Richland County Title VI

Overview

It is the policy of Richland County to assure affirmative compliance with Title VI of the Civil Rights Act of 1964, as amended, and in accordance with all other related statutes, regulations and Executive Orders. The assurances previously given by the Federal Highway Administration are hereby reaffirmed and extend to the Federal Transit Administration. Examples of the application of this policy include, but are not limited to, the following:

No person in the United States will on the grounds of race, color, or national origin be excluded from participation in, be denied the benefit of, or be otherwise subjected to discrimination under any program or activity for which the Department receives federal financial assistance from the U. S. Department of Transportation, including the Federal Highway Administration and the Federal Transit Administration.

All Federally funded or Federally assisted programs will be administered as the County, sub-recipients, contractors, subcontractors, and other participants in federal financial assistance comply with all requirements imposed by or pursuant to, civil rights acts and Department of Transportation regulations.

The County does not discriminate in its selection and retention of contractors, including without limitation, those whose services are retained for, or incidental to, construction, planning, research, highway safety, engineering, public transportation, property management, fee contracts, and other formal commitments with person for services and expenses incidental to the acquisition of right of way.

Federal-aid contractors may not discriminate in their selection and retention of subcontractors who participate in federal-aid construction, acquisition of right of way and related projects, including those who supply materials and lease equipment.

Public Participation Plan

This Public Participation Plan explains how Richland County shares information with the public and gathers feedback on programs and projects.

The County strives to have an effective public involvement process that is proactive and provides complete information, timely public notice, full public access to key decisions and an opportunity for early and continuing involvement. County meetings are conducted in accessible locations and materials can be provided in accessible formats and in languages other than English. The goal is to make sure all citizens, including minority, low-income, LEP individuals, and persons with disabilities, have a meaningful opportunity to participate in the decision-making.

The County:

  • Provides timely public notice about meetings and projects
  • Shares clear and complete information
  • Offers early and ongoing opportunities for the public input
  • Advertises public meetings through the County’s social media
  • Removes barriers to participation whenever possible

Public Participation Guidelines

To support inclusive public involvement, the County:

  • Notifies the public early about upcoming projects
  • Expands notification areas based on the size and impact of the project
  • Holds public meetings in convenient, accessible locations
  • Schedules meetings at times that are convenient for the public, including evenings when appropriate
  • Provides language assistance services and reasonable accommodations upon request
  • Advertises meetings through multiple methods, including social media, the County website, and signage in the project area
  • Collects attendance information through sign-in sheets (name, contact information, etc.)
  • Encourages public comments through written forms, email, or other accessible methods during the comment period
  • Documents feedback received during meetings, including verbal comments

County staff reviews and considers public input as part of the decision-making process. In planning public meetings, County staff considers the following to obtain maximum attendance:

  • appropriate number of meetings and hearings needed
  • appropriate locations
  • convenient days and times
  • the needs of underserved and underrepresented populations

The American with Disabilities Act (ADA) of 1990 encourages the involvement of people with disabilities in the development and improvement of transportation and paratransit plans and services. In accordance with ADA guidelines, all meetings conducted by Richland County Government will take place in locations that are accessible to persons with mobility limitations. Also, auxiliary aids and services are provided when necessary to ensure effective communications, unless an undue burden or fundamental alteration would result, to allow a person with a disability to participate. “Auxiliary aids” include such services or devices as qualified interpreters, assistive listening headsets, telecommunication devices for deaf persons (TDD’s), videotext displays, Brail materials, and larger print materials. Richland County public meeting notices specify that special accommodations will be provided upon request.

Complaint Procedures

Richland County is committed to making sure no person is treated unfairly in its programs or services. This includes protections under Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, and other civil rights laws.

These procedures do not deny the right of the complainant to file formal complaints with other State or Federal agencies, or to seek private counsel for complaints alleging discrimination. These procedures are part of an administrative process that does not provide for remedies that include punitive damages or compensatory remuneration for the complainant.

Every effort will be made to obtain early resolution of complaints at the lowest possible level. The option of informal mediation meeting(s) between the affected parties and the investigator may be utilized for resolution, at any stage of the process. The County will make every effort to pursue a resolution of the complaint. Initial interviews with the complainant and the respondent will include requests for information regarding specific relief and settlement options.

Complaint Process

The Title VI Complaint Procedures apply to complaints filed under Title VI of the Civil Rights Act of 1964, relating to any program and/or activity administered by Richland County or its sub-recipients, consultants, and/or contractors. Intimidation or retaliation of any kind is prohibited by law.

These procedures do not deny the right of the complainant to file formal complaints with other State or Federal agencies, or to seek private counsel for complaints alleging discrimination. These procedures are part of an administrative process that does not provide for remedies that include punitive damages or compensatory remuneration for the complainant.

Every effort will be made to obtain early resolution of complaints at the lowest possible level. The option of informal mediation meeting(s) between the affected parties and the investigator may be utilized for resolution, at any stage of the process. Richland County will make every effort to pursue a resolution of the complaint. Initial interviews with the complainant and the respondent will include requests for information regarding specific relief and settlement options.

How to file a complaint

Step 1: Submit your complaint

  • Complaints must be filed within 180 days of the alleged incident
  • Complaints should be in writing and signed on the County Complaint Form
  • Complaint must present a detailed description of the issues, including names, job titles, and addresses of those individuals perceived as parties in the action complained against.

Your complaint should include:

  • Your name and contact information
  • The date of the alleged act(s) of discrimination (date when the complainant(s) became aware of the alleged discrimination; or the date on which the conduct was discontinued or the latest instance of the conduct.
  • Complaint must present a detailed description of the issues, including names, job titles, and addresses of those individuals perceived as parties in the action complained against.

If you are unable to submit your complaint in writing due to a disability or other reason, you may file a verbal complaint. County staff will document the information for you.

Step 2: Send you complaint

Submit your complaint to:
Richland County Government
Attn: Title VI Designee
2000 Hampton St
Columbia, SC 29204
gcs@richlandcountysc.gov

Complaints may also be filed with:
Federal Highway Administration
US Department of Transportation Office of Civil Rights
1200 New Jersey Ave, SE
Washington, DC 20590

SCDOT
Attn: Title VI Program
PO Box 191
Columbia, SC 29229

Complaint Dismissal

A complaint may be recommended for dismissal for the following reasons:

  • The complainant request withdrawal of the complaint.
  • The complainant fails to respond to repeated requests for additional information needed to process the complaint.
  • The complainant cannot be located after reasonable attempts to contact.

Investigation of Complaints

In cases where the County assumes responsibility for investigation, the County will provide the respondent with the opportunity to respond to the allegations in writing. The County will designate an investigative team responsible for evaluating the complaint, developing an investigative plan, conducting interviews, collecting and analyzing evidence, and preparing an investigative report.

Richland County’s final investigative report will be submitted to the Federal Highway Administration (FHWA), or appropriate federal agency, within 90 days of receipt of the complaint. FHWA will issue a final agency decision (FAD) and provide written notification of the decision to the complainant and respondent.

Appeals

If the complainant does not agree with the decision, he/she may file an appeal to:

County Administration
2020 Hampton St Suite 4069
Columbia, SC 29204

  • Appeals must be submitted within 30 days of receiving your decision
  • Appeals must be in writing

Limited English Proficiency (LEP)

The federal government and recipients of federal financial assistance are required to take reasonable steps to ensure that Limited English Proficiency (LEP) persons have meaningful access to programs, services, and information. This LEP Plan serves as a guide in addressing Richland County responsibilities as a recipient of federal financial assistance from the U.S. Department of Transportation (DOT) concerning the needs of individuals with limited English language skills. Further, this plan is developed in accordance with Title VI of 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 under any Richland County Government-assisted program or activity because they face challenges communicating in English.

Bases of Authority

Discrimination against a person because of their limited ability to use the English language is a form of national origin discrimination, which is prohibited by Title VI of the Civil Rights Act of 1964. One requirement of Title VI to publish guidance for its respective recipients clarifying that obligation to ensure discrimination does not occur. The USDOT issued policy guidance, "DOT Guidance to Recipients on Special Language Services to LEP Beneficiaries" to clarify the responsibilities of recipients of federal financial assistance and to ensure compliance with LEP regulations. These regulations impact state and local government agencies, including Richland County Government, private and non-profit entities, and other sub recipients of Richland County Government-assisted funding.

Plan Summary

This plan details procedures on how to identify a person who may need language assistance, the ways in which assistance may be provided, the approach for training staff, how to notify LEP person that assistance is available, and information for future plan updates.

In developing this plan, Richland County will utilize the U.S. DOT four-factor LEP analysis which considers the following:

  1. The number or proportion of LEP persons in the County service area to be served - this Plan focuses on all Limited English Proficiency individuals, which makes up the majority of the non-English speaking population in Richland County. That equates to approximately 14,000 LEP persons to be served.
  2. The frequency with which LEP individuals come in contact with County services - we have evaluated this factor by identifying the departments that have the heaviest contact with the public and by surveying departments to determine where the greatest need is for translation and interpretative services.
  3. The nature of importance of the program, activity or service provided by the County to the LEP population - this factor is used to prioritize different aspects of the LEP Plan during implementation; and
  4. The resources available to the County and overall cost to provide LEP assistance.

Monitoring, Evaluation, and Updating

The Title VI Designee monitors the progress of the plan and maintain the plan components. This Plan is designed to be flexible and easily updated. The County reviews and update its Four-Factor Analysis and Language Access practices at least annually, or more frequently as needed. This review considers updated demographic data, the frequency and nature of language assistance requests, feedback from LEP individuals and community organizations, and any changes to County programs or services. These efforts ensure ongoing compliance with Title VI of the Civil Rights Act of 1964 and related federal LEP guidance, specifically with regards to changes being made at the federal level regarding the LEP Program.

Each update should examine all plan components such as:

  • How LEP persons were encountered?
  • Were LEP persons’ needs met?
  • What is the current LEP population in Richland County, South Carolina?
  • Has there been any change in the types of language assistance where translation services are needed?
  • Is there still a need for continued language assistance for previously identified Richland County programs?
  • Have Richland County’s available resources, such as technology, staff, and financial cost changed?
  • Has Richland County fulfilled the goals of the LEP Plan; and
  • Were any complaints received?

Any questions or comments regarding this plan should be directed to the Richland County Government Title VI Designee.

Richland County Government
Title VI Designee
2000 Hampton St
Columbia, SC 29204
Phone: 803-766-5120
Email: gcs@richlandcountysc.gov

Accessibility for Individuals with Disabilities

The American with Disabilities Act (ADA) of 1990 encourages the involvement of people with disabilities in the development and improvement of transportation and paratransit plans and services. In accordance with ADA guidelines, all meetings conducted by Richland County Government will take place in locations that are accessible to persons with mobility limitations. Also, auxiliary aids and services are provided when necessary to ensure effective communications, unless an undue burden or fundamental alteration would result, to allow a person with a disability to participate. “Auxiliary aids” include such services or devices as qualified interpreters, assistive listening headsets, telecommunication devices for deaf persons (TDD’s), videotext displays, Brail materials, and larger print materials. Richland County public meeting notices specify that special accommodations will be provided upon request.

All public involvement activities comply with the Americans with Disabilities Act (ADA):

  • Meetings are held in ADA-accessible facilities
  • Auxiliary aids and services (e.g., sign language interpreters, large print materials) are provided upon request
  • Virtual participation options are offered when feasible
  • Public notices include information on how to request accommodations