HomeMy WebLinkAboutItem 6f Adoption of Title VI Programs for SLO Transit and PW Department Item 6f
Department: Public Works
Cost Center: 5201/5001
For Agenda of: 9/2/2025
Placement: Consent
Estimated Time: N/A
FROM: Aaron Floyd, Interim Public Works Director
Prepared By: Matt Pennon, Diversity, Equity, and Inclusion Manager; Natalie Harnett,
Policy and Projects Manager; Alex Fuchs, Mobility Services Business
Manager
SUBJECT: ADOPTION OF TITLE VI PROGRAMS FOR SLO TRANSIT AND FOR THE
PUBLIC WORKS DEPARTMENT
RECOMMENDATION
1. Adopt a Draft Resolution entitled, “A Resolution of the City Council of the City of San
Luis Obispo, California, approving the adoption of San Luis Obispo (SLO) Transit’s
Federal Transit Administration Title VI Program update for federal fiscal years 2026-
2028”; and (Attachment A)
2. Adopt a Draft Resolution entitled, “A Resolution of the City Council of the City of San
Luis Obispo, California, approving the adoption of the Public Works Department’s Title
VI Program Plan.” ( Attachment B)
POLICY CONTEXT
The City of San Luis Obispo (City) is a direct recipient of Federal Transit Administration
(FTA) funds and, as such, is subject to Title VI of the Civil Rights Act of 1964 and related
non-discrimination requirements under U.S. Department of Transportation regulations.
The City is also a subrecipient of Federal Highway Administration (FHWA) funds through
the California Department of Transportation (Caltrans). Title VI prohibits discrimination on
the basis of race, color, or national origin in programs and activities rec eiving federal
financial assistance.
In accordance with FTA Circular 4702.1B, all direct recipients must submit a Title VI
Program every three years to demonstrate compliance. This program must be approved
by the recipient’s governing board prior to submission to the FTA. For SLO Transit, the
current update is due by October 1, 2025.
Separately, Caltrans, acting as a pass-through agency for FHWA funds, is requiring that
recipient agencies, including the City of San Luis Obispo, establish a Title VI program that
is subject to review by Caltrans pursuant to 23 CFR 200.9(b)(7).
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Item 6f
While the City’s Transit Program has historically maintained its own standalone Title VI
Program, the City has now developed a department-wide Title VI Program Plan for Public
Works in response to Caltrans’ request. Although there is some overlap between the two
plans, the Transit Program includes additional operational requirements, including
specific public outreach and service monitoring requirements related to ongoing transit
operations—not just capital projects.
To streamline review and approval, both the updated SLO Transit Title VI Program and
the new Public Works Title VI Program are being presented to the City Council together,
as separate attachments, within a single Council agenda item.
Both Title VI Programs must be adopted by the recipient’s governing body— in this case,
the City Council—prior to submission to the FTA and to Caltrans. Attachment A includes
a draft Resolution approving the SLO Transit Title VI Program for federal fiscal years
2026–2028. Attachment B includes a draft Resolution approving the Public Works
Department Title VI Program.
DISCUSSION
Background
The discussion below outlines the key elements required to be included in each of the
plans.
Attachment C – SLO Transit Plan
The FTA provides financial assistance to agencies for the improvement, maintenance,
and operations of their respective transit systems. The objectives of the FTA’s Title VI
Program are to ensure that the level and quality of public transportation service i s
provided in a non-discriminatory manner; to promote full and fair participation in public
transportation decision-making without regard to race, color, or national origin; and to
ensure meaningful access to transit-related programs and activities by persons with
limited English proficiency. SLO Transit’s Title VI Program must include the following
elements to be considered in compliance:
1. A copy of SLO Transit’s Title VI notice to the public
2. A copy of the SLO Transit’s instructions to the public regarding how to file a Title
VI discrimination complaint, including a copy of the complaint form
3. A list of any public transportation-related Title VI investigations, complaints, or
lawsuits filed since the time of the last submission
4. A public participation plan and a summary of outreach efforts made since the last
Title VI Program submission
5. A copy of SLO Transit’s plan for providing language assistance to persons with
limited English proficiency
6. A table depicting the racial breakdown of the membership of transit-related, non-
elected planning boards, advisory councils or committees (i.e. Mass
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Item 6f
Transportation Committee)
7. System-wide service standards policies for vehicle load, vehicle headway, on-time
performance, service availability, vehicle assignments, and transit amenities
In compliance with federal statutory and administrative requirements, s taff updated SLO
Transit’s Title VI Program for federal fiscal years 2026-2028 (Attachment C). Once the
program update is approved, staff will submit it to the FTA for review and approval.
Attachment D – Public Works Plan
The FHWA provides financial assistance to agencies for the planning, construction, and
maintenance of transportation infrastructure. Its Title VI Program ensures that federally
funded highway programs are delivered in a non-discriminatory manner. In June 2025,
Caltrans conducted a Title VI Program assessment and found the City to be out of
compliance with updated Federal Highway Administration (FHWA) requirements —
something common among agencies that had not previously been asked to formalize a
Title VI Program. While the City already integrates many of these practices through its
Public Engagement and Noticing (PEN) Manual, this new Public Works Title VI Program
(Attachment D) formalizes that approach. Supporting documents will be posted to the
Public Works website, and will include the following elements required by Caltrans to be
considered compliant:
1. Title VI Implementation Plan (Title VI Plan)
2. Title VI Coordinator
3. Title VI/Non-Discrimination Policy Statement
4. Limited English Proficiency (LEP) Assessment (Four Factor Analysis)/ Language
Access Plan (LAP)
5. Dissemination of Title VI Information
6. Title VI Training for LPA Staff
7. Title VI Assurances in Contract Documents and Agreements
8. Title VI Complaint Procedures
9. Title VI Data Collection
10. Internal/External Title VI Reviews
11. Title VI Accomplishments and Goals Report (Title VI Annual Work Plan)
Once the program is approved, staff will submit it to Caltrans for review and approval.
Previous Council Actions
1. On January 21, 2020, City Council approved SLO Transit’s FFY2021-23 Title VI
Program update.
2. On March 21, 2023, City Council adopted Resolution No. 11401 approving SLO
Transit’s FFY2023-25 Title VI Program update and SLO Transit’s FY2022-23 Public
Transportation Agency Safety Plan.
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Item 6f
Public Engagement
The following is a summary of the outreach performed for SLO Transit’s Title VI Program
update.
1. Transit Rider Surveys – Between May 12 and May 16, 2025, 105 surveys from
current riders were collected to determine how well they read and speak English,
language(s) other than English spoken at home, language encounters with SLO
Transit staff, how they get information about SLO Transit services, and why they
ride the bus.
2. Community Partner Surveys – Between May 22 and June 10, 2025, community
partners were invited to complete a survey to assess the extent to which they
encounter Limited English Proficiency (LEP) populations, the types of services
they offer to LEP persons, challenges with serving pers ons with LEP, and
frequency of requests from LEP persons to translate/interpret transit information.
3. Informational Meetings – On June 11, 2025, staff held two in-person public
meetings (1:30 p.m. and 5:00 p.m.) to provide an overview of the Title VI Program
requirements and findings from the program update process. It was also an
opportunity for the public to provide feedback on SLO Transit’s services and
programs.
CONCURRENCE
The City’s Office of Diversity, Equity, and Inclusion concurs with the recommended
actions to adopt both Title VI Programs.
ENVIRONMENTAL REVIEW
The California Environmental Quality Act (CEQA) does not apply to the recommended
actions in this report, because the actions do not constitute a “project” under CEQA
Guidelines Sec. 15378.
FISCAL IMPACT
Budgeted: Yes Budget Year: 2025-26
Funding Identified: Yes
Fiscal Analysis:
Funding
Sources
Total Budget
Available
Current
Funding
Request
Remaining
Balance
Annual
Ongoing
Cost
General Fund $ 0 $ 0 $ 0 $ 0
Transit Fund $ 0 $ 0 $ 0 $ 0
Other:
Total $ 0 $ 0 $ 0 $ 0
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Item 6f
SLO Transit’s annual budget includes costs of printing services, digital and print
advertising, and for public outreach opportunities. These activities include production of
vital documents in both English and Spanish. No additional funds are needed to
implement the Title VI Program. Historically, 50 percent of SLO Transit’s eligible operating
expenses are funded through FTA financial assistance programs. SLO Transit’s operating
budget in FY 2025-26 is $5,992,190 which means half (approximately $3 million dollars)
would be ineligible for FTA assistance without an adopted Title VI Program . Additionally,
a majority of SLO Transit’s capital projects are funded through FTA programs including
procurement of electric buses, charging infrastructure, and maintenance of transit
facilities. Without access to FTA financial assistance, some or all of these projects may
not be able to move forward.
Over the years, the City has received FHWA-administered funding for multiple
infrastructure projects and remains committed to pursuing future opportunities. Most
notably, the City has been allocated over $10 million in Highway Bridge Program funds
for the Prado Road Bridge and Road Widening project. Formal adoption of this Title VI
Program is essential to safeguard current funding and ensure continued eligibility for
future federal assistance.
ALTERNATIVES
1. Council could choose to adopt only one of the two Title VI Programs—for
example, the Transit Program or the Public Works Program —while deferring or
declining adoption of the other. However, doing so may jeopardize the City’s eligibility
for federal funding through the respective agency (FTA or Caltrans/FHWA).
2. Council could choose not to adopt either Title VI Program. Council could choose
not to adopt either the SLO Transit or Public Works Title VI Program. Should Council
pursue this option, the City would become ineligible to receive financial assistance
from the FTA, which funds the majority of SLO Transit’s operating and capital costs.
Additionally, this could jeopardize the City’s access to FHWA funds administered
through Caltrans, potentially impacting future transportation and infrastructure
projects.
3. Council could choose to direct changes to one or both plans. Should Council
pursue this option, depending on how substantive the changes are, staff would either
return to Council at a later date with updated p lan(s) for adoption or Council could
approve the plans and direct staff make the necessary changes. Delaying Council
adoption could jeopardize the City’s eligibility for federal funding.
ATTACHMENTS
A - Draft Resolution approving SLO Transit’s Title VI Program Update
B - Draft Resolution approving the Public Works Department’s Title VI Program
C - SLO Transit Title VI Program, Final Draft
D - Public Works Department Title VI Program, Final Draft
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R ______
RESOLUTION NO. _____ (2025 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, APPROVING THE ADOPTION OF SAN LUIS
OBISPO (SLO) TRANSIT’S FEDERAL TRANSIT ADMINISTRATION
TITLE VI PROGRAM UPDATE FOR FEDERAL FISCAL YEARS 2026 -
2028
WHEREAS, the Federal Transit Administration (FTA) provides financial assistance
to develop new transit systems and improve, maintain, and operate existing systems ; and
WHEREAS, the recipients of FTA grants are responsible for managing their
programs in accordance with federal requirements and the FTA is responsible for
ensuring recipients follow federal statutory and administrative requirements including Title
VI of the Civil Rights Act of 1964; and
WHEREAS, the City of San Luis Obispo is a direct recipient of financial assistance
from the FTA for San Luis Obispo (SLO) Transit’s capital and operating costs required to
comply with federal requirements; and
WHEREAS, the FTA requires direct recipients to document their compliance with
Title VI requirements by submitting a Title VI Program approved by the recipient’s
governing board to the FTA every three years; and
WHEREAS, the City Council of the City of San Luis Obispo is SLO Transit’s
governing board and is must approve the Title VI Program update prior to submittal; and
WHEREAS, staff has prepared an updated Title VI Program for federal fiscal years
2026-2028 in accordance with federal statutory and administrative requirements and has
included all required elements for transit providers that operate fewer than 50 fixed route
vehicles and are located in an Urbanized Area of fewer than 200,000 in population.
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis
Obispo hereby take the following actions:
SECTION 1. The City Council hereby approves and adopts the San Luis Obispo
(SLO) Transit’s Title Program update for federal fiscal years 2026-2028.
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Resolution No. _____ (2025 Series) Page 2
R ______
SECTION 2. Environmental Review. The California Environmental Quality Act
(CEQA) does not apply to the recommended action because the action does not
constitute a “Project” under CEQA Guidelines Sec. 15378.
Upon motion of Council Member ___________, seconded by Council Member
___________, and on the following roll call vote:
AYES:
NOES:
ABSENT:
The foregoing resolution was adopted on this 2nd day of September 2025.
___________________________
Mayor Erica A. Stewart
ATTEST:
______________________
Teresa Purrington
City Clerk
APPROVED AS TO FORM:
______________________
J. Christine Dietrick
City Attorney
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the
City of San Luis Obispo, California, on ______________________.
___________________________
Teresa Purrington
City Clerk
Page 206 of 357
R ______
RESOLUTION NO. _____ (2025 SERIES)
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN LUIS
OBISPO, CALIFORNIA, APPROVING THE ADOPTION OF THE CITY OF
SAN LUIS OBISPO PUBLIC WORKS DEPARTMENT TITLE VI
PROGRAM
WHEREAS, the Federal Highway Administration (FHWA) provides financial
assistance to states, local governments, and tribal entities for planning, construction,
maintenance, and improvement of highways, bridges, and other surface transportation
infrastructure; and
WHEREAS, Local Public Agencies (LPAs) that receive FHWA funds through the
California Department of Transportation (Caltrans) are required to establish a Title VI
Program in compliance with 23 CFR 200.9(b)(7), which is subject to review by Caltrans;
and
WHEREAS, the City of San Luis Obispo is a Local Public Agency that receives
FHWA funds through Caltrans; and
WHEREAS, in June 2025, Caltrans’ Office of Local Civil Rights Compliance
completed a Title VI Program Assessment of the City of San Luis Obispo and determined
the City to be non-compliant with several FHWA Title VI Program requirements, issuing
findings and recommendations for corrective action; and
WHEREAS, in response to the notice of findings and recommendations, City staff
promptly undertook corrective action by preparing a Title VI Program to ensure
compliance with federal and state requirements, and will submit the adopted Program to
Caltrans following City Council approval; and
WHEREAS, Caltrans has closed out the 2025 assessment and will verify
completion of the identified corrective actions during the next scheduled program
assessment in June 2026, with the City required to submit an updated Title VI Program
Assessment Online Form by May 31, 2026.
NOW, THEREFORE, BE IT RESOLVED by the Council of the City of San Luis
Obispo hereby take the following actions:
SECTION 1. The City Council hereby approves and adopts the City of San Luis
Obispo Public Works Department Title VI Program, attached hereto as Exhibit A, in
accordance with FHWA and guidance from Caltrans.
SECTION 2. The City Council directs staff to implement the corrective actions
identified in the 2025 Caltrans Title VI Program Assessment and to prepare and submit
all required documentation for the next program assessment scheduled for June 2026.
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Resolution No. _____ (2025 Series) Page 2
R ______
SECTION 3. The City Council authorizes City staff to make administrative changes
to the Public Works Title VI Plan, including updates necessary to maintain compliance
with Caltrans requirements and revisions without further Council action.
SECTION 4. The City Council affirms its commitment to ensuring that all federally
funded programs, services, and activities are administered in a non -discriminatory
manner and in full compliance with Title VI of the Civil Rights Act of 1964.
SECTION 5. Environmental Review. The California Environmental Quality Act
(CEQA) does not apply to the recommended action because the action does not
constitute a “Project” under CEQA Guidelines Sec. 15378.
Upon motion of Council Member ___________, seconded by Council Member
___________, and on the following roll call vote:
AYES:
NOES:
ABSENT:
The foregoing resolution was adopted on this 2nd day of September 2025.
___________________________
Mayor Erica A. Stewart
ATTEST:
______________________
Teresa Purrington
City Clerk
APPROVED AS TO FORM:
______________________
J. Christine Dietrick
City Attorney
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the official seal of the
City of San Luis Obispo, California, on ______________________.
___________________________
Teresa Purrington
City Clerk
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Title VI Program for San Luis
Obispo (SLO) Transit, Operated
by the City of San Luis Obispo,
CA
Public Review Draft: June 11, 2025
Final Draft: September 2, 2025
Prepared by:
City of San Luis Obispo
Public Works Department
990 Palm Street
San Luis Obispo, CA 93401
Tel: (805) 781-7121
www.slocity.org
Page 1 of 41 Page 209 of 357
Page 2 of 41 Page 210 of 357
Table of Contents
I: CIVIL RIGHTS STATEMENT ...................................................................................................................................... 4
II: TITLE VI NOTICE TO THE PUBLIC .......................................................................................................................... 5
III: TITLE VI COMPLAINT PROCEDURES ................................................................................................................... 6
POST-SUBMITTAL ACTIONS............................................................................................................................................ 7
IV: TRANSIT -RELATED TITLE VI INVESTIGATIONS, COMPLAINTS, AND LAWSUITS .......................................... 7
V: PUBLIC PARTICIPATION PLAN .............................................................................................................................. 8
PUBLIC PARTICIPATION TOOLBOX ................................................................................................................................... 9
MAJOR SERVICE REDUCTION OR FARE INCREASE .......................................................................................................... 11
SUMMARY OF OUTREACH EFFORTS MADE SINCE LAST TITLE VI SUBMISSION .................................................................. 12
VI: LANGUAGE ASSISTANCE PLAN......................................................................................................................... 14
FOUR FACTOR ANALYSIS ............................................................................................................................................. 15
FACTOR 1 – THE NUMBER OF PERSONS WITH LEP ELIGIBLE TO BE SERVED OR LIKELY TO BE ENCOUNTERED BY SLO
TRANSIT .................................................................................................................................................................... 15
FACTOR 2 – FREQUENCY WITH WHICH LEP PERSONS COME INTO CONTACT WITH SLO TRANSIT’S SERVICES AND PROGRAMS
................................................................................................................................................................................. 17
FACTOR 3: THE NATURE AND IMPORTANCE OF SLO TRANSIT’S SERVICES AND PROGRAMS IN PEOPLE’S LIVES ................... 21
FACTOR 4: THE RESOURCES AVAILABLE TO SLO TRANSIT FOR LEP OUTREACH AND THE ASSOCIATED COSTS .................. 21
VII: FOUR FACTOR ANALYSIS FINDINGS................................................................................................................ 22
OVERSIGHT ................................................................................................................................................................ 23
TRAINING EMPLOYEES ................................................................................................................................................ 23
TRANSLATION OF VITAL DOCUMENTS ............................................................................................................................ 24
VIII: DECISION MAKING BODIES .............................................................................................................................. 24
MASS TRANSPORTATION COMMITTEE (NON-ELECTED MEMBERS) ................................................................................... 24
IX: SERVICE STANDARDS AND POLICIES .............................................................................................................. 25
VEHICLE LOAD............................................................................................................................................................ 25
VEHICLE HEADWAY (FREQUENCY) ................................................................................................................................ 26
ON-TIME PERFORMANCE ............................................................................................................................................. 26
SERVICE AVAILABILITY – ACCESS TO THE BUS ............................................................................................................... 26
VEHICLE ASSIGNMENT POLICY ..................................................................................................................................... 26
TRANSIT AMENITY POLICY ........................................................................................................................................... 26
MONITORING SERVICE STANDARDS .............................................................................................................................. 27
X: PROGRAM SPECIFIC REQUIREMENTS ............................................................................................................... 27
SUB-RECIPIENT ASSISTANCE AND MONITORING ............................................................................................................. 27
TITLE VI EQUITY ANALYSIS .......................................................................................................................................... 27
DEMOGRAPHIC DATA COLLECTION AND REPORTING ...................................................................................................... 28
TRANSIT SERVICE MONITORING ................................................................................................................................... 28
SERVICE AND FARE EQUITY ANALYSIS .......................................................................................................................... 28
XI: ATTACHMENTS ..................................................................................................................................................... 28
Page 3 of 41 Page 211 of 357
I: Civil Rights Statement
San Luis Obispo (SLO) Transit is committed to ensuring that no person is excluded from
participation in or denied the benefits of its transit services on the basis of race, color, or
national origin.
This program has been prepared in accordance with Section 601 of Title VI of the
Civil Rights Act of 1964, Executive Order 13116 (Improving Access to Services for
Persons with Limited English Proficiency), and the Federal Transit Administration
(FTA) Circular 4702.1.B (Title VI Requirement and Guidelines for Federal Transit
Administration Recipients).
Section 601 of Title VI of the Civil Rights Act of 1964 states that, “No person shall, on the
grounds of race, color, or national origin, be excluded from participation in, be denied the
benefits of, or be subjected to discrimination under any program or activity receiving
federal assistance.”
Executive Order 13166 states that, “Federal agencies are to examine the services they
provide, identify any need for services to those with Limited English Proficiency (LEP),
and develop and implement a system to provide those services so LEP persons can have
meaningful access to them.”
Per FTA Circular 4702.1.B, this program meets the following objectives:
• Ensure that the level and quality of public transportation service is provided in a
nondiscriminatory manner; and
• 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 program and activities by person with
limited English proficiency.
This document was prepared by SLO Transit, a program of the City of San Luis Obispo’s
Public Works Department and approved by the City Council of the City of San Luis Obispo
(Attachment A – Resolution No. XXXXX (2025 Series). The document complies with all
applicable federal requirements for all transit agencies.
For additional information on SLO Transit, or its efforts to comply with the Civil Rights Act
of 1964, Executive Order 13166 Improving Access to Services for Persons with Limited
English Proficiency, or the FTA Circular 4702.1.B please contact:
Alex Fuchs
Mobility Services Business Manager
1260 Chorro Street
San Luis Obispo, CA 93401
Email: slotransit@slocity.org
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II: Title VI Notice to the Public
SLO Transit informs the public of its commitment to Title VI compliance and the right to file a
civil rights complaint using the following notification.
Figure 1 - Notice to the Public (English)
Figure 2 - Notice to the Public (Spanish)
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Table 1 lists the locations whereby the Notice to the Public is posted.
Table 1 - Notice to the Public Posting Locations
Location Description Location
Bus Interior All SLO Transit revenue vehicles
SLO Transit Webpage Civil Rights | City of San Luis Obispo, CA (slocity.org)
Public Works Department Office 919 Palm Street, San Luis Obispo, CA
Mobility Services Division Office 1260 Chorro Street, San Luis Obispo, CA
Downtown Transit Center 800 block of Osos Street, San Luis Obispo, CA
III: Title VI Complaint Procedures
Any person who believes that she or he has been discriminated against on the basis of
race, color, and/or national origin may file a Title VI complaint with SLO Transit by
completing and submitting a Title VI Complaint Form (Attachment B). The Diversity,
Equity, and Inclusion (DEI) Manager is the City’s designated Title VI Coordinator .
SLO Transit staff are responsible for receiving complaints, investigations, and preparation
of notices. The DEI Manager is responsible for tracking complaints, investigations , and
lawsuits and for recommending changes, if necessary, to ensure continued compliance.
English and Spanish versions of the Title VI complaint form is available on SLO Transit’s
webpage at Civil Rights | City of San Luis Obispo, CA (slocity.org). Physical copies can
also be obtained in person at the Mobility Services Office located at 1260 Chorro Street,
San Luis Obispo, CA. Once the form is obtained, complainants can follow the steps below
to complete and submit the form.
1. Complete the Complaint Form. If a customer needs assistance in completing the
form, then they may contact SLO Transit at 805-781-7121 for assistance.
2. Sign the Complaint Form. Customers are required to sign the Complaint Form.
3. Submit the Complaint Form. Civil rights complaints should be filed immediately.
However, SLO Transit will investigate complaints up to 180 days after the alleged
incident. Customers should submit their complaints to:
City of San Luis Obispo
Mobility Services Business Manager
1260 Chorro Street
San Luis Obispo, CA 93401
Email: slotransit@slocity.org
Phone: (805) 781-7121
Page 6 of 41 Page 214 of 357
Alternatively, customers may also submit their complaints directly to the FTA’s
Office of Civil Rights using the following address :
Federal Transit Administration
Office of Civil Rights
Attention: Complaint Team
East Building, 5th Floor – TCR
1200 New Jersey Avenue SE
Washington, DC 20590
Post-Submittal Actions
The following post-submittal actions are taken to ensure complaints are thoroughly
investigated and that the complainant is informed of the results of the investigation.
1. Acknowledgement. Complaints will be recorded and assigned a complaint
number. SLO Transit will review the complaint to determine if there was a Title VI
violation(s). Staff will send an acknowledgement letter for receipt of complaint
(Attachment B) informing the customer that their complaint for was received and
that SLO Transit will investigate.
2. Investigation. SLO Transit has up to thirty (30) days to investigate the complaint.
If more information is needed to resolve the case, then SLO Transit may contact
the complainant. The complainant has thirty (30) days from the date of contact to
send requested information to the investigator assigned to the case.
If the investigator is not contacted by the complainant or does not receive the
additional information within thirty (30) days, then SLO Transit can administratively
close the case. The case can also be administratively closed if the complainant no
longer wishes to pursue their case.
3. Outcome. After the investigator reviews the complaint, one of the following letters
will be issued to the complainant: a closure letter or a Letter of Finding (LOF). A
closure letter summarizes the allegations and states that there was not a Title VI
violation and that the case will be closed.
A LOF summarizes the allegations and the interviews regardi ng the alleged
incident, and explains whether any disciplinary action, additional training of the
staff member, or other action will occur. If the complainant wishes to appeal the
decision, then they have ten (10) days after the date of the closure letter or the
LOF to do so.
IV: Transit-Related Title VI Investigations,
Complaints, and Lawsuits
SLO Transit maintains a list of public transit-related Title VI investigations, complaints,
and lawsuits filed since the time of the last Title VI program submission which alleges
discrimination on the basis of race, color, or national origin. This list includes the date that
the investigation, lawsuit, or complaint was filed; a summary of the allegation(s); the
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status of the investigation, lawsuit, or complaint; and actions taken by SLO Transit in
response, or findings related to the investigation, lawsuit, or complaint.
As of the writing of this program, there are zero (0) transit-related Title VI investigations,
complaints, or lawsuits which allege discrimination on the grounds of race, color, national
origin, or any other form of discrimination as shown in Table 2 below.
Table 2 - List of Transit-Related Title VI Investigations, Complaints, and Lawsuits
Type Date Summary (Incl.
basis of complaint) Status Action(s)
Taken
Investigations
1.
2.
Lawsuits
1.
2.
Complaints
1.
2.
V: Public Participation Plan
SLO Transit’s Public Participation Plan (PPP), developed in alignment with the City’s
Public Engagement and Noticing Manual, is both a strategic guide and a commitment to
inclusive, transparent, and equitable engagement. The PPP emphasizes early,
continuous, and meaningful public involvement, particularly for those traditionally
underserved like minority and Limited English Proficiency (LEP) populations, ensuring all
voices are considered when making transit decisions.
The PPP ensures that:
• Community members affected by transit decisions can participate in shaping
outcomes that may impact their environment or health.
• Public input meaningfully informs service planning.
• Diverse perspectives are considered throughout the decision-making process.
• SLO Transit actively engages individuals and groups who may be impacted.
Guided by the principles of Inform, Consult, and Collaborate (See Figure 3); SLO
Transit provides clear information, actively seeks feedback, and partners with the public
in identifying and evaluating alternatives.
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Figure 3 - Action Plan Matrix
To support equitable participation, SLO Transit maintains a network of nonprofits,
businesses, and community organizations—particularly those serving underrepresented
groups. Follow-up with participants helps close the feedback loop, and an engagement
toolbox supports accessible, effective outreach.
Public Participation Toolbox
SLO Transit uses a variety of tools to ensure effective, inclusive, and bilingual public
engagement. These tools support transparent communication and provide accessible
opportunities for community feedback.
Media and Communication Channels
• Print and Digital Media: Advertisements and notices in newspapers and other
periodicals, and on social media (X, Instagram, etc.)
• Television and Radio: Use of press releases, radio spots, and news segments.
• Outdoor Advertising: Information displayed on-board buses, at bus shelters, and
public offices.
• Website: Meeting notices and public information are regularly posted on SLO
Transit’s website.
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• Web-Based Feedback: Public comments are collected through online survey
platforms.
• Email: The public can send questions and comments directly to SLO Transit at
slotransit@slocity.org.
On-Board and Rider Communication
• Bus Cards & Flyers: On-board bus cards and flyers are regularly used to inform
riders about service changes, meeting schedules, and hearing notices.
• On-Board Messaging: Service alerts and public engagement opportunities
displayed on digital messaging boards on buses.
• Rider Alerts: Printed materials available on buses and posted at public offices,
online, and on social media (See Figure 4).
Figure 4 - Example Rider Alert
Community Outreach
• Community Partners: Flyers and notices are distributed via email and/or mail to
list of local organizations representing traditionally underserved communities.
• Informational Sessions & Workshops: Informational sessions and/or workshops
are hosted as part of the development or updating of planning documents (e.g.
Short-Range Transit Plan).
Page 10 of 41 Page 218 of 357
• Public Hearings: City Council holds meetings twice a month which serve as public
input opportunities. The Mass Transportation Committee is a transit advisory body
of the Ci ty and meets every other month which also serves as public input
opportunities.
• Legal Notices: Published in accordance with legal requirements to ensure
transparency and public awareness.
This toolbox is designed to reach a broad and diverse audience, ensuring all community
members—regardless of language, location, or access to technology—have the
opportunity to stay informed and participate.
Major Service Reduction or Fare Increase
If the City Council, based on staff recommendations and supporting documentation,
determines that a major service reduction and/or fare increase may be necessary, SLO
Transit staff will provide public notification and opportunities for input in accordance with
the City’s Public Noticing and Engagement Manual and with SLO Transit’s Major Service
Reduction and Fare Increase Policy (Attachment C). The schedule shall provide a
minimum of 45 (calendar) days public notice of the service or fare changes prior to t heir
implementation.
Procedure
A minimum of two public meetings (one prior to 5:00 p.m. and one after 5:00 p.m.) will be
scheduled and advertised. Public notices will be posted in English and Spanish at the
locations listed below. Figure 5 is an example of a public notice for the Short-Range
Transit Plan Update public meetings.
• City Hall (990 Palm Street)
• Mobility Services office (1260 Chorro Street)
• Downtown Transit Center
• Onboard all fixed-route transit vehicles
• County/City Public Library (995 Palm Street)
• SLO Transit website (with email link for public comment)
• Social media platforms
• Legal notices in local newspapers
• Press releases distributed to local media outlets
Page 11 of 41 Page 219 of 357
Figure 5 - Notice for Short-Range Transit Plan Meetings
Public meetings will be conducted in convenient, accessible, and diverse locations ,
with the following considerations:
• Locations will be served by transit routes whenever possible.
• Meetings will be facilitated by SLO Transit staff.
• Public comments will be formally recorded and archived.
• A public meeting may be held during a regularly scheduled Mass Transportation
Committee (MTC) meeting.
• Spanish-language assistance will be available at each meeting to ensure
inclusive participation.
Summary of Outreach Efforts Made Since Last Title VI Submission
Since SLO Transit’s previous Title VI Plan submission, there have been significant public
outreach conducted for various planning and programming efforts as summarized below.
All these outreach activities were advertised to the public in both English and Spanish.
Short-Range Transit Plan Update
In September 2023, SLO Transit kicked off a joint Short -Range Transit Plan update in
coordination with the area’s regional service provider, San Luis Obispo Regional Transit
Authority. SLO Transit’s Short-Range Transit Plan was adopted by its board on April 15,
2025 and recommends services, programs, and fares changes for fiscal years 2025-26
through 2029-30. Throughout the plan update process, thorough public engagement was
conducted as part of the Short-Range Transit Plan update process including the following
efforts:
Page 12 of 41 Page 220 of 357
• Onboard Surveys were collected in October 2023, on all SLO Transit fixed route
and tripper services. A total of 427 survey responses were received.
• Stakeholder Workshops were in November and included representatives from
other government agencies, transit providers, and higher education institutions
throughout the county.
• Community (online) Surveys were collected between November and December
2023, using a Survey Monkey and using the City’s Open City Hall program. A total
of 254 survey responses were received.
• Three Joint Advisory Body Meetings were held between March and October 2024,
to present progress on the plan update and to solicit feedback from committee
members and the public.
• Three Community Workshops were held in June 2024 to present and receive
feedback from the public on the initial service alternatives analysis.
• City Council Study Session was held on July 16, 2024, and provided another
opportunity for the public to provide input through written correspondence and
through public testimony.
• MTC Meeting was held on January 8, 2025, to present the draft SRTP and to
receive feedback from the committee and the public as to what recommendations
to incorporate into the final plan.
• Targeted outreach was conducted in January 2025 with a focus on engaging
community organizations that serve disadvantaged communities.
Transit Innovations Study
In 2023, a Transit Innovation Study was conducted to explore and evaluate transit
operational improvements. The findings of the study were compiled into a report and
provides actionable recommendations to help meet the City’s climate and mode split
objectives. The study’s recommendations are planned to be implemented with the 2024-
25 Supplemental Budget, with future budgets, and through updates to applicable planning
documents.
The consultant produced seven memos on topics ranging from existing conditions and
needs assessment to service enhancements evaluation. Between May and August of
2023 memos were sent to both internal and external stakeholders for review and
comment. The comments were then incorporated into their respective memos and
compiled into a draft report. Staff completed an initial review of the draft report then
scheduled a workshop through which stakeholders would have an opportunity to review
the recommendations as presented by the consultant and to re-prioritize them based on
their experiences of transit in the City and beyond.
On September 25, 2023, staff held a stakeholder workshop and invited those involved in
the memo review process as well as representatives from the City’s Community
Development Department, Ride-On Transportation, Cal Poly’s Associated Students, Inc.
ASI), SLO Climate Coalition, YIMBY Action, and Diversity SLO. The workshop included
a breakout session based on participants’ areas of interests, a recommendation
prioritization exercise, and an open discussion about the applicability of the
Page 13 of 41 Page 221 of 357
recommendations to SLO Transit. Staff asked participants during the workshop to rank
the draft recommendations based on the effect of their ability to increase ridership. The
results of the workshop helped re-prioritize the recommendations and were incorporated
into the final report.
Annual Unmet Transit Needs Assessment
Every year the San Luis Obispo Council of Governments (SLOCOG) conducts an Unmet
Transit Needs Assessment. The purpose of this assessment is to ensure that any unmet
transit needs that are found reasonable to meet are programmed before Transportation
Development Act (TDA) funds are expended for non-transit uses. SLO Transit is an
eligible recipient of TDA funds and, therefore, is subject to the Unmet Transit Needs
Assessment. SLO Transit promotes the public notices on its buses, on its website, and at
meetings of the City’s Mass Transportation Committee. SLO Transit also receives a list
of comments submitted by the public and provides SLOCOG responses to the comments.
K-12 Discount Pass Pilot Program
Based on feedback from parents of the local school district, SLO Transit recommended
to its board the approval of a K-12 discount 15-Ride pass pilot program. On November
13, 2023, staff met with Laguna Middle School staff to discuss expanding K -12 fare and
pass options. School staff forwarded SLO Transit contact information and the proposed
student pass and fare options to the school’s Parent Teacher Association for review. In
January 2024, City Council approved the pilot program and in February 2024 the ne w
discount pass became available to the public.
In August 2024, staff attended Laguna Middle School’s orientation day to promote the
new discount pass pilot program and to provide students and parents with information
about our services. A banner was also installed across the street from the school
advertising the new pilot program. In September 2024, staff attended Pacheco
Elementary School’s Back to School Night for the same reason. On April 15, 2025, City
Council approved formalization of the pilot program based on the utilization of the new
pass option.
Other Outreach Efforts
Every year, the City participates in the National Public Works Week. The City and other
municipal agencies in the county attend Downtown San Luis Obispo’s Farmers’ Market
to highlight our respective programs and projects. SLO Transit staff attends the event and
provides information to the public as well as answers questions about services and
programs. Staff also regularly attends Cal Poly events throughout the year to engage with
students, faculty, and staff.
VI: LANGUAGE ASSISTANCE PLAN
SLO Transit has developed its Language Assistance Plan (LAP) to address SLO Transit’s
responsibilities as a recipient of federal funding . The LAP helps to identify reasonable
steps for providing language assistance to persons with Limited English Proficiency (LEP)
who wish to access transit services and programs. Persons with LEP are those who do
not speak English as their primary language and have limited ability to read, write or
understand English.
Page 14 of 41 Page 222 of 357
SLO Transit’s goal is to provide meaningful access for persons with LEP to all of its
services, programs, and information. Efforts to effectively engage persons with LEP will
ensure that they can equally contribute to and benefit from the development and
improvement of SLO Transit’s services and programs.
SLO Transit will comply with the Safe Harbor Provision, which outlines circumstances that
can provide a “safe harbor” for recipients regarding translation of written materials for LEP
populations. The Safe Harbor Provision states that, if a recipient provides written
translation of vital documents for each eligible LEP language group that constitutes five
percent or 1,000 persons, whichever is less, of the total population of persons eligible to
be served or likely to be affected or encountered, then such action will be considered
strong evidence of compliance with the recipient’s written translation obligations. These
safe harbor provisions apply to the translation of written documents only.
Four Factor Analysis
In order to ensure meaningful access to programs and activities, SLO Transit uses the
information gathered from a Four Factor Analysis to determine the specific language
services that are appropriate to provide. This analysis helps SLO Transit to determine if
it communicates effectively with persons with Limited English Proficiency (LEP) and
informs language access planning. The Four Factor Analysis is local assessment that
considers:
1. Factor 1 - The number or proportion of persons with LEP eligible to be served or
likely to be encountered by SLO Transit
2. Factor 2 - The frequency with which persons with LEP come into contact with SLO
Transit’s services and programs
3. Factor 3 - The nature and importance of SLO Transit’s services and programs in
people’s lives
4. Factor 4 - The resources available to SLO Transit for LEP outreach, as well as the
costs associated with that outreach
Factor 1 – The Number of Persons with LEP Eligible to be Served or
Likely to be Encountered by SLO Transit
The first step in determining the appropriate components of a Language Assistance Plan
is understanding the proportion of persons with LEP who may encounter SLO Transit’s
services, their literacy skills in English, their native language, the location of their
communities and neighborhoods and, more importantly, if any are underserved because
of a language barrier.
SLO Transit evaluated the level of English literacy and to what degree people in its service
area speak a language other than English and what those languages are. Data for this
review is derived from the United States Census Bureau’s 2023 American Community
Survey. Refer to Table 3 for source details.
Page 15 of 41 Page 223 of 357
Table 3: Census Data Source Information
San Luis Obispo County Overview
SLO Transit’s service system encompasses an area of twenty-two square miles in the
County of San Luis Obispo, California as shown in Figure 6. The primary languages in
the county are English and Spanish. Of county residents aged five and older, six percent
reported speaking English less than “very well”. Within the County of San Luis Obispo,
13.4 percent of residents speak Spanish at home. Residents who speak Spanish and
reported speaking English less than “very well” make up 4.4 percent of the population.
Further detailed statistics can be found in Table 4 below.
Figure 6 - Location of the City of San Luis Obispo
San Luis Obispo (City) Overview
SLO Transit serves the City of San Luis Obispo and the adjacent university campus. The
primary languages spoken in the City of San Luis Obispo are English and Spanish. The
total population of the City is 48,039, and of residents aged five and older, three percent
report speaking English less than “very well.”
Nearly 10 percent of the population of the City speaks Spanish and, of that number, two
percent (911 residents) report speaking English less than “very well.” Following Spanish
speakers, those who primarily speak languages other than English account for 6.7
percent of the population. These languages include “Other Indo-European languages,”
“Asian and Pacific Islander languages,” and “Other languages” as outlined by the Census
Bureau.
Criteria Figure
Table ID DP02
Survey/Program American Community Survey
Vintage 2023
Dataset ACSDP5Y2023
Product ACS 5-Year Estimates Data Files
GEOs California; San Luis Obispo County, California; San Luis Obispo City, California
Web Address https://api.census.gov/data/2023/acs/acs5/profile
Page 16 of 41 Page 224 of 357
Table 4: Comparison of Language Spoken at Home
Language Spoken at Home
San Luis Obispo County San Luis Obispo (City)
Estimate Percent
of Total Estimate Percent
of Total
Total Speak Only English 22,1301 82.1% 38,864 83.4%
Total Speak Language Other Than English 48,194 17.9% 7,760 16.6%
Total Speak Spanish 36,081 13.4% 4,608 9.9%
Total Speak English Less Than “Very Well” 48,194 6.0% 1,404 3.0%
Total Population (5 years and older) 269,495 46,624
Speak English Less Than “Very Well” – Detail (ACS Survey Language Categories)
Speaks Spanish 11,847 4.4% 911 2.0%
Speaks Other Indo-European Languages 1,466 0.5% 165 0.4%
Speaks Asian / Pacific Islander Languages 1,742 0.6% 291 0.6%
Speaks Other Language 1,035 0.4% 37 0.1%
Factor 1 Summary of Findings
Based on the available population data for the SLO Transit service area and for the region
in which SLO Transit operates, no single LEP language group meets or exceeds the
DOT’s Safe Harbor provisions threshold of five percent or 1,000 persons (which is less)
required to provide written translation of vital documents. However, SLO Transit is
committed to translating all vital documents, including press releases and public notices,
into Spanish.
Factor 2 – Frequency with which LEP Persons Come into Contact with
SLO Transit’s Services and Programs
To determine the frequency of contract between persons with LEP and SLO Transit
services, SLO Transit deployed a variety of surveys to employees, riders, and community
partners. The survey results and a summary of findings for each survey is presented in
this section.
SLO Transit Employee Survey
SLO Transit conducted internal surveys of employees including drivers, dispatch, road
supervisors, and management staff. The intent of the survey was to determine what
language skills already exist among SLO Transit employees and the number and nature
of encounters with riders or other community members with LEP.
The first question asked employees if they could communicate in a language other than
English, and if so, what language(s). Although varying degrees of fluency were indicated,
six of the 17 respondents can speak one or more languages other than English. Of the
six who indicated they spoke a language other than English, two spoke Spanish, one
spoke German, and one spoke Mandarin. The remaining two respondents did not indicate
which language they spoke other than English.
The survey also asked if, in the previous month, whether employees encountered
customers who were unable to communicate in English and , if so, the frequency to which
they heard one of ten languages. All respondents reported encountering riders with LEP
speaking a language other than English between “rarely” to “daily”. The most common
Page 17 of 41 Page 225 of 357
non-English language encountered was Spanish followed by Chinese (Cantonese,
Mandarin) as shown in Table 5.
Table 5 - How Often Have You Encountered Riders With Limited English Proficiency
Speaking The Following Language?
Not At All Rarely Occasionally Sometimes Often Daily
Spanish 5 3 2 1 3 3
French 16 0 1 0 0 0
Tagalog 15 0 1 1 0 0
Japanese 16 1 0 0 0 0
Chinese
(Cantonese, Mandarin) 14 0 3 0 0 0
Italian 17 0 0 0 0 0
Portuguese 15 0 1 1 0 0
German 15 1 0 1 0 0
Persian 16 0 0 1 0 0
Hindi 17 0 0 0 0 0
All Other Languages 0 0 1 0 0 0
The next survey question asked what type of needs and/or requests for assistance
employees had received from riders with LEP. The most types of needs and/or request
for service include information on routes and directions (50 percent) followed by
information on bus times (39 percent), translation assistance (22 percent), and ADA
information (six percent).
Employee Survey Findings
The information obtained through this survey indicates a bout one-third of SLO Transit
staff members that responded to the survey speak one or more languages other than
English, many of which speak Spanish. Additionally, riders that speak Spanish are among
the most frequently encountered LEP populations. The survey also revealed that riders
with LEP most often requested information about bus routes and directions to points of
interest in the community.
Community Partners Survey
SLO Transit also surveyed community partners, listed in Attachment D, to assess the
extent to which they come into contact with LEP populations , the types of services they
offer to LEP persons, challenges with serving persons with LEP, and frequency of
requests from LEP persons to translate/interpret transit information. Questions and
consolidated responses are provided below.
Of the 13 community partners contacted, only four completed the survey. Of the four
respondents, three indicated that up to 25 percent of the individuals served by their
organization are persons with LEP. The fourth organization indicated that between 50
percent and 75 percent of individuals served are persons with LEP. All of the respondents
indicated that Spanish is the most commonly spoken language, aside from English,
amongst persons with LEP served by their organization. No other languages were
indicated.
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When asked about the type of services their organization provides to persons with LEP,
all of the respondents indicated that interpretation (in -person and remote) services are
provided. When asked about the frequency of requests to translate and/or interpret
transit-related information, two organizations indicated ‘very often’, one indicated
‘somewhat often’, and one indicated ‘not often at all’. Lastly, when asked about challenges
faced by their organization when serving persons with LEP, three respondents indicated
‘lack of bilingual staff’ and one indicated ‘limited access to interpreters’.
Community Partner Survey Findings
Though the number of responses was low, relevant and actionable information can be
surmised from the data. Spanish is the most common language spoken by persons with
LEP served by the respondent organizations. In-person and remote translation services
are offered by all respondents and several of them often get requests to translate transit-
related information. Lastly, lack of bilingual staff and/or limited access to interpreters is a
challenge for all respondents.
Transit Rider Survey
A survey of transit riders was conducted between May 12-16, 2025, to determine how
well do current riders read and speak English, language(s) other than English spoken at
home, encounters with SLO Transit staff, how they get information about SLO Transit
services, and why they ride the bus. The survey was offered in both English and Spanish
and was available in print and digitally via QR Code. Attachment E includes a copy of the
survey form. A total of 111 riders completed the survey: 105 in English and 6 in Spanish.
Below are the questions and consolidated responses.
Table 6: English Proficiency of SLO Transit Riders Surveyed
How well do you read English How well do you speak English
Total Percent Total Percent
Very Well 103 94% 102 92%
Somewhat Well 5 5% 4 4%
Not Very Well 2 2% 5 5%
Of the riders surveyed, 103 of the respondents (94 percent) indicated that they read
English “very well” and 102 (92 percent) of the respondents indicated that they speak
English “very well” as shown in Table 6. Of the riders surveyed, 33 percent said they
spoke a language other than English at home. Of respondents who provided what
language they spoke at home, 73 percent indicated Spanish. Table 7 shows the
languages other than English spoken at home.
Table 7: Language other than English spoken at home
Language No. of Respondents
Spanish 16
Hindi 1
Russian 2
Chinese 1
Japanese 1
Page 19 of 41 Page 227 of 357
Language No. of Respondents
Filipino 1
Riders were asked if they have called SLO Transit dispatch for assistance, and if so, how
easy it was to communicate with staff. Though the original intent of the question was to
assess ease of communication with dispatch staff, it was interpreted by riders to mean
communication with staff in general. Of the riders surveyed, 90 percent indicated that they
communicate with staff “very well” as shown in Figure 7.
Figure 7 - How Well Were You Able to Communicate with Staff?
Riders were asked where they get information about SLO Transit services. Of the riders
surveyed, the most common responses were internet (54 percent), ask bus drivers (28
percent), and from friends, family, and coworkers (17 percent) as shown in Figure 8. Of
the respondents, 28 (25 percent) indicated that they get information from more than one
source.
Figure 8 - Where Do You Get Information About SLO Transit Services?
90%
6%4%
Very Well Somewhat Well Not very well
28%
11%
17%
54%
16%
0%
10%
20%
30%
40%
50%
60%
Ask Bus Drivers Call dispatch From Friends,
family,
coworkers
Internet (google)SLO Transit App
Page 20 of 41 Page 228 of 357
Lastly, riders were asked an open-ended question about why they ride the bus. The
responses were categorized into the following themes:
• Not owning a car
• Transportation option for those with medical conditions
• Affordability
• Environmental reasons
• Convenient and no-cost for Cal Poly students
Transit Rider Survey Findings
Based on the transit rider survey, Limited English Proficiency is not a barrier to SLO
Transit’s services. Within SLO Transit’s service area, three percent of residents speak
English less than “very well” and based on the rider surveys, five percent of respondents
reported speaking English “not very well” and two percent reported reading English “not
very well”. This indicates that SLO Transit is likely serving residents with Limited English
Proficiency at a rate that is more than representative of the population it serves.
Finally, of residents reporting which language they spoke other than English at home, 73
percent reported speaking Spanish. This indicates that, while not required, SLO Transit’s
practice of translating vital documents into Spanish is a benefit to both riders and non-
riders of the service area.
Factor 3: The Nature and Importance of SLO Transit’s Services and
Programs in People’s Lives
Access to SLO Transit’s services and programs is critical to the lives of many in SLO
Transit’s service area. Many depend on SLO Transit’s fixed route services for access to
jobs and to essential community services like schools, shopping , and medical
appointments. As part of the public outreach for the Short-Range Transit Plan (2025)
update, 70 percent of riders surveyed indicated they use the bus three or more times a
week for various purposes including university (47 percent), work (19 percent), and
medical or social services (8 percent).
Because of the essential nature of the services and the importance of these programs in
the lives of many of the region’s residents, there is a need to ensure that language is not
a barrier to access. The City will continue to translate vital documents into Spanish and
offer interpreters and translations services where possible. The City also partners with a
variety of community organizations to support historically underserved and
underrepresented groups to ensure equitable access to public services.
Factor 4: The Resources Available to SLO Transit for LEP Outreach and
the Associated Costs
The City has a Bilingual Certification Examination program which assesses City
employees’ Spanish speaking and writing skills. Depending upon the results of the
examination, employees will be certified for oral and/or written Spanish speaking
translation services. All City departments and programs can utilize these certified bilingual
employees for free translation services. Certified employees are compensated for this
Page 21 of 41 Page 229 of 357
service as negotiated through their respective Memorandum of Understanding. SLO
Transit utilizes certified bilingual employees to translate vital documents into Spanish.
SLO Transit’s annual budget includes costs of printing services, digital and print
advertising, and for public outreach opportunities. These activities include production of
English and Spanish documents and notifications. The City’s website, including SLO
Transit information, can be translated into multiple languages , as shown in Figure 9,
powered by Google Translate.
Figure 9 - City Website Translation Options
VII: Four Factor Analysis Findings
A quick summary of the Four-Factor Analysis findings shows the importance of language
assistance to members of the SLO Transit community who do not speak English very
well, and the City’s and SLO Transit’s commitment to provide that assistance.
• Factor 1 found that three percent of the City’s population speaks English less than
“very well”; this SLO Transit’s LEP population. Even though no language is spoken
by more than five percent or 1,000 people within the service area, per the
Department of Transportation’s “safe harbor” provision threshold, SLO Transit is
committed to translating all vital documents into Spanish.
• Factor 2 found that persons with LEP frequently use SLO Transit services and
often interact with SLO Transit employees. Only four percent of transit riders
surveyed reported communicating with staff “not very well.” Riders most common
source of information is the internet followed by asking bus drivers.
• Factor 3 found that both English speaking and persons with LEP rely on SLO
Transit services to access essential services like jobs, school, medical
appointments, and for recreation. The City has an extensive community
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partnership network that assist with distributing information and gathering
feedback on transit services.
• Factor 4 found that resources are available and within budget for SLO Transit to
continue translating vital documents and to publish notifications in English and in
Spanish.
Oversight
Oversight includes monitoring, evaluating, and updating of the Language Assistance Plan
and the Public Participation Plan. SLO Transit have a responsibility to improve community
engagement to ensure compliance with SLO Transit’s Title VI Plan, Public Participation
Plan, Language Assistance Plan, and other community outreach efforts. Monitoring of the
Language Assistance Plan will include:
• On a triennial basis, SLO Transit will review regional census data for changing
patterns of LEP populations
• Ongoing collaboration with regional and community partners
• Ongoing review of translation requests at SLO Transit’s website and other material
• Post-Event Assessments (PEA)
Post-Event Assessments
Following service changes, fare increases and planning projects, staff will assess the
effectiveness of public involvement against the goals established in this plan. This
assessment will ask the questions:
1. Did the public know there was an opportunity to participate?
2. Was the purpose of the participation clearly presented to the public?
3. Did the public have access to appropriate resources and information to allow for
meaningful participation?
4. Did the decision making process allow for consideration and incorporation of public
input?
5. Were there complaints about the public engagement process?
6. Were the public engagement efforts cost effective?
7. What additional methods could have been employed to improve the process?
8. Should the Public Participation Plan or Language Assistance Plan be amended?
Training Employees
The purchased transportation contractor retains the existing staff from the incumbent
transit contractor if a new contractor is awarded the contract. Currently, dispatch and
customer service staff are bilingual and/or have bilingual staff readily available. The
purchased transportation contractor utilizes translation applications (i.e. Google
Translate) to assist in communication with customers with LEP if bilingual staff is
unavailable.
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Translation of Vital Documents
It is existing practice of SLO Transit to translate the vital documents listed in Table 8 into
Spanish.
Table 8 - SLO Transit Vital Documents
Document Type Translation Status
Civil Rights complaint forms Done
Fare and service change announcements (Rider alerts) On-going
Legal notices On-going
Printed media (Rider’s Guide, route brochures) Done
Passenger Code of Conduct policy Done
General promotional materials On-going
Website Done
VIII: Decision Making Bodies
The City encourages all residents, minorities, women, and persons with disabilities who
live in the City to serve on committees and boards.
Mass Transportation Committee (Non-Elected Members)
The Mass Transportation Committee (MTC) assists with the ongoing program of public
transit in the City and on Cal Poly’s campus. The MTC provides recommendations and
input to the Council regarding routes, schedules, capital projects, fares, marketing, and
additional services. The MTC meets in-person the second Wednesday of every other
month at 2:30 p.m. at City Hall, 990 Palm Street, San Luis Obispo.
The MTC has seven members, consisting of one Cal Poly designated employee, one Cal
Poly student representative designated by Associated Students, Inc. (ASI), one senior
citizen, one person from the business community, one person with technical
transportation planning experience, one persons from disabled community, one member
at-large, and one student. Racial and ethnic make-up of the committee members is shown
in Table 9 below.
Table 9 - Racial and Ethnic Make-up of the Mass Transportation Committee
White /
Caucasian
Hispanic
/ Latino
Black /
African
American
Arab
American
/ Middle
Eastern /
North
African
Asian /
Asian
American
/ South
Asian
American
Indian /
Alaska
Native
Native
Hawaiian
/ Other
Pacific
Islander
Indigenous
(Not Lised)
Two
or
More
Prefer
Not to
Answer
5 2 0 0 0 0 0 0 0 0
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IX: Service Standards and Policies
SLO Transit’s Short-Range Transit Plan, adopted on April 15, 2025, outlines service
standards, policies, and performance measures to monitor service performance for the
next five-year period (Table 4 on pages 29-30). SLO Transit is also required to set service
policies for the distribution of transit amenities for each mode and vehicle assignment
(pages 97-98). The plan includes the following service standards and policies relevant to
the Title VI Program Plan.
• Vehicle Load
• Vehicle Headway (Frequency)
• On-time Performance (Schedule Adherence)
• Service Availability
• Vehicle Assignment Policy
• Transit Amenity Policy
The City of San Luis Obispo Transit currently has an active fleet of seventeen (17) buses1
that are used for the City of San Luis Obispo fixed-route transit service. Only eleven (11)
of these buses are used at peak periods of service. This does not trigger the threshold of
additional service standards which transit providers that operate 50 or more fixed -route
vehicles in peak service must include as part of their Title VI Program.
Vehicle Load
Vehicle load is expressed as the ratio of passengers to the total number of seats on a
vehicle. SLO Transit sets a standard load factor of 1.25 during peak times and 1.0 for off-
peak times for bus capacity. When capacity exceeds 125 percent for any route, it is SLO
Transit’s intention of alleviating overcrowding by dispensing additional supplemental
service. Table 10 shows peak and off-peak standard load factor for each vehicle type
within its revenue fleet.
Table 10 - Vehicle Load by Vehicle Type
Vehicle Type Seated
Capacity
Standing
Capacity
Total
Capacity
Peak
Load
Off-Peak
Load
Gillig 30’ 28 14 42 1.25 1.0
Gillig 35’ 32 16 48 1.25 1.0
Gillig 40’ 40 20 60 1.25 1.0
Proterra 35’ 29 15 44 1.25 1.0
1 Fourteen heavy-duty buses, one double-decker bus, one cutaway bus, and one replica trolley
Page 25 of 41 Page 233 of 357
Vehicle Type Seated
Capacity
Standing
Capacity
Total
Capacity
Peak
Load
Off-Peak
Load
New Flyer 35’ 32 16 48 1.25 1.0
Dennis 40’
(Double-Decker) 86 43 129 1.25 1.0
El Dorado 28’
(Cutaway) 28 14 42 1.25 1.0
Vehicle Headway (Frequency)
Vehicle headway is the amount of time between two buses traveling in the same direction
on a given route. SLO Transit buses are scheduled with 20-, 45- and 60-minute headways
depending upon individual route demand and period of operations. As a standard, SLO
Transit operates 60-minute headways, at a minimum, throughout the year, Table 11
outlines the headways during different periods of operations.
Table 11 - Headways by Period of Operation (in Minutes)
Service Weekday Weekday
Evening
Saturday
Peak
Saturday
Off Peak
Sunday
Peak
Sunday
Off Peak
Route
Level 20-60 45-60 45-60 45-60 45-60 45-60
On-Time Performance
Among the most important service standard for riders is on-time performance or
adherence to published schedules. A vehicle is considered on-time if it departs a time
point no more than five minutes after as shown on the route schedule. Buses are not
allowed to depart earlier than the scheduled time points. SLO Transit’s on-time
performance objective is 95 percent or greater.
Service Availability – Access to the Bus
SLO Transit’s standard for service is availability is that 90 percent of residents in the
service area live within a quarter of a mile walk of a bus route. Consideration is given to
new markets as demand warrants and as resources become available.
Vehicle Assignment Policy
Buses are assigned to certain routes based on ridership as well as maneuverability.
Routes with higher demand are assigned larger buses (i.e. 35-foot and 40-foot) to
accommodate higher passenger loads. Certain routes serve older residential areas with
narrow rights-of-way which may require use of smaller, more maneuverable buses (i.e.
30-foot).
Transit Amenity Policy
SLO Transit serves 166 individual stops in the service area – many located and installed
more than 30 years ago. Of these stops, 50 have shelters and 111 have benches. Solar
lights are installed at 23 stops and electronic, real -time schedule signs are installed at 3
stops. Almost all the SLO Transit bus stops have an information kiosk (96 percent).
Page 26 of 41 Page 234 of 357
Various stops are shared with the regional transit operator – San Luis Obispo Regional
Transit Authority.
All bus stops should have, at a minimum, a sign denoting the route(s) that serve it and
information kiosks for the posting of route schedules and/or rider alerts. The recently
adopted Short-Range Transit Plan includes a proposed measure to install solar lighting
at 100 percent of bus stops. A bench will be installed at bus stops with ten or more
combined daily boardings and a shelter and a bench will be installed at bus stops with 20
or more combined daily boardings. Boardings at individual stops that are shared between
multiple routes will be added together to estimate daily boardings for the purpose of
determining whether a threshold has been met. There is no threshold for installation of
trash receptables and are instead evaluated on a case-by-case basis.
Maintenance requests for existing stops and new bus shelter requests can be made by
contacting SLO Transit through email at slotransit@slocity.org or via the City’s mobile
application Ask SLO. When the annual maintenance and/or repair costs to any amenity
are greater than the value or cost of the structure, SLO Transit reserves the right to
permanently remove the amenity.
Monitoring Service Standards
Table 12 lists the schedule and methodology used for the on-going monitoring and
measurement of service standards and policies.
Table 12 - Service Standards and Policies Monitoring
Service Standard/Policy Sample Schedule Methodology
Vehicle Load All routes bi-annually NTD survey data and staff
observations
Vehicle Headways Assessed annually (as part of
service planning) Service review
On-Time Performance Assessed monthly Ride checks
Service Accessibility Assessed annually (as part of
service planning) Service review
Vehicle Assignment Policy Assessed annually Service review
X: Program Specific Requirements
Sub-recipient Assistance and Monitoring
A subrecipient is an entity that receives federal funds from another state or local
government agency to carry out part of a federal program. SLO Transit does not have
subrecipients nor does it have subrecipient oversight responsibilities.
Title VI Equity Analysis
SLO Transit has not constructed a facility since the last Title VI program update and,
therefore, has not undergone a Title VI Equity Analysis. An equity analysis is a review
conducted to determine whether a policy, program, or project fairly serves all populations,
Page 27 of 41 Page 235 of 357
especially those that are historically underserved or disadvantaged, such as persons of
low-income and persons of Limited English Proficiency.
When SLO Transit considers and/or plans to construct a new maintenance facility, transit
hub, and/or operations center, the City will conduct an equity analysis to maintain full
compliance with FTA’s Title VI regulations.
Demographic Data Collection and Reporting
SLO Transit operates fewer than 50 buses in peak service and is therefore not required
to collect or report on demographic and service profile nor ridership and travel patterns
for this plan update.
Transit Service Monitoring
SLO Transit operates fewer than 50 buses in peak service and is therefore not required
to monitor the performance of its transit service for this plan update.
Service and Fare Equity Analysis
SLO Transit operates fewer than 50 buses in peak service and is therefore not required
to evaluate service and fare equity changes for this plan update.
XI: Attachments
The following pages are attachments to SLO Transit’s Title VI Program.
Page 28 of 41 Page 236 of 357
Attachment A – Resolution No. XXXXX (2025 Series)
PLACEHOLDER FOR RESOLUTION
Page 29 of 41 Page 237 of 357
Title VI Complaint Form
City of San Luis Obispo Transit – SLO Transit
Name: ____________________________________________________________________________________
Address: __________________________________________________________________________________
City: ______________________________________________ State: ____________ Zip Code: ______________
Home Telephone No: ( ) ______________________ | Work Telephone No: ( )___________________
Email Address: ________________________________
Are you Filing this complaint on your own behalf? Yes No
If answering YES, please supply the name and relationship of the person for whom you are complaining:
Name: ____________________________________Relationship: __________________________________
Please explain why you have filed for a third party:
__________________________________________________________________________________________
Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a
third party: Yes No
What do you believe is the reason for your discrimination?: Race Color National Origin
Date of Alleged Incident: ______________________________
Explain as clearly as possible what happened and how you believe you were discriminated against. Indicate
who was involved. Be sure to include the names and contact information of any witnesses. If more space is
needed, please use the back of the form.
Attachment B - Title VI Complaint Procedures Forms
Page 30 of 41 Page 238 of 357
Have you filed this complaint with any other federal, state, or local agency; or with any federal
or state court?
Yes No
If yes, check all that apply:
Federal agency Federal Court State Agency State Court Local Agency
Please provide information about a contact person at the agency/court where the complaint was filed:
Name: ________________________________________ Agency:_____________________________________
Address: __________________________________________________________________________________
Telephone Number: _________________________________
Please sign below. You may attach any written materials or other information that you think is relevant to
your complaint.
Signature: ____________________________________________ Date: _______________________________
Please mail this form to:
City of San Luis Obispo
Mobility Services Business
Manager
Mobility Services
1260 Chorro Street
San Luis Obispo, CA 93401
(805)781-7121
Title VI of the Civil Rights Act of 1964 states: “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 subjected to discrimination
under any program or activity receiving Federal financial assistance.”
The City of San Luis Obispo Transit (SLO Transit) respects civil rights and
operates its programs and services without regard to race, color or national
origin. SLO Transit is committed to complying with Tile VI requirements in
all of its programs and services.
Any person who believes he/she has been subjected to discrimination in
the delivery of or access to public transportation origin, may file a
complaint with SLO Transit. Such complaint must be filed in writing with
SLO Transit no later than 180 days after the alleged discrimination. A letter
of acknowledging receipt of complaint will be mailed within 30 days.
For more information on the Title VI transit obligations and how to file a
complaint, please contact SLO Transit: City of San Luis Obispo Mobility
Services Business Manager, Mobility Services Dept, 1260 Chorro Street, San
Luis Obispo, CA 93401
Page 31 of 41 Page 239 of 357
TÍTULO VI FORMULARIO DE RECLAMACIÓN
City of San Luis Obispo Transit – SLO Transit
Nombre: __________________________________________________________________________________
Domicilio:_________________________________________________________________________________
Ciudad: _____________________________________ Estado: ____________ Código postal: ______________
Número de teléfono de casa: ( ) __________________ | Número de Trabajo: ( )____________________
Correo electrónico: ________________________________
¿Está presentando esta queja en su propio nombre? Si No
Si responde SÍ, proporcione el nombre y la relación de la persona por la que presenta la queja:
Nombre: ______________________________________ Relación: ___________________________________
Por favor explique por qué ha presentado la solicitud para un tercero:
__________________________________________________________________________________________
Por favor, confirme que ha obtenido el permiso de la parte afectada si está presentando la solicitud en
nombre de un tercero: Si No
¿Cuál cree usted que es el motivo de su discriminación?: Raza Color Origin nacional
¿Cuál fue la fecha de la supuesta discriminación?: ______________________________
Explique con la mayor claridad posible qué sucedió y cómo cree que fue discriminado. Indique quiénes
estuvieron involucrados. Asegúrese de incluir los nombres y la información de contacto de los testigos. Si
necesita más espacio, utilice el reverso del formulario.
Page 32 of 41 Page 240 of 357
¿Ha presentado la queja ante cualquier otra agencia federal, estatal o local, o ante cualquier agencia federal o
la corte estatal?
Si No
En caso afirmativo, marque todo lo que corresponda:
Agencia Federal Corte federal Tribunal Estatal Agencia del estado Agencia local
Proporcione información sobre una persona de contacto en la agencia / tribunal donde se presentó la queja
archivado:
Nombre:_____________________________________ Agencia:_____________________________________
Habla a: __________________________________________________________________________________
Teléfono: _________________________________
Firme a continuación. Puede adjuntar cualquier material escrito u otra información que considere relevante
para su queja.
Firma: ____________________________________________ Fecha: _______________________________
Por favor envíe este
formulario a:
City of San Luis Obispo
Mobility Services Business
Manager
Mobility Services
1260 Chorro Street
San Luis Obispo, CA 93401
(805)781-7121
El Título VI de la Ley de Derechos Civiles de 1964 establece: “Ninguna persona
en los Estados Unidos, por motivos de raza, color u origen nacional, será
excluida de participar, se le negarán los beneficios ni será objeto de
discriminación en ningún programa o actividad que reciba asistencia
financiera federal.”
El Servicio de Tránsito de la Ciudad de San Luis Obispo (SLO Transit) respeta
los derechos civiles y opera sus programas y servicios sin importar la raza, el
color ni el origen nacional. SLO Transit se compromete a cumplir con los
requisitos del Título VI en todos sus programas y servicios.
Cualquier persona que considere haber sido objeto de discriminación en la
prestación o el acceso al transporte público puede presentar una queja ante
SLO Transit. Dicha queja debe presentarse por escrito a SLO Transit a más
tardar 180 días después de la presunta discriminación. Se enviará por correo
una carta de acuse de recibo de la queja dentro de los 30 días.
Para obtener más información sobre las obligaciones de tránsito del Título VI
y cómo presentar una queja, comuníquese con SLO Transit: Gerente
comercial de Servicios de Movilidad de la ciudad de San Luis Obispo,
Departamento de servicios de movilidad, 1260 Chorro Street, San Luis Obispo,
CA 93401
Page 33 of 41 Page 241 of 357
Acknowledgement Letter for Receipt of Complaint
[enter date]
[first name][last name]
[address 1]
[address 2]
[City], [state] [zip]
Dear [salutation & last name]:
This letter is to acknowledge receipt of your complaint against San Luis Obispo Transit alleging
_____________________________________________________________________________.
An investigation will begin shortly. If you have additional information you wish to convey or
questions concerning this matter, please feel free to contact this office by telephoning _____
___________ or write to me at this address. s
Sincerely,
Mobility Services Business Manager
City of San Luis Obispo
Public Works Department
1260 Chorro Street
San Luis Obispo, CA 93401
(805)781-7121
slotransit@slocity.org
Page 34 of 41 Page 242 of 357
Carta de acuse de recibo de la queja
[Ingresar fecha]
[Nombre][Apellido]
[Dirección 1]
[Dirección 2]
[Ciudad], [Estado] [Código postal]
Estimado/a [Saludo y apellido]:
Esta carta es para acusar recibo de su queja contra San Luis Obispo Transit, alegando
_____________________________________________________________________________.
En breve se iniciará una investigación. Si tiene información adicional o preguntas sobre este
asunto, no dude en comunicarse con esta oficina llamando al _____ ___________ o escríbame a
esta dirección.
Atentamente,
Mobility Services Business Manager
City of San Luis Obispo
Public Works Department
1260 Chorro Street
San Luis Obispo, CA 93401
(805)781-7121
slotransit@slocity.org
Page 35 of 41 Page 243 of 357
City of San Luis Obispo Transit – SLO Transit
Service Reduction
&
Fare Increase Policy
I.Purpose
49 USC Chapter 53, Section 5307(d)(1)(I) provides that urban grant recipient shall have:
“a locally developed process to solicit and consider
public comment before raising a fare or carrying out a
major reduction of transportation.”
The City of San Luis Obispo’s fixed-route SLO Transit system is a recipient of Federal
Transit funding and therefore must establish an acceptable public meeting procedure with
respect to fare increase and major service reductions as required by Federal law.
II.Definitions
a.Major Service Reduction:
i.An indefinite reduction of more than 15 percent of daily revenue miles or hours;
or
ii.A number of indefinite service reductions in any given fiscal year that add up to
more than 15 percent of daily revenue miles or hours.
b. Fare Increase:
i.Any increase to a fare price per unit of service.
c.Emergency Service Change:
i.Service change that is to be in effect for fewer than thirty (30) days; and
ii.Service change does not meet the criteria of Section II.A.
Examples of emergency service changes include, but are not limited to; those
due to power failure, severe weather, major construction, reconstruction, and
improvement projects.
III. Procedure
Attachment C - Major Service Reduction and Fare Increase Policy
Page 36 of 41 Page 244 of 357
a.If a Major Service Reduction or Fare Increase is determined to be necessary by SLO
Transit staff, a recommendation and supporting materials will be submitted to the City
of San Luis Obispo City Council (Council) for consideration.
b.If the Council determines that a Major Service Reduction or Fare Increase may be
necessary based on staff’s recommendation and supporting documentation, staff will
schedule and advertise a no less than two public meetings to be conducted in accordance
with City’s most recently adopted Public Engagement Manual. One said meeting will be
held during typical work day hours (before 5 p.m.) and the other after work day hours
(after 5 p.m.). At a minimum, public notices for public meetings will be posted at or
electronically sent to the following locations, in both English and Spanish:
i.City Hall (990 Palm St.)
ii.Transit Center
iii. On board fixed-route vehicles
iv. County/City Public Library
v.Local Access TV Channel 21
vi. SLO Transit website with email link for comments
vii. City of San Luis Obispo website with email link for comments
viii. Social Media (e.g. Facebook)
ix. Paid and legal notices in local print periodicals
x. Press Releases to local media outlets
c.A public meeting on the Major Service Reduction or Fare Increase will be held
in a convenient, accessible and diverse location.
i.The location selected will be along bus routes whenever possible;
ii.The public meeting will be held under the supervision of SLO Transit
Manager;
iii. The public comments will be recorded and filed; and
iv. The public meeting may be held at a regular Mass Transit Advisory Committee
meeting.
v.Spanish speaking assistance availability
d. After the public meeting is closed, staff will give a recommendation for consideration by
the Council
e.If Council adopts a plan for a Major Service Reduction or Fare Increase, the SLO
Transit Manager shall be authorized and directed to implement the action according to
the approved transit schedule. The schedule shall provide a minimum of 45 (calendar)
days public notice of the service or fare changes prior to their implementation.
Page 37 of 41 Page 245 of 357
IV. Exemptions
The following criteria establish certain instances which are exempt from the
requirement to solicit public comment:
a.Standard seasonal variations;
b. Special Events (e.g. marathon, triathlon, etc.)
c.Changes imposed and under the control of private organizations (e.g. CalPoly)
d.An Emergency Service Change;
e.Experimental service changes for a period of 180 days or less, unless the changes
extend beyond 180 days and meet the criteria of a Major Service Reduction as defined
in Section II.A;
f.Any fare, ticket or pass rate changes that do not result in increased fares per unit
of service;
g.Increases in service; or
h. Decreases in fares.
Page 38 of 41 Page 246 of 357
Attachment D – Community Partners List
Below is a list of the community partners that were contacted to complete a survey as
part of the Four Factor Analysis.
•People’s Self-Help Housing (PSHH)
•Community Action Partnership of SLO (CAPSLO)
•Housing Authority of SLO (HASLO)
•County of San Luis Obispo Public Health
•Cal Poly Transportation & Parking Department
•Transitions Mental Health Association (THMA)
•Gay and Lesbian Alliance (GALA)
•Race Matters
•San Luis Obispo Chamber of Commerce
•San Luis Coastal Unified School District
o SLO High School Leadership
o Laguna Middle School Leadership
o Bishops Peak Principal
o CL Smith Principal
o Hawthorne Elementary Principal
o Los Ranchos Elementary Principal
o Sinsheimer Elementary Principal
o Teach Elementary Principal
•Cal Poly University Office of Diversity and Inclusion
•Ride-On Transportation
•San Luis Obispo County Access for All (Pathpoint)
Page 39 of 41 Page 247 of 357
San Luis Obispo Transit
1260 Chorro Street, San Luis Obispo, CA 93401
805.781.7012
www.slotransit.org
TITLE VI PROGRAM UPDATE – RIDER SURVEY (ENGLISH VERSION)
We want your feedback to improve services for riders with limited English. This short survey
helps us better support all riders. Your answers are confidential. Thank you!
1.How well do you read English?
a.Very well
b.Somewhat well
c.Not very well
2.How well do you speak English?
a.Very well
b.Somewhat well
c.Not very well
3.Do you speak a language(s) other than English at home?
a.No
b.Yes, I speak __________________________
4.Have you called SLO Transit Dispatch for assistance?
a.Yes
b.No
5.If yes, how well were you able to communicate with staff?
a.Very well
b.Somewhat well
c.Not very well
6.How do you get information about SLO Transit services?
a.Ask bus drivers
b.Call dispatch
c.From friends, families, co-workers
d.Internet (Google)
e.Other: _____________________________________
7.Why do you ride the bus?
Attachment E - Transit Rider Survey Form
Page 40 of 41 Page 248 of 357
City of San Luis Obispo, Title, Subtitle
San Luis Obispo Transit
1260 Chorro Street, San Luis Obispo, CA 93401
805.781.7012
www.slotransit.org
ENCUESTA DEL TÍTULO VI – ACCESO AL IDIOMA
Queremos conocer su opinión para mejorar los servicios para personas con dominio limitado
del inglés. Esta breve encuesta nos ayuda a brindar mejor apoyo a todos los pasajeros. Sus
respuestas son confidenciales. Hay ayuda disponible en su idioma si la necesita. ¡Gracias!
1.¿Qué nivel de inglés tiene?
a.Muy bien
b.Algo bien
c.No muy bien
2.¿Habla bien inglés?
a.Muy bien
b.Algo bien
c.No muy bien
3.¿Habla en casa otro(s) idioma(s) distinto(s) del inglés?
a.No
b.Sí, hablo ____________________________
4.¿Ha llamado a SLO Transit Dispatch para pedir ayuda?
a.Sí
b.No
5.En caso afirmativo, ¿cómo de bien pudo comunicarse con el personal?
a.Muy bien
b.Algo bien
c.No muy bien
6.¿Cómo obtiene información sobre los servicios de SLO Transit?
a.Pregunte a los conductores
b.Llama a la central
c.De amigos, familiares, compañeros de trabajo
d.Internet (Google)
e.Otros: ________________________________
7.¿Por qué viaja en autobús?
Page 41 of 41 Page 249 of 357
Page 250 of 357
Title VI Program for the
City of San Luis Obispo Public Works
Department
Final Draft: 07, 29, 2025
Prepared by:
City of San Luis Obispo
Public Works Department
919 Palm Street
San Luis Obispo, CA 93401
Tel: (805) 781-7200
www.slocity.org
Page 251 of 357
I: Non-Discrimination Policy Statement ___________________________________________ 1
II: Non-Discriminatory Legislation ________________________________________________ 2
III: Organization Staffing and Responsibilities ______________________________________ 3
Title VI Coordinator _______________________________________________________________________ 3
Title VI Specialist _________________________________________________________________________ 3
Title VI Liaison ___________________________________________________________________________ 3
IV: Title VI Complaint Procedures ________________________________________________ 4
Post-Submittal Actions ______________________________________________________________ 5
Title VI Investigations, Complaints, and Lawsuits _______________________________________________ 6
Title VI Program Information _______________________________________________________________ 6
Public Works Website _____________________________________________________________________ 7
Social Media Network _____________________________________________________________________ 7
Public Notices ___________________________________________________________________________ 7
Community Outreach Conducted by the Department____________________________________________ 8
VI: Language Assistance Plan ___________________________________________________ 8
Limited English Proficiency _________________________________________________________________ 9
Title VI Information Dissemination ___________________________________________________________ 9
VII: Data Collection and Analysis ________________________________________________ 10
Title VI Assurances and Provisions __________________________________________________________ 10
Review and Remedial Action ______________________________________________________________ 10
Environmental Justice ____________________________________________________________________ 11
IX: Staff Training _____________________________________________________________ 11
X: Annual Work Plan _________________________________________________________ 11
Appendix ___________________________________________________________________ 13
A. Limited English Proficiency Plan ___________________________________________________ 13
B. Notice to Public _________________________________________________________________ 17
C. Complaint Form _________________________________________________________________ 18
D. Community Partners _____________________________________________________________ 22
E. US DOT Title VI Assurances A-E ____________________________________________________ 23
APPENDIX A ____________________________________________________________________________ 23
APPENDIX B ____________________________________________________________________________ 24
APPENDIX C ____________________________________________________________________________ 25
APPENDIX D ____________________________________________________________________________ 26
APPENDIX E ____________________________________________________________________________ 27
Page 252 of 357
1
I: Non-Discrimination Policy Statement
The City of San Luis Obispo (SLO) Public Works Department is committed to ensuring
compliance with Title VI of the Civil Rights Act of 1964 and other non-discriminatory
authorities, such that no person shall be excluded from participation in or be denied the
benefits of any program or activity conducted by the City of SLO Public Works Department
on the grounds of race, color, national origin, sex, age, disability, religion, sexual
orientation, gender identity, or any other category protected by State or Federal law.
Further, no person shall be subjected to discrimination under any program or activity
conducted by the City of SLO Public Works Department, on the grounds of race, color,
national origin, sex, age, disability, religion, sexual orientation, gender identity, or any
other category protected by State or Federal law.
Title VI compliance is a condition of receipt of federal funds. The Title VI Coordinator is
authorized to ensure compliance with this policy, Title VI of the Civil Rights Act of 1964,
42 U.S.C § 2000d and related statutes, and the requirements of 23 Code of Federal
Regulation (CFR) pt. 200 and 49 CFR pt. 21.
_________________________________ _____________________
Matt Pennon Date
DEI Manager
City of San Luis Obispo
Page 253 of 357
2
II: Non-Discriminatory Legislation
Title VI of the Civil Rights Act of 1964 – Provides 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 subjected to discrimination, under any program or activity
receiving Federal financial assistance (as implemented through 23 CFR 200.9 and 49
CFR 21).
Section 162(a) of the Federal-Aid Highway Act of 1973 (Section 324, Title 23 U.S.C.)
– Prohibits discrimination on the basis of sex by recipients and sub-recipients of Federal
financial assistance.
Section 504 of the Rehabilitation Act of 1973 – Prohibits discrimination on the basis of
disability by recipients and sub-recipients of Federal financial assistance.
The Age Discrimination Act of 1975 (Section 6101-6107, Title 42 U.S.C.) – Prohibits
discrimination on the basis of age by recipients and sub-recipients or Federal financial
assistance.
The Civil Rights Restoration Act of 1987 (Public Law 200-209) – Clarifies that the
original intent of Congress in Title VI of the Civil Rights Act of 1964, Title IX of the
Educational Amendments of 1972, the Age Discrimination Act of 1975, and Section 504
of the Rehabilitation Act of 1973 was to apply the non-discrimination statutes to all
programs and activities of Federal-aid recipients, sub-recipients, contractors and
vendors, whether all such programs are federally assisted or not.
Executive Order 12898 (issued February 11, 1994) – Addresses Environmental Justice
regarding minority and low-income populations and requires agencies to develop
strategies to address disproportionately high and adverse human health or environmental
effects of their programs on minority and low-income populations; promote
nondiscrimination in federal programs substantially affecting human health and the
environment; and provide minority and low-income communities access to public
information and an opportunity for public participation in matters relating to human health
or the environment.
Executive Order 13166 (issued August 16, 2000) – Addresses improved access to
services for persons with limited English proficiency. Agencies are directed to evaluate
services provided and implement a system that ensures that Limited English Proficiency
(LEP) persons are able to meaningfully access the services provided consistent with, and
without unduly burdening, the fundamental mission of the local agency. Agencies are
directed to ensure that recipients of federal financial assistance provide meaningful
access to program, services and information to their LEP applicants and beneficiaries
free of charge.
Page 254 of 357
3
III: Organization Staffing and Responsibilities
The City of SLO’s Title VI program is built to work toward the ultimate goal of assuring full
compliance with the provisions of Title VI of the Civil Rights Act of 1964 and related
statutes. To accomplish this, the City has designated the Title VI Coordinator, along with
other roles, to be responsible for the overall program implementation of and compliance
with Title VI. The roles and responsibilities are as follows:
Title VI Coordinator
• Ensures that the City’s Title VI program is up to date with all requirements set forth
by the Federal Highway Administration (FHWA), California Department of
Transportation (Caltrans), and any other applicable jurisdictions.
• Maintains open line of communication with City Manager, City Council, and other
City leadership positions to facilitate the Title VI Program.
• Directs all staff to coordinate and attend trainings.
• Promptly processes and resolves Title VI complaints.
• Ensures Title VI reviews of the City’s Federal-aid program areas, including pre-
and post-grant reviews for compliance with Title VI requirements.
• Provides an annual report of Title VI activity goals, including an annual review of
the Title VI Program Plan.
• Creates and distributes Title VI information for public dissemination.
Title VI Specialist
• Ensures applicable staff are present for Title VI trainings and diligently following
Title VI procedures.
• Prepares and coordinates Title VI Plan and Annual Report submission.
• Ensures that Title VI Assurances have been incorporated into all Federal-aid
Contracts and Agreements.
• Ensures the collection of statistical data (race, color, national origin, sex, etc.) of
participants in and beneficiaries of the City’s Federal-aid programs, activities, and
services.
• Analyzes data collected to determine effectiveness of outreach methods to avoid
group exclusion and encourage group participation.
• Develops complaint procedures, complaint log, and ensures that all applicable staff
are properly trained in the complaint reporting procedures.
• Develops Title VI information for public dissemination.
Title VI Liaison
• Attends trainings as to maintain knowledge of current Title VI requirements.
• Reports complaints through complaint procedure listed as part of the City’s Title
VI Implementation Plan.
• Incorporates required Title VI language into relevant contracts and agreements.
Page 255 of 357
4
Figure 1 – Title VI Organization Chart
IV: Title VI Complaint Procedures
Any person who believes that they have been discriminated against on the basis of race,
color, and/or national origin may file a Title VI complaint with Public Works by completing
and submitting a Title VI Complaint Form (Appendix C). Complaints must be filed no more
than 180 days after the alleged incident occurred and must include complete information,
including the complainant’s contact information, details of the alleged discrimination, and
the complainant’s signature.
English and Spanish versions of the Title VI complaint form is available on SLO Public
Work’s webpage Accessibility & Civil Rights | City of San Luis Obispo, CA. Physical
copies can also be obtained in person at the Public Works Office located at 919 Palm
Street, San Luis Obispo, CA 93401.
Page 256 of 357
5
Once the form is obtained, complainants can follow the steps below to complete and
submit the form.
1. Complete the Complaint Form. If a customer needs assistance in completing the
form, then they may contact Public Works at 805-781-7200 for assistance.
2. Sign the Complaint Form. Customers are required to sign the Complaint Form.
3. Submit the Complaint Form. Civil rights complaints should be filed immediately.
However, SLO Public Works will investigate complaints up to 180 days after the
alleged incident. Customers should submit their complaints to:
City of San Luis Obispo
Attn: Title VI Coordinator
919 Palm Street
San Luis Obispo, CA 93401
Alternatively, customers may also submit their complaints directly to the FHWA’s Office
of Civil Rights or Caltrans Office of Civil Rights using the following address:
Federal Highway Administration
U.S. Department of Transportation
Office of Civil Rights
1200 New Jersey Avenue, SE
8th Floor E81-104
Washington, DC 20590
California Department of Transportation
Office of Civil Rights
Attention: Title VI Program Branch
1823 14th Street, MS 79
Sacramento, CA 95811
Post-Submittal Actions
The following post-submittal actions are taken to ensure complaints are thoroughly
investigated and that the complainant is informed of the results of the investigation.
1. Acknowledgement. Complaints will be recorded and assigned a complaint
number. SLO Public Works will review the complaint to determine if there was a
Title VI violation(s). Staff will send an acknowledgement letter for receipt of
complaint informing the customer that their complaint was received and that SLO
Public Works will investigate.
2. Investigation. SLO Public Works has up to ninety (90) days to investigate the
complaint. If more information is needed to resolve the case, then SLO Public
Works may contact the complainant. The complainant has ten (10) days from the
date of contact to send the requested information to the investigator assigned to
the case.
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If the investigator is not contacted by the complainant or does not receive the
additional information within ten (10) days, then SLO Public Works can
administratively close the case. The case can also be administratively closed if the
complainant no longer wishes to pursue their case.
3. Decision. After the investigator reviews the complaint, one of the following letters
will be issued to the complainant: a closure letter or a Letter of Finding (LOF). A
closure letter summarizes the allegations and states that there was not a Title VI
violation and that the case will be closed. A LOF summarizes the allegations and
the interviews regarding the alleged incident, and explains whether any disciplinary
action, additional training of the staff member, or other action will occur.
4. Appeal. If the complainant wishes to appeal the decision, then they have ten (10)
days after the date of the closure letter or the LOF to do so.
Title VI Investigations, Complaints, and Lawsuits
SLO Public Works maintains a list of public Title VI investigations, complaints, and
lawsuits filed since the time of the last Title VI program submission which alleges
discrimination on the basis of race, color, or national origin. This list includes the date that
the investigation, lawsuit, or complaint was filed; a summary of the allegation(s); the
status of the investigation, lawsuit, or complaint; and actions taken by SLO Public Works
in response, or findings related to the investigation, lawsuit, or complaint. Public Works
does not have any investigations, complaints, or lawsuits with regards to Civil Rights
Violations at this time.
V: Public Outreach and Information Resources
The purpose of public participation is to help ensure that the residents of the City of San
Luis Obispo are kept informed and involved in Public Works' various programs, projects
and activities. Public Works is committed to ensuring it serves the residents in the City of
San Luis Obispo by delivering efficient, responsive, and cost-effective public works
services that protect and enhance the safety, health, and quality of life in the City of San
Luis Obispo. Public Works values public participation and encourages involvement by the
community.
Following are the outreach strategies that will be implemented by Public Works in an effort
to reach the citizens of the City of San Luis Obispo and provide equal access to up-to-
date information and promote an active channel of communication.
Title VI Program Information
The Title VI Plan, Public Notice (see Appendix B), Non-discrimination Title VI Policy
Statement, Complaint Process, Complaint Forms (see Appendix C) and Title VI Brochure
are posted on Public Works' website. Public Works' Title VI Policy Statement shall be
included in bid specification posting for federally funded projects, included by reference
of the Presidential Executive Order Number 11246 as amended by Executive Order (1)
75 and as approved by Department of Labor Relations (41 CFR Part 61) construction and
consultant contracts and the Public Notice shall be posted at the front counter of the
Public Works main office, and all Public Works public access facilities.
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Public Works Website
Public Works maintains a well-organized website that is accessible to the public. The
website provides information regarding the different divisions and services within Public
Works; news and events; online services; down-loadable materials; Board meeting
calendar and agenda; reports; citizen brochures; City road closures; updates on projects
and programs; City of San Luis Obispo Title VI Plan – 2025; information regarding public
transportation; City of San Luis Obispo's Capital Improvement Plan; Policies and Program
information, etc. Public Works provides language translation on its website.
Social Media Network
Public Works has a social media network presence on X (Twitter), Facebook, Instagram,
and YouTube to support our public outreach efforts. We use this media forum to
disseminate information to the public on events, programs, news releases, media
advisories, construction project information, informational videos, new services, etc. The
consumer, via their computing device, can choose their desired language which enables
an individual with Limited English Proficiency (LEP) equal access to information, allowing
Public Works to continue promoting a culture of dialogue between the public and Public
Works.
Public Notices
Public Works will post public notices to the City’s website that will provide contact
information, translation capabilities and resources for translation services if language
assistance is required. This will be done in accordance with the City’s Public Engagement
and Noticing (PEN) Manual, which can be found at PEN Manual Templates | City of San
Luis Obispo, CA.
Guided by the principles of Inform, Consult, and Collaborate (See Figure 1); SLO Public
Works provides clear information, actively seeks feedback, and partners with the public
in identifying and evaluating alternatives.
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Figure 2 - Action Plan Matrix
To support equitable participation, SLO Public Works maintains relationships with a
network of nonprofits, businesses, and community organizations, particularly those
serving underrepresented groups. Follow-up with participants helps close the feedback
loop, and an engagement toolbox supports accessible, effective outreach.
Community Outreach Conducted by the Department
SLO Public Works staff regularly engage with the community to provide information,
answer questions, and build awareness around current and upcoming infrastructure
projects. Outreach efforts include participation in events such as the Downtown San Luis
Obispo Farmers’ Market “Public Works Week”, where staff highlight major initiatives and
gather input from the public. Staff also hold community workshops to gather public input
on specific project designs such as active transportation and public park projects.
VI: Language Assistance Plan
SLO Public Works has developed its Language Assistance Plan (LAP) to address SLO
Public Works’ responsibilities as a recipient of federal funding. The LAP helps to identify
reasonable steps for providing language assistance to persons with Limited English
Proficiency (LEP) who wish to access services and programs. Persons with LEP are
those who do not speak English as their primary language and have limited ability to read,
write or understand English.
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Table 1: Comparison of Language Spoken at Home in San Luis Obispo
Language Spoken
Group
Population
Estimate
Group’s
Percentage
of
Population
Estimate
Portion of Group
that Speaks
English Very Well
Portion of Group
that Does Not
Speak English
Very Well
English Only 38,864 83.4% 38,864 (100%) 0 (0%)
Spanish 4,608 9.9% 3,697 (80.2%) 911 (19.8%)
Other Indo-European Languages 1,362 2.9% 1,197 (87.9%) 165 (12.1%)
Asian/Pacific Island Languages 1,395 3.0% 1,104 (79.1%) 291 (20.9%)
Other Languages 395 0.8% 358 (90.6%) 37 (9.4%)
Total Population Above 5 Years 46,624 45,220 (97%) 1,404 (3%)
Source: US Census: American Community Survey 2023 ACS 5-Year Estimate
https://data.census.gov/table/ACSST5Y2023.S1601?q=San+Luis+Obispo+city,+California+language
Limited English Proficiency
A Limited English Proficiency (LEP) person is a person that does not speak English as a
primary language and has a limited ability to read, write, or comprehend English. Per
Executive Order 13166, agencies which receive Federal funding must examine their
federally funded services and develop and implement processes that will allow LEP
persons to meaningfully access said services. Executive Order 13166 also requires that
agencies receiving Federal funding must establish guidance for providing meaningful
access to LEPs, prepare a plan to overcome language barriers in federally funded
programs and activities, and ensure that stakeholders have adequate opportunity to
provide input.
As shown in Table 1 above, 3.0% of residents in the City of San Luis Obispo are
considered LEP persons, with the majority of those LEP persons primarily speaking
Spanish (9.9% of the community). As outlined in the City’s LEP Plan (Appendix A), the
City has conducted a LEP Needs Assessment, using a Four Factor Analysis to identify
need and provide access to the LEP community in compliance with Executive Order
13166.
Title VI Information Dissemination
SLO Public Works’s goal is to provide meaningful access for persons with LEP to all of
its services, programs, and information. Efforts to effectively engage persons with LEP
will ensure that they can equally contribute to and benefit from the development and
improvement of SLO Public Work’s services and programs.
In order to ensure that Title VI and related Civil Rights information is readily available to
the public, the city will develop public notices consisting of posters, flyers, and complaint
forms that are available in English and Spanish. The languages selected for the
informational materials were based upon language data provided from the US Census;
see Table 1 above. Said flyers and posters will be placed in the City Hall lobby, in a highly
visible and accessible location. The public notices will also be available for viewing on the
City’s website, at www.slocity.org.
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SLO Public Works will comply with the Safe Harbor Provision, which outlines
circumstances that can provide a “safe harbor” for recipients regarding translation of
written materials for LEP populations. The Safe Harbor Provision states that, if a recipient
provides written translation of vital documents for each eligible LEP language group that
constitutes five percent or 1,000 persons, whichever is less, of the total population of
persons eligible to be served or likely to be affected or encountered, then such action will
be considered strong evidence of compliance with the recipient’s written translation
obligations. These safe harbor provisions apply to the translation of written documents
only.
VII: Data Collection and Analysis
Demographic and related data collected and used by City staff comes from governmental
sources responsible for collecting and vetting the information for consistency and
accuracy. These sources include, but are not limited to, the U.S. Bureau of Labor Statics,
U.S. Census Bureau, U.S. Bureau of Economic Analysis, California Department of
Finance, California Department of Labor, and the California Employment Development
Department.
Additionally, staff may also collect project-specific demographic data utilizing data
collection as appropriate through the public outreach process on federally funded
projects. Such outreach that may give staff the opportunity to collect demographic data
may include door hangers, posters, emails, social media releases, press releases to local
newspaper, public meetings, virtual meetings, and public comment through websites
generated for projects.
VIII: Implementing Title VI Program Activities
Title VI Assurances and Provisions
The City’s Title VI Coordinator will ensure that any federally-funded project documents
contain the necessary Title VI Assurances and other language. Such assurances include,
but may not be limited to:
• FHWA Form 1273 (Title VI and other non-discriminatory requirements)
ο Required on all FHWA contracts and subcontracts valued greater than
$10,000
• Title VI Assurances Appendix A-E (Appendix E)
ο Appendix A-E to be attached to Federal-Aid contracts
Review and Remedial Action
Public Works will conduct periodic Title VI self-assessment of its programs and activities
for compliance. Where applicable, revise policies, procedures and directives to include
Title VI requirements.
When irregularities occur in the administration of Title VI programs, corrective action will
be taken to resolve identified Title VI issues. Swift action will be taken to correct any
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deficiencies found by Public Works, Caltrans, or the Federal Highway Administration
(FHWA), not to exceed 90 days, in order to implement Title VI compliance in accordance
with this plan.
Public Works will periodically conduct Title VI compliance reviews of Consultants,
Contractors and Subcontractors. The review of selected recipients of Federal Aid
Highway or other Federal funds will be conducted to ensure adherence to Title VI
requirements. Public Works shall confirm guidelines provided to consultants, contractors,
and subcontractors including Title VI language, provisions, and related requirements, as
applicable.
Environmental Justice
Public Works strives to identify and address the public works and transportation needs of
the citizens of the City of San Luis Obispo and ensures that the benefits and burdens of
investments are being fairly distributed. Safety and improving the quality of life of City
residents is Public Works' primary concern. Striving to be transparent in the process of
government and insuring access for all is what Public Works strives to do in providing the
best, cost-effective facilities and projects to the public.
In accordance with Executive Order 12898, “Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income Populations”, the City will develop
strategies to address disproportionately high and adverse health or environmental effects
on minority and low-income populations to promote nondiscrimination in Federal-aid
programs substantially affecting human health and the environment, and to provide
minority and low-income communities access to public information and an opportunity for
public participation in matters relating to human health or the environment.
IX: Staff Training
Training will be provided every two years, and within six months of hiring a new employee,
by the Office of DEI for all Public Works staff.
Training will include the following:
1. Information on what Title VI is, what staff responsibilities are;
2. How to Identify and document language needs of LEP persons;
3. How to deliver services effectively to LEP persons;
4. Procuring interpreter services needed;
5. Description of language assistance services offered to the public;
6. Documentation of language assistance requests; and
7. How to handle a potential Title VI/LEP complaint.
X: Annual Work Plan
The City of San Luis Obispo Public Works Department will annually establish and monitor
program goals and accomplishments. The Title VI Coordinator will ensure that employee
training is conducted, language translation services continue to be available, public
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participation is optimal, and appropriate Title VI signage is posted. This also includes
updating community statistics and corresponding with state and federal agencies as
necessary.
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Appendix A
Limited English Proficiency Plan
Background
Executive Order 13166, “Improving Access to Services for Persons with Limited English
Proficiency” requires that Federal agencies work to ensure that the recipients of Federal
financial assistance provide meaningful access to their Limited English Proficiency (LEP)
applicants and beneficiaries.
As such, local agencies are required to ensure that federally funded programs and
activities normally provided in English are accessible to LEP Persons. Each local agency
shall perform an annual assessment to determine if modifications are needed to their
programs and activities to ensure meaningful access by LEP persons. The assessment
which is referred to as a “Four-Factor” analysis is based on the following factors:
1. Factor 1 - The number or proportion of persons with LEP eligible to be served or
likely to be encountered by SLO Public Works
2. Factor 2 - The frequency with which persons with LEP come into contact with SLO
Public Work’s services and programs
3. Factor 3 - The nature and importance of SLO Public Work’s services and programs
in people’s lives
4. Factor 4 - The resources available to SLO Public Works for LEP outreach, as well
as the costs associated with that outreach.
Figure 1 - Location of the City of San Luis Obispo
San Luis Obispo (City) Overview
SLO Public Works serves the City of San Luis Obispo and the adjacent university campus.
The primary languages spoken in the City of San Luis Obispo are English and Spanish.
The total population is approximately 47,000 (US Census: American Community Survey
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2023 5-Year Estimate). Of the 46,624 residents, approximately 9.9% of the residents are
Spanish speaking, 2.9% of the residents are Other Indo-European Language speaking,
and 3.0% are Asian/Pacific Island Language speaking.
Four-Factor Analysis
1. The number or proportion of LEP persons eligible to be served or likely to be
encountered.
As shown in Table 1 below, San Luis Obispo has approximately 46,624 residents. 1,404
(3.0%) of residents are considered LEP persons, with the majority of those LEP persons
primarily speaking Spanish (4,608, 9.9% of the community), Other Indo-European
Languages (1,362, 2.9% of the community), and Asian/Pacific Island Languages (1,395,
3% of the community). The remaining 395 (0.8%) of the population speak other
languages.
Table 1: Comparison of Language Spoken at Home in San Luis Obispo
Language Spoken
Group
Population
Estimate
Group’s
Percentage
of
Population
Estimate
Portion of Group
that Speaks
English Very Well
Portion of Group
that Does Not
Speak English
Very Well
English Only 38,864 83.4% 38,864 (100%) 0 (0%)
Spanish 4,608 9.9% 3,697 (80.2%) 911 (19.8%)
Other Indo-European Languages 1,362 2.9% 1,197 (87.9%) 165 (12.1%)
Asian/Pacific Island Languages 1,395 3.0% 1,104 (79.1%) 291 (20.9%)
Other Languages 395 0.8% 358 (90.6%) 37 (9.4%)
Total Population Above 5 Years 46,624 45,220 (97%) 1,404 (3%)
Source: US Census: American Community Survey 2023 ACS 5-Year Estimate
https://data.census.gov/table/ACSST5Y2023.S1601?q=San+Luis+Obispo+city,+California+language
2. The frequency of LEP contacts.
No data has been collected regarding the frequency of contact with LEP persons at the
City. Most interactions with LEP persons occur at the City’s Finance Department due to
residents paying utility bills. Based on observation from Finance Department front-counter
staff, the frequency for translation from Spanish to English is on average once per day.
Currently the City’s Human Resources Department retains a list which lists all City staff
which are certified translators for various languages. If front counter staff that speak
Spanish or another language are not available, City staff will reach out to a certified
translator from the list. Public Works staff do not regularly receive requests for translation
through Federally funded programs/projects, though the outreach components of said
programs/projects do typically have multi-lingual resources. Further, if translation
services are needed, staff will provide said translation in a timely manner.
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3. The nature and importance of programs, services, or activities provided by the City of
San Luis Obispo.
From observation provided by Public Works staff, it is rare that translation services are
requested for programs, services, or activities which are federally funded. As stated
above, the front counter Staff with the City’s Finance Department are the ones who most
frequently encounter LEP persons requesting and/or needing translation services.
Though Public Works Staff has received very few requests for translation services on
federally funded projects, programs and services, Staff is keenly aware that three percent
of the City’s residents are LEPs and therefore it is reasonably likely that LEPs will be
stakeholder in any of the said projects, programs and services. As such, when Staff has
encountered the need for translation services, Staff has provided the services readily.
4. The Resources Available for LEP persons. After a review of the City’s currently
available resources for LEP persons, the City has determined that the current available
resources are lacking and inconsistent. The City will remedy the lack of resources,
through the action plan listed in the next section.
Action Plan
In order to ensure compliance with Title VI, and Executive Order 13166 the following
publications and services will be made available for LEP person use:
• Non-Discrimination Policy Statement
ο Statement shall be printed in English and Spanish. Said statement will be
posted in the City Hall lobby in a highly visible location.
• Title VI Rights Poster
ο Posters shall be printed in English and Spanish. Said posters will be posted
in the City Hall lobby in a highly visible location, and additional copies will
be available for the public to review and take.
• Title VI Complaint Form
ο Complaint forms shall be printed in English and Spanish. Said forms will be
in the City Hall lobby in a highly visible location.
• Title VI Webpage on City’s Website
ο All of the City’s Title VI resources will be posted on the City’s website at the
following link: www.slocity.org
• Future Planning and Projects
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ο Public Works will ensure that all future projects and planning documents
that are federally funded utilize outreach methods that are compliant with
Title VI and other related non-discriminatory assurances.
ο Additionally, the City will ensure that outreach materials are available in
English and Spanish, and that translators are readily available as necessary
for any LEP Persons that would like to contribute or participate.
Lastly, the Title VI Specialist will request an updated list of certified translators from the
Human Resources Department every six months and distribute said list to those who are
likely to encounter LEP persons, such that a translator can be contacted the moment one
is needed.
To ensure continuous compliance, the City will review the Title VI Implementation Plan
and Limited English Proficiency Plan regularly, but at a minimum, as new data from the
US Census becomes available. As new regulations are created, the City will act promptly
to update the existing plans and relevant resources.
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Appendix B
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18
Appendix C
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19 Page 271 of 357
20
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21
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Appendix D
Below is a list of the community partners that were contacted to complete a survey as
part of the Four Factor Analysis.
• People’s Self-Help Housing (PSHH)
• Community Action Partnership of SLO (CAPSLO)
• Housing Authority of SLO (HASLO)
• County of San Luis Obispo Public Health
• Cal Poly Transportation & Parking Department
• Transitions Mental Health Association (THMA)
• Gay and Lesbian Alliance (GALA)
• Race Matters
• San Luis Obispo Chamber of Commerce
• San Luis Coastal Unified School District
o SLO High School Leadership
o Laguna Middle School Leadership
o Bishops Peak Principal
o CL Smith Principal
o Hawthorne Elementary Principal
o Los Ranchos Elementary Principal
o Sinsheimer Elementary Principal
o Teach Elementary Principal
• Cal Poly University Office of Diversity and Inclusion
• Ride-On Transportation
• San Luis Obispo County Access for All (Pathpoint)
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Appendix E
US DOT Title VI Assurances A-E
APPENDIX A
During the performance of this contract, the contractor, for itself, its assignees, and successors in
interest (hereinafter referred to as the “contractor”) agrees as follows:
1. Compliance with Regulations: The contractor (hereinafter includes consultants) will
comply with the Acts and the Regulations relative to Nondiscrimination in Federally-
assisted programs of the U.S. Department of Transportation, Federal Highway
Administration, as they may be amended from time to time, which are herein incorporated
by reference and made a part of this contract.
2. Non-discrimination: The contractor, with regard to the work performed by it during the
contract, will not discriminate on the grounds of race, color, national origin, age, sex, or
disability in the selection and retention of subcontractors, including procurements of
materials and leases of equipment. The contractor will not participate directly or indirectly
in the discrimination prohibited by the Acts and the Regulations, including employment
practices when the contract covers any activity, project, or program set forth in Appendix
B of 49 CFR Part 21.
3. Solicitation for Subcontracts, Including Procurements of Materials and Equipment:
In all solicitations, either by competitive bidding, or negotiation made by the contractor for
work to be performed under a subcontract, including procurements of materials, or leases
of equipment, each potential subcontractor or supplier will be notified by the contractor of
the contractor’s obligations under this contract and the Acts and the Regulations relative
to Non-discrimination on the grounds of race, color, national origin, age, sex, or disability.
4. Information and Reports: The contractor will provide all information and reports required
by the Acts, the Regulations, and directives issued pursuant thereto and will permit access
to its books, records, accounts, other sources of information, and its facilities as may be
determined by the Recipient or the FHWA to be pertinent to ascertain compliance with
such Acts, Regulations, and instructions. Where any information required of a contractor
is in the exclusive possession of another who fails or refuses to furnish the information,
the contractor will so certify to the Recipient or the FHWA, as appropriate, and will set
forth what efforts it has made to obtain the information.
5. Sanctions for Noncompliance: In the event of a contractor’s noncompliance with the
Nondiscrimination provisions of this contract, the Recipient will impose such contract
sanctions as it or the FHWA may determine to be appropriate, including, but not limited
to:
a. withholding payments to the contractor under the contract until the contractor
complies; and/or
b. cancelling, terminating, or suspending a contract, in whole or in part.
6. Incorporation of Provisions: The contractor will include the provisions of paragraphs
one through six in every subcontract, including procurements of materials and leases of
equipment, unless exempt by the Acts, the Regulations and directives issued pursuant
thereto. The contractor will take action with respect to any subcontract or procurement as
the Recipient or the FHWA may direct as a means of enforcing such provisions including
sanctions for noncompliance. Provided, that if the contractor becomes involved in, or
threatened with litigation by a subcontractor, or supplier because of such direction, the
contractor may request the Recipient to enter into any litigation to protect the interests of
the Recipient. In addition, the contractor may request the United States to enter into the
litigation to protect the interests of the United States.
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APPENDIX B
CLAUSES FOR DEEDS TRANSFERRING UNITED STATES PROPERTY
The following clauses will be included in deeds effecting or recording the transfer of real property,
structures, or improvements thereon, or granting interest therein from the United States pursuant
to the provisions of Assurance 4:
NOW THEREFORE, the U.S. Department of Transportation as authorized by law and upon the
condition that the California Department of Transportation will accept title to the lands and
maintain the project constructed thereon in accordance with Title 23 U.S.C., the regulations for
the administration of the preceding statute, and the policies and procedures prescribed by the
FHWA of the U.S. Department of Transportation in accordance and in compliance with all
requirements imposed by Title 49, Code of Federal Regulations, U.S. Department of
Transportation, Subtitle A, Office of the Secretary, Part 21, Nondiscrimination in Federally-
assisted programs of the U.S. Department of Transportation pertaining to and effectuating the
provisions of Title VI of the Civil Rights Act of 1964 (78 Stat. 252; 42 U.S.C. § 2000d to 2000d-4),
does hereby remise, release, quitclaim and convey unto the California Department of
Transportation all the right, title and interest of the U.S. Department of Transportation in and to
said lands described in Exhibit A attached hereto and made a part hereof.
(HABENDUM CLAUSE)
TO HAVE AND TO HOLD said lands and interests therein unto the California Department of
Transportation and its successors forever, subject, however, to the covenants, conditions,
restrictions and reservations herein contained as follows, which will remain in effect for the period
during which the real property or structures are used for a purpose for which Federal financial
assistance is extended or for another purpose involving the provision of similar services or
benefits and will be binding on the California Department of Transportation, its successors and
assigns.
The California Department of Transportation, in consideration of the conveyance of said lands
and interest in lands, does hereby covenant and agree as a covenant running with the land for
itself, its successors and assigns, that (1) no person 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 with regard to any facility located wholly or in part on, over, or under such lands
hereby conveyed [,] [and]* (2) that the California Department of Transportation will use the lands
and interests in lands and interest in lands so conveyed, in compliance with all requirements
imposed by or pursuant to Title 49, Code of Federal Regulations, U.S. Department of
Transportation, Subtitle A, Office of the Secretary, Part 21, Nondiscrimination in Federally-
assisted programs of the U.S. Department of Transportation, Effectuation of Title VI of the Civil
Rights Act of 1964, and as said Regulations and Acts may be amended[, and (3) that in the event
of breach of any of the above-mentioned non-discrimination conditions, the Department will have
a right to enter or re-enter said lands and facilities on said lands, and that above described land
and facilities will thereon revert to and vest in and become the absolute property of the U.S.
Department of Transportation and its assigns as such interest existed prior to this instruction].*
(*Reverter clause and related language to be used only when it is determined that such a clause
is necessary in order to make clear the purpose of Title VI.)
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APPENDIX C
CLAUSES FOR TRANSFER OF REAL PROPERTY ACQUIRED OR IMPROVED UNDER THE
ACTIVITY, FACILITY, OR PROGRAM
The following clauses will be included in deeds, licenses, leases, permits, or similar instruments
entered into by the California Department of Transportation pursuant to the provisions of
Assurance 7(a):
A. The (grantee, lessee, permittee, etc. as appropriate) for himself/herself, his/her heirs, personal
representatives, successors in interest, and assigns, as a part of the consideration hereof, does
hereby covenant and agree [in the case of deeds and leases add “as a covenant running with the
land”] that:
1. In the event facilities are constructed, maintained, or otherwise operated on the property
described in this (deed, license, lease, permit, etc.) for a purpose for which a U.S. Department of
Transportation activity, facility, or program is extended or for another purpose involving the
provision of similar services or benefits, the (grantee, licensee, lessee, permittee, etc.) will
maintain and operate such facilities and services in compliance with all requirements imposed by
the Acts and Regulations (as may be amended) such that no person on the grounds of race, color,
or national origin, will be excluded from participation in, denied the benefits of, or be otherwise
subjected to discrimination in the use of said facilities.
B. With respect to licenses, leases, permits, etc., in the event of breach of any of the above
Nondiscrimination covenants, the California Department of Transportation will have the right to
terminate the (lease, license, permit, etc.) and to enter, re-enter, and repossess said lands and
facilities thereon, and hold the same as if the (lease, license, permit, etc.) had never been made
or issued.*
C. With respect to a deed, in the event of breach of any of the above Nondiscrimination covenants,
the California Department of Transportation will have the right to enter or re-enter the lands and
facilities thereon, and the above described lands and facilities will there upon revert to and vest
in and become the absolute property of the California Department of Transportation and its
assigns.*
(*Reverter clause and related language to be used only when it is determined that such a clause
is necessary to make clear the purpose of Title VI.)
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APPENDIX D
CLAUSES FOR CONSTRUCTION/USE.ACCESS TO REAL PROPERTY ACQUIRED UNDER
THE ACTIVITY, FACILITY OR PROGRAM
The following clauses will be included in deeds, licenses, permits, or similar
instruments/agreements entered into by the California Department of Transportation pursuant to
the provisions of Assurance 7(b):
A. The (grantee, licensee, permittee, etc., as appropriate) for himself/herself, his/her heirs,
personal representatives, successors in interest ,and assigns, as a part of the consideration
hereof, does hereby covenant and agree (in the case of deeds and leases add, “as a covenant
running with the land”) that (1) no person on the ground of race, color, or national origin, will be
excluded from participation in, denied the benefits of, or be otherwise subjected to discrimination
in the use of said facilities, (2) that in the construction of any improvements on, over, or under
such land, and the furnishings of services thereon, no person on the ground of race, color, or
national origin, will be excluded from participation in, denied the benefits or, or otherwise be
subjected to discrimination, (3) that the (grantee, licensee, lessee, permittee, etc.) will use the
premises in compliance with all other requirements imposed by or pursuant to the Acts and
Regulations, as amended, set forth in this Assurance.
B. With respect to (licenses, leases, permits, etc.) in the event of breach of any of the above of
the above Non-discrimination covenants, the California Department of Transportation will have
the right to terminate the (license, permits, etc., as appropriate) and to enter or re-enter and
repossess said land and the facilities thereon, and hold the same as if said (license, permit, etc.,
as appropriate) had never been made or issued.*
C. With respect to deeds, in the event of breach of any of the above Nondiscrimination covenants,
the California Department of Transportation will there upon revert to and vest in and become the
absolute property of the California Department of Transportation and its assigns.
(*Reverter clause and related language to be used only when it is determined that such a clause
is necessary to make clear the purpose of Title VI.)
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27
APPENDIX E
During the performance of this contract, the contractor, for itself, its assignees, and successors in
interest (hereinafter referred to as the “contractor”) agrees to comply with the following non-
discrimination statutes and authorities, including, but not limited to: Pertinent Non-Discrimination
Authorities:
During the performance of this contract, the contractor, for itself, its assignees, and successors in
interest (hereinafter referred to as the “contractor”) agrees to comply with the following non-
discrimination statutes and authorities, including, but not limited to: Pertinent Non-Discrimination
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); 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 CR 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 U.S.C. § 471, 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 of 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 49 C.F.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).
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