons with limited English proficiency.

KPTA would request assistance from other governmental agencies, local citizens and local school districts. KPTA has an agreement with the Kalkaska Public School District that they will assist us by providing individuals from their staff that speak the needed foreign language. KPTA also has a working agreement with local citizen, Mr. Rheo Charteand to assist us with any French speaking persons that may need KPTA service. KPTA have  “I Speak Cards” available at the Kalkaska Public Transit Office to help determine what language assistance would be needed.

Kalkaska County is a rural area located in Northern Michigan with a population of approximately 17,000 residents. We feel that our LAP policy is adequate for Kalkaska County at this time. Our plan will be reviewed annually and updated as needed.

IX. Community Outreach.

1. Kalkaska Public Transit Authority has engaged the public in its planning and decision-making processes, as well as its marketing and outreach activities since the last Title VI submission. 
2. a.      KPTA Board of Directors represents the following: The twelve townships of Kalkaska County and the Village of Kalkaska. Board members and KPTA staff members are members of local service groups, township/village/county/Commission on Aging boards. One of our board members has to be a high school senior.
3. b.      KPTA Board members meet the third Thursday of each month. Meetings are posted and the public are invited to attend.
4. c.       KPTA staff members meet with senior housing residents bi-monthly to see if their needs for transportation are being met by KPTA. Suggestions are then reviewed and taken to the full KPTA Board of Directors.
5. d.      All complaints are handled and investigated by Management personnel. Within seven (7) days complainants are advised of our finding and with the complainants input solutions are made.
6. e.       Public input is always welcome. Meetings with the LAC Board to review new routes, fare cost and other items that will benefit the people of Kalkaska County. An open door policy for the improvement is always welcomed. All information is posted for the public on our website which has a language translator available for viewing.

KPTA submits to the Michigan Department of Transportation an annual application for funding. Funding requests are for capital items and operating expense. KPTA also receives local milage money to assist in operating a county wide bus program. The annual application is available to the public for their review.

X. Membership of Non-Elected Committees.

Kalkaska Public Transit Authority encourages the participation of minorities on all of our non elected committees and boards.

Kalkaska Public Transit Authority will publicly advertise and post on our website to encourage minority participation on this committee.

Kalkaska Public Transit

Minority Representation on Decision-Making Bodies

Body

Caucasian

Latino

African American

Asian American

Native American

Population

94.9%

1.7%

0.7%

0.4%

0.7%

Board of Directors

100%

0%

0%

0%

0%

LAC Board

100%

0%

0%

0%

0%

XI. Equity Analysis.

If Kalkaska Public Transit Authority builds a facility in the future we will comply by the Equity Analysis requirement as follows. 

1. Kalkaska Public Transit Authority will complete a Title VI equity analysis during the planning stage with regard to where the project is located or sited to ensure the location is selected without regard to race, color, or national origin.
2. When evaluating locations of facilities, Kalkaska Public Transit Authority will give attention to other facilities with similar impacts in the area to determine if any cumulative adverse impacts might result.
3. If Kalkaska Public Transit Authority determines that the location of the project will result in a disparate impact on the basis of race, color, or national origin, Kalkaska Public Transit Authority 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.