Title VI

Overview

Richland County Government Title VI Program Plan

June 2025

Draft

Introduction and Purpose

Richland County, South Carolina Government is a recipient of federal financial assistance for some County programs, services, and facilities. This requires Richland County to comply with various non-discrimination laws and regulations, including Title VI of the Civil Rights Act of 1964. Richland County Government also requires that their sub‐recipients adhere to state and federal law and other related statutes. In the event that non‐compliance is discovered, the County will make a good faith effort to correct any deficiencies arising out of complaints related to Title VI; and evaluate the impact of any program or activity on the affected Title VI populations.

Title VI is an overarching civil rights law which prohibits discrimination in any program, service or activity that receives federal assistance. It assures 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 benefit of, or be otherwise subjected to discrimination under any program or activity receiving federal assistance." Since 1964, Title VI has been broadened by other statues to prohibit discrimination based on gender, age, disability, and socioeconomic status. Further, the Civil Rights Restoration Act of 1987 clarified that discrimination is prohibited throughout an entire agency if any part of the organization receives federal funds.

Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency (LEP)," provides that individuals who have a limited ability to read, write and speak, or understand English are entitled to language assistance. As an inclusive county, Richland County welcomes a diverse population and remains dedicated to providing equal access to services for all citizens of the county. The County provides technical assistance, resources, guidance and other information regarding Title VI to maintain standards of compliance, and takes reasonable steps to provide meaningful access to services for persons with Limited English Proficiency (LEP).

The goals of Richland County’s Title VI Program are:

  1. To assign roles, responsibilities, and procedures for ensuring compliance with Title VI of the Civil Rights Act of 1964 and related regulations and directives;
  2. To ensure that people affected by Richland County’s programs and projects receive the services, benefits, and opportunities to which they are entitled without regard to race, color, or national origin;
  3. To prevent discrimination in Richland County programs and activities, whether those programs and activities are federally funded or not;
  4. To establish procedures for identifying impacts in any program, service, or activity that may create illegal adverse discrimination on any person because of race, color, or national origin; or on minority populations, low-income populations, the elderly, and all interested persons and affected Title VI populations;
  5. To establish procedures to annually review Title VI compliance within specific program areas within Richland County;
  6. To set forth procedures for filing and processing complaints by persons who believe they have been subjected to illegal discrimination under Title VI in City services, programs or activities.

This guide is not a comprehensive inventory of all aspects of the Title VI requirements, but rather a framework for subrecipients striving to establish a compliant Title VI program. Richland County is committed to achieving full compliance and expects every department, manager, supervisor, employee, and sub-recipient of federal-aid funds administered by the County to be aware of the responsibilities and requirements under Title VI and related non-discrimination statutes. The County has developed this Title VI Plan to assure that services, programs, and activities are offered, conducted, and administered fairly, without regard to race, color, or national origin of the participants or beneficiaries of federally funded programs, services, or activities.

Title VI Policy Statement (authorities)

Standard U.S. DOT Title VI Assurances

The Richland County Government (LPA) (hereinafter referred to as the "Recipient") HEREBY AGREES THAT, as a condition to receiving any Federal financial assistance from the U.S. Department of Transportation (DOT) through the Federal Highway Administration (FHWA) or the Federal Transit Administration (FTA), is subject to and will comply with the following:

Statutory/Regulatory Authorities

  • Title VI of the Civil Rights Act of 1964(§42 U.S.C. 2000d et seq., 78 stat. 252), (prohibits discrimination on the basis of race, color, national origin);
  • 49 C.F.R. Part 21(entitled Non-discrimination in Federally-Assisted Programs of the Department of Transportation-Effectuation of Title VI of the Civil Rights Act of 1964);
  • 28 C.F.R. section 50.3 (U.S. Department of Justice Guidelines for Enforcement of Title VI of the Civil Rights Act of 1964), The preceding statutory and regulatory cites hereinafter are referred to as the “Acts” and “Regulations”, respectively.

General Assurances

In accordance with the Acts, the Regulations, and other pertinent directives, circulars, policy, memoranda, and/or guidance, the Recipient hereby gives assurance that it will promptly take any measures necessary to ensure that

“No person in the United States will, 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,” for which the Recipient receives Federal financial assistance from the Department of Transportation, including the FEDERAL HIGHWAY ADMINISTRATION (FHWA) AND THE FEDERAL TRANSIT ADMINISTRATION (FTA).

The Civil Rights Restoration Act of 1987 clarified the original intent of Congress, with respect to Title VI and other Non-discrimination requirements (The Age Discrimination Act of 1975, and Section 504 of the Rehabilitation Act of 1973), by restoring the broad, institutional-wide scope and coverage of these non-discrimination statutes and requirements to include all programs and activities of the Recipient, so long as any portion of the program is Federally assisted.

Specific Assurances

More specifically, and without limiting the above general Assurance, the Recipient agrees with and gives the following Assurances with respect to its Federally-assisted programs:

  1. The Recipient agrees that each "activity”, “facility”, or “program”, as defined in §§21.23(b) and 21.23(e) of 49 C.F.R. §21 will be (with regard to an “activity”) facilitated, or will be (with regard to a facility (operated, or will be (with regard to a “program”) conducted in compliance with all requirements imposed by, or pursuant to the Acts and, the Regulations.
  2. That the Recipient will insert the following notification in all solicitations for bids, Requests for Proposals for work, or material subject to the Acts and the Regulations made in connection with all programs and activities and, in adapted form, in all proposals for negotiated agreements regardless of funding source:

    "Richland County Government (LPA), in accordance with Title VI of the Civil Rights Act of 1964 (78 Stat. 252, 42 U.S.C §§2000d to 2000d-4) and the Regulations, hereby notifies all bidders that it will affirmatively ensure that in any contract entered into pursuant to this advertisement, disadvantaged business enterprises will be afforded full and fair opportunity to submit bids in response to this invitation and will not be discriminated against on the grounds of race, color, or national origin in consideration for an award."
  3. The Recipient will insert the clauses of Appendix A and E of this Assurance in every contract or agreement subject to the Acts and the Regulations.
  4. The Recipient will insert the clauses of Appendix B of this Assurance, as a covenant running with the land, in any deed from the United States effecting or recording a transfer of real property, structures, use, or improvements thereon, or interest therein to a Recipient.
  5. That where the Recipient receives Federal financial assistance to construct a facility, or part of a facility, the Assurance will extend to the entire facility and facilities operated in connection therewith.
  6. That where the Recipient receives Federal financial assistance in the form, or for the acquisition or real property or an interest in real property, the Assurance will extend to the rights to space on, over, or under such property.
  7. That the Recipient will include the clauses set forth in Appendix C and Appendix D of this Assurance, as a covenant running with the land, in any future deeds, leases, licenses, permits, or similar instruments entered into by the Recipient with other parties:

    (a) for the subsequent transfer of real property acquired or improved under the applicable activity, project, or program; and
    (b) for the construction or use of, or access to, space on, over or under real property acquired, or improved under the applicable activity, project, or program.
  8. That this Assurance obligates the Recipient for the period during which Federal financial assistance is extended to the program, except where the Federal financial assistance is to provide, or is in the form of, personal property, or real property, or interest therein, or structures or improvements thereon, in which case the Assurance obligates the Recipient, or any transferee for the longer of the following periods:

    (a) the period during which the property is used for a purpose for which the Federal financial assistance is extended, or for another purpose involving the provision of similar services or benefits; or
    (b) the period during which the Recipient retains ownership or possession of the property.
  9. The Recipient will provide for such methods of administration for the program as are found by the Secretary of Transportation or the official to whom he/she delegates specific authority to give reasonable guarantee that it, other recipients, sub-recipients, sub-grantees, contractors, subcontractors, consultants, transferees, successors in interest, and other participants of Federal financial assistance under such program will comply with all requirements imposed or pursuant to the Acts, the Regulations and this Assurance.
  10. The Recipient agrees that the United States has a right to seek judicial enforcement with regard to any matter arising under the Acts, the Regulations, and this Assurance.

THIS ASSURANCE is given in consideration of and for the purpose of obtaining any and all Federal grants, loans, contracts, property, discounts or other Federal financial assistance extended after the date hereof to the Recipient by the Department of Transportation under any program or activity and is binding on it, other recipients, sub-grantees, contractors, subcontractors, transferees, successors in interest and other participants. The person or persons whose signatures appear below are authorized to sign this Assurance on behalf of the Recipient.

Notice to the Public

Program Administration

Richland County’s Title VI Plan is administered by the Government and Community Services Director under the direct supervision of the County Administrator. The Title VI Coordinator has the responsibility for coordinating the administration of Title VI and related statutes, programs, plans, and assurances. Compliance determinations are made on a case-by-case basis. For more information, please contact the Title VI Coordinator by email at harris.phillip@richlandcountysc.gov or phone at 803-576-5120.

Title VI Organization and Staffing Chart

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The image shows that the Title VI Coordinator reports to the Government and Community Services office which reports to the County Administrator.

Title VI Coordinator Responsibilities

The Title VI Coordinator is charged with the responsibility for implementing, monitoring, and enforcing Richland County’s compliance with Title VI. These responsibilities are as follows:

  1. Conduct Title VI compliance reviews of department program area activities of federal financial assistance;
  2. Collects data (race, color, national origin, sex disability, and age) on the County’s relevant boards, commissions, and committees, and participants in the beneficiaries of the County’s programs, activities, and services;
  3. Coordinate, conduct or facilitate a training program on Title VI for County’s employees, contractors, and recipients of federal grant funds;
  4. Ensure that Title VI requirements are included in policy directives and that the procedures used have built in safeguards to prevent discrimination;
  5. Manage the County’s Limited English Proficiency (LEP) Program ensuring that County information and services are accessible to customers;
  6. Develop and disseminate Title VI information for public dissemination, where appropriate.
  7. Conduct meetings to review the project impact;
  8. Coordinate the gathering of environmental information for the Annual Title VI Update Report;
  9. Maintain Legislative and Procedural Information – Federal laws, rules and regulations, the current Richland County Title VI Plan, and other resource information pertaining to the implementation and administration of the County’s Title VI program;
  10. Process, review and investigate Title VI complaints received in accordance with Richland County's Complaint Procedures. If people believe they or any other program beneficiaries have been subject to unequal treatment or discrimination as to the receipts of benefits and/or services, or on the grounds of race, color, national origin, or gender, they may file a complaint with Richland County.

Employee Training

Richland County is committed to ensure on-going Title VI training for our Title VI Coordinator and all staff that has Title VI responsibilities. The Title VI Coordinator provides Title VI training videos in closed captioning and on-demand for employees, contractors, subrecipients, and Title VI program and service administrators. The training provides comprehensive information on Title VI provisions, application to program operations, and identification of Title VI issues and resolution of complaints.

All employees are expected to follow the Title VI policy and the guidelines set forth. Title VI policy education and literature are available to all Richland County employees. New employees will be provided access to the Title VI informational brochure at New Employee Orientation. Current employees are provided with updated education and literature as the County deems necessary. Training will consist of review of the current Title VI Plan and Title VI Brochure located in Appendix A and will be provided in person or virtual/online.

Public Outreach and Involvement

Public outreach and involvement apply to and affects Richland County’s mission and work program as it relates to Richland County, South Carolina’s service planning. In seeking public comment and review, Richland County makes a concerted effort to reach all segments of the population, including people from minority and low-income communities, and organizations representing these and other protected classes. The County utilizes a broad range of public outreach information and involvement opportunities, including a process for written comments, public meetings after effective notice, settings for open discussion, information services, and consideration of and response to public comments. Richland County continues to evaluate means of informing persons of their rights with all Federal and state laws, including status referenced by Title VI.

Complaint Procedures

These complaint procedures cover all complaints filed under Title VI of the Civil Rights Act of 1964 as amended, Section 504 of the Rehabilitation Act of 1973, Civil Rights Restoration Act of 1987. They are part of an administrative process, which does not provide for remedies that include punitive damages or compensatory remuneration for the complainant. Every effort is made to obtain early resolution of complaints at the lowest managerial/administrative level possible. There is an option of informal mediation meeting(s) between the affected parties and the investigator that may be used for resolution, at any stage of the process. The investigator will make every effort to pursue a resolution of the complaint.

Procedures

Any person who believes that he/she or any specific class of persons has been subjected to discrimination or retaliation prohibited by any of the Civil Rights authorities prohibited under Title VI based upon race, color, sex, age, national origin or disability may file a written complaint with Richland County. The County includes the following language on all printed information materials, the County’s website, in press releases, in public notices, in published documents, and on documents provided to customers and to members of the public:

Richland County Government is committed to ensuring that no person is excluded from participation in programs and activities or is denied the benefits of its services based on race, color or national origin, as protected by Title VI of the Civil Rights Act of 1964.

For additional information on the County’s nondiscrimination policies and procedures, or to file a complaint, please visit our website at www.richlandcountysc.gov, or contact the Director of Government and Community Services, Title VI Coordinator for Richland County.

Instructions for filing Title VI complaints are posted on the County’s website and are also included in information disseminated to the employees, contractors, and members of the public as needed.

1. How a complaint shall be filed:

The complaint is to be filed in the following manner:

  1. A formal complaint must be filed within 180 calendar days of the alleged occurrence, unless the time for filing is extended by the processing agency. The complaint shall be in writing and signed by the complainant(s). Any person with a disability may request to file a complaint using an alternative format. Richland County prefers, but does not require, a complainant to use the County Complaint Form when submitting a complaint. The complaint should include:
    i. The complainant's name, address, and contact information (i.e., telephone number, email address, etc.);
    ii. The date(s) of the alleged act of discrimination (if multiple days, include the date when the complainant(s) became aware of the alleged discrimination and the date on which the alleged discrimination was discontinued or the latest instance); and
    iii. A description of the alleged act of discrimination to include sufficient information to understand the facts that led the complainant to believe that discrimination occurred in a program.
  2. In the case where a complainant is unable or incapable of providing a written statement, a verbal complaint of discrimination may be made to the Title VI Coordinator or designee. Under these circumstances, the complainant will be interviewed, and the Coordinator will record or memorialize the interview.
  3. The complaint shall be submitted to Dr. Phillip Harris, Director of Government and Community Services and Title VI Coordinator, 2020 Hampton St. Columbia, SC 29204 (or via email at harris.phillip@richlandcountysc.gov, or through the harassment online form at www.richlandcountysc.gov/harassment. The complainant will receive acknowledgement that the complaint has been received and forwarded to the processing.
2. Where to file a complaint:

Complaints may be submitted through:

A. The online complaint form – www.richlandcountysc.gov/harassment,

B. Employee Protection Line – 800-576-5262 County Code 30042, or

C. The Title VI Coordinator, Dr. Phillip Harris, may be reached at harris.phillip@richlandcountysc.gov or phone at 803-576-5120.

3. Time frame within which the complaint shall be processed by the agency:

If a complaint is submitted through the online process, the complainant will receive an email acknowledging receipt of the complaint. The Title VI Coordinator shall begin an investigation of the claim to substantiate or refute allegations. The investigation shall, at a minimum, include discussing the complaint with the complainant, the alleged offender, and any witnesses. A determination as to whether the complaint is substantiated or un-substantiated will be made as quickly as possible. A report of the investigation must include recommendations for remedial action. The Title VI Coordinator will be maintained in a log of all Title VI complaints including: date of receipt, determination, and action taken. The complaint log will be retained for a period of no less than four (4) years.

4. Processing the Complaints

The Title VI Coordinator will process all Title VI complaints. The Title VI Coordinator is responsible for:

  • Reviewing the complaint upon receipt to ensure that all required information is provided, the complaint meets the filing deadline date which is 180 days from the date the alleged discriminatory act occurred and falls within the County’s jurisdiction;
  • Investigating the complaint. If the complaint is against Richland County, then the Administration Office or it’s designee will investigate the complaint. Additionally, a copy of the complaint will be forwarded to the County Attorney.
  • Any comments or recommendations from legal counsel will be reviewed by the Title VI Coordinator and the Administration Office.
  • Once the County has concluded its investigation, the Title VI Coordinator will report findings, and all parties associated with the complaint will be properly notified that there is a resolution.
5. Withdrawing a complaint:

Complainants may withdraw their complaint at any time by notifying the office or Title VI Coordinator in writing. Withdrawal of a complaint may or may not result in the termination of the Title VI Coordinator’s investigation or any subsequent action. The Title VI Coordinator will maintain records of the complaint, including date of receipt and action taken, for a period of no less than four (4) years.

6. Dismissal

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

  • The complainant requests 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 the complainant.

Hearings and Appeals

Within 30 days of the receipt of the written notice of resolution, a complainant may file a written appeal from the Title VI Coordinator’s final determination of the complaint. Appeals shall be set forth in writing and directed to the County Administrator, Mr. Leonardo Brown, and may request an in-person hearing. Such requests shall be set forth in writing with the written appeal. If a hearing is requested, the complainant shall be notified of the date, time, and location of the hearing. Within 14 days of the County Administrator’s receipt of the appeal, the complainant shall be notified of the agency’s final determination of the complaint/appeal. The federal law requires that a complaint be filed with the department within 180 days of the alleged discrimination. If the complainant chooses to withdraw his/her complaint, the reason for withdrawal shall be documented in writing.

Anti-Retaliation Policy

It is Richland County’s policy that persons filing a complaint of discrimination should have the right to do so without fear of retaliation, interference, intimidation, coercion, or reprisal.

Retaliation involves three elements:

  1. An individual engaged in protected activity of which the recipient was aware;
  2. The recipient took a significantly adverse action against the individual; and
  3. There is evidence to show the protected activity was the cause of the recipient’s adverse action.

Retaliation is treated as a separate act of prohibited discrimination, even if it happens in response to a disparate treatment or disparate impact allegation.

Language Assistance Plan for Limited English Proficiency

Richland County Government’s Language Assistance Plan has, as its purpose, seeks to help all citizen’s, regardless of English proficiency, experience meaningful and equitable access to County information, programs, services, and civic engagement. The establishment and operation of this policy meets the objectives set forth in Title VI and Executive Order 13166. Furthermore, Executive Order 13166 establishes compliance standards to ensure that the programs and activities that are provided in English are also accessible to those communities with Limited English Proficiency (LEP).

Richland County has taken steps to ensure that rendered programs and services are at no cost to the citizens with Limited English Proficiency. The County’s Title VI Policy and Complaint Procedures are hosted on the County’s webpage in English and made available in other languages. Richland County translates documents on a case-by-case basis. The Title VI Coordinator will review the LAP annually to determine if any modifications and updates are necessary to meet language assistance deficiencies.

To determine if or when language assistance is required, Richland County assess the program, service, or activity by using the following four factors:

  1. The number of LEP persons eligible to be served or likely to be impacted by the County’s program, service, or activity;
  2. The frequency with which LEP individuals come into contact with the program, service, or activity;
  3. The nature and importance of the program, service, or activity to people’s lives; and
  4. The resources available to Richland County.

Providing Notice to LEP Persons

LEP persons are notified of the availability of language assistance through the following approaches:

  • Following our Title VI policy statement included on vital County documents.
  • County website utilizes Google translation feature.
  • through signs posted in County buildings and facilities.
  • through ongoing outreach efforts to community organizations, schools, and religious organizations.

Annual Reporting

Data Collecting

Richland County program areas are responsible for collecting data when implementing and/or maintaining activities, encounters, events, programs, projects, or services with the public. Data collection includes, at a minimum:

  • Race,
  • National origin,
  • Primary non-English language in the project impact or service area(s),
  • Number of LEP individuals, by language group, who requested or received spoken language services.

Each program area is responsible for collecting Title VI/Nondiscrimination-related data and analyzing the data annually to identify and address any trends or patterns of discrimination. Data collection is key to ensuring that Richland County programs, services, facilities and projects effectively meet the needs of all citizens without discrimination.

Reporting

Analysis

Appendices

Recipient Compliance

Title VI Assurance Form (Online)

Click here to view form.

Title VI Assurance Form (Print, Sign and Mail)

Title VI Assurance of Compliance(DOCX, 37KB)

Download, print and mail to:

Dr. Phillip Harris
Richland County Government
2020 Hampton St., Ste. 3014
Columbia, SC 29204

Discrimination Complaint Form

Discrimination Complaint Log

Notifying the Public to Rights Under Title VI

Richland County operates its programs and services without regard to race, color, and national origin in accordance with Title VI of the Civil Rights Act of 1964. Any person who believes they have been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with Richland County.

For more information on Richland County Title VI Plan, and the obligations and procedures to file a complaint, contact 803-766-5120; email harris.phillip@richlandcountysc.gov or visit the Government and Community Services Office at Suite 3014 202 Hampton St, Columbia, SC 29204. For more information on how to contact Richland County to find out about Title VI, visit https://richlandcountysc.gov/titlevi.

A complainant may file a complaint directly with Richland County Title VI Coordinator by following the complaint procedures also found on the agency’s website. A complaint can also be filed with

If information is needed in another language, contact 803-766-5120. Si necesita información en otra idioma, por favor contacto 803-766-5120.

Americans with Disabilities Act (ADA) Transition Plan

This ADA Transition Plan reflects Richland County’s commitment to ADA compliance, and details the stages of the County’s plan and timeline for: (1) evaluating accessibility by identifying any structural barriers associated with public facilities; (2) identifying accommodations and/or modifications that can be provided to make programs and services accessible; and (3) prioritizing the remediation of any deficiencies and formulating a budget and schedule for those improvements.

Introduction

ADA regulations prohibit discrimination against individuals on the basis of disability and require state and local governments to make their programs and services accessible to persons with disabilities. These requirements focus on providing accessibility by addressing and eliminating structural barriers associated with public facilities.

As detailed below, Richland County has made a significant commitment to improving the accessibility of its public facilities. The purpose of this Plan is to ensure the County identifies prohibited structural barriers to its public facilities, and, where structurally feasible, schedules and implements ADA required improvements in order to remove those barriers.

The ADA requires that the Transition Plan include the following components:

  • Identification of physical barriers in a public entity’s facilities that limit the accessibility of its programs, activities, or services to individuals with disabilities;
  • Identification of the methods to be used to remove any barriers limiting accessibility;
  • A schedule for completion of the necessary steps to achieve accessibility in public facilities; and
  • The name of the public entity’s ADA Coordinator.

Step 1: Identification of Physical Barriers in Richland County's Facilities

The first phase of the ADA Transition Plan is to evaluate Richland County’s public facilities for accessibility. The Risk Manager, and officials from the Planning and Buildings and Grounds Departments will coordinate to conduct accessibility evaluations of the following facilities:

  • Sidewalks, crosswalks, and curb ramps,
  • Publicly accessible buildings, and
  • Parking lots serving publicly accessible buildings.

For each facility evaluated, a survey of the County’s Public Facilities (“Access Survey”) will be completed. Any deficiencies, suggested improvements, and observations relating to structural feasibility of improvements will be noted and recorded on the Survey. An Inventory of Public Facilities (“the Inventory”) will also be created, and will serve as the central database for identified structural barriers, suggested improvements, and comments relating to structural feasibility of improvements.

Evaluation of Sidewalks, Crosswalks, and Curb Ramps

The Survey will contain the following ratings to assess the condition of each Richland County sidewalk, crosswalk, and curb ramp:

Rating 1 – Not Applicable: A facility not considered to require accessibility, for example, limited access highways.

Rating 2 – Not Accessible: Significant discontinuity such as steps, no ramps, more than 100 feet of unpaved walkway, heaving, vertical displacement, other severe distress, flooding, etc.

Rating 3 – Partially Accessible: Not designed to current standards, problems with geometry of sidewalks, ramps and landings, no detectable warnings, handrails, etc.

Rating 4 – Accessible: May need additional improvements, for example circuitous routes, insufficient width, etc.

Rating 5 – Fully Accessible: Designed to current standards, but reasonable accommodations may still be required for individual cases.

Step 2: Identification of Methods to Remove Barriers

The second phase of Richland County’s ADA Transition Plan is to develop a method to remove barriers. This includes identification of the nature of needed improvements and a determination regarding structural feasibility of improvements under the ADA standards, and prioritization of necessary improvements.

Once the necessary improvements have been identified and prioritized, this information, along with a list of any improvements determined to be physically unfeasible, will be presented at a to the appropriate department.

A. Nature of Improvements and Structural Feasibility

The nature of necessary improvements will be determined during Step 1 – the accessibility evaluation of Richland County facilities – and will be incorporated into the ADA Transition Plan after completion of Step 1. Any improvements that County officials determine are not structurally feasible, based on ADA regulations, will also be incorporated into the Plan.

B. Priority of Improvements

The priority of improvements to parking lots and publicly accessible spaces in Richland County buildings will be based on the severity of the accessibility barrier and the frequency of public presence at the facility. All new construction or renovations to existing facilities have complied with ADA standards. As such, the County does not expect that its publicly accessible buildings and parking lots will require major structural improvements.

Step 3: Schedule for Completion of Necessary Improvements

Once the Inventory of Public Facilities has been completed, and necessary improvements have been prioritized as provided above, Richland County will formulate an estimated budget for the improvements. The schedule for improvements will depend heavily upon the number and severity of the deficiencies identified during the accessibility evaluation, and the costs associated with the improvements. Richland County however, reiterates its commitment to making its public facilities accessible to all persons, regardless of disability.

Nondiscrimination Authorities

Federal Laws

  • Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq., 78 stat. 252), (prohibits discrimination on the basis of race, color, national origin); and 49 CFR Part 21.
  • The Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, (42 U.S.C. § 4601), (prohibits unfair treatment of persons displaced or whose property has been acquired because of Federal or Federal-aid programs and projects);
  • Federal-Aid Highway Act of 1973, (23 U.S.C. § 324 et seq.), (prohibits discrimination on the basis of sex);
  • Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. § 794 et seq.), as amended, (prohibits discrimination on the basis of disability); and 49 CFR Part 27;
  • The Age Discrimination Act of 1975, as amended, (42 U.S.C. § 6101 et seq.), (prohibits discrimination on the basis of age);
  • Airport and Airway Improvement Act of 1982, (49 USC § 4 71, Section 47123), as amended, (prohibits discrimination based on race, creed, color, national origin, or sex);
  • The Civil Rights Restoration Act of 1987, (PL 100-209), (Broadened the scope, coverage and applicability of Title VI of the Civil Rights Act of 1964, The Age Discrimination Act of 1975 and Section 504 of the Rehabilitation Act of 1973, by expanding the definition of the terms "programs or activities" to include all of the programs or activities of the Federal-aid recipients, sub-recipients and contractors, whether such programs or activities are Federally funded or not);
  • Titles II and III of the Americans with Disabilities Act, which prohibit discrimination on the basis of disability in the operation of public entities, public and private transportation systems, places of public accommodation, and certain testing entities (42 U.S.C. §§ 12131-12189) as implemented by Department of Transportation regulations at 49 C.P.R. parts 37 and 38;
  • The Federal Aviation Administration's Non-discrimination statute (49 U.S.C. § 47123) (prohibits discrimination on the basis of race, color, national origin, and sex);
  • Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, which ensures discrimination against minority populations by discouraging programs, policies, and activities with disproportionately high and adverse human health or environmental effects on minority and low-income populations;
  • Executive Order 13166, Improving Access to Services for Persons with Limited English Proficiency, and resulting agency guidance, national origin discrimination includes discrimination because of limited English proficiency (LEP). To ensure compliance with Title VI, you must take reasonable steps to ensure that LEP persons have meaningful access to your programs (70 Fed. Reg. at 74087 to 74100);
  • Title IX of the Education Amendments of 1972, as amended, which prohibits you from discriminating because of sex in education programs or activities (20 U.S.C. 1681 et seq).

Title VI Brochure