Resolution 2013-206 RESOLUTION No. 2013 2 6
RESOLUTION SUPERSEDING AND REPLACING RESOLUTION
NO. 2009-223, WHICH ADOPTED THE COLLIER METROPOLITAN
PLANNING ORGANIZATION'S PUBLIC INVOLVEMENT PLAN,
AND ADOPTING THE COLLIER AREA TRANSIT PUBLIC
PARTICIPATION PLAN.
WHEREAS, the Board of County Commissioners receives Federal financial assistance
from the Federal Transit Administration (FTA) and, as a condition of continuing to receive such
assistance, must comply with Title 49, section 5307 of the Code of Federal Regulations; and
WHEREAS, on October 1, 2009, the Board adopted Resolution 2009-223, which
adopted the Collier Metropolitan Planning Organization's (MPO)Public Involvement Plan; and
WHEREAS, on May 9, 2013, the Alternative Transportation Modes (ATM) Director
provided comments on the MPO's draft Public Participation Plan, specifically requesting that
amendments be made to ensure satisfaction of the requirements for the FTA Program of Projects;
and
WHEREAS, on June 14, 2013, the MPO Board adopted a revised Public Participation
Plan, which FTA later indicated needed further revision to meet its public involvement
requirements for the Program of Projects; and
WHEREAS, on July 16, 2013, ATM staff provided a draft public participation, which
includes a limited English proficiency plan (collectively, the "Public Participation Plan"), to the
Collier County Public Transit Ad Hoc Advisory Committee for review;
WHEREAS, on July 18, 2013, ATM staff placed the Public Participation Plan out for
public inspection and input for the required 45-day comment period; and
WHEREAS, on August 20, 2013, the Collier County Public Transit Ad Hoc Advisory
Committee unanimously endorsed the Collier Area Transit Public Participation Plan; and
NOW, THEREFORE BE IT RESOLVED BY THE BOARD OF COUNTY
COMMISSIONERS OF COLLIER COUNTY THAT:
1 0
The Board of County Commissioners hereby approves and adopts the Collier Area
Transit Public Participation Plan.
This Resolution adopted this 244 day of ex1,NweY, 2013 after motion, second and
majority vote in favor of passage.
A'1'1'EST BOARD OF COUNTY COMMISSIONERS
DWIGHT E. BROCK, CLERK COLLIE' I UNTY, FLORIDA
By: 1 1
L
By: a • G=• r. iller, Esq. Chairwoman
Deputy • S
Attest as to Chairman'
signature only.
Approved as to form and legality:
By:
Scott R. Teach
Deputy County Attorney
2
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Collier Area T•ansit (CAT) Public Participation Plan
Table of Contents
Acronyms 3
Purpose 4
Background 4
Public Participation Goals and Public Involvement Tools Evaluation 4
Public Outreach Techniques 6
Limited English Proficiency Plan (LEP) 6
Transit Advisory Network (TAN) 7
Website 7
Media Coverage 7
Public Hearings 7
Public Workshops 7
Brochures 7
Public Transit Ad-Hoc Advisory Committee and Advertisement Requirements 8
Public Participation Plan 8
Title VI Program 9
Fare Modifications 9
Service Reductions 9
Service Expansions 9
Disadvantaged Business Enterprise Program and Goal Setting 10
Program of Projects 10
Comprehensive Operational Analysis 10
Transit Development Plan (Major Update) 10
Transit Development Plan (Minor Update) I I
Transit Priorities 11
Appendix I 12
Limited English Proficiency Plan 12
Appendix 2 24
45 Day Public Involvement Process for Transit Plans & Programs 24
Appendix 3 26
30 Day Public Involvement Process for Transit Plans & Programs 26
Appendix 4 28
15 Day Public Involvement Process for Transit Plans & Programs 28
Collier Area Transit (CAT) Public Participation Plan
Acronyms
ATM —Alternative Transportation Modes
BCC— Board of County Commissioners
CAT—Collier Area Transit
CFR—Code of Federal Regulations
COA—Comprehensive Operational Analysis
DBE— Disadvantaged Business Enterprise
DOT— Department of Transportation
FDOT— Florida Department of Transportation
FHWA— Federal Highway Administration
FTA—Federal Transit Administration
FY— Fiscal Year
ISTEA— Intermodal Surface Transportation Efficiency Act of 1991
LEP—Limited English Proficiency
MAP-21 —Moving Ahead for Progress in the 21st Century
MPO—Metropolitan Planning Organization
POP—Program of Projects
PPP—Public Participation Plan
SAFETEA—Safe, Accountable, Flexible and Efficient Transportation Equity Act
SAFETEA-LU —Safe, Accountable, Flexible and Efficient Transportation Equity Act, a legacy for users
TAN—Transit Advisory Network
TDP—Transit Development Plan
TDSP—Transportation Disadvantaged Service Plan
TEA-21 —Transportation Equity Act for the 21st Century
Collier Area Tra nsit (CAT) Public Participation Plan
Purpose
The Public Participation Plan (PPP) identifies a proactive public involvement process for the
development of plans and programs of the Collier Area Transit (CAT) system. This process
provides for complete information, timely public notice, full access to key decisions and early
and continuing involvement of the public.
The obligation to provide information and consider public input in decision-making was made
explicit by the Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA). This strong
federal emphasis on public involvement was continued in the Transportation Equity Act for the
21' Century (TEA-21) in 1998, continued in the Safe, Accountable, Flexible and Efficient
Transportation Equity Act (SAFETEA), sustained in the Safe, Accountable, Flexible and
Efficient Transportation Equity Act, a legacy for users (SAFETEA-LU) and finally through
Moving Ahead for Progress in the 21" Century (MAP-21). The true test of a successful public
involvement plan is the level of public awareness and feedback. Too often, public participation
does not occur until after the community-at-large becomes aware of an unpopular decision, at
which point large citizen efforts become necessary to change decisions after the fact. A planning
process that involves the average citizen early makes the public a participant in any decision that
is ultimately made.
CAT previously adopted the Collier Metropolitan Planning Organizations (MPO) Public
Participation Plan. However, with recent amendments of the MPO Plan which did not include a
transit component, it became necessary for CAT to establish its own plan.
Background
Public transportation services for the over 333,000 citizens living in Collier County, Florida are
provided through Collier Area Transit (CAT). The Collier County Alternative Transportation
Modes (ATM) Department is responsible for planning, operating, and managing CAT public
transportation services through a contract operator. CAT currently operates ten fixed-route bus
routes as well as paratransit service within unincorporated Collier County, the City of Naples,
Marco Island, and Immokalee. Since inception in 2001, CAT's annual ridership has increased
from just fewer than 100,000 trips in 2001 to over 1.2 million trips in FY2012. Over roughly the
same time period, from 2000 to 2010, the population in the county has grown by approximately
28 percent.
Public Participation Goals and Public Involvement Tools
Evaluation
The effectiveness of any program and policy plan depends upon its success in meeting the
expectations of the public. Further, plans and programs need to be reassessed periodically to
determine if the public's evolving needs and expectations are adequately provided for through
the plan. In order to ensure that this occurs, the public must be kept informed of activities, and
Collier Area Tr:nst (CAT) Pu_:biic Participation Plan
must be given a meaningful opportunity to participate in the development and review of public
policy. Thus it is important to have an ongoing program to involve citizens through the use of
the public transit ad hoc advisory committee, public workshops, press releases and other public
outreach activities.
The public participation goal of CAT is to provide complete information, timely public notice,
and full access to key decisions during the planning process; and to support early and continuing
involvement of the public.
PUBLIC EVALUATION PERFORMANCE METHODS TO
INVOLVEMENT CRITERIA GOAL(S) MEET GOAL(S)
TOOL
Public Participation Annual report to Statistical increase in Update the PPP as
Plan indicate if the PPP overall PPP needed to incorporate
reflects the practices evaluation score. the improvement
and effectiveness of strategies resulting
CAT. from the public
involvement
evaluations.
Transit Advisory Number of returned Maximum of 2% Make immediate
Network items return rate per corrections when
mailing. items are returned.
Developing Number of Increase number of Attend festivals,
Community community meetings community meetings special events,
Knowledge of CAT attended attended. lectures, etc.
Press Releases Number of press Minimum of 15 Encourage publication
releases submitted per advertisements per of press releases in
year year. order to keep the
public and media
informed of CAT
activities.
Small Group Calls, letters, etc.; N/A. These meetings ATM & CAT staff
Meetings Meet the expectations are held at the request will be available in a
of the group of affected groups. timely manner to hold
small group meetings
regarding any CAT
activity or issue. The
meeting should be
formatted to provide
specific information
requested by the
group and should
highlight issues that
are interest to the
group.
Coiiier Area Transit (CAT) Public Participation Plan
Public Transit Ad Hoc Calls, letters, etc.; Monitor committee ATM staff will
Advisory Committee Attendance member attendance encourage appointed
and contact the BCC members to attend
for direction if committee meetings.
members do not meet Lack of attendance
the specific may indicate the need
attendance to replace that
requirements of the committee member.
adopted bylaws.
CAT Logo Call, letters, etc. Recognition of the The CAT logo should
logo. be used on all CAT
products and
publications and
materials for all CAT
sponsored activities.
Take Ones Number of Take Ones 100% of all releases ATM & CAT staff
Posted on Buses posted on buses. shall post the releases
to ensure that the
riders are informed of
CAT activities.
Public Outreach Techniques
Collier County ATM staff uses several different techniques for public outreach. Listed below
are the techniques currently being pursued:
r .-z
The intent of the CAT Limited English Proficiency Plan is to ensure access to the planning
process and information published by CAT where it is determined that a substantial number of
residents in the planning area do not speak or read English proficiently. The production of
multilingual publications and documents and/or interpretation at meetings or events will be
provided to the degree that funding permits based on current laws and regulations. The LEP is
included in Appendix 1.
Collier Area Transit (CAT) Public Participation Plan
The Collier County ATM staff maintains a Transit Advisory Network (TAN) which includes, but
is not limited to the following individuals:
1. Elected officials
2. Local Government staff
3. Individuals expressing an interest in transportation planning activities.
4. Local media
5. Minority publications and/or other media outlets, when and where available
6. Homeowner's Associations
7. Civic groups
8. Collier County Libraries
Collier ATM staff shall, when feasible, electronically distribute announcements/invitations to the
TAN for upcoming activities.
Collier County staff shall maintain a website for the transit system. The website shall, at a
minimum, contain the following information:
1. Contact information (mailing address, phone, fax and email)
2. Meeting calendar
3. Routes & Schedule
4. Work products and publications
5. Comment/Question Forms
Collier County ATM staff submits legal ad notices as required for plans and programs. Legal
ads are submitted to the Naples Daily News, the newspaper of general circulation in Collier
County. When applicable, legal ads are also submitted to Nuevos Ecos, a bi-weekly publication.
Public hearings will be held as required by Federal, State or local laws. The public hearing may
be held as part of a regularly scheduled Board of County Commissioners (BCC), Metropolitan
Planning Organization (MPO) Board or Public Transit Ad Hoc Advisory Committee meeting.
,'" �' ';
Public workshops may be held prior to the adoption of a plan or program or may be held to gain
input on the transit system.
"a ,
Collier County ATM staff distributes information brochures about the transit system to local
jurisdictions, local libraries, Chambers of Commerce, etc.
Collier Area Transit (CAT) Public Participation Plan
:`oci4-1.1 Media
Collier County ATM staff will work toward distributing information about the transit system to
the public via social media.
Public Transit Ad-Hoc Advisory Committee and Advertisement
Requirements
On February 26, 2013, the Collier County Board of County Commissioners (BCC) adopted a
resolution creating the Public Transit Ad-Hoc Advisory Committee. The purpose of this
committee is to provide input to staff to assist in identifying ways to improve the transit system,
serve as advocates for the system and make recommendations to the Board of County
Commissioners in matters related to transit policies, issues, programs and plans to provide mass
transit services to the citizens of Collier County. The duration of this advisory committee is one
year from the date of its first meeting. The committee consists of:
• 9 voting members
o 8 representatives from large employers, health care related services, social
services, and transportation and planning professionals. A minimum of 2 of the
representatives must be passengers of the system.
o 1 representative appointed by the Collier County School Board
Staff will strive to have a press release published a minimum of seven days prior to the meeting.
The press releases will also be posted on all buses. Agendas will be mailed or emailed to
committee members and interested parties a minimum of 7 days prior to the meeting.
Public Participation Plan
The Public Participation Plan (PPP) will be reviewed annually by the Collier County Alternative
Transportation Modes (ATM) staff to ensure the CAT planning process provides full and open
access to the general public. The PPP shall also be reviewed as part of the triennial certification
process conducted by the Federal Transit Administration (FTA).
A public comment period of 45 days shall be provided prior to the adoption or amendment of the
PPP. Notice of the 45 day comment period shall be published in a newspaper of general
circulation in Collier County and a notification will be mailed out to the TAN.
A copy of the proposed amendments will be published on the Collier Area Transit website.
The specific public involvement process for the public participation plan is included in Appendix
2 (45 Day Public Involvement Process for Transit Plans & Programs).
Collier Area Transit (CAT) Public Participation Plan
The following programs and plans will utilize the 30 Day Public Involvement Process for
Transit Plans & Programs included in Appendix 3.
Title VI Program
As required by the Federal Transit Administration, CAT must review and update a Title VI
Program every 3 years. This plan ensures that the level and quality of public transportation
service is provided in a nondiscriminatory manner; promote full and fair participation in public
transportation decision-making without regard to race, color or national origin; and ensure
meaningful access to transit-related programs and activities by persons with limited English
proficiency.
Fare Modifications
Fare increases are increases to the base full adult fare. When the full adult fare is increased,
discount fares and fare media may also be increased at the same time. Fare decreases are
decreases to the base full adult fare. When the full adult fare is decreased, discount fares and
fare media may also be decreased at the same time. Fare modifications are adopted by the
Collier County BCC and implement by Collier Area Transit.
Service Reductions
Service reductions occur when CAT does the following to an individual route or to set of routes:
1. Reduce the span of service hours (hours in a day when service operates) and/or
2. Reduce the days in which service operates and/or
3. Reduce the frequency of service and/or
4. Eliminate a route in its entirety or major portion thereof, unless that route was a planned
service development or experimental services that has been in existence less than two
years.
Service Expansions
Service expansions occur when CAT does the following to an individual route or to set of routes:
I. Increase the span of service hours (hours in a day when service operates) and/or
2. Increase the days in which service operates and/or
3. Increase the frequency of service and/or
4. Add a new route.
Collier Are r i CAT) Public Participation Plan
Disadvantaged Business Enterprise Program and Goal Setting
Collier County BCC has established a Disadvantaged Business Enterprise (DBE) program in
accordance with regulations of the U.S. Department of Transportation, 49 Code of Federal
Regulations (CFR) Part 26 applicable to all federally funded transit projects. It is the policy of
the BCC to ensure that DBEs as defined in Part 26, have an equal opportunity to receive and
participate in Department of Transportation (DOT) assisted contracts. Every three years a goal
must be established. The methodology for determining the goal is contained in the DBE
program.
Program of Projects
A program of projects (POP) is a list of projects proposed by a designated recipient to be funded
from urbanized area formula FTA funds. The POP includes a brief description of the projects,
total project costs and federal share for each project. The POP is developed on an annual basis.
Comprehensive Operational Analysis
A comprehensive operational analysis (COA) is an in-depth study of a transit system designed to
identify strengths and weaknesses, and development recommendations for improvement.
Transit Development Plan (Major Update)
A transit development plan (TDP) is a Florida Department of Transportation (FDOT) required;
10 year horizon plan intended to support the development of an effective multi-modal
transportation system. The TDP serves as the basis for defining public transit needs which is a
prerequisite to receive state funds. Collier County is required to develop and adopt a TDP major
update every 5 years. This document is produced in coordination with the Collier Metropolitan
Planning Organization (MPO). Collier County ATM staff will coordinate the public
involvement requirements identified in the CAT PPP, while the MPO staff shall be responsible
for completing the public involvement requirements identified in their adopted PPP.
Collier A.re.i Ti-..;;s,t ;CAI; Public Participation Plan
The following programs and plans will utilize the 15 Day Public Involvement Process for
Transit Plans & Programs included in Appendix 4. Also, all documents and activities not
specifically listed otherwise in this document will follow the standard process included in
Appendix 4.
Transit Development Plan (Minor Update)
The FDOT requires annual updates in the form of a progress report on the TDP. The minor
update must include the following elements:
I. Past year accomplishments compared to the original recommendations from the last
major update;
2. Reasons for any discrepancies between the plan and its implementation for the past year;
3. Revisions to the coming year's recommendations, as appropriate;
4. Added detail to recommendations for the final years of the updated plan; and
5. A revised standardized financial plan, including revised financial tables.
Collier County ATM staff will coordinate the public involvement requirements identified in the
CAT PPP, while the MPO staff shall be responsible for completing the public involvement
requirements identified in their adopted PPP.
Transit Priorities
Annually the FDOT requests priorities that they consider for funding in the development of their
work program. Transit priorities are usually coordinated with the Collier MPO. Collier County
ATM staff will coordinate the public involvement requirements identified in the CAT PPP, while
the MPO staff shall be responsible for completing the public involvement requirements identified
in their adopted PPP.
CoWer Area Trinsit (CAT) Public Participation Plan
Appendix 1
Collier Area Transit (CAT) Public Participation Plan
Collier Area Transit (CAT) operates under the supervision of the Collier County Department of
Alternative Transportation Modes (ATM) for the Collier County Transportation Services
Division. CAT serves as the public transit provider for Collier County, serving the Naples,
Marco Island, and Immokalee areas. CAT funds the transit program with the use of local, state
and federal dollars. Involving our citizens in the transit planning process including the
utilization of funds, communicating the program of projects, and more importantly
communicating our level of service standards to the community are all vital processes that CAT
undertakes as part of ensuring that services are provided in accordance with Title VI.
Reaching all parts of our population and providing language assistance to persons with limited
English proficiency in a competent and effective manner will help ensure that our services are
safe, reliable, convenient, and accessible to everyone in our community including LEP persons.
The Limited English Proficiency (LEP) Plan plays an integral role in this process. This
document will detail the LEP Plan, developed in conjunction with best practice standards for
public involvement.
Background Information
Limited English proficient or LEP" are individuals who have a limited ability to read,
write, speak, or understand English, who speaks a language at home other than English as
his/her primary language, and who speaks or understands English `not well' or `not at all'.
According to the 2000 U.S. Census, more than 10 million people reported that they do not speak
English at all, or do not speak English well. The number of persons reporting that they do not
speak English at all or do not speak English well grew by 65 percent from 1990 to 2000. Among
limited English speakers, Spanish is the language most frequently spoken, followed by Chinese
(Cantonese or Mandarin), Vietnamese, and Korean.
Public transit is a key means of achieving mobility for many LEP persons. According to the 2000
Census, more than 11% of LEP persons aged 16 years and over reported use of public transit as
their primary means of transportation to work, compared with about 4% of English speakers.
Catering to LEP persons will help increase and retain ridership among the agency's broader
immigrant communities in two important ways:
Agencies that reach out to recent immigrant populations in order to conduct a needs assessment
and prepare a language implementation plan (pursuant to the DOT LEP Guidance) will send a
positive message to these persons that their business is valued.
Community outreach designed to identify appropriate language assistance measures can also
assist the agency in identifying the transportation needs of immigrant populations and ensuring
that an agency's transit routes, hours and days of service, and other service parameters are
responsive to the needs of these populations.
C'Dllierrit'e: Tc';n`it (CAT} Pliblic P.rticlpation Plan
Introduction
Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq., and its implementing
regulations provide that no person in the United States shall, on the grounds of race, color, or
national origin, be excluded from participation in, be denied the benefits of, or be otherwise
subjected to discrimination under any program or activity that receives Federal financial
assistance. The Supreme Court, in Lau v. Nichols, 414 U.S. 563 (1974), interpreted Title VI
regulations promulgated by the former Department of Health, Education, and Welfare to hold
that Title VI prohibits conduct that has a disproportionate effect on LEP persons because such
conduct constitutes national origin discrimination.
Executive Order 13166: Improving Access to Service for Persons with Limited English
Proficiency was signed in year 2000 to clarify Title VI of the Civil Rights Act of 1964. Its
purpose was to ensure accessibility to programs and services to eligible persons who are not
proficient in the English language.
This executive order stated that individuals who do not speak English well and who have a
limited ability to read, write, speak, or understand English are entitled to language assistance
under Title VI of the Civil Rights Act of 1964 with respect to a particular type of service, benefit,
or encounter. It reads in part,
"Each Federal agency shall prepare a plan to improve access to its federally conducted
programs and activities by eligible LEP persons. Each plan shall be consistent with the
standards set forth in the LEP Guidance, and shall include the steps the agency will take to
ensure that eligible LEP persons can meaningfirlly access the agency's programs and activities. "
Not only do all federal agencies have to develop LEP Plans, as a condition of receiving federal
financial assistance, but also state and local recipients are required to comply with Title VI and
LEP guidelines of the federal agency from which they receive funds.
Federal financial assistance includes grants, training, use of equipment, donations of surplus
property and other assistance. Recipients of federal funds range from state and local agencies to
nonprofits and other organizations. Title VI covers a recipient's entire program or activity. This
means all components of a recipient's operations are covered. Simply put, any organization
that receives federal financial assistance is required to follow this Executive Order.
The US Department of Transportation (DOT) published "Policy Guidance Concerning
Recipients' Responsibilities to Limited English Proficient Person" in the December 14, 2005
Federal Register. The guidance explicitly identifies local transit operators as organizations that
must follow this guidance:
The guidance applies to all DOT funding recipients, which include state departments of
transportation, state motor vehicle administrations, airport operators, metropolitan planning
organizations, and regional, state, and local transit operators, among many others. Coverage
Collier Area Transit (CAT) Public Participation Plan
extends to a recipient's entire program or activity, i.e., to all parts of a recipient's operations.
This is true even if only one part of the recipient receives the Federal assistance. For example, if
DOT provides assistance to a state department of transportation to rehabilitate a particular
highway on the National Highway System, all of the operations of the entire state department of
transportation—not just the particular highway program or project—are covered by the DOT
guidance.
The intent of this Limited English Proficiency Plan is to ensure access to the planning process
and information published by Collier Area Transit where it is determined that a substantial
numbers of residents in Collier County do not speak or read English proficiently. The production
of multilingual publications and documents and/or interpretation at meetings or events will be
provided to the degree that funding permits based on current laws and regulations.
Laws and Policies Guiding Limited English Proficiency Plans
The FTA references the DOT LEP guidance in its Circular 4702.1A, "Title VI and Title VI-
Dependent Guidelines for FTA Recipients," which was published on April 13, 2007. Chapter IV
part 4 of this Circular reiterates the requirement to take responsible steps to ensure meaningful
access to benefits, services, and information for LEP persons and suggests that Federal Transit
Administration (FTA) recipients and sub recipients develop a language implementation plan
consistent with the provisions of Section VII of the DOT LEP guidance.
Collier Area Transv, CAT) P;ablic Participation Plan
As part of the DOT and FTA requirements, the LEP Plan will be assessed and evaluated. The
following matrix illustrates these laws, policies and considerations:
Title VI of the Civil Rights Act of 1964 Limited English Proficiency Executive
Order 13166
Federal Law Federal Policy
Enacted in 1964 Enacted in August 2000
Considers all persons Considers eligible population
Contains monitoring and oversight Contains monitoring and oversight
compliance review requirements compliance review requirements
Factor criteria is required, no numerical or Factor criteria is required, no numerical or
percentage thresholds percentage thresholds
Provides protection on the basis of race, Provides protection on the basis of national
color, and national origin origin
Focuses on eliminating discrimination in Focuses on providing LEP persons with
federally funded programs meaningful access to services using four
factor criteria
Annual Accomplishment and Upcoming Annual Accomplishment and Upcoming
Goals Report to FHWA Goals Report to FHWA
Who is an LEP individual?
As defined in the 2000 United States Census, it is any individual who speaks at home other than
English as his/her primary language, and who speaks or understands English "not well" or "not
at all".
Collier Area Tr.-insit iCAT) Public Participation Plan
Determining the need
As a recipient of federal funding, Collier Area Transit must take reasonable steps to ensure
meaningful access to the information and services it provides. As noticed in the Federal Register/
Volume 70, Number 239/ Wednesday, December 14, 2005/ Notices, there are four factors to
consider in determining "reasonable steps".
Factor 1 - The number and proportion of LEP persons served or encountered in the eligible
service population
Factor 2 - The frequency in which LEP persons encounter Transit Programs, Activities and
Services
Factor 3 - The nature and importance of the program, activity, or service provided by the
recipient to people's lives
Factor 4 - The resources available to the recipient and cost
The DOT Policy Guidance gives recipients of federal funds substantial flexibility in determining
what language assistance is appropriate based on a local assessment of the four factors listed
above. The following is an assessment of need in Collier County in relation to the four factors
and the transit planning process.
LEP Assessment for Collier Area Transit
For the purposes of conducting this assessment, Collier Area Transit is utilizing information
derived from the 2000 census in addition to charts, maps and other demographic information and
documents prepared by Collier Metropolitan Planning Organization.
Factor 1 — The Number and proportion of LEP persons served or encountered in the
eligible service population
The first step towards understanding the profile of individuals who could participate in the transit
planning of services process is a review of Census data. Tables 1 and 2 displays the primary
language spoken and number of individuals that are LEP.
For our purposes, we are considering people that speak English `not well' or `not at all,' and only
the top four language groups are included in the analysis.
Collier Area Transit (CAT) Public Participation Plan
Table 1, derived from the 2010 US Census, shows the number and percent of the population,
with regard to their English language skills, for the cities and the unincorporated portions of the
County. As indicated, over 15% of the area population 5 years of age or older is not proficient in
English; that is, they speak English less than "very well".
Tables 1: Limited English Proficient Persons in Collier County
2010 Census Data and 2007-2011 American Community Survey 5 year estimates
Jurisdiction Population Population 5 Number of LEP Percentage of
years and over Persons (5 years LEP Persons (5
and over) years and over
Everglades City 334 310 0 0.00%
City of Naples 20,091 19,667 724 3.68%
City of Marco 16,573 16,172 1,199 7.41%
Island
Naples Area 320,087 302,602 48,895 16.49%
(Including the
unincorporated
County
Total Area 357,085 338,751 51,818 15.30%
(includes all
cities and
unincorporated
County)
Collier Area Transit i CAT) Public Participation Plan
Table 2 shows the number and percent of LEP persons by language spoken at the individual's
home. Of the LEP persons with the area, 12.12% speak Spanish at home making this the most
significant percent of the area's population. The second most common language of the area's
LEP population is Other Indo-European languages, with 2.79%. Asian and Pacific Islander
languages represents 0.32% and 0.06% speak "other" languages at home.
Table 2: language Spoken at Home by LEP Persons
2010 Census Data and 2007-2011 American Comm unity Survey 5 year estimates
LEP Persons Spanish Other Indo- Asian & Pacific Other
Language European Islander Languages
Languages Languages
5 Years and 0 0 0 0
over —
Everglades City
5 Years and 363 292 10 54
over — City of
Naples
5 Years and 903 259 37 0
over — Marco
Island
5 Years and 39,806 8,906 1,041 142
over — Naples
Area (including
the
unincorporated
County)
5 Years and 41,072 9,462 1,088 196
over—Total
Percent of Total 12.12% 2.79% 0.32% 0.06%
Populations 5
Years and over
Factor 2 — The frequency in which LEP Persons encounter transit programs, activities and
services
Based on the 2010 census information there is a small, but growing size of the LEP population in
this region that will likely increase the probability of future contact with the CAT program,
services and activities. In recognition of a growing LEP population CAT has taken proactive
steps to ensure that communication about transit services, meetings, activities, surveys and other
important information is provided in the three main spoken languages: English, Spanish and
Creole. In addition to providing literature in these three languages, we also ensure to have
available persons (mostly staff members) to serve as language interpreters in public meetings in
addition to a sign language person.
Collier Area Tran:;c (CAT) Public Participation Plan
Factor 3 — The nature and importance of the program, activity, or service provided by the
recipient to people's lives
Collier Area Transit provides an essential service to the community during emergency
evacuation such as hurricanes, fires and other disasters. We also help disseminate information to
the public on security awareness, emergency preparedness and the importance of the modes and
type of services we provide. If this information is not accessible to people with limited English
proficiency, or if language services in these areas are delayed, the consequences to these
individuals could be life threatening. It is precisely because of this that CAT ensures that all
segments of the population, including LEP persons, have been involved or have had the
opportunity to be involved in the transit planning of services process to be consistent with the
goal of the Federal Environmental Justice program and policy.
The impact of proposed transit projects and investments on underserved and under-represented
population groups is part of the evaluation process in use of federal funds during the preparation
of our program of projects and two essential transit documents:
• The Transit Development Plan (TDP)
• The Transportation Disadvantaged Service Plan (TDSP)
Inclusive public participation is a priority consideration in all transit plans, studies and programs.
The impacts of transit improvements resulting from these planning activities have an impact on
all residents. Understanding and continued involvement are encouraged throughout the process.
Collier Area Transit is concerned with input from all stakeholders, and makes every effort to
ensure that the planning process is as inclusive as possible.
Factor 4-The resources available to the recipient and cost
Given the current financial constraints, full multi-language translations of large transit planning
documents such as the TDP, TDSP and other large planning documents are not considered to be
warranted at this time. However, Collier Area Transit ensures that all vital communication
information of programs, activities and services are made available to the LEP population in
English, Spanish and Creole, which are the three main spoken languages in the area.
Collier Area Transit will continue efforts to provide language translation and interpretation
services taking into account the available funding. As new 2010 Census data becomes available,
Collier Area Transit will monitor LEP population and adjust its LEP policy accordingly. If
warranted in the future, CAT will consider new techniques to reach the LEP population, such as
(1) the translation of executive summaries for key documents, such as the TDP and TDSP (2) the
translation of document summaries, which are designed to capture all of the significant points of
the full document
Collier Area Transit (CAT) Public Participation Plan
Collier Area Transit has translated many essential documents such as:
• Bus Schedules and route maps
• Riders Guide
• Notice of right to language assistance
• Fare Announcements
• Service Change announcement
• Notices pertaining to upcoming events
• Power Point Presentations
• Title VI language in English, Spanish and Creole
• Public Notices
• Information on website
• Prohibited behavior signage
Meeting the Requirements
Engaging the diverse population within the Collier County area is important. Collier Area Transit
is committed to providing quality services to all citizens, including those with limited English
proficiency. All language access activities detailed below will be coordinated in collaboration
with the CAT staff.
Safe Harbor Stipulation
Federal law provides a `safe harbor' stipulation so recipients of federal funding can ensure
compliance with their obligation to provide written translations in languages other than English
with greater certainty. A `safe harbor' means that as long as a recipient (CAT) has created a plan
for the provision of written translations under a specific set of circumstances, such action will be
considered strong evidence of compliance with written translation obligations under Title VI.
However, failure to provide written translations under the circumstances does not mean there is
noncompliance, but rather provides for recipients a guide for greater certainty of compliance in
accordance with the four-factor analysis.
Evidence of compliance with the recipient's written translation obligations under `safe harbor'
includes providing written translations of vital documents for each eligible LEP language group
that constitutes 5% or 1,000 persons, whichever is less of eligible persons served or likely to be
affected. Translation also can be provided orally. The `safe harbor' provision applies to the
translation of written documents only. It does not affect the requirement to provide meaningful
access to LEP individuals through competent oral interpreters where oral language services are
needed and reasonable to provide.
Collier Area Transit (CAT) Pi.,blic Partcipation Plan
Providing Notice to LEP Persons
US DOT guidance indicates that once an agency has decided, based on the four factors, to
provide language services, it is important that the recipient notify LEP persons of services
available free of charge in a language the LEP persons would understand. Example methods for
notification include:
• Signage that indicates when free language assistance is available with advance notice;
• Stating in outreach documents that language services are available;
• Working with community-based organizations and other stakeholders to inform LEP
individuals of CAT services and the availability of language assistance;
• Using automated telephone voice mail or menu to provide information about available
language assistance services;
• Including notices in local newspapers in languages other than English;
• Providing notices on non-English-language radio and television about MPO services and
the availability of language assistance; and
• Providing presentations and/or notices at schools and community based organizations
(CBO).
Collier Area Transit will publicize the availability of interpreter services, free of charge, if
requested at least 7 days prior to meetings, workshops, forums or events. These events will be
publicly advertised via web site, onboard our buses, newspaper, etc. We will also continue to
use additional tools as appropriate such as:
• Signage
• Flyers
• Take-ones
• Handouts available in vehicles and at stations
• Announcements in vehicles and at stations
• Agency website
• Newspaper and radio advertisements
• community-based organizations
• Collier County library systems
• Announcements and community meetings.
• Surveys
An interpreter is a person who translates spoken language orally, as opposed to a translator, who
translates written language and transfers the meaning of written text from one language into
another. CAT will provide language interpreter and translating services as needed.
As covered under Title VI requirements for nondiscrimination, CAT will include Title VI
language in all Public Notice material as applicable.
Collier Area Transit (CAT) Public Participation Plan
Language Assistance
A goal of the Collier Area Transit is to provide user-friendly materials that will be appealing and
easy to understand. CAT will continue to provide materials to the LEP population in alternative
formats, such as schedules, flyers, user's guide, depending on the work product.
CAT Staff Training
What the Guidance Says:
"Staff members should know their obligations to provide meaningful access to information and
services for LEP persons, and all employees in public contact positions should be properly
trained An effective LEP plan would likely include training to ensure that:
Staff knows about LEP policies and procedures.
Staff having contact with the public (or those in a recipient's custody) is trained to work
effectively with in person and telephone interpreters.
In order to establish meaningful access to information and services for LEP individuals, CAT
will continue to train its employees and will include LEP training as part of the new employee
orientation. In addition, CAT will make a list of staff identifying the different languages that they
can assist with. This list will be kept in the front desk in case an LEP person request language
assistance, the staff member will be able to promptly locate an interpreter for public assistance.
Collier- Area Transit ;CAT) Pirblic Participation Plan
Appendix 2
13rn ins
Collier Area Transit (CAT) Public Participation Plan
,..,,;.',,,,, . ...—,,,,.:,. ...,,: •ATM staff will update and amend transit plans and programs as required.
'et-',..14,02,&&,,`,..,43","4-3,*;331.:-.,0!"=" •When updating or amending,ATM staff shall include any new federal or state requirements.
. lit, ,:,;:2:,-, •ATM staff will submit a news release at least 7 days prior to the workshop that will provide detailed information
....t",1',ii,'::...R.-1%-17.4:,::,.,1.:,t •ATM staff will post news release at least 7 days prior to the workshop in interior advertising area on all buses. I
:),N .e,::!'. •ATM staff to submit a legal advertisement announcing the public comment period in one newspaper of general
1. ,..*.i.:4;.;.. .',":",,'''...:,-'.3.'t. •ATM staff to submit a legal advertisement announcing the public comment period in one newspaper of general
""i'.1.1,....'":4`....1:'t';`t-t.'",.t.,,'t. •ATM staff will post a news release in interior advertising area on all buses announcing the public comment period.
,A, ,,, _..;,, •At least 45 days prior to the public meeting and adoption of the plan/program,ATM staff will distribute copies of the
"`/).",ik, :. draft plan/program and comment forms to local government agency offices and libraries.
. ':',!'Ist., ,,,..,,,:,,r,;: •At least 45 days prior to the public meeting and adoption of the plan/program,ATM staff will post the draft
' ' ,33,3.33" , ,... ,,,. plan/program and comment forms to the ATM website.
„1.'.',t,';''',,k.'',,'....;''''-."' " •ATM staff will distribute electronic copies of the draft plan/program with notice of the public comment period to the
"...;t' "."',..-4•.4.-` --,`‘. transit advisory network and others upon request.
..'t3.!;.`",,,t,....3,A,/,„3„:.,. ".3...3,'33;..3, •ATM staff to provide electronic copy of draft plan/program to applicable advisory committees for review,this will be
,''.r:Vc3'1°..,,,:'z',: ,.:,'-;,4 accomplished in coordination with appropriate advisory committee staff liaisons.
-74,...,4,, _ ,r,,-,' •ATM staff will respond verbally or in writing to all public input received during the public comment period.
' ''`.-';‘,,,, .... '''',',.' •When significant written and/or oral comments are received on the draft plan/program,a summary of the comments 1
i i ''' -. ' 'i ' and responses shall be provided to the adopting Board for review
.....__ _ ....__ ____ _. ......_
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...",,, .'3.,..".,...`, •The adopting Board will consider the recommendations of any applicable reviewing committee/Board when adopting the
r ".'tt_.",":-,,L. ,., 3.3 t,:";,"; •The adopting Board will consider the comments received druing the public comment period when adopting the
Collier Area Transit (CAT) Public Participation Plan
Appendix 3
'Dray Irc,risit Plans & Programs
Collier Area Transit (CAT) Public Participation Plan
aa, •ATM staff will update and amend transit plans and programs as required.
,,,. -,,,,;,,,?'..,if..:-.: i7• •When updating or amending,ATM staff shall include any new federal or state requirements.
.i. a13a
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,.
a •ATM staff will submit a news release at least 7 days prior to the workshop that will provide detailed information
„ .;4 regarding the location,time and subject matter.
-0^ •;:; ,,tea*€ `.,. •ATM staff will post news release at least 7 days prior to the workshop in the interior advertising area on all buses.'•< '3 � •ATM staff will respond to public comments made at the workshop.
a P
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•ATM staff to submit a legal advertisement announcing the public comment period in one newspaper of general
�•t circulation.
•ATM staff to submit a legal advertisement announcing the public comment period in one newspaper of general
circulation that is published in Spanish,if a paper so exists.
•ATM staff will submit a news release announcing the public comment period.
b r y . ,..1; •ATM staff will post a news release in the interior advertising area on all buses announcing the public comment period.
", At least 30 days prior to the public meeting and adoption of the plan/program,ATM staff will distribute copies of the 't
;%- •draft plan/program and comment forms to local government agency offices and libraries.
44 •At least 30 days prior to the public meeting and adoption of the plan/program,ATM staff will post the draft I
fix: plan/program and comment forms to the ATM website.
f�, t . •ATM staff will distribute electronic copies of the draft plan/program with notice of the public comment period to the 1
';,,,,,,',,,,,—,.',:,-i.„1- i c -' transit advisory network and others upon request.
"€� .g •ATM staff to provide electronic copy of draft plan/program to applicable advisory committees for review,this will be
•• '+t ..- accomplished in coordination with appropriate advisory committee staff liaisons. ;
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[;,,• s •ATM staff will respond verbally or in writing to all public input received during the public comment period.
''• •If formal Board action is required,when significant written and/or oral comments are received on the draft
plan/program,a summary of the comments and responses shall be provided to the adopting Board for review.
y ..._. -..�.,..........—
� ••The adopting Board will meet at the end of the public comment period,
•The adopting Board will consider the recommendations of any applicable reviewing committee/Board when adopting the
plan/program.
? y l •The adopting Board will consider the comments received druing the public comment period when adopting the
i s`
f plan/program.
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1"
Collier Area Tr-,nsit (CAT) Public Participation Plan
Appendix 4
Collier Area Transit (CAT) Public Participation Plan
':„.:,,,,N„ -,-;t:i..":iZ
e •ATM staff will update and amend transit plans and programs as required.
o�1.t •
a 4 tom, •When updating or amending,ATM staff shall include any new federal or state requirements.
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x. •ATM staff will submit a news release ac lease 7 days prior to the workshop that will provide detailed information
regarding the location,time and subject matter.
a' a ,„ •ATM staff will post news release at least 7 days prior to workshop in the interior advertising area on all buses. i
f ,';a 1 "`e •ATM staff will respond to public comments made at the workshop. 4
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5{ ATM staff will post a news release in the interior advertising area on all buses announcing the public comment period. 1
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•At least 15 days prior to the public meeting and adoption of the plan/program,ATM staff will distribute copies of the 1.
draft plan/program and comment forms to local government agency offices and libraries.
> •At least 15 days prior to the public meeting and adoption of the plan/program,ATM staff will post the draft
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•ATM staff will distribute electronic copies of the draft plan/program with notice of the public comment period upon
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mss ;• ATM staff to provide electronic copy of draft plan/program to applicable advisory committees for review,this will be !
a ,; accomplished in coordination with appropriate advisory committee staff liaisons.
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•ATM staff will respond verbally or in writing to all public input received during the public comment period. !
•If formal Board action is required,when significant written and/or oral comments are received on the draft j
plan/program,a summary of the comments and responses shall be provided to the adopting Board for review.
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a`.t •The adopting Board will meet at the end of the public comment period.
•The adopting Board will consider the recommendations of any applicable reviewing committeeiBoard when adopting the S
plan/program.
•The adopting Board will consider the comments received druing the public comment period when adopting the
r t plan/program.
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