Kalkaska Public Transport Authority

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    • Home
    • About KAT
      • About Us
      • Board Meetings
      • Employment Oppurtunities
      • Our Staff
    • SERVICES
      • LIST OF SERVICES
      • Door to Door (Village)
      • Door to Door (Countywide)
      • Flex Schedule
      • Student Transportation
      • Transportation to TC, MI
      • Non-Emergency Medical
    • Fares
      • Fares
      • Reduced Fare Application
      • No-Show Policy
    • Resources & Links
      • Public Transportation
      • Schools
      • Government
      • Community Events
      • Cab & Charter
    • Policies
      • Title VI Policy
      • ADA
      • FOIA
      • KAT Riders Policy
      • KAT No Show Policy
      • Service Animal Policy
      • KAT Anti-Bullying Policy
    • FAQ
    • Contact US

231-258-6808

Kalkaska Public Transport Authority

Kalkaska Public Transport AuthorityKalkaska Public Transport AuthorityKalkaska Public Transport Authority
  • Home
  • About KAT
    • About Us
    • Board Meetings
    • Employment Oppurtunities
    • Our Staff
  • SERVICES
    • LIST OF SERVICES
    • Door to Door (Village)
    • Door to Door (Countywide)
    • Flex Schedule
    • Student Transportation
    • Transportation to TC, MI
    • Non-Emergency Medical
  • Fares
    • Fares
    • Reduced Fare Application
    • No-Show Policy
  • Resources & Links
    • Public Transportation
    • Schools
    • Government
    • Community Events
    • Cab & Charter
  • Policies
    • Title VI Policy
    • ADA
    • FOIA
    • KAT Riders Policy
    • KAT No Show Policy
    • Service Animal Policy
    • KAT Anti-Bullying Policy
  • FAQ
  • Contact US

Kalkaska Public Transit Authority

TITLE VI PLAN

Kalkaska Public Transit Authority

Title VI Plan

Date Adopted: October 30, 2023 

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

Title VI of the Civil Rights Act of 1964 prohibits discrimination based on 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, hereinafter referred to as KPTA, is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services based on 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 KPTA in its administration and management of Title VI related activities.

KPTA Coordinator contact information:

Theresa 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 (see Appendix G) and brochures shall be prominently and publicly displayed at the KPTA facility and in their revenue vehicles. The name of the Title VI coordinator information will be posted on the KPTA website, kalkaskatransit.com. Any additional information relating to nondiscrimination can be obtained from KPTA Title VI Coordinator.

Nondiscrimination information shall be disseminated to KPTA employees annually (See Appendix A). This information reminds employees of KPTA policy statement, and of their nondiscrimination responsibilities in their daily work and duties. All employees of KPTA are provided a copy of the plan and are required to sign an Acknowledgement of Receipt (see appendix B).

During new employee orientation, new employees 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 who receive payments from KPTA 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 employee’s indication the receipt of the KPTA Title VI Plan, copies of the Title VI complaints or lawsuits and complainants, and the Title VI investigations.

V. Title VI Complaint Procedures:

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

  1. The complainant’s 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. 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 or by e-mail with the KPTA at the following address:

KPTA

1251 Island Lake Road, PO Box 1046

Kalkaska, Michigan 49646.

Phone: 231-258-6808 Fax: 231-258-6810

kpta@att.net

KPTA encourages all complainants to certify all mail that is sent through the U.S. Postal Service and /or ensure that all written correspondence can be tracked easily. For complaints originally submitted by facsimile, an original, signed copy of the complaint must be mailed the KPTA Title VI Coordinator as soon as possible, but no later than 180 days from the alleged date of coordination. The complaint can be hand delivered to KPTA 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. Please note      that in responding to any requests for additional information, a complainant’s      failure to provide the requested information may result in the administrative      closure of the 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. In the letter notifying the complainant that      the complaint is not substantiated (Appendix F), 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.

Once sufficient information for investigating the complaint is received by KPTA, a written response will be drafted subject to review by the transit's attorney. If appropriate, KPTA’S attorney may administratively close the complaint. In this case, KPTA will notify the complainant of the action as soon as possible.

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:

KPTA has had no investigations, complaints or lawsuits filed.

Lawsuits, Complaints, or Investigations Alleging Discrimination

  

Type   (Investigation, Lawsuit, Complaint)


Date


Summary of   Complaint


Status


Action(s) Taken

 





 





 





 





VII. Four Factor Analysis:

KPTA is required to take reasonable steps to ensure meaningful access to their programs and activities by LEP persons. While designed to be a flexible and fact-dependent standard, the starting point is an individualized assessment that balances the following four factors:

  • The number or proportion of LEP persons      eligible to be served or likely to be encountered by the program or      grantee.
  • the frequency with which LEP individuals      meet the program.
  • the nature and importance of the      program, activity, or service provided by the program to people's lives;      and
  • the resources available to the      grantee/recipient or agency, and costs.

Factor 1: Number/Proportion of LEP Persons in Service Area

  • Include data from sources such as the US Census Bureau’s Demographic      and Housing Characteristics or American Community Survey
  • Include a listing of the counts and percentages of LEP individuals      present in your service area by language.
  • Identify if any of the LEP languages reach the LEP threshold of 5%,      or the Safe Harbor Threshold (1,000 persons).

KPTA examined the US Census report from 2020 and the Bureau’s Demographic and Housing Characteristics and was able to determine that approximately 2.2%, or 384 people within the KPTA service area age 5 and older spoke a language other than English. Of the 384 reporting they speak other languages than English, 59 or <1% of respondents speak English less than “very well.” The Spanish language comprised the largest non-English speaking language group with 1.1%. The other largest non-English speaking language group was the Other Indo-European languages at 1%. 

Factor 2: The KPTA 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 KPTA 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. 

Factor 3: The nature and importance of the program, activity, or service provided by the KPTA 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, 97.7% or 16,511 speak only English.

Factor 4: KPTA assessed the available resources and overall costs assessed 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 a formal LEP plan is needed currently.

VIII. Limited English Proficiency (LEP) Plan:

Although we do not feel that a LEP plan is needed at this time, The KPTA 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. There are also free online/mobile app resources to offer assistance.

Kalkaska County is a rural area located in Northern Michigan with a population of approximately 16,893 residents. We feel that our LEP policy is adequate for Kalkaska County currently. Our plan will be reviewed annually and updated as needed.

IX. Public Participation Plan:

  1. KPTA 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. 

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 must be a high school senior.

b. KPTA Board members meet the third Thursday of each month. Meetings are posted and the public are invited to attend.

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.

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.

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, kalkaskatransit.com, which has a language translator available for viewing.

f. 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. Part of the annual application is a public notice, which includes a 30-day public comment period.

X. Membership of Non-Elected Committees:

KPTA encourages the participation of minorities on all our non-elected committees and boards. 

KPTA will publicly advertise and post on our website to encourage minority participation on this committees such as the LAC (Local Advisory Committee).

  

Kalkaska Public Transit

 

Minority Representation on Decision-Making Bodies

 

Body


Caucasian


Latino


African American


Asian American


Native American

 

Population


94.4%


2.2%


1.2%


0.4%


0.9%

 

Board of Directors


100%


0%


0%


0%


0%

 

LAC Board


100%


0%


0%


0%


0%

XI. Equity Analysis:

If KPTA builds a facility in the future, we will comply by the Equity Analysis requirement as follows. 

  1. KPTA will complete a Title VI equity analysis during the planning       stage regarding 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, KPTA will give attention       to other facilities with similar impacts in the area to determine if any       cumulative adverse impacts might result.
  3. If KPTA determines that the location of the project will result in       a disparate impact based on race, color, or national origin, KPTA 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 based       on race, color, or national origin.

Appendix A Employee Annual Education Form

Title VI Policy

Annual Training of KPTA Employees will review the following:

No person shall, on the grounds of race, color, or national origin, be excluded from participation in, denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.

All employees of Kalkaska Public Transit Authority are expected to consider, respect, and observe this policy in their daily work and duties. If a citizen approaches you with a question or complaint, direct him or her to the Title VI Coordinator:

Theresa Fisher, Title VI Coordinator

Kalkaska Public Transit Authority

PO Box 1046

Kalkaska, Michigan 49646

In all dealings with citizens, use courtesy titles (i.e. Mr., Mrs., Ms., or Miss) to address them without regard to race, color or national origin.

Appendix B Acknowledgement of receipt of Title VI Plan

I hereby acknowledge the receipt of Kalkaska Public Transit Authority Title VI Plan. I have read the plan and am 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 Title VI in Federal Transit Administration (FTA) Circular 4702.1B.

Signature

Your name printed

Date

Appendix C TITLE VI COMPLAINT FORM

Title VI of the 1964 Civil Rights Act requires that “No person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.” If you feel you have been discriminated against in transit services, please provide the following information to assist us in processing your complaint. 

Section I

Please print clearly:

Name:   

Address:  

Telephone (Home):  Telephone (Cell):  

E-Mail Address:  

Section II

Are you filing this complaint on your own behalf:  [ ]Yes* [ ] No 

*If you answered “yes” please go to Section III.

If not, what is the name and relationship of the 

person for whom you are complaining:  

Please explain why you have filed for a third Party:  

Please confirm that you have obtained the permission of the

Aggrieved party you are filing on behalf of: [ ] Yes [ ] No

Section III

Discrimination was based on:

[ ] Race [ ] Color [ ] National origin [ ] Income [ ] Other

Date of Alleged Discrimination (Month, Day, Year):  

Where did the alleged discrimination take place:______________________________________

Please explain as clearly as possible what happened. Provide the name(s) of witnesses and others involved in the alleged discrimination. (Attach additional sheets if necessary and provide a copy of written materials pertaining to your case.)

Section IV

Have you previously filed a Title VI complaint with this agency? [ ] Yes [ ] No

Section V

Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State Court? [ ] Yes [ ] No

If yes check all that apply

[ ] Federal Agency

[ ] Federal Court [ ] State Agency

[ ] State Court [ ] Local Agency

Please provide contact information for agency/court where the complaint was filed.

Name:  

Title:  

Agency:  

Address:  

Telephone:  

What type of corrective action would you like to see taken: ____________________________________________________________________________________________________________________________________________________________

Section VI

Name of agency complaint is against:

Contact person:  

Title:  

Telephone number:  

Please attach any documents you have which support the allegation. Then date and sign this form and send to the Title VI Coordinator at: 

Theresa Fisher, Title VI Coordinator

Kalkaska Public Transit Authority

1251 Island Lake Rd, PO Box 1046

Kalkaska, MI 49646

Signature: 

Printed Name: ____________________________________

Date: 

Appendix D Letter Acknowledging Receipt of Complaint

Today’s Date: 

Complainant Name and Address

Dear 

This letter is to acknowledge the receipt of your complaint against Kalkaska Public Transit Authority alleging:

   

Kalkaska Public Transit Authority will start an investigation into your complaint. If you have any additional information you wish to convey or questions concerning this matter, please feel free to contact me at 231-258-6808 or write to me at this address.

Sincerely,

Theresa Fisher, Title VI Coordinator

Kalkaska Public Transit Authority

1251 Island Lake Rd, PO Box 1046

Kalkaska, MI 49646

Appendix E 

Letter to Notify Complainant that the Complaint

is Substantiated

Today’s Date: 

To:

Dear Mr./Ms. ______:

The matter referenced in you letter of (date) against Kalkaska Public Transit Authority alleging Title VI violation has been investigated.

(An/Several) apparent violation(s) of Title VI of the Civil Rights Act of 1964, including those mentioned in your letter (was/were) identified. Efforts are underway to correct these deficiencies.

Thank you for calling this important matter to our attention. You were extremely helpful during our review program. (If a hearing is requested, the following sentence may be appropriate.) You may be hearing from this office, or from federal authorities, if your services should be needed during the administrative hearing process.

Sincerely,

Theresa Fisher, Title VI Coordinator

Kalkaska Public Transit Authority

1251 Island Lake Rd, PO Box 1046

Kalkaska, MI 49646

Appendix F 

Letter to Notify Complainant that the Complaint

is Not Substantiated

Today’s Date: 

To:

Dear Mr./Ms.__________:

The matter referenced in your complaint of (date) against KPTA alleging ____________________ has been investigated.

The results of the investigation did not indicate that the provisions of Title VI of the Civil Rights Act of 1964, had been violated. As you know, Title VI prohibits discrimination based on race, color, or national origin in any program receiving federal financial assistance.

The KPTA has analyzed the materials and facts pertaining to your case for evidence of the KPTA failure to comply with any of the civil rights laws. There was no evidence found that any of these laws have been violated.

I therefore advise you that your complaint has not been substantiated, and that I am closing this matter in our files.

You have the right to 1) appeal within seven calendar days of receipt of this final written decision from KPTA, and/or 2) file a complaint externally with the U.S. Department of Transportation and/or Federal Transit Administration at:

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

Thank you for taking the time to contact us. If I can be of assistance to you in the future, do not hesitate to call me.

Sincerely,

Theresa Fisher, Title VI Coordinator

Kalkaska Public Transit Authority

1251 Island Lake Rd, PO Box 1046

Kalkaska, MI 49646

Appendix G

Posters and Brochures to be displayed in Kalkaska Public Transit Authority Revenue Vehicles and Facilities

Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that “no person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal 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-based race, color, or national origin, as protected by Title VI in Federal Transit Administration (FTA) Circular 4702.1B. If you feel you are being denied participation in or being denied benefits of the transit services provided by Kalkaska Public Transit Authority, or otherwise being discriminated against because of your race, color, or national origin may contact or office at:

Theresa Fisher, Title VI Coordinator

Kalkaska Public Transit Authority

1251 Island Lake Road NW, PO Box 1046

Kalkaska, Michigan 49646

For more information, visit our website at kalkaskatransit.com

 

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