Title VI Non-Discrimination Plan

East Central Wisconsin Regional Planning Commission’s (ECWRPC) Title VI Non-Discrimination Plan is intended to assure that no person shall on the grounds of race, color or national origin as provided by the Title VI of the Civil Rights Act of 1964, and the Civil Rights Restoration Act of 1987 (P.L. 100.259) be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any ECWRPC sponsored program or activity. A Title VI Non-Discrimination Plan protects anyone intended to be the beneficiary of, applicant for, or participant in a Federally assisted program. ECWRPC assures every effort will be made to ensure nondiscrimination in all of its programs and activities, whether those programs and activities are federally funded or not. ECWRPC’s region is made up of the following counties: Outagamie, Winnebago, Calumet, Shawano, Menominee, Waupaca, Waushara, Marquette, Green Lake and Fond du Lac. ECWRPC is a designated Metropolitan Planning Organization (MPO) for the Appleton and Oshkosh urbanized areas and serves the Fond du Lac urbanized area. The Appleton urbanized area or the MPO is also a Transportation Management Area (TMA).

ECWRPC will not:

• Deny any protected individual service, financial aid or benefit under the program or the opportunity to participate as a member of a planning or advisory body
• Restrict a protected individual in the employment of any advantage or privilege enjoyed by others
• Treat protected individuals differently in terms of whether they satisfy admission, eligibility, or membership requirements
• Subject a protected individual to segregation or separate treatment
• Use criteria or methods of administration that have the effect of subjecting individuals to discrimination
• Make decisions in regard to facility location with the purpose or effect of subjecting persons to discrimination
• Discriminate with regard to the routing, scheduling, or quality of transit service
• Use race, color, or national origin as a basis for determining frequency of service, age and quality of vehicles assigned to routes, quality of stations serving different routes, and location of routes

LIMITED ENGLISH PROFICIENCY PROGRAM

ECWRPC’s Limited English Proficiency Program has been prepared to address its responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq, and its implementing regulations, which state that no person shall be subjected to discrimination on the basis of race, color or national origin.

Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq., and its implementing regulations provide that no person shall be subjected to discrimination on the basis of race, color, or national origin under any program or activity that receives Federal financial assistance.

Most individuals in Wisconsin read, write, speak and understand English. There are some individuals for whom English is not their primary language.  If these individuals have a limited ability to read, write, speak, or understand English, they are considered limited English proficient, or ‘‘LEP.’’

Executive Order 13166, ‘‘Improving Access to Services for Persons with Limited English Proficiency,’’^[1] directs each federal agency that is subject to the requirements of Title VI to publish guidance for its respective recipients clarifying that obligation.

The US DOT “Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP) Persons” ^[2] discusses the concept of “safe harbor” with respect to the requirements for translation of written materials.

The LEP Safe Harbor provision stipulation was created to provide access to vital documents in a written format for non-English users who, because of small numbers may not meet the threshold for providing more expansive language access services as identified in the Language Assistance Plan.

Safe Harbor requires, at a minimum, a written translation of vital documents (ADA paratransit eligibility forms, Title VI complaint forms, information regarding access to essential services, etc.) for each LEP group that meets the LEP language threshold (5% or 1,000 individuals, whichever is less).

[1] 65 Federal Register 50121, August 16, 2000.
[2] 70 Federal Register 74087, December 14, 2005.