Whitewater Valley Regional Transit Title VI Policy
I. INTRODUCTION
WHITEWATER VALLEY REGIONAL TRANSIT’S COMMITMENT TO CIVIL RIGHTS
This update of Whitewater Valley Regional Transit’s Title VI Program has been prepared to ensure that the level and quality of Union County’s demand response services are provided in a nondiscriminatory manner and that the opportunity for full and fair participation is offered to Whitewater Valley Regional Transit’s riders and other community members. Additionally, through this program, Union County has examined the need for services and materials for persons for whom English is not their primary language and who have a limited ability to read, write, speak, or understand English.
While it is a matter of principle that Union County is committed to ensuring that no person is excluded from participation in, or denied the benefits of, or subjected to discrimination in the receipt of any of Whitewater Valley Regional Transit’s services on the basis of race, color, or national origin. The contents of this program have been prepared in accordance with Section 601 of Title VI of the Civil Rights Act of 1964 and Executive Order 13116 (Improving Access to Services for Persons with Limited English Proficiency) and other statutes and authorities that prohibit discrimination in any Federally assisted program or service.
Under the Civil Rights Act of 1964, and as a recipient of federal funding under the programs of the Federal Transit Administration (FTA) of the U.S. Department of Transportation (US DOT), Whitewater Valley Regional Transit has an obligation to ensure that:
• The benefits of its bus services are shared equitably throughout the service area;
• The level and quality of bus services are sufficient to provide equal access to all riders in its service area;
• No one is precluded from participating in Whitewater Valley Regional Transit’s service planning and development process;
• Decisions regarding service changes or facility locations are made without regard to race, color, or national origin and that development and urban renewal benefitting a community as a whole not be unjustifiably purchased through the disproportionate allocation of its adverse environmental and health burdens on the community’s minority population; and
• A program is in place for correcting any discrimination, whether intentional or unintentional.
II. GENERAL REQUIREMENTS
Notice to the Public
To make Whitewater Valley Regional Transit riders aware of its commitment to Title VI compliance, and their right to file a civil rights complaint, Whitewater Valley Regional Transit has presented the following information, in both English and Spanish, on its website, pamphlet, and onboard buses.
Your Civil Rights
Whitewater Valley Regional Transit operates its programs and services without regard to race, color, or national origin, in accordance with Title VI of the Civil Rights Act and other statutes and authorities that prohibit discrimination in Federally assisted programs and activities. Any person who believes they have been aggrieved by any unlawful discriminatory practice under Title IV may file a complaint with Whitewater Valley Regional Transit. For more information on Whitewater Valley Regional Transit’s civil rights program and the procedures to file a complaint, please contact (765) 458-7277; email [email protected] or visit our administrative office at 615 West High Street Liberty, IN 47353 from Monday through Friday 8am-5pm. A complaint may also be filed directly with the FTA, Office of Civil Rights, 1200 New Jersey Avenue SE, Washington DC 20590. For more information about Whitewater Valley Regional Transit programs and services, visit whitewatervalleyregionaltransit.com. If information is needed in another language, please contact (765)458-7277.
Discrimination Complaint Procedures
Whitewater Valley Regional Transit has established a process for riders to file a complaint under Title VI. Any person who believes that she or he has been discriminated against on the basis of race, color, or national origin by Whitewater Valley Regional Transit may file a Title IV complaint by completing and submitting the agency’s Title VI Complaint available at our administrative offices or on our website whitewatervalleyregionaltransit.com.
Whitewater Valley Regional Transit will notify INDOT of all formal complaints within five business days of receiving the complaint.
** Complaint form attached**
The Whitewater Valley Regional Transit’s Complaint Procedure
If you believe that you have received discriminatory treatment by the Whitewater Valley Regional Transit on the basis of race, color, or national origin you have the right to file a complaint with the Union County Council on Aging and Age’s Director.
Methods of filing a complaint:
Complete the Complaint Form, and send it to:
Whitewater Valley Regional Transit
615 West High Street, PO Box 333
Liberty, IN 47353
Verbal complaints are accepted and transcribed by the Executive Director. To make a verbal complaint, call (765) 458-7277 and ask for Trisha Persinger.
The Director investigates complaints received no more than 180 days after the alleged incident. The Director will process complaints that are complete. Once the complaint is received, the Director will review it and the complainant will receive an acknowledgement letter informing them whether the complaint will be investigated by the management of Whitewater Valley Regional Transit.
Whitewater Valley Regional Transit has up to thirty days to investigate the complaint. If more information is needed to resolve the case, the Executive Director may contact the complainant. The complainant has thirty days from the date of the letter to send requested information to the investigator assigned to the case.
If Whitewater Valley Regional Transit’s investigator is not contacted by the complainant or does not receive the additional Information within thirty days, Whitewater Valley Regional Transit 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, one of two letters will be issued 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.
A 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, she/he has ten days after the date of the letter or the LOF to do so.
A person may also file a complaint directly with the Federal Transit Administration, at:
Federal Transit Administration
Office of Civil Rights
1200 New Jersey Avenue SE
Washington, DC 20590
Active Lawsuits, Complaints or Inquiries Alleging Discrimination
Whitewater Valley Regional Transit maintains a list of active investigations conducted by FTA and entities other than FTA, including lawsuits and complaints naming Whitewater Valley Regional Transit that allege discrimination on the basis of race, color, or national origin. This list includes the date that the transit-related Title VI investigation, lawsuit, or complaint was filed; a summary of the allegation(s); the status of the investigation, lawsuit or complaint, and actions taken by Whitewater Valley Regional Transit in response, or final findings related to the investigation, lawsuit, or complaint.
As of the writing of this program, there are 0(zero) complaints pending which allege discrimination on the grounds of race, color, or national origin, or any other form of discrimination.
Active Lawsuits, Complaints or Inquiries Alleging Discrimination
Type (Investigation, Lawsuit, Complaint) Date Summary of Complaint Status Action(s) Taken
III. WHITEWATER VALLEY REGIONAL TRANSIT’S PUBLIC PARTICIPATION PLAN
Key Principles
Whitewater Valley Regional Transit’s Public Participation Plan (PPP) has been prepared to ensure that no one is precluded from participating in Whitewater Valley Regional Transit’s service planning and development process. It ensures that:
• Potentially affected community members will have an appropriate opportunity to participate in decisions about a proposed activity that will affect their environment and/or health.
• The public’s contribution can and will influence Whitewater Valley Regional Transit’s decision making.
• The concerns of all participants involved will be considered in the decision-making process; and,
• Whitewater Valley Regional Transit will seek out and facilitate the involvement of those potentially affected.
Through an open public process, Whitewater Valley Regional Transit has developed a public participation plan to encourage and guide public involvement efforts and enhance access to Whitewater Valley Regional Transit’s transportation decision-making process by minority and Limited English Proficient (LEP) populations. The public participation plan describes the overall goals, guiding principles and outreach methods that Whitewater Valley Regional Transit uses to reach its riders.
Limited English Proficient (LEP) Goals of the Public Participation Plan
The overarching goals of Whitewater Valley Regional Transit’s PPP include:
• Clarity in Potential for Influence – The process clearly identifies and communicates where and how participants can have influence and direct impact on decision making.
• Consistent Commitment – Whitewater Valley Regional Transit communicates regularly, develops trust with riders and our community and builds community capacity to provide public input.
• Diversity – Participants represent a range of socioeconomic, ethnic and cultural perspectives, with representative participants including residents from low-income neighborhoods, ethnic communities and residents with Limited English Proficiency
• Accessibility – Every reasonable effort is made to ensure that opportunities to participate are physically, geographically, temporally, linguistically, and culturally accessible.
• Relevance – Issues are framed in such a way that the significance and potential effect is understood by participants.
• Participant Satisfaction – People who take the time to participate feel it is worth the effort to join the discussion and provide feedback.
• Partnerships – Whitewater Valley Regional Transit develops and maintains partnerships with communities through the methods described in its public participation plan.
• Quality Input and Participation – That comments received by Whitewater Valley Regional Transit are useful, relevant and constructive, contributing to better plans, projects, strategies and decisions.
Objectives of the Public Participation Plan
Whitewater Valley Regional Transit’s Public Participation Plan is based on the following principles:
• Flexibility – The engagement process will accommodate participation in a variety of ways and be adjusted as needed.
• Inclusiveness – Whitewater Valley Regional Transit will proactively reach out to and engage low income, minority and LEP populations from the Whitewater Valley Regional Transit service area.
• Respect – All feedback will be given careful and respectful consideration.
• Proactive and Timeliness – Participation methods will allow for early involvement and be ongoing.
• Clear, Focused and Understandable – Participation methods will have a clear purpose and use for the input, and will be described in language that is easy to understand.
• Honest and Transparent – Information provided will be accurate, trustworthy, and complete.
• Responsiveness – Whitewater Valley Regional Transit will respond and incorporate appropriate public comments into transportation decisions.
• Accessibility – Meetings will be held in locations which are fully accessible and welcoming to all area residents, including, but not limited to, low-income and minority members of the public and in locations relevant to the topics being presented and discussed.
Whitewater Valley Regional Transit will use its public participation plan when considering all fare changes, major modifications to routes and schedules, and other transit planning projects when:
• A fare increase/decrease or significant change in the method of fare payment is being considered.
• Advance reservation policy is reduced or increased.
• Area for deviating to pick up passengers is changed.
• A new route is established.
• An existing route is proposed for elimination.
• Considering the total discontinuance of service on any line or group of lines on any given day when service is currently offered.
• Any system-wide change in service hours that exceeds (plus or minus) 10% of current total service hours.
• Routing on any given route or group of routes that affects more than 25% of the riders using the affected route(s); or
• Schedules are changed on any given route or group of routes that reduces the total number of one-way bus trips by more than 25% of the current number of bus trips.
• For minor schedule and service changes not rising to the level of those above, Whitewater Valley Regional Transit will post service change notices on appropriate buses and stops sixty days in advance of the change date.
IV. WHITEWATER VALLEY REGIONAL TRANSIT’S PUBLIC PARTICIPATION PROCESS
Outreach Efforts – Alerting Riders and Encouraging Engagement
Whitewater Valley Regional Transit’s PPP includes many new mediums extending beyond the traditional approach which relied on legal notices and intermittent media coverage. While Whitewater Valley Regional Transit maintains these elements to its outreach program along with traditional seat-drop flyers, Whitewater Valley Regional Transit has availed itself of the communication methods more widely used by members of our community and riders.
While there may be minor variation in the outreach process from time-to-time, the outline below provides the general steps for engaging riders in the decision-making process using a fare or service change as an example.
1. A service/fare change proposal is developed internally or as a result of public comment.
2. An internal review by the appropriate committees is conducted by the Union County Service Review Committee, which is the Union County Board of Directors for Union County Aged and Aged.
3. Proposals are reviewed by Whitewater Valley Regional Transit’s Passenger Advisory Committee (PAC).
4. A Title VI review of the proposal is conducted.
5. If required, authorization from the Whitewater Valley Regional Transit’s Board of Directors is sought to proceed to a public comment period.
6. Public outreach venues, dates and times are determined with consideration of the proposed changes and their impact on specific locations/populations within the Whitewater Valley Regional Transit service area.
7. Bilingual (English and Spanish) public outreach materials and a program are developed.
8. Outreach In advance of public information sessions is released (using toolbox of mediums listed below);
1. An Email is transmitted to Whitewater Valley Regional Transit community partners.
2. Local radio station(s) Kicks 96.1 and G101.3 interviews may be conducted (if available).
3. The public comment period ends.
4. A Whitewater Valley Regional Transit Board of Director summary package is presented detailing the outcome of the public participation process along with staff recommendations.
5. The final service/fare change date is set.
6. Outreach is conducted in advance of any service or fare change.
7. Bilingual system timetable and website updated in advance of the proposed change.
Selection of Meeting Locations
When determining locations and schedules for public meetings, Whitewater Valley Regional Transit will:
• Schedule meetings at times and locations that are convenient and accessible for minority and LEP communities.
• Employ different meeting sizes and formats including town hall type meeting formats.
• Coordinate with community organizations, educational institutions, and other organizations to implement public engagement strategies that reach out specifically to members of affected minority and/or LEP communities.
• Consider radio, television, or newspaper ads as well as podcasts that serve LEP populations.
• Ensure that transportation is available to and from the meeting if requested.
• Provide opportunities for public participation through means other than written communication, such as one-on-one interviews or use of audio or video recording devices to capture oral comments.
Whitewater Valley Regional Transit Mediums
• Print – Newspapers and other periodicals
• Outdoor – Advertising on-board buses (interior and exterior)
• Website – Whitewater Valley Regional Transit has assembled a comprehensive website
• Social Media – Whitewater Valley Regional Transit has used Facebook since 2015 to help engage the community
• On-board Flyers – Whitewater Valley Regional Transit regularly uses seat drops and flyers to provide riders with details of service changes and schedules of public meetings and hearings.
• Direct Mail to Community Partners
• Public Information Sessions
• Public Hearings
• Legal Notices
Addressing Comments
The Incorporation of Public Comments into Decisions
All comments received through the public participation plan are given careful, thoughtful consideration. Because there are a number of different ways riders or members of the community can comment on proposed service or fare changes by mail PO Box 333 Liberty, IN 47353, email [email protected], social media (Whitewater Valley Regional Transit Facebook page), public meetings and website, all comments are assembled into a single document for presentation to the Whitewater Valley Regional Transit Board of Directors for consideration and input.
Identification of Stakeholders
Our Community Partners
Stakeholders are those who are either directly or indirectly affected by a plan, or the recommendations of the plan. Those who may be adversely affected, or who may be denied benefits of a plan’s recommendation(s), are of particular interest in the identification of specific stakeholders. Stakeholders can come from a number of groups including general citizens/residents, minority and low-income persons, public agencies, and private organizations and businesses. While stakeholders may vary based on the plan or program being considered, Whitewater Valley Regional Transit has assembled a listing of stakeholders with whom we regularly communicate through email and direct mail. A complete list of Whitewater Valley Regional Transit’s community stakeholders can be obtained by contacting Whitewater Valley Regional Transit.
Stakeholder List
V. DECISION MAKING BODIES
Non-Elected Committees and Councils
At Whitewater Valley Regional Transit, decisions regarding policy, service changes, fares, capital programming and facility locations are made by Union County Board of Directors. Whitewater Valley Regional Transit’s Board of Directors are composed of four (4) members representing Liberty, Indiana.
Board of Directors 4 Caucasian
VI. SUMMARY OF CHANGES
Service Change Evaluations Since September 2018
Since Whitewater Valley Regional Transit’s 2008 Title VI Plan Submission there have been no changes in Whitewater Valley Regional Transit’s fare structure. There have been no service changes.
These changes, the associated outreach and Title VI determination and Whitewater Valley Regional Transit Board Approval are available by contacting Whitewater Valley Regional Transit.
Program Specific Requirements
Title VI Monitoring (September 2018 Title VI Plan)
The results of the ongoing monitoring of service standards as defined in the Whitewater Valley Regional Transit’s [September 2018] program can be obtained by contacting Whitewater Valley Regional Transit.
Demographic Service Profile
Because Whitewater Valley Regional Transit operates fewer than 50 buses in peak service, a demographic service profile was not prepared for this plan update.
VII. GRANTS, REVIEWS AND CERTIFICATIONS
Pending Applications for Financial Assistance
N/A
Civil Rights Compliance Reviews in the Past 3 Years
Whitewater Valley Regional Transit has not been the subject of any such reviews since its 2018 submission
Recent Annual Certifications and Assurances
Whitewater Valley Regional Transit executed its most recent Certifications and Assurances to the FTA in June 2021 and is in the process of executing 2022 certifications and assurances.
Contact
For additional information on the Whitewater Valley Regional Transit Title VI Plan, or its efforts to comply with the Civil Rights Act of 1964 or Executive Order 13166 Improving Access to Services for Persons with Limited English Proficiency, please contact:
Whitewater Valley Regional Transit
PO Box 333, 107 North Main Street
Liberty, IN 47353
765-458-7277
VIII. LANGUAGE ASSISTANCE PLAN
Improving Access for People with Limited English Proficiency (LEP)
In order to ensure meaningful access to programs and activities, Whitewater Valley Regional Transit uses the information obtained in a Four Factor Analysis to determine the specific language services that are appropriate. This analysis helps Whitewater Valley Regional Transit to determine if it communicates effectively with LEP persons and informs language access planning.
The Four Factor Analysis is a local assessment that considers:
1. The number or proportion of LEP persons eligible to be served or likely to be encountered by Whitewater Valley Regional Transit.
2. The frequency with which LEP persons come into contact with Whitewater Valley Regional Transit services and programs.
3. The nature and importance of Whitewater Valley Regional Transit’s services and programs in people’s lives; and
4. The resources available to Whitewater Valley Regional Transit for LEP outreach, as well as the costs associated with that outreach.
Factor 1 – Number of LEP Persons in Service Region
The first step in determining the appropriate components of a Language Assistance Plan is understanding the proportion of LEP persons who may encounter Whitewater Valley Regional Transit’s services, their literacy skills in English and their native language, the location of their communities and neighborhoods and, more importantly, if any are underserved because of a language barrier.
To do this, Whitewater Valley Regional Transit evaluated the level of English literacy and to what degree people in its service area speak a language other than English and what those languages are. Data for this review is derived from the United States Census and the American Community Survey July 1, 2019. Data was reviewed by Whitewater Valley Regional Transit’s Board of Directors and the Union County Board of Commissioners in its entirety.
Service Area Overview
Whitewater Valley Regional Transit’s service area encompasses approximately 165.2 square miles of Union County and is home to a population speaking more than 1 different language. Of the total service area population, 6,661, less than 1% of residents report speaking English less than very well. The most populous groups in the category are shown below. Of the remaining populations, those reporting English “less than very well” range from 1% to 2% of the total service area population.
Union County, Indiana
Label Estimate Margin of Error
Total: 6,661 ±61
Speak only English 6,493 ±56
Spanish: 45 ±45
Speak English less than “very well” 25 ±28
Vietnamese: 15 ±32
Speak English less than “very well” 15 ±32
Other Asian and Pacific Island languages: 5 ±10
Speak English less than “very well” 5 ±10
The Locations of the LEP Community
The map in Exhibit A illustrates the distribution of population densities by Census Tract where individuals speak English “Less than Very Well.”
Factor 2 – Frequency of LEP Use
There are many places where Whitewater Valley Regional Transit riders and members of the LEP population can come into contact with Whitewater Valley Regional Transit services including the use of demand response buses, calls to customer service representatives, and Whitewater Valley Regional Transit’s outreach materials. An important part of the development of Whitewater Valley Regional Transit’s Language Access Plan is the assessment of major points of contact, including:
• The use of the bus service (on-board signage, announcements, and driver language skills).
• Communication with Whitewater Valley Regional Transit’s customer service staff.
• Printed outreach materials.
• Web-based outreach materials.
• Public meetings.
• Demand response reservation agents.
• Local news media (print and radio).
Whitewater Valley Regional Transit distributed a language survey to its employees. The objective of the survey was to evaluate the needs of Whitewater Valley Regional Transit customers who are not able to communicate in English. The first question asked, In What Way(s) Do You Interact with Whitewater Valley Regional Transit riders? The chart below illustrates the results.
Method of Interaction Percent of Responses
Telephone 14%
Face to Face 100%
Email 14%
Fax 14%
Next, the survey asked how often employees encounter LEP customers. The chart below outlines the results.
Frequency of Interaction Percent of Responses
Often
Sometimes
Rarely
Never 100%
Next, the survey asked employees to identify how often they interact with the following languages on a typical workday.
Language Percent of Interactions
Spanish 0%
Asian 0%
The survey asked, overall, how effective employees are in communicating with Limited English Proficient Whitewater Valley Regional Transit passengers. The results are summarized below.
Effectiveness Percent of Total Responses
Very Effective 100%
Moderately Effective
Less Effective
Unable to Communicate
Community Partners
Whitewater Valley Regional Transit also canvassed its community partners to assess the extent to which they encountered LEP populations. Community partners were asked the following questions:
1. Do you encounter non-English speaking/reading people who need your services?
2. If so, what are the top three languages that you encounter?
3. How do you address language barriers?
4. Do you find language to be a barrier in preventing you from providing service?
Question Union County Library FSSA Office Union County School Corporation
Do you encounter non-English speaking/reading people who need your services? Rarely Rarely Sometimes
If so, what are the top three languages that you encounter?
Spanish Spanish Spanish
How do you address language barriers? With local translators With local translators With local translators
Do you find language to be a barrier in preventing you from providing service? No No No
Consulting Directly with the LEP Population
In addition to the U.S. Census data, employee survey, and outreach to community partners, Whitewater Valley Regional Transit implemented a survey of its riders. A copy of the survey is attached in Appendix A.
Information on survey of riders
Many of the surveys returned showed that 60% of the riders used the Transit monthly, for the needs of medical.
Factor 3 – The Importance of Whitewater Valley Regional Transit Service to People’s Lives
Access to the services provided by Whitewater Valley Regional Transit is critical to the lives of many in the service area. Many depend on Whitewater Valley Regional Transit’s services for access to jobs and for access to essential community services like schools, shopping, and medical appointments. Riders eligible for service under the Americans with Disabilities Act (ADA) require service for the same reasons. Because of the essential nature of the services and the importance of these programs in the lives of many of the region’s residents, there is a need to ensure that language is not a barrier to access.
Survey data reflecting trip purpose
100 surveys were distributed. 25 were returned. Out of the 25 returned:
• Weekly use of Transit 9/25 36%
• Monthly use of Transit 15/25 60%
• As needed use of Transit 1/25 4%
• Work 4/25 16%
• Medical 20/25 80%
• Shopping 1/25 4%
• School 0/25 0%
If limited English proficiency is a barrier to using these services, then the consequences for the individual could limit their access to obtain health care, education, or employment. Critical information from Whitewater Valley Regional Transit which can affect access includes:
• Route and schedule information
• Fare and payment information
• Information regarding making the best use of the system (How To)
• Service announcements
• Safety and security announcements
• Complaint and comment forms
• Outreach related to opportunity for public comments
• Information about demand response services under the ADA and other special programs
• What to do in an emergency
The following notice is posted on all Whitewater Valley Regional Transit vehicles.
The Whitewater Valley Regional Transit ensures that no person shall, on the grounds of race, color, or national origin be excluded from participating in or denied benefits of or be subjected to discrimination as it relates to the provision of public transportation services provided by the Whitewater Valley Regional Transit.
Any person who wants additional information on Whitewater Valley Regional Transit’s nondiscrimination obligation or believes that he or she individually or as a member of any specific class of persons, has been subjected to discrimination on the basis of race, color, or national origin may file a complaint with the Whitewater Valley Regional Transit within 180 days of the date of the alleged discrimination.
To file a complaint contact Whitewater Valley Regional Transit at 765-458-7227, whitewatervalleyregionaltransit.com or send a letter to 615 West High Street Liberty, IN 47353. A complaint may also be filed directly with the FTA, Office of Civil Rights, 1200 New Jersey Avenue SE, Washington DC 20590.
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La compañía Unión County Tránsito garantiza que ninguna persona, por motivos de raza, color, origen nacional estén excluida de la participación o negado de los beneficios o ser subjeto de discriminación en respecto a los servicios proveídos de la Autoridad del transporte público.
Cualquier persona que cree que él o ella a título individual o como miembro de una clase específica de personas, ha sido subjeto de discriminación por motivos de raza, color, o origen nacional puede presentar una queja a la compañía Unión County Tránsito dentro de los 180 días siguientes a la fecha de la supuesta discriminación.
Para presentar una queja al Unión County Tránsito, llame al 765-458-7227, whitewatervalleyregionaltransit.com, o escribe una calta y envía a 615 West High Street Liberty, IN 47353. Se puede presentar una queja directamente ante el FTA, Oficina de Derechos Civiles, 1200 New Jersey Avenue SE, Washington DC 20590.
Factor 4 – Resources and Costs for LEP Outreach
Whitewater Valley Regional Transit has committed resources to improving access to its services and programs for LEP persons.
Today, bilingual information (English/Spanish) is distributed in an extensive number of mediums including the following:
• A bi-lingual English/Spanish website
• A complete bilingual English/Spanish Rider’s Guide to demand response services (ADA paratransit)
• Bilingual English/Spanish outreach materials
• Bilingual English/Spanish representation at public meetings
• Bilingual English/Spanish guides and training for Whitewater Valley Regional Transit drivers.
• Increased use of Bilingual English/Spanish on Facebook posts
To date, the costs associated with these efforts fit within the Whitewater Valley Regional Transit’s marketing and outreach budget.
Costs are predominantly associated with translation services and material production.
Outcomes
New tools and alerting riders of language assistance
Following the “Four Factor Analysis”, Whitewater Valley Regional Transit concluded that, while there is currently extensive outreach and materials for the Spanish speaking LEP population of the service area, additional services would assist other LEP populations regardless of the total population in the region. These include:
1. Offering a speaking translator if needed.
2. Adding translation services for telephone communications with customer service representatives.
3. Assigning new staff charged with improvement community engagement; and
4. Creating a page with multiple languages for print and web-based posting indicating how Whitewater Valley Regional Transit provides language assistance.
5. Use a smart phone with translation application.
Additional recommendations gleaned from the internal staff survey include:
1. Offering employees conversational or transit specific language training
2. Recruiting more multilingual employees.
Whitewater Valley Regional Transit is considering all these items and other methods that become available.
Oversight
Monitoring, Evaluating and Updating the Language Assistance Plan and Public
Participation Process
The monitoring of the Language Assistance Plan will include:
• Annual reviews of regional census data for changing patterns of LEP populations.
• Update the policy every three years.
• Ongoing collaboration with regional partners.
• Ongoing review of Google Translate requests at Union County’s website; and
• Post Event Assessments (PEA)
Post-Event Assessments
Following service changes, fare increases and planning projects, the Director assesses the effectiveness of public involvement against the goals established in this plan. This assessment will ask the questions:
• Did the public know there was an opportunity to participate?
• Was the purpose of the participation clearly articulated to the public?
• Did the public have access to appropriate resources and information to allow for meaningful participation?
• Did the decision-making process allow for consideration and incorporation of public input?
• Were there complaints about the public engagement process?
• Were the public engagement efforts cost effective?
• What additional methods could have been employed to improve the process?
• Should the Public Participation Process or Language Assistance Plan be amended?
Training Employees
Whitewater Valley Regional Transit conducts annual and new employee training on how to use LEP translation services that are available to the public and how to inform passengers of services and documents available for LEP populations. Whitewater Valley Regional Transit also conducts training for office staff on how to use translation applications.
Employee awareness training for the ability to basically communicate with the LEP and low-literacy population.
Description of Employee training program related to LAP
The Whitewater Valley Regional Transit Operators are provided a copy of the Title VI Plan. The organization reviews the plan together on an annual basis. The employees are asked to sign off on the plan and provided the opportunity to discuss or provide ant thoughts or feedback.
Translation of Vital Documents
Whitewater Valley Regional Transit has translated many vital documents into Spanish and is in the process of translating others. The list of documents that are or will be translated is provided below:
• Civil Rights Complaint Form
• ADA Eligibility Applications
• ADA Service Overview Booklet
• Service change announcements
• Notification of free language services – New print and web-based content
• Maps and schedules, rider information, ADA service information, news and event announcements are all translated into Spanish on Whitewater Valley Regional Transit’s website whitewatervalleyregionaltransit.com
• Service Complaint Forms in Spanish
_INDOT_Section_5310-5311_Title_VI_Plan Updated Complaint Form 01182022 Spanish
