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HomeMy WebLinkAbout100620-06.7A D M I N I S T R A T I V E S T A F F R E P O R T 6 . 7 T O M a y o r a n d T o w n C o u n c i l O c t o b e r 6 , 2 0 2 0 S U B I E C T : R e s o l u t i o n N o . 6 8 - 2 0 2 0 , a p p o i n t i n g t h e C i f y E n g i n e e r a s t h e T i t l e V I C o o r d i n a t o r a n d a p p r o v i n g t h e T i t l e V I P r o g r a m f o r t h e T o w n o f D a n v i l l e B A C K G R O U N D T i t l e V I , w h i c h w a s e n a c t e d a s p a r t o f t h e C i v i l R i g h t s A c t o f 1 9 6 4 , p r o h i b i t s d i s c r i m i n a t i o n o n t h e b a s i s o f p r o t e c t e d s t a t u s , s u c h a s r a c e , c o l o r , s e x , a g e , d i s a b i l i t y a n d n a t i o n a l o r i g i n i n p r o g r a m s a n d a c t i v i t i e s r e c e i v i n g f e d e r a l f i n a n c i a l a s s i s t a n c e . S u b s e q u e n t f e d e r a l l e g i s l a t i o n a n d r e g u l a t i o n s n o w r e q u i r e t h a t r Í a n y p r o g r a m o p e r a t e d b y a n a g e n c y r e c e i v e s f e d e r a l f u n d s , t h e e n t i r e a g e n c y m u s t c o m p l y w i t h T i t l e V I . T h e s e r e g u l a t i o n s a l s o r e q u i r e t h a t t h e a g e n c y a p p o i n t a T i t l e V I c o o r d i n a t o r a n d a d o p t a f o r m a l T i t l e V I p r o g r a m . D I S C U S S I O N T h e T o w n p e r i o d i c a l l y r e c e i v e s f e d e r a l a i d t h r o u g h C a l t r a n s o n a n u m b e r o f r o a d w a y p r o j e c t s . \ A l h i l e t h e T o w n a l r e a d y c o m p l i e s w i t h t h e n o n - d i s c r i m i n a t i o n p r o v i s i o n s o f T i t l e V I , w e d o n o t h a v e a f o r m a l T i t l e V I p r o g r a m n o r a d e s i g n a t e d T i t l e V I c o o r d i n a t o r . B a s e d o n g u i d a n c e p r o v i d e d b y C a t t r a n s a n d a r e v i e w o f p r o g r a m s f r o m o t h e r c i t i e s , t h e T o w n h a s p r e p a r e d a d r a f t p r o g r a m ( A t t a c h m e n t B ) . I t i s a l s o r e c o û u n e n d e d t h a t t h e C i t y E n g i n e e r , w h o h a s t h e m o s t i n v o l v e m e n t w i t h C a l t r a n s a n d f e d e r a l l y f u n d e d p r o j e c t s , b e d e s i g n a t e d a s t h e T o w n ' s T i t l e V I C o o r d i n a t o r . P U B L I C C O N T A C T P o s t i n g o f t h e m e e t i n g a g e n d a s e r v e s a s n o t i c e t o t h e g e n e r a l p u b l i c . F I S C A L I M P A C T N o n e R E C O M M E N D A T I O N A d o p t R e s o l u t i o n N o . 6 8 - 2 0 2 0 , a p p o i n t i n g t h e C i t y E n g i n e e r a s t h e T i t l e V I C o o r d i n a t o r a n d a p p i o v i n g t h e T i t l e V I P r o g r a m f o r t h e T o w n o f D a n v i l l e . P r e p a r e d a n d R e v i e w e d b y : 7 7 , 1 { ß . R o b e r t B . E w i n g C i t y A t t o r n e y t u ) A t t a c h m e n t s : A - R e s o l u t i o n N o . 6 8 - 2 0 2 0 . B - T o w n o f D a n v i l l e T i t l e V I P r o g r a m 2 T i t l e V I P r o g r a m O c t o b e r 6 , 2 0 2 0 D o c u S i g n E n v e l o p e l D : 2 9 F D 3 A 4 E - 6 3 9 1 - 4 4 7 0 - 8 1 4 D - 6 F 6 9 8 0 4 E 7 2 0 S R E S O L U T I O N N O . 6 8 - 2 0 2 0 A P P O I N T I N G T H E C I T Y E N G I N E E R A S T H E T I T L E V I C O O R D I N A T O R A N D A P P R O V I N G T H E T I T L E V I P R O G R A M F O R T H E T O W N O F D A N V I L L E W H E R E A S , T i t l e V I o f t h e C i v i l R i g h t s A c t o f 1 9 6 4 T i t l e V I , p r o h i b i t s d i s c r i m i n a t i o n o n t h e b a s i s o f p r o t e c t e d s t a t u s , s u c h a s r a c e , c o l o r , s e x , a g e , d i s a b i l i t y a n d n a t i o n a l o r i g i n i n p r o g r a m s a n d a c t i v i t i e s r e c e i v i n g f e d e r a l f i n a n c i a l a s s i s t a n c e ; a n d W H E R E A S , s u b s e q u e n t f e d e r a l l e g i s l a t i o n a n d r e g u l a t i o n s r e q u i r e t h a t a n y a g e n c y r e c e i v i n g f e d e r a l f u n d s m u s t c o m p l y w i t h T i t l e V I b y a p p o i n t i n g a T i t l e V I c o o r d i n a t o r a n d a d o p t i n g a f o r m a l T i t l e V I p r o g r a m ; a n d W H E R E A S , t h e T o w n o f D a n v i l l e d o e s r e c e i v e f e d e r a l f u n d s f o r , a m o n g o t h e r t h i n g s , t r a n s p o r t a t i o n i m p r o v e m e n t s a d m i n i s t e r e d b y t h e T o w n ' s E n g i n e e r i n g D i v i s i o n ; n o w t h e r e f o r e , b e i t R E S O L V E D , t h a t t h e D a n v i l l e T o w n C o u n c i l h e r e b y a p p o i n t s t h e C i t y E n g i n e e r a s t h e T o w n ' s T i t l e V I C o o r d i n a t o r a n d a p p r o v e s t h e T i t l e V I p r o g r a m p r e s e n t e d t o t h e T o w n C o u n c i l . A P P R O V E D b y t h e D a n v i l l e T o w n C o u n c i l a t a r e g u l a r m e e t i n g o n O c t o b e r 6 , 2 0 2 0 b y t h e f o l l o w i n g v o t e : A Y E S : N O E S : A B S T A I N E D : A B S E N T : M A Y O R A P P R O V E D A S T O F O R M : A T T E S T : D æ u s l g n c d b y : P a l u r B . E * * t C I T Y A T T O R N E Y C I T Y C L E R K A T T A C H M E N T A Town of Danville TITLE VI PROGRAM Town of Danville 510 La Gonda Way Danville, CA 94526 www.danville.ca.gov ATTACHMENT B 1 Title VI of the Civil Rights Act of 1964 “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.” Title VI of the Civil Rights Act of 1964; 42 U.S.C. § 2000d, et seq. Town of Danville Equal Opportunity and Nondiscrimination Policy The Town of Danville is committed to providing equal opportunities to all employees, applicants, residents, customers, and persons doing business with the Town and will ensure that people may participate in, enjoy the benefits of, and be free from discrimination under any program or activity it administers without regard to any protected status, including: • Age • Ancestry • Color • Gender • Gender Expression • Gender Identify • Genetic Information • Marital Status • Medical Condition • Mental Disability • Military and Veteran Status • National Origin • Physical Disability • Sex (includes pregnancy, childbirth, breastfeeding and/or medical conditions) • Sexual Orientation I. Summary The Town of Danville’s mission is to excel at providing quality services for the benefit of all residents while developing, maintaining, and enhancing the resources of the area. Title VI of the Civil Rights Act of 1964 (Title VI) is a federal law that requires no person in the United States on the grounds of race, color, or national origin, be excluded from, be denied the benefits or be subjected to discrimination under any program or activity receiving federal financial assistance. The Federal-Aid Highway Act of 1973 added the requirement that there be no discrimination on the basis of sex. Title VI applies to recipients and sub-recipients of federal financial assistance. The Civil Rights Restoration Act of 1987 makes clear that pursuant to Title VI discrimination is prohibited throughout any department of a local agency that accepts Federal financial assistance. 2 The Town periodically receives federal funding from the Federal Highway Administration (FHWA) and other federal program funding. As a recipient of such federal aid, the Town is required to comply with Title VI and the related Department of Transportation regulations (Title 49 CFR Part 21). The following Title VI Program and Language Assistance Plan was developed to guide the Town of Danville in its administration and management of Title VI related activities. II. Introduction Title VI and Related Authorities Title VI of the Civil Rights Act of 1964 states the following: “No person in the United States shall on the grounds 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.” Section 162(a) of the Federal-Aid Highway Act of 1973 (Section 324, Title 23 U.S.C.) added the requirement that there be no discrimination on the grounds of sex. The Civil Rights Restoration Act of 1987, P.L. 100-209, provides clarification of the original intent of Congress in Title VI of the 1964 Civil Rights Act, Title IX of the Educational Amendments Act of 1972, the Age Discrimination Act of 1975, and Section 504 of the Rehabilitation Act of 1973. Executive Order 12898 (issued February 11, 1994) addresses Environmental Justice regarding minority and low-income populations. Agencies must develop strategies to address disproportionately high and adverse human health or environmental effects of their programs on minority and low-income populations; promote nondiscrimination in federal programs substantially affecting human health and the environment; and provide minority and low income communities access to public information and an opportunity for public participation in matters relating to human health or the environment. Executive Order 13166 (issued August 16, 2000) improves access to services for persons with limited English proficiency. Agencies are directed to evaluate services provided and implement a system that ensures that Limited English Proficiency (LEP) persons are able to meaningfully access the services provided, consistent with, and without unduly burdening the fundamental mission of the local agency. Agencies are directed to ensure that recipients of federal financial assistance provide meaningful access to programs, services and information to their LEP applicants and beneficiaries free of charge. Language barriers have the potential of prohibiting LEP persons from: • Obtaining services and information relating to transportation services, programs and projects. • Taking advantage of the transit system, which could affect their jobs and social opportunities. • Understanding the benefits to which they are entitled when their home or business is acquired through eminent domain. 3 Limited English Proficiency (LEP) Limited English Proficient persons refer to persons for whom English is not their primary language and who have a limited ability to read, write, speak or understand English. It includes people who reported to the U.S. Census that they speak English less than very well, not well or not at all. LEP person are entitled to language assistance under Title VI of the Civil Rights Act of 1964, and federal assistance recipients shall take reasonable steps to ensure meaningful access to benefits, services, information and other important portions of their programs and activities. Town Governance The Town is a general law city which operates under the Council-Manager form of government. The Town Council consists of five members, elected at large to four-year terms, with the members rotating the roles of Mayor and Vice-Mayor. III. Title VI Program Title VI Statement The Town of Danville, under Title VI of the Civil Rights Act of 1964, is committed to operating its programs, activities, and services in such a way that no person shall be excluded from the equal distribution of its services and amenities based on their race, color, national origin, sex, disability, or age. The Town has developed a notice to the public informing them of their rights under Title VI. Appendix A includes the Title VI Notice to the Public. Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with the Town of Danville, Caltrans and/or Federal Highway Administration. The Town’s complaint process and complaint forms are included in Appendix B. The Town’s objective is to: • Ensure that the level of quality of programs, projects and services are provided without regard to race, color, national origin, sex, disability or age; • Promote the full and fair participation of all affected populations in decision making; • Prevent the denial, reduction, or delay in benefits related programs and activities that benefit minority populations or low-income populations; and • Ensure meaningful access to programs and activities for persons with Limited English Proficiency. The Town is committed to complying with Title VI requirements for all programs and services delivered to the public. The Title VI Program (Program) serves as a guide and reflection of the commitment to preserving the civil rights for all individual and group benefactors of Town programs and services. 4 Title VI Coordinator The Town’s primary Title VI Coordinator, the City Engineer, is responsible for the overall Title VI Program. The Title VI Coordinator provides guidance and technical assistance on Title VI matters and has overall program responsibility for preparing reports and developing program procedures. Additional assistance is provided by the Human Resources Manager (e.g., personnel and job applicant issues). The Title VI Coordinator responsibilities include: a. Promptly processing and resolving Title VI complaints; b. Collecting demographic data (race, color, national origin) of participants in and beneficiaries of the City’s Federal-aid programs, activities, and services; c. Promptly resolving areas of deficiency; d. Conducting periodic Title VI audits; e. Ensuring that Title VI requirements are included in policy directives and that the procedures used have built-in safeguards to prevent discrimination; f. Coordinating the development and implementation of staff training regarding the City’s Title VI program; and g. Developing and coordinating Title VI information for public dissemination, including where appropriate in languages other than English. Title VI Requirements To meet the general requirements of Title VI, the Town utilizes the following procedures: a. Posting Title VI notifications at public counters, Internet, etc. b. Publishing brochures c. Address and filing Title VI discrimination complaints d. Training staff on Title VI law and requirements e. Providing access to LEP populations, if and when applicable f. Providing information and outreach to ensure Disadvantaged Business Enterprise (DBE) involvement in bidding g. Providing contract opportunities to minority businesses through the bidding process h. Meeting environmental justice regulations when applicable i. Adhering to service standards j. Including FHWA Form 1273 in all Federal Aid Contracts A. Notice of Rights The Town of Danville will display the "Notice of Rights" (Appendix A) for public view at various Town facilities with customer service counters and on the public website. The notice states that the Town will comply with Title VI and ensures that no person on the grounds of color, race national origin, sex, disability or age will be excluded from the participation in, be denied the benefits of, or be otherwise subjected to discrimination under any of our programs, activities, or services. 5 B. Complaint Procedures Any person who believes they have been discriminated against on the basis of race, color, national origin, sex, disability or age by the Town of Danville may file a Title VI complaint by completing and submitting the Town’s Title VI Complaint Form. The Town investigates complaints received no more than 180 days after the alleged incident. The Town will process complaints that are complete. Once the complaint is received, the Town will review it to determine if our Town has jurisdiction. The complainant will receive an acknowledgement letter informing them whether the complaint will be investigated by the Town. The Town has 14 days to investigate the complaint. If more information is needed to resolve the case, the Town may contact the complainant. The complainant has 10 business days from the date of the letter 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 10 business days, the Town can administratively close the case. A case can be administratively closed also if the complainant no longer wishes to pursue their case. After the investigator reviews the complaint, they 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, they have 15 days after the date of the letter or the LOF to do so. A person may also file a complaint directly with the Federal Highway Administration. C. Public Participation Plan The Town is committed to ensuring that projects, programs, and services delivered by the Town are sensitive to the various demographic backgrounds within the City. The Town Public Participation Plan (PPP) is for use by the Town to promote public involvement in the planning and decision- making process of projects, programs, and services. As a recipient of Federal funding, the Town is required to adhere to Title VI of the Civil Rights Act of 1964 and to integrate the PPP into its Title VI Program. This plan provides guidelines for involving the public to ensure that all groups are represented and their needs considered. The Town is committed to ensuring it serves the residents and businesses of the Town fairly, consistently, and in the most cost-efficient and appropriate manner within available resources. Goals and Objectives The goal of the City’s PPP is to offer a variety of opportunities for the public to engage in planning and decision-making activities. To meet this goal, the objectives of the PPP are as follows: • To determine what non-English languages and/or other barriers, if any, may exist to public participation within the Town service area. 6 • To provide a general notification of meetings for public input, in a manner that is understandable to all populations in the service area. • To hold meetings in locations that are accessible and reasonably welcoming to all area residents, including, but not limited to minority, Limited English Proficiency (LEP), and low-income members of the public. • To utilize a variety of communication methods to capture public input from populations that are not likely to attend or engage in public meetings. Stakeholders Limited English Proficiency Populations A LEP individual is someone with limited ability to read, write, speak, or comprehend English. Reasonable efforts will be made to engage LEP populations utilizing techniques, such as the development of public notices in appropriate non-English Languages that will provide contact information where individuals can be informed of the affected project or services to provide input and comments. In addition, non-profit organizations and other advocacy groups can be utilized to disseminate and provide insight into the needs of LEP populations. Low-Income Populations The Town will identify low-income populations within the service area. The low-income threshold will be defined as households with a per capita income of 80 percent or less of the national average. Low-income populations in the Town will be given reasonable opportunity to provide input on plans and programs to avoid disproportionate harm or lack of benefit. Public Comment Process Offered by the Town Council The public has a right to express their opinion during the regular Council meetings held the first and third Tuesday of every month. Council meetings have typically been held at 7:30 p.m. in the Town Meeting Hall at 201 Front Street. However, during the current COVID-19 pandemic, meetings have been held via Zoom at 5 p.m. with no live presence. at 4 p.m. For the most current information regarding the Town Council schedule and their meeting, check the Town’s website at https://www.danville.ca.gov/129/Agendas -Minutes Outreach Efforts Engaging minority and LEP populations can be challenging and the Townwill use multiple techniques to actively solicit policy input in the planning process for a project. The Townwill engage the community through the City’s website, social media, and brochures placed at the library, community centers, public parks, and recreation areas within the communities. The Townstaff and/or a contracted non-English language interpreter are available upon request to attend community meetings to inform residents of the City’s services and provide them an opportunity to express their input in a language they are comfortable communicating in upon request. Appropriate techniques among the following will be used to inform, educate, and gain input from the public about the City’s projects, services, or activities: 7 • Surveys or questionnaires - mail-in, online, telephone, personal interview • Articles or press releases in the appropriate publications • Timely consultation with advisory committees • Distribution of informal reports, flyers, or brochures • Informal presentations at community forums • Information about meetings, public hearings, and special events on the City’s website • Direct mailings to those expressing interest in or commenting about certain topics • General mailings with posters and flyers to area post offices and appropriate agencies, offices, and organizations for distribution to citizens D. Environmental Justice In accordance with Executive Order 12898 (Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations), the Town will identify and address the environmental effects of programs, policies, and activities on minority and low-income populations. The Town will consider demographic data into their project design and involve the public in the planning and development process to assess the environmental impacts of projects on the community. The public’s input and data analysis enable the Town to develop measures to mitigate any potential adverse effects on minority and low-income populations. The Town is not required to conduct environmental justice analyses of projects where NEPA documentation is not required. IV. Language Assistance Plan Plan Purpose The purpose of this Language Assistance Plan is to identify reasonable steps to provide language assistance for Limited English Proficiency (LEP) persons who seek meaningful access to Town services as required by Executive Order 13166. As defined by this order, a person with Limited English Proficiency is one who does not speak English as their primary language and who has a limited ability to read, speak, write or understand English. The Town of Danville will ensure that individuals have meaningful access to its programs, activities, and services by developing and carrying out the Language Assistance Plan herein. The Town has determined that there are currently not a sufficient number of LEP persons to warrant any special programs at this time. This determination is based on the following information: • There is no census data on language specific to Danville, but based on information provided by the San Ramon Valley Unified School District, their English language results for all demographic groups are above average. • The California Office of Environmental Health Hazard Assessment Linguistic Isolation results for Danville show that the percentile of Linguistic Isolation is below 10%. • The Town also applied the U.S. Department of Transportation’s four-factor LEP analysis, which considers the following factors: o The number or proportion of LEP persons served or encountered in the eligible service population. The Department of Justice’s Safe Harbor Provision stipulates that 8 translations of vital documents should be available for LEP populations that comprise five percent of the general population or 1,000 persons, whichever is lowest. The Town does not have any LEP populations meeting that threshold. o The frequency with which LEP persons come into contact with Town programs, activities and services. Based on personal experience of Town staff with over 20 years of experience with the Town in HR, City Clerk and Public works, the Town has had zero contacts where an individual has had a language barrier. o The nature and importance of the programs provided by the Town to LEP persons. The Town of Danville receives Federal Aid for projects that enhance safety for motorists, pedestrians and bicyclists. o Resources available for LEP outreach. The Town has typically had staff capable of providing basic translation and interpretation. The City Clerk has identified resources available for more complex translation and interpretation needs. The Town will continue to monitor the language needs of the community, utilizing the tools described above. Training The Town will provide Title VI training to appropriate Staff. These trainings are offered at minimum every two years. Trainings will be offered online or through an instructor-led class. Additional resources are provided on the Town’s website to enhance the learning objectives. The following components will be covered to ensure compliance: • Understanding the Title VI Policy and LEP responsibilities • Language assistance that the Town offers • Documentation of language assistance requests • How to handle a Title VI and/or LEP complaint Appendix A – Notice to the Public Title VI Notice of Rights Town of Danville The Town of Danville operates its programs and services without regard to race, color, national origin, sex, disability, or age in accordance with Title VI of the Civil Rights Act of 1964. If you believe you have been subjected to discrimination as prohibited by Title VI, you may file a written complaint with the Town or with Caltrans or the Federal Highway Administration. For more information or to obtain a copy of the City’s Title VI complaint procedures and complaint form contact: Town of Danville Attn: Title VI Coordinator 510 La Gonda Way, Danville, CA 94526 www.danville.ca.gov If the complainant is unable to write a complaint, a representative may file on his or her behalf, or Towns taff will provide assistance. Complaints must be filed within 180 calendar days of the alleged incident. If information is needed in another language or an alternative format, please call 925-314-3310. • Spanish: Si necesita servicios de traducción para otro lenguaje, aparte de Ingles, por favor llamar al 925-314-3310 para asistencia. Appendix B- Complaint Forms English Complaint Form Section I Name: Address: Telephone (Home/Cell): Telephone (Work): Email: Do you require an accessible format? Large Print Audio Tape TTY/TDD Other Section II Are you filing this complaint on your own behalf? Yes No If you answered “yes” to this question, go to Section IIII. If not, please supply the name and relationship of the person for whom you are filing: Have you obtained permission from this person? Please explain why you are filing for this person: Section III I believe the discrimination I experienced was based on (check all that apply): ( ) race ( ) color ( ) national origin ( ) sex ( ) disability ( ) age ____________ Date of Alleged Discrimination (month, day, year): Explain as clearly as possible what happened and why you believe you were discriminated against. Describe all persons who were involved. Include the name and contact information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses. Section IV Have you previously filed a Title VI complaint with the Town of Danville? Yes No Contact name: Telephone number: Section V Have you filed this complaint with any other federal, state or local agency or with any federal or state court? If yes, check all that apply: ( ) Federal Agency: ( ) Federal Court: ( ) State Agency: ( ) State Court: ( ) Local Agency: ( ) Local Court: Please provide contact information for the person you spoke to at the above agency: Name: Title: Agency: Address: Telephone: You may attach any written materials or other information that you think is relevant to your complaint. Your signature and date are required below: Signature Date Town of Danville operates without regard to race, color or national origin. If you need assistance completing this form, contact the Town of Danville at: 925-314-3310 Email: Sjones@danville.ca.gov Please submit this form in person or by mail to: Town of Danville Title VI Coordinator, City Engineer 510 La Gonda Way Danville, CA 94526 Appendix C – Title VI Complaint Procedures Any person who believes she or he has been discriminated against on the basis of race, color, national origin, sex, disability or age by the Town of Danville (hereinafter referred to as “the Town”) may file a Title VI complaint by completing and submitting the Town’s Title VI Complaint Form. The Town investigates complaints received no more than 180 days after the alleged incident. The Town will process complaints that are complete. Once the complaint is received, the Town will review it to determine if our Townh as jurisdiction. The complainant will receive an acknowledgement letter informing her/him whether the complaint will be investigated by our Town. The Town has 14 days to investigate the complaint. If more information is needed to resolve the case, the Town may contact the complainant. The complainant has 10 business days from the date of the letter 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 10 business days, the Town can administratively close the case. A case can be administratively closed also if the complainant no longer wishes to pursue their case. After the investigator reviews the complaint, they 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, they have 15 days after the date of the letter or the LOF to do so. A person may also file a complaint directly with the Federal Highway Administration. Appendix D – Tracking of Title VI Complaints The Town is required to prepare and maintain a list of any of the following that allege discrimination on the basis of race, color, national origin, sex, disability or age: • Active investigations • Lawsuits • Complaints naming the Town of Danville Below is the list that will be used for tracking these incidents: Investigations, Lawsuits and Complaints Date (Month, Day, Year) Summary (Include basis of complaint: race, color, national origin) Status Actions Taken Complaints Investigations Lawsuits Appendix G – Title VI Program and Language Assistance Plan Staff Training Form No person shall, on the grounds of race, color, national origin, sex, disability, or age be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. Employees of the Town of Danville are expected to consider, respect, and observe this policy. Citizen questions or complaints shall be directed to the Town of Danville Title VI Coordinator. I hereby acknowledge receipt of Town of Danville’s Title VI Program and Language Assistance Plan. I have read the plan and am committed to ensuring that no person is excluded from participation in, or denied the benefits of services delivered by the Town of Danville on the basis of race, color, or national origin, as protected by Title VI. ___________________________ Signature ___________________________ Print Name ___________________________ Date