Title VI Plan For the Federal Transit Administration And State Department of Transportation

December 31, 2018 – December 31, 2021 Table of Contents

Introduction ...... 3

Title VI Complaint Procedures ...... 4 - 5

Record of Title VI or Other Civil Rights Investigations, complaints, or lawsuits ...... 5

Limited English Proficiency Outreach Plan ...... 5 - 7

Notification of Beneficiaries of Title VI Rights ...... 8

Analysis of Construction Projects ...... 8

Summary of Public Participation Efforts ...... 8 - 9

Attachment A – Title VI Non-Discrimination Policy Statement ...10

Attachment B -Title VI Complaint Form...... 11 - 12

Attachment C – Public Participation Plan ...... 13 - 16

Attachment D -Public Outreach Efforts, 2014 - 2018...... 17

Attachment E – Title VI Notification of Complaint Procedures ...18 - 19

Attachment F – Public Participation Notification Policy ...... 20 - 21

Attachment G – 2015 Regional Population Map...... 22*

Attachment I – Service Standards ...... 23 - 24

Attachment J – Service Policies ...... 25 - 26

Attachment K – Table of Advisory Committee Membership...... 27

*data source: Chelan-Douglas Transportation Council 2015 Demographic Profile

Link Transit Title VI Plan, 2018 - 2021 Page 2 Introduction Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color and national origin in programs and activities receiving Federal financial assistance.

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

Title VI Mission Link Transit’s Title VI Program’s primary goal is to ensure all management, staff, contractors, local agencies, and service beneficiaries are aware of the provisions of Title VI and the responsibilities associated with Title VI of the Civil Rights Act of 1964.

Link’s Title VI Program is responsible for providing leadership, direction and policy to ensure compliance with Title VI and Environmental Justice and Limited English Proficiency principles and to ensure that social impacts to communities and people are recognized and considered throughout the transportation planning and decision- making process. Please do not hesitate to call our office for further assistance.

What is Title VI? Title VI of the Civil Rights Act of 1964 is the main legal authority for the Office of Equal Opportunity, External Civil Rights nondiscrimination programs. Title VI prohibits discrimination on the basis of race, color, or national origin in programs or activities receiving federal financial assistance. Once an agency accepts federal funds, all of its programs and activities are covered, regardless of their funding source. Related statutes and Presidential Executive Orders under the umbrella of Title VI address Environmental Justice (EJ) in minority and low-income populations, and services to those individuals with Limited English Proficiency (LEP), women and the disabled.

What does this mean? Link Transit cannot, on the basis of race, color, national origin or sex, either directly or through contractual means: • Deny program services, aids or benefits; • Provide a different service, aid or benefit, or provide them in a manner different than what is provided to others; • Segregate or separately treat individuals in any matter related to the receipt of any service, aid, or benefit.

This plan documents Link Transit’s effort to comply with these requirements.

TITLE VI COMPLAINT PROCEDURES

Link Transit is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by Title VI in Federal Transit Administration (FTA) Circular 4702.1.B. If you believe you have been subjected to discrimination under Title VI, you may file a complaint.

In 2017, Link Transit participated in triennial federal review, during which time Link’s Title VI complain form was review with recommendation to modify the categories of reported discrimination, separating the “race and/or color” to two distinct options of “race” and “color”. The recommendation to include Spanish language in the document rather than providing a separate Spanish language document was also implemented.

Link Transit Title VI Plan, 2018 - 2021 Page 3 How to file a Title VI Complaint You may file a signed, written complaint up to one hundred and eighty (180) days from the date of alleged discrimination. The complaint should include the following information:

• Your name, mailing address, and contact information (i.e., telephone number, email address, etc.) • How, when, where and why you believe you were discriminated against. Include the location, names and contact information of any witnesses. • Other information that you deem significant to the report.

A form is available at Link Transit which may be completed for this purpose. (See “Attachment B”.)

The complaint may be filed in writing with Link Transit at the following address:

Link Transit Title VI Coordinator 2700 Euclid Avenue Wenatchee, WA 98801 By phone: 509/664.7620 By Facsimile: 509/664.6486

NOTE: Link Transit 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 to the Title VI Coordinator as soon as possible, but no later than 180 days from the alleged date of discrimination.

What happens to my complaint after it is submitted to Link Transit? All complaints alleging discrimination based on race, color or national origin in a service or benefit provided by Link Transit will be directly addressed by Link Transit. Link Transit shall also provide appropriate assistance to complainants, including those persons with disabilities, or who are limited in their ability to communicate in English. Additionally, Link Transit shall make every effort to address all complaints in an expeditious and thorough manner.

In instances where additional information is needed for investigation of the complaint, Link Transit will contact the complainant in writing. 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.

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

How will I be notified of the outcome of my complaint? Link Transit will send a final written response to the complainant and advise the complainant of his or her right to: 1) appeal within 7 calendar days of receipt of the final written decision from Link Transit, and/or, 2) file a complaint externally with the U.S. Department of Transportation and/or the Federal Transit Administration.

Every effort will be made to respond to Title VI complaints within 60 working days of receipt of such complaints, if not sooner.

Link Transit Title VI Plan, 2018 - 2021 Page 4 In addition to the complaint process described above, a complainant may file a Title VI complaint with the following offices:

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

RECORD OF TITLE VI OR OTHER CIVIL RIGHTS, INVESTIGATIONS, COMPLAINTS OR LAWSUITS

To date, there have been no Title VI investigations, complaints or lawsuits.

• In 2010 a claim of religious discrimination was made to the Human Rights Commission by an applicant for the position of Coach Operator. The complainant alleged that he was subjected to discrimination based on creed when Link Transit failed to hire him and accommodate his religious conviction. The conclusion reached by the Human Rights Commission was that there was no reasonable cause with this claim.

• In 2013 a claim of race discrimination was made to the Equal Employment Opportunity Office by a former employee. The complainant alleged that he was subject to discrimination when he was terminated, disciplined and singled out because of his race. The EEOC ruled that based upon its investigation they were unable to conclude that the information obtained established violations of the statutes.

LIMITED ENGLISH PROFICIENCY (LEP) PLAN

Link Transit is committed to overcoming language barriers by implementing consistent standards of language assistance across its service area.

The United States is home to millions of national origin minority individuals who are Limited English Proficiency (LEP). That is, their primary language is not English and they cannot speak, read, write or understand the English language at a level that permits them to interact effectively with recipients of Federal financial assistance. Because of language differences and the inability to effectively speak or understand English, persons with LEP may be subject to exclusion from programs or activities, experience delays or denials of services. These individuals may be entitled to language assistance with respect to a particular type of service. The federal government and those receiving assistance from the federal government must take reasonable steps to ensure that LEP persons have meaningful access to the programs, services, and information those entities provide. This will require agencies to establish creative solutions to address the needs of this ever-growing population of individuals, for whom English is not their primary language.

Analysis of Factors

No. 1: The number or proportion of LEP persons in the service area.

Link Transit Title VI Plan, 2018 - 2021 Page 5 According to the 2017 American Community Survey, the total population for Chelan County 77,800 is and Douglas County is 41,945 for a combined population of 119,745 in the two counties. English is spoken by 75.0% of Chelan County and 71.8% of Douglas County. Overwhelmingly, Spanish speaking in the household represents 23.2% of the non-English speaking Chelan County and 25.9% of the non-English speaking Douglas County.

Of those non-English speaking residents 40.0% also speak English less than very well in Chelan County. Likewise 46.1% speak English less than very well in Douglas County.

Other languages spoken in the two county area include Indo-European languages 0.08%, Asian and Pacific Island 0.3% (228) and all other languages 0.4%in Chelan County. Likewise in Douglas County Indo-European languages 0.8% (301), Asian and Pacific Island languages 0.5%and all other languages 0.2%.

Link Transit’s jurisdiction covers two broad areas: Chelan and Douglas Counties which are largely English speaking. The vast majority of individuals wishing to ride transit are proficient in English, so that LEP services are not normally required.

No information was available regarding the percentage of bilingual residents of the counties.

No. 2. The frequency with which LEP individuals come into contact with the service. All contacts with Link Transit are made through its offices located in Wenatchee, WA. We serve LEP persons daily via our , contracted services, and demand response services. Guest Services Representatives speak Spanish and translate in person or over the phone a total of approximately 10-12 times a day.

No. 3: The nature and importance of service provided by Link Transit. Link Transit provides important transit services to the public through its fixed route, paratransit programs as well as bilingual (English/Spanish) Mobility Management and Travel Training services.

No. 4. The resources available to the recipient of the federal funds to assure meaningful access to the service by LEP persons. Link Transit’s current in-house language capabilities are Spanish and English. Experienced staff are fluent in these languages. They serve as interpreters as needed on those occasions when a person with limited English proficiency contacts the transit system. The transit system also recognizes the need to have language services in other languages besides Spanish and has implemented a Language Line service to address that need. Additionally, Link Transit has an outreach program where Spanish-speaking customers are taught how to ride the through training and one-on-one assistance.

• Link Transit provides most publications, including schedules and posted Rider Alerts, in both English and Spanish. • Special notices of public meetings and other events are made available in Spanish. • Link Transit budgets yearly for Language Line services.

Implementation Plan Link Transit identifies LEP persons in the service area by ridership, telephone contact counts, board surveys, and planning software based on census data and implements language services according to the published plan.

When possible, Link Transit seeks to hire guest services representatives that are bilingual (Spanish/English). Our Executive Assistant/Clerk of the Board is bilingual and is made available to assist with Spanish speaking customers.

Employees in several departments have representatives that are trained on the Language Line. Timetables in bus schedules and rider alerts are printed in English and Spanish. Link Transit Title VI Plan, 2018 - 2021 Page 6 Link Transit’s Title VI policy and a Complaint Form are available on our website in both English and Spanish. Beginning in 2009, all printed maps and schedules contain Title VI language, that notice is also printed in both English and Spanish. Link posts flyers on the bus as the information changes. Bilingual employees also assist our Marketing Coordinator when visiting employers and businesses in the community to educate individuals about the services we provide. Link also has the assistance from Spanish speaking employees when promoting new services such as the Eco Pass program to large employers with a LEP/Spanish speaking demographic.

In order to comply with 49 CFR 21.9(d), Link Transit and its sub-recipients must provide information to beneficiaries regarding their Title VI obligations and inform beneficiaries of the protections against discrimination afforded them by Title VI. LINK TRANSIT has established a statement of rights and a policy statement. At this time Link Transit has no sub recipients.

Link Transit Title VI Plan, 2018 - 2021 Page 7 NOTIFYING BENEFICIARIES OF THEIR RIGHTS UNDER TITLE VI

1. Our website includes our Title VI policy and complaint form. The website also states:

LINK TRANSIT does not discriminate on the basis of race, color or national origin.

LINK TRANSIT no descrimina en base de raza, color o origen nacional.

2. Our Title VI policy and complaint form are also posted at our Operations and Maintenance Facility (located at 2700 Euclid Avenue, Wenatchee, WA) and at our intermodal center, Columbia Station (located at 300 South Columbia Street, Wenatchee, WA). Individuals who believe they have been discriminated against may request a complaint form from our Guest Services staff at Columbia Station or from our Receptionist at our Operations Base.

3. If information is needed in another language, contact the Title VI Coordinator at 509-664-7608.

ANALYSIS OF CONSTRUCTION PROJECTS

Over the last three years Link Transit has not completed a construction project requiring an environmental assessment (EA) or environmental impact statement (EIS).

INCLUSIVE PUBLIC PARTICIPATION

Community Outreach is a requirement of Title VI. Recipients and sub-recipients shall seek out and consider the viewpoints of minority and low-income populations in the course of conducting public outreach. Recipients have wide latitude to determine what specific measures are most appropriate and should make this determination based on the composition of the affected population, the public involvement process, and the resources of Link Transit. Link Transit has engaged the public in its planning and decision-making processes, as well as its marketing and outreach activities. Link Transit has developed a comprehensive Public Participation Plan (PPP) which outlines the goals and objectives for public participation (See Attachment C). Between 2014-2018, the public was invited to participate in these activities (See Attachment D):

Transit Development Plan (TDP). The Transit Development Plan is a requirement of the Washington State Legislature. The Plan is prepared by the independent transit properties and submitted yearly into the State Department of Transportation. A summary document with information such as the size of the fleet, costs, revenue, service revenue hours, revenue miles, expense and capital expenditures is provided for public review. Public hearings are held to obtain comments on the TDP.

Transit Improvement Plan (TIP). The Transit Improvement Plan is prepared by the cities and counties. The TIP is a planning document that addresses capital projects and improvement projects in cities and counties. All TIPs from local jurisdictions (counties and cities) as well as the Link’s TDP are collected into a Regional TIP (RTIP), which is required by the federal government. The TIP is only for capital projects and represents the capital section of the Transit Development Plan, and projects must be listed in the RTIP to be funded.

Link Transit Title VI Plan, 2018 - 2021 Page 8 Public hearings are held to obtain comments from the public on the RTIP.

Board Meetings. The Board of Directors holds monthly meetings, which are noticed and opened to the public.

Public Meetings. When new service is proposed information is disseminated to the neighborhoods affected and public meetings are scheduled.

Major Service Change. The public was included in many public meetings regarding potential service changes to invite their comment. At each of these meetings Spanish speaking employees were in attendance to assist individuals who do not speak English.

Fare Increase. Public hearings are set when a fare increase is proposed by Link Transit. At each of these meetings Spanish speaking employees were in attendance to assist individuals who do not speak English.

Travel Training Class. Link Transit has developed a travel training program to reach out to community groups (senior centers, senior facilities, and the disabled community) to conduct travel training classes. Since 2011 we have been able to expand Travel Training to Spanish speaking guests by cross training a Spanish speaking Guest Services Representative to assist with Travel Training. Travel Training classes are ongoing.

Customer Complaint Process. Citizens may call Link’s Guest Services Department at 509/662.1155 to lodge a complaint or comment. All complaints/comments are input into a database and distributed to the relevant manager who researches the complaint and responds back to the citizen.

General Awareness and Phone Surveys. Link conducts onboard rider and general awareness surveys. Most recently in 2016 and 2017, Link Transit engaged in a multi-part public survey for community input regarding future planning and service to potentially expand Link’s level of service. These surveys were conducted in person on Link buses and Link facilities, were made available in English/Spanish, advertised in local news media and social media platforms, mailed discrete survey response documents to each household in Link’s public transportation benefit area, and developed a website for response. Origin/Destination and ridership surveys, as well as public surveys are conducted by Link staff and hired survey takers, to assist Link Transit in service planning.

Bilingual Outreach. Link Transit’s Guest Services group provides Spanish-speaking guests with information on public transit services in Spanish. Guest Services assistance is utilized in outreach programs and offered for programs and public meetings.

Link Transit Title VI Plan, 2018 - 2021 Page 9 ATTACHMENT A: ATTACHMENT B: 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 in order to assist us in processing your complaint and sent it to the name listed below:

Español: Título VI de la ley de derechos civiles de 1964 requiere que "ninguna persona en los Estados Unidos, por razón de raza, color u origen nacional, se excluirá de la participación en, ser negada los beneficios de o ser sujeta a discriminación bajo cualquier programa o actividad recibir asistencia financiera federal". Si usted siente que ha discriminado en los servicios de tránsito, por favor proporcione la siguiente información para ayudarnos a procesar su queja y envió al nombre que se enumeran a continuación:

Link Transit Title VI Coordinator / Coordinador del Titulo VI 2700 Euclid Avenue Wenatchee, WA 98801 509-664-7620 509-664-6486 (fax)

Please print clearly: Favor de escribir claramente

Name: ______Nombre

Address: Domicilio

City, State, Zip Code: ______Ciudad, Estado, Código postal

Telephone Number: ______(home)______(cell)

Número Telefónico: (hogar) (cel.)

Person discriminated against: ______Persona discriminada

Address of person discriminated against: Domicilio de Persona discriminada

City, State, Zip Code: Ciudad, Estado, Código Postal

Please indicate why you believe the discrimination occurred: Sírvanse indicar por qué cree que la discriminación ha ocurrido:

______Race / Raza ______Color / Color ______National Origin / Orígenes Nacionales ______Income / Ingreso ______Other / Otro

1 What was the date of the alleged discrimination? ______¿Cuál fue la fecha de la presunta discriminación?

Where did the alleged discrimination take place? ______¿Dónde ocurrió la supuesta discriminación?

Please describe the circumstances as you saw it: ______Por favor describa las circunstancias como Ud. lo vio:

______

______

______

______

Please list any and all witnesses’ names and phone numbers: Sírvase proporcionar todos los testigos con los nombres y números de teléfono: ______

______

______

______

What type of corrective action would you like to see taken? ¿Qué tipo de medidas correctivas le gustaría ver? ______

______

______

Please attach any documents you have which support the allegation. Then date and sign this form and send to the Title VI Coordinator at the address listed on page 1 of this document. Por favor de adjuntar todos los documentos que usted tiene, los que sostienen la acusación. A continuación, favor de apuntar la fecha y firmar el formulario y enviarlo al Coordinador del Título VI a la dirección que aparece en la página numero1 de este documento.

______Your signature Su firma

______Print name Nombre imprimido

______Date Fecha

2 ATTACHMENT C: Link Transit Public Participation Plan

Purpose The purpose of this Public Participation Plan (PPP) is to establish procedures that encourage the full participation of all citizens in the Link Transit service area, including but not limited to low income and minority individuals, and those with limited English proficiency. While traditional means of soliciting public involvement may not reach such individuals, or might not allow for meaningful avenues of input, the intent of this effort is to take reasonable actions throughout the planning process to provide opportunities for historically under-served populations to participate.

This document will lay out procedures to provide opportunities for all area citizens to participate in the development of short and long term plans for the Link Transit system. Where appropriate, Link Transit will make improvements to its public participation system.

A notice will be posted in local newspapers, noting the existence of this public participation plan and a copy will be sent, at a minimum, to the stakeholders identified in this document.

Goals and Objectives for the Public Participation Plan

The goal of the PPP is to offer opportunities for the engagement of all citizens of Link Transit’s service area to participate in the development of short and long term plans.

In support of this goal, our objectives are:

• To determine what non-English languages and other cultural barriers exist to public participation within Link Transit’s service area. • To provide a general notification of meetings, particularly forums for public input, in a manner that is understandable to all populations in the area. • To hold meetings in locations which are accessible and reasonably welcoming to all area residents, including, but not limited to, low-income and minority members of the public. • To provide avenues for a two-way flow of information and input from populations which are not likely to attend meetings. • To provide a framework of actions appropriate to various types of plans and programs, as well as amendments or alterations to any such plan or program. • To use various illustrative visualization techniques to convey the information including but not limited to charts, graphs, photos, maps and the internet.

Identification of Stakeholders Stakeholders are those who are either directly, or indirectly, affected by a plan, or the recommendations of that plan. Those who may be adversely affected, or who may be denied the benefit of a plan’s recommendation(s) are of particular interest in the identification of specific stakeholders. Stakeholders are broken down into several groups: general citizens, minority and low income persons, public agencies, and private organizations and businesses.

Some of the techniques that can be used to engage the general population are public notices of meetings in local newspapers, open house format public information meetings in locations such as local grocery stores, etc. Staff will also continue to utilize onboard surveys, focus groups, use of local media and the internet platforms to encourage participation from the public.

Minorities: Other than Hispanic, minority populations make up less than 2 percent of the population in Link Transit’s service area. Hispanics make up the largest minority, with an average of 27.25% of the population of

Link Transit Title VI Plan, 2018 - 2021 Page 13 each county we serve. Black and Asians make up 0.2% and 0.75% respectively. American Indians and Pacific Islanders and others represent less than ½ percent each.

Engaging minority, and low-English proficiency (LEP) populations can be challenging. Language and cultural differences may not be compatible with the more traditional means of engaging the public in the planning process. Link Transit has made reasonable efforts to engage minority populations using non-English media such as radio and Spanish-language newspapers. In the past we have had representatives from the local Hispanic Chamber of Commerce on our Citizens Advisory Committee and reached out through local churches to spread notices of public hearings to Spanish speaking members of the congregation. Focus groups have, and will, continue to be used in some situations to garner input from specific portions of the population. We provide in house translation services, utilize the services of a language line and offer Travel Training services with Spanish speaking employees.

We offer assistance in the event an individual would need alternative language interpretation including sign language. To date, we have not been requested to provide this service.

Chelan County* Category Number Percent Population Total 72,453 100 White 51,202 70.7 Black 177 0.2 American Indian/Alaskan 514 0.7 Asian 570 0.8 Hawaiian/Pacific Islander 89 0.1 Other 76 0.1 Two or More 1,112 1.5 Hispanic 18,713 25.8

Douglas County* Category Number Percent Population Total 38,431 100 White 26,070 67.8 Black 85 0.2 American Indian/Alaskan 293 0.8 Asian 269 0.7 Hawaiian/Pacific Islander 51 0.1 Other 52 0.1 Two or More 598 1.6 Hispanic 11,013 28.7 *2010 Demographic Profile Data (last count)

Low-Income: The 2010 census listed the per capita income in 2009 for Chelan County as $23,339. The median household income was $48,086. The percentage of persons living below the poverty level was 13%.

In Douglas County the per capita income was $22,522. The median household income was $47,430. The percentage of persons living below the poverty level was 14.6%

While low-income individuals may have access to all of the traditional means of public involvement discussed earlier in the discussion of “general citizens” they may be less likely to become involved or offer input. Some methods of gaining input either directly or indirectly from this portion of the population include focus groups, on- board surveys and involvement of agencies who work with low-income individuals and families such as the local employment offices, housing groups and welfare providers. Link Transit Title VI Plan, 2018 - 2021 Page 14 Public Agencies: Public agencies can provide valuable input to the planning process. Pertinent public agencies include those that have clients who fall into under-represented populations, including but not limited to minorities, low-income and limited English proficiency households. All these agencies have insight into the transportation needs of their clients and are useful partners in overcoming barriers that may not be understood by professionals dealing more directly with the provision of services.

Private Organizations and Businesses: Private organizations and business offer a number of perspectives that are valuable to our planning processes. We have extensive contact with service providers who work closely with the developmentally disabled and elderly populations who often times cross over into those in the low-income, minority and limited English proficiency demographic.

In the past one of the most successful ways for Link Transit to participate with private organizations and businesses were through our Citizens Advisory Committee. Participation in the LTAC waned during 2012 and that group was discontinued in 2013. We are currently in the process of creating a “Transportation Coalition” as part of our Human Services Transportation Planning effort. Link Transit also has the ability to periodically establish temporary committees, work groups, task forces or advisory boards to assist in the development of changes and implementation of plans. Link will make an effort to ensure that these committees include a variety of community representatives, business leaders, representatives from diverse populations and advocates.

Outreach Efforts Link Transit has board approved public participation/public notification policies. (See Attachment F) In addition to the processes set out in this policy, staff will use the following techniques during its planning studies as deemed appropriate by staff.  Presentations to professional, citizen and other organizations  Articles in community newspapers  Interviews with local radio stations (both English and Spanish speaking)  Press releases and meetings with local media representatives  Information conversations with individuals and small groups  Interviews with individuals who are or may be affected by proposed plans  User and non-user surveys  Use of illustrative visualization techniques to convey the information including but not limited to, charts, graphs, photos, maps and the internet.

During any planning process the public is invited to contact Link Transit with comments and/or to request additional information. Requests can be made via telephone by contact Link Transit Guest Services at 509-662- 1155 or by contacting our website at www.linktransit.com Comments will be collected, documented and presented to the Link Transit Board of Directors.

Link Transit Public Participation Contact List Aging & Adult Care of Central Washington Wenatchee School District Homeless Family Advocate Program Wenatchee School District Wenatchee Downtown Association Wenatchee WorkSource (Employment Development) Chelan-Douglas Regional Services Network Washington Growers Clearing House Chelan-Douglas Housing Authority Chelan Chamber of Commerce Wenatchee Valley Chamber of Commerce Leavenworth Chamber of Commerce Entiat Chamber of Commerce

Link Transit Title VI Plan, 2018 - 2021 Page 15 Cashmere Chamber of Commerce North Central Washington (NCW) Hispanic Chamber of Commerce Lake Chelan Community Hospital, Chelan, WA Cascade Medical Center, Leavenworth, WA Central Washington Hospital, Wenatchee, WA Wenatchee Valley Medical Center & Hospital, Wenatchee, WA Wenatchee Police Department East Wenatchee Police Department Chelan County Sheriff Department Douglas County Sheriff Department Lilac Services for the Blind in NCW Mission Vista (programs for the disabled) Chelan-Douglas Developmental Disabilities Wenatchee Valley Transportation Council (MPO & RTPO offices) Local City & County Clerk Offices: Chelan County; Douglas County; City of Chelan; city of Leavenworth; City of Cashmere; City of Entiat; Town of Waterville; City of Wenatchee; City of Rock Island and City of East Wenatchee Wenatchee Valley Skill Source (Job Training) Wenatchee Valley College Wenatchee Valley Technical Skills Training Center Port of Chelan County (Economic Development) Port of Douglas County (Economic Development) Wenatchee Branch Department of Social and Health Services Wenatchee Valley Traffic Association (Trucking Industry) Wenatchee Valley Mall Valley North Mall

Link Transit Title VI Plan, 2018 - 2021 Page 16 Attachment D: Record of Link Transit Public Hearings 2014-2018

2014 • April 15, 2014: Public Hearing on Proposed Minor Service Improvements for 2014 Resolution 2014-05 • August 19, 2014: Public Hearing on Link Transit’s Six-Year Development Plan (TDP) 2014-2019 & 2015 Program of Projects (POP) Resolution 2014-08 • November 18, 2014: Public Hearing on Link Transit’s Title VI Program & Update Resolution 2014-11 • November 18, 2014: Public Hearing for Link Transit’s 2015 Operating & Capital Budget Resolution 2014-12

2015 • May 19, 2015: Public Hearing on Link Transit’s Equal Employment Opportunity (EEO) Program & Plan Resolution 2015-06 • May 19, 2015: Public Hearing on Link Transit’s Paratransit Policies & Procedures 2015-07 • May 19, 2015: Public Hearing on Link Transit’s Fare Policy for Trolley/Shuttle Routes 2015-08 • August 18, 2015: Public Hearing on Link Transit’s Six-Year Development Plan (TDP) 2015-2020 & 2016 Program of Projects (POP) Resolution 2015-08 • November 17, 2015: Public Hearing for Link Transit’s 2016 Operating & Capital Budget Resolution 2015-10

2016 • August 16, 2016: Public Hearing on Link Transit’s Six-Year Development Plan (TDP) 2016-2021 & 2017 Program of Projects (POP) Resolution 2016-05 • November 15, 2016: Public Hearing for Link Transit’s 2017 Operating & Capital Budget Resolution 2016-06

2017 • August 15, 2017: Public Hearing on Link Transit’s Six-Year Development Plan (TDP) 2017-2022 & 2018 Program of Projects (POP) Resolution 2017-07 • November 21, 2017: Public Hearing for Link Transit’s 2018 Operating & Capital Budget Resolution 2017-08

2018 • March 20, 2018: Public Hearing on Public Records Disclosure Policy Amendment Related to the Costs Providing Copies of Public Records per RCW 42.56.120 • April 17, 2018: Public Hearing on Link Transit’s Proposed July 2018 Service Improvement Plan • August 21, 2018: Public Hearing on Link Transit’s Six-Year Development Plan (TDP) 2018-2023 & 2019 Program of Projects (POP) Resolution 2018-12 • November 20 2018: Public Hearing for Link Transit’s 2019 Operating & Capital Budget Resolution 2018-04 ATTACHMENT E:

TITLE VI NOTICATION OF COMPLAINT PROCEDURES

What is Title VI of the Civil Rights Act of 1964? Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color and national origin in programs and activities receiving Federal financial assistance.

Link Transit is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by Title VI in Federal Transit Administration (FTA) Circular 4702.1.A If you believe you have been subjected to discrimination under Title VI, you may file a complaint.

How to file a Title VI Complaint? You may file a signed, written complaint up to one hundred and eighty (180) days from the date of alleged discrimination. The complaint should include the following information:

• Your name, mailing address, and how to contact you (i.e., telephone number, email address, etc.) • How, when, where and why you believe you were discriminated against. Include the location, names and contact information of any witnesses. • Other information that you deem significant

The complaint may be filed in writing with Link Transit at the following address:

Link Transit, Title VI Coordinator 2700 Euclid Avenue Wenatchee, WA 98801 By phone: 509-664-7620 or 1-509-662-1155 By Facsimile: 509-664-6486

NOTE: Link Transit 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 to the Title VI Coordinator as soon as possible, but no later than 180 days from the alleged date of discrimination. Please use this address to request additional information about Title VI.

What happens to my complaint after it is submitted to Link Transit? All complaints alleging discrimination based on race, color or national origin in a service or benefit provided by Link Transit will be directly addressed by Link Transit. Link Transit shall also provide appropriate assistance to complainants, including those persons with disabilities, or who are limited in their ability to communicate in English. Additionally, Link Transit shall make every effort to address all complaints in an expeditious and thorough manner.

In instances where additional information is needed for investigation of the complaint, Link Transit will contact the complainant in writing. Please note that in responding to any requests for additional information, a

Link Transit Title VI Plan, 2018 - 2021 Page 18 complainant’s failure to provide the requested information may result in the administrative closure of the complaint.

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

How will I be notified of the outcome of my complaint? Link Transit will send a final written response to the complainant and advise the complainant of his or her right to 1) appeal within 7 calendar days of receipt of the final written decision from Link Transit, and/or 2) file a complaint externally with the U.S. Department of Transportation and/or the Federal Transit Administration. Every effort will be made to respond to Title VI complaints within 60 working days of receipt of such complaints, if not sooner.

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

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

Link Transit Title VI Plan, 2018 - 2021 Page 19 ATTACHMENT F:

PUBLIC PARTICIPATION AND NOTIFICATION POLICY

Policy Level: Board Department: Executive Effective Date: January 17, 2012 Revision Date(s): June 18, 2018 Submitted by: Richard DeRock, General Manager

Approved by: Resolution 2012-01, Revisions: Resolution 2018-11

Policy Statement & Purpose It is the policy of Link Transit to maintain an open and participative process and to consider public comment prior to a fare increase, a major service change, short and/or long term planning programs, as well as Link Transit’s Title VI Plan, Disadvantaged Business Enterprise (DBE) Plan, and Americans with Disabilities Act (ADA) Plan. Public input is solicited while proposals are under consideration. The public are notified prior to the implementation of any recommendations.

It is the intent of Link Transit to comply with the Federal Public Comment on Fare and Services Changes rules (FTA Circular 9030.1A, Chapter V,5(0)), and public participation requirements under Title VI, DBE, and ADA regulations.

Definitions For the purpose of the Federal Service and Fare Change comment requirement, Link Transit’s definition of a Service Change is as follows: A change of 25% or more in revenue service hours or route structures. The definition of a Fare Increase is as follows: An increase of any amount over the existing base fare.

Procedures In order to insure maximum opportunity for community input and involvement in the decision making process, Link Transit adheres to the following procedures:

1. Provide a 14-day or appropriate advance notice of a public hearing to consider the proposal in The Wenatchee World, Douglas County Empire Press, Leavenworth Echo, Chelan Mirror, Cashmere Valley Record, El Mundo and other publications, as deemed appropriate by the General Manager.

2. Mail notification of public hearing and availability of specific proposal to community organizations that represent and service the consumers, and regional radio stations.

3. Provide customer information regarding the fare increase/service change proposal and process for public comment on board service vehicles.

4. Post notification of public hearing and the specifics of the proposal on the Agency website.

5. Link Transit staff has the ability to periodically establish temporary committees, work groups, task forces or advisory boards to assist with the review of any fare increase proposals, changes in service, as well as short or long term plans and programs, including the merits of such proposals. These ad

Link Transit Title VI Plan, 2018 - 2021 Page 20 hoc committees will represent the community and organizations with an interest in public transportation, prior to finalizing recommendations.

6. Conduct regional open house meetings, and/or focus groups to solicit public input and consider recommendations to the proposed service changes or short or long term planning programs. The open house meetings will include a staff presentation of proposed plans, service changes and/or fare increases. It will also include an opportunity for input and comment from any interested individuals in attendance. Records of the open house meetings are retained by Link Transit.

7. Following the conclusion of the open house meetings and/or focus groups, the Link Transit Board of Directors will conduct a formal public hearing to consider both the staff recommendations and the public comment. The final decision regarding any service change, fare increase, or Plan update or change will be made by a simple majority vote of the Board of Directors. Where possible, the effective date of the service change or fare increase shall be 30 days after the date of the public hearing.

Documentation Records of the public participation process will be maintained by Link Transit. Documentation of the process will include, but are not limited to:

1. Notice of the Open House 2. Minutes of the Open House 3. Customer service information on board vehicles 4. Record of outreach conducted 5. Public comment received 6. Minutes of the Public Hearing

Link Transit Title VI Plan, 2018 - 2021 Page 21

2 page 2 (Source: Chelan-Douglas 2015 Demographic Profile, CDTC)

Source: 2010 U.S. Census

Map 1: Concentrations of Minority Populations in the Chelan-Douglas Metropolitan Planning Area Link Transit Title VI Plan, 2018-2021 A TTACHMENT G: Regional Minority Population Map 15 | Chelan-Douglas Transportation Council 2015 Chelan-Douglas Demographic Profile ATTACHMENT I: Service Standards

Route Type Average Maximum Vehicle Load

40-foot Bus 55 passengers urban, 39 passengers highway (1.3 load factor) 35-foot Bus 48 passengers urban, 30 passengers highway (1.4 load factor) 30-foot Bus 40 passengers urban, 28 passengers highway (1.3 load factor) International Aeroelite 26 passengers urban, 20 passengers highway (1.3 load factor) Ford Supreme 21 passengers urban, 16 passengers highway (1.3 load factor) Dodge Sprinter 17 passengers urban, 13 passengers highway (1.3 load factor)

Link Transit Vehicle Headways Service Span (by Route Type) Service Frequency (in minutes) Regional Urban Service Trolleys Small DART Route City Routes Weekdays 4:30 a.m. – 9:50 a.m. ~:30 10:00 a.m. – 3:30 p.m. :60/:90 3:30 p.m. – 8:10 p.m. ~:30 6:00 a.m. – 9:00 p.m. :30/:60 5:30 a.m. – 10:00 a.m. :30 10:00 a.m. – 6:30 p.m. :15 5:30 a.m. – 7:30 p.m. >1:30 Varies* *DART is demand based service Saturday 7:15 a.m. – 6:00 p.m. >2:00 7:30 a.m. – 5:30 p.m. :60 :30 ------Service Minimums As a standard, Link’s minimum span of fixed route service operation is as follows: Weekdays: 6:00 a.m. – 7:00 p.m. Saturdays: 7:30 a.m. – 5:30 p.m.

Service operates on regional lines about every 30 minutes during AM and PM peak operating periods. During off peak service hours, service runs hourly between Leavenworth and Wenatchee. On our routes to Chelan, day baseline service departs at intervals of one hour and fifteen minutes to one hour and thirty minutes based on travel time and vehicle assignments.

On Saturdays, Link Transit operates minimal service to these communities, providing 4 round trips to Chelan and five round trips to Leavenworth.

Urban service in the Greater Wenatchee area receives thirty minute headways on all fixed routes Monday through Friday. Service begins at 5:30 AM and ends at approximately 9:00 PM Monday through Friday.

Saturday urban service operates at 60 minute headways in Wenatchee and East Wenatchee. On Saturdays, Link Transit operates five fixed routes, beginning service at 7:30 AM and ends at 5:30 PM.

Urban Trolleys operate 15 minute headways between 10 AM and 6 PM Monday through Friday. Saturday Trolley service begins operation at 10 AM and operates 30 minute headways until 5:30 PM.

Link Transit Title VI Plan, 2018 - 2021 Page 23 Route Deviated service is demand based routed service. Service frequency is based on population density and varies by route. Link Transit currently operates route deviated service to the communities of Rock Island, Malaga, Waterville, Ardenvoir, Manson and Lake Wenatchee. This service is available Monday through Friday only.

DART service typically serves areas of low demand where fixed routed service is not feasible. This service is available to anyone, regardless of age or disability, and is utilized by booking the individuals trip 24 hours in advance. This service is currently available Monday through Friday.

On Time Performance Link Transit monitors on time performance on all fixed routes at all time points. Link Transits goal for fixed routed service is that ninety-five (95) percent of the Link Transits fixed route vehicles will travel through all published time points and complete their established runs no more than 5 minutes late in comparison to the established schedule/published timetables. The minimum standard for on time performance is currently set at 85%.

Performance Measures Performance of the Link system is measured differently for system-wide performance and the performance of individual routes. At the system-wide level, the ridership per hour, hours of service and subsidy per passenger are the three key indicators. These measures show how effective the service is at attracting riders to the system, how much service is provided, and how cost effective the service is based on ridership. These measures must be considered together, with the goal to strike a balance between them, as improvements in one measure can often come at the expense of performance in another.

The performance of individual routes is assessed on the basis of passenger boardings per vehicle-hour, meaning the total number of passengers, plus transfers, divided by the total number of vehicle-hours in service. Using boardings (including transfers) gives credit to a route that may carry an above average number of transferring passengers, which is generally a vital role in the performance of an effective transit network.

The transit services are scheduled and operated according to the following key performance indicators.

Performance targets are assessed as part of a continuous quality improvement framework, and will be adjusted upward when consistently met.

Establishing Performance Levels Link Transit performance levels are established by route category and will be evaluated and adjusted upward as performance levels are met.

Urban Fixed Route Services All routes: Averaging 18 passengers per service hour, with a minimum average of 9 boardings per hour.

Regional Fixed Routes All routes: Averaging 13 passengers per hour, with a minimum average of 8 boardings per hour.

Rural Flex Route Deviated Services All routes: Averaging 10 passengers per service hour, with a minimum average of 5 boardings per hour.

Urban Trolleys All routes: Averaging 18 passengers per hour, with a minimum average of 12 boardings per hour.

DART Averaging 5 passengers per hour with a minimum average of 3.5 boardings per hour.

Link Transit Title VI Plan, 2018 - 2021 Page 24 ATTACHMENT J: Service Policies

Link Transit will consider new or revised routes to serve residents, places of work, middle and high schools, major shopping centers and public facilities in the urban, regional and small communities that are beyond the maximum 3/4 mile walking distances.

Vehicle Loading / Vehicle Assignment Link will design its services to keep the number of passengers on its vehicles at a comfortable level, always within the limits of safety. In peak periods, this means that some passengers may be expected to stand for part of the trip. In off-peak periods, services will be designed to try to provide a seat to all off-peak customers, given the less frequent service. Where services operate on a highway, services will be planned for all riders to be seated.

Consideration is given to matching the capacity of the vehicles to the ridership levels on the route to avoid unnecessary increases in service levels. All vehicles are wheelchair lift equipped.

Our regional routes are assigned 40 foot vehicles when available. Because of the longer trip times, these vehicles are equipped with reclining seats and reading lights for passenger comfort. The larger vehicles also allow for more seating for longer trips at highway speeds.

In the urban area, vehicles are typically 30-35 feet in length. These vehicles are assigned to the urban routes because their size allows them to travel more easily within the urban environment. Some of these buses are equipped with both front and rear doors for ease of access and exit. Vehicles are assigned based on passenger load, route demand and run cut.

Vehicles with smaller passenger capacities, such as the Ford Supreme and Dodge Sprinter, are normally assigned to routes in smaller communities with lower ridership demand.

Link Transit also operates seasonal ski service to Mission Ridge. These vehicles are equipped with ski and snowboard racks. In summary, vehicle resources are assigned in an equitable fashion.

Passenger standards are calculated on the basis of an average over one hour in the peak period, at the busiest point on the route. For instance, if a service operates at 15-minute intervals, then 4 buses would pass the busiest point in an hour. The average number of passengers for these 4 buses must fall within the service standards, even though any one bus may be more crowded than the average. If the standard is consistently exceeded for the average calculation, Link Transit will consider larger vehicles for the route(s) in question, or more frequent service to improve the situation.

Passenger Amenities Bus stops should be placed at most intersections, passenger generators and transfer points subject to minimum spacing criteria. The spacing of stops should not normally be less than 700 feet in developed areas (2 blocks) and 1500 feet in underdeveloped areas (specific major trip generators may require variances in stop spacing). Currently, Links stop spacing minimum standard is 3/4 mile in urban areas. Regarding service along highway corridor, Link still authorizes flag stops where it is safe to board and deboard passengers.

Where appropriate in urban areas, Link will provide various amenities such as passenger information kiosks, benches and litter receptacles.

Amenity Criteria Passenger bus shelters: Passenger stops generating 10 or more boardings per hour Senior residences & institutional facilities if appropriate

Link Transit Title VI Plan, 2018 - 2021 Page 25 Unique exposure to inclement weather Terminals and transfer points

Passenger Information kiosks: All signed bus stops in urban areas.

Benches/ Simme-Seats: Bus stops generating 4-9 passengers per hour Bus stops near senior residences

Litter receptacles: Placed at shelters and waiting areas that may generate unusually high volumes of litter

In 2013, Link began installation of safety lighting at shelters at poorly lit areas.

Development around the major stops should be encouraged to follow transit supportive design principles – closer to the street, favor pedestrian connections, and customer friendly uses in commercial areas such as coffee shops, or passenger amenities.

Bus stops at intersections should be located in the safest position, considering traffic and street conditions. Where possible, stops should be located close to signalized intersections.

Pull outs should be considered for stops located near major trip generators, transfer points, timing points or anywhere else where a bus is likely to have an extended stop time.

Link Transit is working with local jurisdictions to insure that the area around stops should be made accessible to people with disabilities, including wheelchairs and other mobility aids. The long-term objective of Link Transit is to accommodate accessible features at all of its stops.

Locating Bus Stations/Terminals Bus terminals and minor turnaround facilities will be located at transit nodes identified as being at the end of a line and convergence of two or more corridors, where local services such as shuttles also connect.

Development around the stations and terminals should incorporate into transit-oriented development uses and design principles.

Link Transit Title VI Plan, 2018 - 2021 Page 26 ATTACHMENT K: Table Depicting Minority Representation on Committees selected by the Recipient

The Link Transit Advisory Council (LTAC) was comprised of community citizens who were appointed by the Link Transit Board of Directors to serve a minimum three (3) year term in an advisory capacity. The Mission of The LTAC is to represent the interests of the Link Transit System’s owners and guests by actively providing input on policies and issues concerning public transportation services provided by Link Transit. Policy and issues include significant areas related to public transportation in general and specifically to Link Transit, i.e. strategic planning and visioning; the system’s mission, goals and objectives; transit development plans and other service planning efforts; the agency’s budget and financial programs; capital projects and operating services.

Members are appointed by the Link Transit Board of Directors according to criteria that ensures the advisory council reflects the diversity of individuals with disabilities or their representatives, community stakeholders, local businesses, community organizations, and riders. The Committee shall consist of ten (10) to twelve (12) maximum voting members. Members are appointed to serve an initial three (3) year term, with the option for the Link Transit Board of Directors to reappoint an LTAC member to serve an additional two (2) year term for a maximum of five consecutive years of service possible.

LTAC Membership Structure

1. Persons with Disabilities 2. Business Community 3. Employment Services 4. Public Sector Senior / Disabled Services 5. Private Sector Senior / Disabled Services 6. Educational Community 7. Hispanic Community 8. Agricultural Community. 9. Other Service-Based Community Organizations / Services 10. Law Enforcement Community 11. Economic Development / Financial Community

Body Caucasian Latino African Asian Native Other American American American Population 69.25 27.25 0.2 .85 .75 1.75 Advisory 90%* 10%* 0 0 0 0 Committee *Percentages averaged for Chelan and Douglas Counties

In 2013 LTAC was disbanded due to a waning participation. The Link Transit Board of Directors is committed to maintaining community involvement through various outreach efforts designed to be responsive to the low income, minority and special needs communities.

Link Transit will develop ad-hoc advisory committees as recommended by staff or resolved by the Board of Directors, as deemed necessary to adequately survey appropriate demographic groups to review, advise and recommend relevant Link Transit actions.

Link Transit Title VI Plan, 2018 - 2021 Page 27