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;
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 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?
How will the complainant be notified of the outcome of the complaint?
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:
Factor 1: Number/Proportion of LEP Persons in Service Area
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:
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.
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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