City of Dothan Title VI Compliance Program

Policy Statement

The City of Dothan ensures compliance with “Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition against discrimination based on National Origin as required by 42 USC Section 2000d and discrimination affecting Limited English Proficient (LEP) Persons” (Guidance) as required by Executive Order (EO) 13166. EO 13166 directs federal agencies that extend assistance, subject to the requirements of Title VI, to publish guidance to clarify recipients' obligations to LEP persons.

The purpose of this plan is to assist the City of Dothan in its administration and management of activities related to Title VI compliance. The City of Dothan's Title VI Compliance Coordinator, Kelly Mierkowski, CDBG Program Administrator who can be contacted at 334-615-4417 and/or T6coordinator@dothan.org

Notice to the Public

The City of Dothan has developed a Title VI Compliance Notice to provide information to the public regarding the City of Dothan’s Title VI obligations and to inform the public of the protections against discrimination afforded to them by Title VI. Each notice includes contact information to file a discrimination complaint with the City of Dothan as well as information to file a complaint directly with the corresponding Federal agency: HUD, EPA, DOJ, FTA, DOT, etc.

The City of Dothan has posted the Title VI Compliance Notice on the agency’s website and in public areas of the Dothan Civic Center, including the public areas and meeting rooms. This notice will be translated into other languages as needed. A copy of each notice is included in Appendix A.

Complaint Procedures and Form

A Title VI complaint may be filed by any individual or individuals who allege that they have been subjected to discrimination or adverse impact under any Federally funded program or activity based on race, color, national origin, disability, age, or sex in discrimination of its programs or activities.

The City of Dothan adopted Title VI complaint procedures to investigate and track complaints. A formal signed written Title VI complaint must be filed within 180 days of the date of the alleged act of discrimination. A copy of the complaint form is included in Appendix B. The complaint procedures and complaint form are also posted on the City of Dothan’s website. If information is needed in another language, the complainant can contact 334-615-4417. The statement “If information is needed in another language, contact 334-615-4417” will be posted with the complaint procedures in English and in any other language(s) spoken by LEP populations that meet the Safe Harbor threshold. Interpreter services will be provided by the Alabama Institute for Deaf and Blind with 48 hours notice. Complaint forms should be submitted to:

Ms. Kelly Mierkowski

Title VI Coordinator

City of Dothan

P.O. Box 2128 Dothan, Alabama 36303

334-615-4417

T6coordinator@Dothan.org

Grievance procedures are as follows:

Once the complaint is received, the City of Dothan will review it to determine who has jurisdiction.

The complainant will receive an acknowledgment letter informing them of whether the complaint will be investigated by the City of Dothan’s office. The City of Dothan will only process complaint forms that are complete and signed.
In a situation where the complainant is unable or incapable of providing a written complaint, a verbal complaint of discrimination may be made to City of Dothan. Under these circumstances, the complainant will be interviewed, and the City of Dothan will assist the complainant in converting the verbal allegations to a formal written complaint.
The City of Dothan has fifteen (15) business days to investigate the complaint. If more information is needed to resolve the case, the City of Dothan will contact the complainant. The complainant has fifteen (15) business days from the date of the letter to send requested information to the investigator. If the investigator does not receive the additional information from the complainant within fifteen (15) business days, the City of Dothan can administratively close the case. A case can also be administratively closed if the complainant no longer wishes to pursue the case.
After the investigator reviews the complaint, they will issue one of two letters 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 accused staff member, or other action will occur. If the complainant wishes to appeal the decision, they have 15 days after the date of the closure letter or the LOF to submit an appeal letter to the City of Dothan.
If the complainant is not satisfied with actions taken locally or if they demand further action, the complaint will be referred to the corresponding federal agency. Contact information for federal agencies on each notice located in Appendix A.

Investigations, Complaints, and Lawsuits

The City of Dothan shall maintain a log of Title VI complaints received. The log shall include the date the complaint was filed, a summary of the allegations, the status of the complaint, and actions taken in response to the complaint. Active Title VI compliance investigations and lawsuits shall also be included in this log and available for public review.

One Title VI compliance related investigation, complaint, or lawsuit has occurred as of the date of adoption of this document. A template of the Log of Title VI Compliance Investigations, Complaints, and Lawsuits that will be used if a complaint or lawsuit is filed can be found in Appendix C.

Public Participation Plan

The City of Dothan commits to provide early and continuous opportunities for public participation. These opportunities are open to everyone including minority, low-income, and Limited English Proficient (LEP) populations. The Public Participation Plan provides for an open exchange of information and ideas between the public and decision makers. The City of Dothan’s Public Participation Plan is ongoing and reviewed regularly to identify, meet, and serve the community’s needs.

To integrate the opinions of minority, low-income, and LEP populations into community outreach activities, the City of Dothan’s Public Participation Plan will:

Coordinate with community-based organizations, such as the Dothan Housing Authority, to identify and implement strategies to reach out to members in the affected minority, low-income, and LEP communities. Examples include newsletters, emails, posted notices in community centers, etc.
Place public notices on the City of Dothan's website.
Utilize the media (social media to notify minority, low-income, and LEP populations of public involvement efforts.)
Hold in-person public meetings in locations, facilities, and at meeting times that are convenient and accessible to the minority, low-income, LEP, and disabled populations.
Ensure the decision-making process adequately considers the issues and concerns raised by minority, low-income, LEP, and disabled populations.
Develop Title VI information in English and other languages as needed.
Make public information available in electronically accessible formats.
Use non-traditional media outlets to solicit input, such as local neighborhood publications, and online outlets like YouTube, X, Instagram, and/or Facebook.
Post public participation opportunities on the City of Dothan’s social media sites. A sample template is shown below.
Provide notices to accommodate those with impaired vision or hearing (see City Commission Resolution 2022-319).

To date, the City of Dothan has hosted in the following public outreach and involvement activities:

CDBG Program staff conducted four public involvement meetings in development of the HUD required CDBG Annual Action Plan. These meetings are an annual occurrence as part of the CDBG Competitive Process. Meetings are typically held in City recreation centers located in low/mod income neighborhoods and at convenient times. City recreation centers are accessible to disabled persons and LEP populations.
1. Public notices for these meetings were posted at the following locations:
  - On public bulletin boards at each recreation center,
  - On public bulletin boards at city hall,
  - On the city’s website and social media outlets,
  - Sent to the Dothan Housing Authority for publication in their newsletter,
  - On Wiregrass 211, Henry-Houston County Association of Service Agencies, and SEACH email and social media announcements,
  - Distributed throughout the community via a public distribution list maintained by the city’s Community Relations staff, and
  - Advertised in the Dothan Eagle.
2. In addition, following project approval by the City Commission, the draft Annual Action Plan is made available for 30 days for public comment at the public library, city hall and on the city’s website before formal adoption by the City Commission. Notices of public participation opportunities will be posted on the city’s social media sites and sent to the city community centers for posting.

Public input received prior to submittal of an application to the Federal Transit Agency for a bus used by the Rose Hill Senior Center was gathered during the following public outreach and involvement activities:

Rose Hill Senior Center staff members participated in and supported Community-Based Transportation Programs for disadvantaged communities.
Public Meetings were held at convenient times and accessible locations for minority, low-income, and LEP populations.
Meeting notifications have been published in outlets that service minority, low- income, and LEP populations.
Rose Hill Senior Center staff members participated in public outreach efforts to explain specific transit proposals and to solicit comments. These outreach efforts included interactions at public open houses and virtual events.
Public notices were posted on the Rose Hill Senior Center’s website, in the receptionist area, and on the transit vehicles.
Notices of public participation opportunities were posted on the Rose Hill Senior Center’s social media sites.

Public input prior to submittal of an application to the EPA for Assessment or Clean-up Grants following EPA protocol and notifications as required by this document.
1. Identification of project partners potentially having an active interest in the project,
2. Formation of an advisory committee of stakeholders,
3. Conducting public meetings to gather input,
4. Posting notice on the city’s website and social media outlets,
5. Advertisement in the Dothan Eagle.

Applications for grant opportunities will:

Provide public input prior to submittal of full applications to various agencies such as: ADECA-LETS, Department of Justice, Office of Civil Rights and associated agencies, AFG (Assistance to Firefighters Grant), FEMA, ADEM State Revolving Loan Fund (SRF), ADECA, and Department of Energy (DOE) will follow established protocols for the specific application process and/or notifications as required by this document.

Public meeting notices for programs or grants that require Title VI compliance will appear substantially in this form or as required by the specific grant agency.

Title VI Public Meeting

Join the City of Dothan for a Public Involvement Meeting regarding a Title VI Program activity will be held at <LOCATION> on <DATE> at <TIME. You will have an opportunity to share ideas about the proposed project and participate in the planning process.

Public comments are also accepted via mail and e-mail. Comments must be postmarked or timestamped on or before <DATE>.

Please find the online comment form at

<WEBSITE>

Send completed comment forms to:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

The Public Participation Plan will be periodically evaluated with the assistance of the public who participate in public involvement activities and events. A Public Participation Effectiveness Survey will be distributed at public meetings to monitor changes in demographics and track the effectiveness of the City of Dothan’s public involvement activities and events held in person and virtually. Responses are anonymous and will be available in English and Spanish. Participants are encouraged to request assistance from staff members as needed.

Surveys completed after in-person activities and events may be deposited into drop boxes by participants which will be positioned near exits and clearly labeled in English and Spanish.

Limited English Proficiency Plan

The Four Factor Analysis is used to identify Limited English Proficient (LEP) persons who need language assistance, outline how language assistance is provided, and describe how the City of Dothan considers the needs of LEP persons. This assessment balances the following four factors:

The number or proportion of LEP persons eligible to be served or likely to be encountered by a program, activity, or service sponsored by the City of Dothan. In addition to the number or proportion of LEP persons served, the analysis identifies:
1. How LEP persons interact with the City of Dothan.
2. Where LEP communities are located and the number or proportion of LEP persons from each language group to determine the appropriate language services for each language group.
3. The literacy skills of LEP populations in their native languages to determine whether document translation will be an effective practice or whether translated auditory resources will be more effective; and
4. Whether or not LEP persons are under-served by the City of Dothan due to language barriers.

2. The frequency with which LEP persons come into contact with the City of Dothan’s program, activities, or services. The following areas were evaluated:

Public meeting participation.
Customer service interactions in-person, over the phone, and online, (including e-mail and social media).

3. The nature and importance of programs, activities, or services provided by the City of Dothan to people’s lives.

4. The resources available to the City of Dothan for outreach to LEP persons and the costs associated with that outreach. The City of Dothan developed a Limited English Proficiency Plan which is in Appendix D. It includes:

Results of the Four Factor Analysis, including a description of the LEP population(s) served:
A description of how language assistance services will be provided.
The methods used by the City of Dothan to provide language assistance services.
A description of how employees are trained to provide timely and reasonable language assistance to LEP populations.
A description of how notice is provided to LEP persons about the availability of language assistance; and
An explanation of how the plan is monitored, evaluated, and updated.

Safe Harbor Provision

In accordance with the Safe Harbor Provision, the 2021 American Community Survey for the City of Dothan did not identify any specific language group which exceeds the threshold of 1,000 persons or 5%, whichever is less, of the total population eligible to be served by the program. However, the ACS did identify 2,511 persons that “speak a language other than English”.

Minority Representation on Planning and Advisory Bodies

The City of Dothan will not deny a person the opportunity to participate as a member of a planning, advisory, or similar body which is an integral part of the program on the grounds of race, color, or national origin, disability, age, or sex.

The City of Dothan has advisory boards, or committees that are appointed by the City of Dothan. If the City of Dothan establishes advisory bodies, a table will be used to depict the racial breakdown of the membership and will be included in future Title VI programs. A sample table is included in Appendix E. Additionally, a description of efforts made to encourage the participation of minorities on such committees will be included.

Guidance on Determining Site or Location of Facilities

When acquiring land, constructing facilities and/or housing, the City of Dothan shall not make selections with the purpose or effect of excluding persons from, denying them the benefits of, or subjecting them to discrimination under any Federally funded program based on the grounds of race, color, or national origin, disability, age, or sex. The City of Dothan shall comply with all applicable Federal requirements including 67 FR 41455 and Executive Order 13166 and subsequent provisions.

Additional Title VI Information

Additional Title VI information is included in Appendix F for subrecipients of federal grants.

Board Meeting Resolution of Approved Title VI Program

The City of Dothan City Commission approved the Title VI Program on <DATE>, 2023. A copy of the AUTHORIZING RESOLUTION is included as Appendix G.

Appendix A

Title VI Notices to the Public

(The following notices are specific to HUD, EPA and FTA programs. An additional notice containing Department of Justice contact information is also included in this appendix. These notices shall be posted on the agency’s website and in all public areas, and/or meeting rooms.)

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TITLE VI NOTICE OF PROTECTION AGAINST DISCRIMINATION

The City of Dothan operates its programs without regard to race, color, and national origin, sex, age, or disability in accordance with Title VI of the Civil Rights Act. Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with the city.

For more information on the civil rights program and the procedures to file a complaint, contact:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

A complaint may be filed directly with

Pamela D. Walsh, Director

Program Standards and Compliance Division, Office of Fair Housing and Equal Opportunity, Department of Housing and Urban Development

451 Seventh Street SW., Room 5226, Washington, DC 20410

telephone: (202) 708-2904

Persons with hearing or speech impairments may access this number via TTY by calling the toll-free Federal Information Relay Service at (800) 877-8339.

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TÍTULO VI AVISO DE PROTECCIÓN CONTRA LA DISCRIMINACIÓN

La Ciudad de Dothan opera sus programas sin distinción de raza, color y origen nacional de acuerdo con el Título VI de la Ley de Derechos Civiles. Cualquier persona que crea que ha sido agraviada por cualquier acto ilícito práctica discriminatoria bajo el Título VI puede presentar una queja ante la City of Dothan

Para obtener más información sobre el programa de derechos civiles y los procedimientos para presentar una queja, comuníquese con:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

Se puede presentar una denuncia directamente ante el

Pamela D. Walsh, Directora

División de Normas y Cumplimiento de Programas, Oficina de Vivienda Justa e Igualdad de Oportunidades, Departamento de Vivienda y Desarrollo Urbano

451 Seventh Street SW., Room 5226, Washington, DC 20410

teléfono: (202) 708-2904

Personas con las personas con discapacidades auditivas o del habla pueden acceder a este número a través de TTY llamando al Servicio Federal de Retransmisión de Información sin cargo al (800) 877-8339.

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TITLE VI NOTICE OF PROTECTION AGAINST DISCRIMINATION

For more information on the civil rights program and the procedures to file a complaint, contact:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

A complaint may be filed directly with

U.S. Department of Justice Civil Rights Division

Federal Coordination and Compliance Section-NWB

950 Pennsylvania Avenue NW, Washington, D.C. 20530

Telephone: (1-888-848-5306) or (202) 307-2678

Persons with hearing or speech impairments may access this number via TTY by calling the toll-free Federal Information Relay Service at

(800) 877-8339.

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TÍTULO VI AVISO DE PROTECCIÓN CONTRA LA DISCRIMINACIÓN

La Ciudad de Dothan opera sus programas sin distinción de raza, color y origen nacional de acuerdo con el Título VI de la Ley de Derechos Civiles. Cualquier persona que crea que ha sido agraviada por cualquier práctica discriminatoria ilegal bajo el Título VI puede presentar una queja ante la ciudad.

Para obtener más información sobre el programa de derechos civiles y los procedimientos para presentar una queja, comuníquese con:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

Se puede presentar una denuncia directamente ante Departamento de Justicia de EE. UU.

División de Derechos Civiles

Sección Federal de Coordinación y Cumplimiento-NWB

950 Pennsylvania Avenue NW, Washington, DC 20530

teléfono: (1-888-848-5306) o (202) 307-2678

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TITLE VI NOTICE OF PROTECTION AGAINST DISCRIMINATION

For more information on the civil rights program and the procedures to file a complaint, contact:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

A complaint may be filed directly with

U.S. EPA External Civil Rights Compliance Office (2310A)

1200 Pennsylvania Ave. NW, Washington, D.C. 20460

Title_VI_Complaints@epa.gov

External Civil Rights Compliance Office: (202) 564-3316

Persons with hearing or speech impairments may access this number via TTY by calling the toll-free Federal Information Relay Service at

(800) 877-8339.

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TÍTULO VI AVISO DE PROTECCIÓN CONTRA LA DISCRIMINACIÓN

La Ciudad de Dothan opera sus programas sin distinción de raza, color y origen nacional de acuerdo con el Título VI de la Ley de Derechos Civiles. Cualquier persona que crea que ha sido agraviada por cualquier práctica discriminatoria ilegal bajo el Título VI puede presentar una queja ante la ciudad.

Para obtener más información sobre el programa de derechos civiles y los procedimientos para presentar una queja, comuníquese con:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

Se puede presentar una denuncia directamente ante Derechos civiles externos de la EPA de EE. UU. Oficina de Cumplimiento (2310A)

1200 Pennsylvania Ave., NW Washington, DC 20460 Title_VI_Complaints@epa.gov

Oficina externa de cumplimiento de derechos civiles: (202) 564-3316

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TITLE VI NOTICE OF PROTECTION AGAINST DISCRIMINATION

For more information on the civil rights program and the procedures to file a complaint, contact:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

A complaint may be filed directly with Federal Transit Administration by contacting:

Office of Civil Rights

Attention: Complaint Team East Building, 5th Floor – TCR 1200 New Jersey Avenue, SE Washington, DC 20590

FTACivilRightsCommunications@dot.gov

If information is needed in another language,

contact 334-615-4417.

Persons with hearing or speech impairments may access this number via TTY by calling the toll-free Federal Information Relay Service at

(800) 877-8339.

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TÍTULO VI AVISO DE PROTECCIÓN CONTRA LA DISCRIMINACIÓN

La Ciudad de Dothan opera sus programas sin distinción de raza, color y origen nacional de acuerdo con el Título VI de la Ley de Derechos Civiles. Cualquier persona que crea que ha sido agraviada por cualquier práctica discriminatoria ilegal bajo el Título VI puede presentar una queja ante la ciudad.

Para obtener más información sobre el programa de derechos civiles y los procedimientos para presentar una queja, comuníquese con:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

Se puede presentar una denuncia directamente ante Administración Federal de Tránsito comunicándose con:

Oficina de Derechos Civiles

Atención: Equipo de Quejas Edificio Este, 5to Piso – TCR 1200 Nueva Jersey Avenue, SE Washington, DC 20590

FTACivilRightsCommunications@dot.gov

Si se necesita información en otro idioma,

contacto 334-863-4129.

Appendix B - Title VI Complaint Form

Section I
Name:
Address:
Phone (Home or Cell):	Phone (Work):
E-mail:
Section II
Are you filing this complaint on your own behalf?	Yes	No
If you answered "yes" to this question, go to Section III.
If not, please supply the name and relationship of the person for whom you are submitting a complaint:
Please explain why you have filed for a third party:

Please confirm that you obtained the permission of the aggrieved party if you are filing on their behalf.	Yes	No
Section III
I believe the discrimination I experienced was based on (check all that apply): Race ¨ Color ¨ National Origin Date of Alleged Discrimination (MM/DD/YYYY): Explain as clearly as possible what happened and why you believe you were the target of discrimination. Describe all persons who were involved. Include the name and contact information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses. If more space is needed, please use the back of this form.

Section IV

Have you previously filed a Title VI complaint with this agency? ¨ Yes ¨ No

Section V

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 and specify 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:

Title:

Agency:

Address:

Phone:

E-mail:

Section VI

Name of agency complaint is against:

Contact person:

Title:

Phone:

E-mail:

Attach any written materials or other information that you think is relevant to your complaint. Signature and date required below:

Signature _________________________ Date________________________________

Please submit this form in person, by mail, or via e-mail using the contact information below:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

Appendix C - Log of Title VI Investigations, Complaints, and Lawsuits

	Date (MM/DD/YYYY)	Summary of Allegations (Include basis of complaint: race, color, or national origin)	Status: Pending or Closed	Actions Taken
Investigations
1.
2.
Complaints
1.	05/28/2023	No evidence that recipient City of Dothan has complied with 40 CFR 7.85(g), 7.90, or 7.95.	Pending - Under Jurisdictional Review	City has been advised by EPA-ECRCO that complaint has not been accepted for investigation.
2.
Lawsuits
1.
2.

Appendix D - Limited English Proficiency Assessment Plan

Introduction

This Limited English Proficiency Plan was prepared to address the City of Dothan’s responsibilities as a recipient of Federal financial assistance relating to the needs of individuals with limited English proficiency. This plan was prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d, et seq. and its implementing regulations which state that no person shall be subjected to discrimination based on race, color, or national origin.

Plan Summary

The City of Dothan developed this Limited English Proficiency Plan to help identify reasonable steps to provide language assistance to persons with limited English proficiency who wish to access services provided by the City of Dothan. As defined in Executive Order 13166, LEP persons are those who do not speak English as their primary language and/or have limited ability to read, speak, write, or understand English.

This Plan outlines how the City of Dothan identifies a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how LEP persons are notified that assistance is available.

As the first step in preparing this plan, the City of Dothan completed the Four Factor Analysis which considers the following factors:

The number or proportion of LEP persons eligible to be served or likely to be encountered by a program, activity, or service sponsored by the City of Dothan.
The frequency with which LEP persons come in to contact with the city of Dothan’s programs, activities, or services.
The nature and importance of programs, activities, or services provided by the City of Dothan to people’s lives.
The resources available to the City of Dothan for outreach to LEP persons and the costs associated with that outreach.

Four Factor Analysis Results

The number or proportion of LEP persons eligible to be served or likely to be encountered by a program, activity, or service sponsored by the city of Dothan.

The City of Dothan reviewed the 2022 U.S. Census Report and determined that the total population for Dothan is estimated to be 71,235. Of those persons, 840, (1.1%) residents report, speaking English less than very well. Those persons with limited English proficiency speak the following languages at home: 466 speak Spanish, 149 speak other Indo-European languages, 204 speak Asian or Pacific Island languages, and 21 speak other languages. The most popular language spoken at home (other than English) is Spanish. The City of Dothan will likely encounter more persons who speak Spanish that benefit from federally funded programs than any other LEP persons.

2. The frequency with which LEP persons come into contact with the City of Dothan programs, activities, or services

The City of Dothan assessed the frequency with which staff and drivers have contact with LEP persons both presently and in the past. The following contact points and frequencies were identified:

Contact Points	Frequency (Low, Medium, or High)
Emergency Services
Community Based Organizations
Information Line
Dispatchers
Route Guides
Reservationist
Website
Social Media
Receptionist
Field Supervisors
Annual Programs, Activities, and Events

3. The nature and importance of programs, activities, or services provided by the City of Dothan to people’s lives.

The largest geographic concentration of LEP individuals in the City of Dothan’s service area communicates by speaking Spanish. It is likely that the City of Dothan will encounter LEP individuals where tickets are sold and at community outreach events.

4. The resources available to the City of Dothan for outreach to LEP persons and the costs associated with that outreach.

The City of Dothan assessed its resources and determined that funds are available

within the current budget for providing language assistance. The City of Dothan also determined which documents would be most beneficial if translated into other languages and the cost associated with this effort. An inventory of available organizations with which the City of Dothan could partner for outreach and translation efforts was also identified. In addition, bilingual staff, volunteer community agencies, and web-based translation services were identified as ways to reduce the cost of translation services.

Limited English Proficiency Plan Outline

Five action items comprise the City of Dothan’s Limited English Proficiency Plan:

Identify Individuals Requiring Language Assistance
Provide Language Assistance
Train Staff
Provide Notice to LEP Persons
Monitor and Update the Limited English Proficiency Plan

1. Identify Individuals Requiring Language Assistance

The City of Dothan identifies an LEP person who requires language assistance by:

Examining customer service records to identify language assistance that was received in the past at meetings, online, or over the phone to determine whether language assistance might be needed for similar situations in the future.
Regularly surveying first-line staff who have direct or indirect contact with LEP individuals; and
Assigning a staff person to greet participants as they arrive at events sponsored by the city of Dothan. By engaging participants in conversation, staff may informally gauge each attendee’s ability to speak and understand English.

2. Provide Language Assistance

The City of Dothan assists an LEP person who requires language assistance by:

Networking with local human service organizations that provide service to LEP individuals and seeking opportunities to provide information on the City of Dothan’s programs and services through these organizations.
Posting the City of Dothan’s Title VI Notice, Complaint Procedures, Complaint Form, and Limited English Proficiency Plan on the City of Dothan’s website.
Identifying in-house staff with other language abilities to assist with translation services.
Making public notices, publications, and other printed materials (including online content) available in other languages.
Placing statements in notices, publications, and online content to notify LEP persons that free language interpreter services are available for meetings with a seven-day advance notice.
Utilizing a web-based translation service application such as Google Translate; and

3. Train Staff

The City of Dothan will train staff members on their roles and responsibilities in providing meaningful access to services for LEP persons by:

Developing a curriculum and corresponding presentation to educate staff on the Title VI requirements for providing meaningful access to services for LEP persons.
Providing staff with a description of language assistance services offered by the City of Dothan.
Providing staff with specific procedures to be followed when encountering a LEP person, including how to handle a potential Title VI complaint; and
Instructing staff on the use of Language Identification Flash Cards.

4. Provide Notice to LEP Persons

The City of Dothan will provide notice to LEP persons in both oral and written communications by:

Offering general information, such as hours of operation, fares, etc., on the city of Dothan’s customer service line in multiple languages.
Providing the following written communications in both English and Spanish
- The City's Community Planning & Development Annual Action Plan
- Consolidated Annual Performance and Evaluation Report (CAPER)
- 5-year Consolidated plan
- Signage that displays safety or system policy information.
- Title VI Notice, Complaint Procedures, and Complaint Form.

5. Monitor and Update the Limited English Proficiency Plan

This plan is designed to be flexible and should be viewed as a work in progress. As such, it is important to consider whether new documents and services should be made accessible for LEP persons and to monitor changes in demographics and types of services.

The City of Dothan will update the Limited English Proficiency Plan as encouraged by the Department of Housing and Urban Development (HUD) and Environmental Protection Agency (EPA). At a minimum, the plan will be reviewed and updated when data from the most recent U.S. Census is made available, when clear and higher concentrations of LEP individuals are present in the city of Dothan’s service area, and/or during the process of updating the City of Dothan’s Title VI Program.

The City of Dothan will monitor and update its Limited English Proficiency Plan by:

Determining how the needs of LEP persons are addressed.
Determining the current LEP population in the service area and whether the need for translation services has changed.
Determining whether local language assistance programs are effective and sufficient to meet the need.
Determining whether the City of Dothan’s financial resources are sufficient to fund the needed language assistance efforts.
Determining whether the City of Dothan has fully complied with the goals of the Limited English Proficiency Plan; and
Determining whether complaints were received concerning the City of Dothan’s failure to meet the needs of LEP individuals.

Dissemination of the City of Dothan’s Limited English Proficiency Plan

The Limited English Proficiency Plan will be disseminated to customers and the community by:

Publishing the Limited English Proficiency Plan and the Title VI Program on the City of Dothan’s website so that any person or agency with internet access can view and download these documents.
Alternatively, any person or agency may request a copy of the documents at no cost via telephone, e-mail, mail, or in-person. LEP individuals may request that these plans be translated into various languages. If feasible, the City of Dothan will accommodate such requests.
Sharing updates to the Limited English Proficiency Plan on the City of Dothan’s social media sites.
Distributing the Limited English Proficiency Plan to human service organizations in the service area.

Questions or comments regarding the Limited English Proficiency Plan may be submitted to the City of Dothan using the following contact information:

Kelly Mierkowski
Title VI Coordinator
City of Dothan
P.O. Box 2128 Dothan, Alabama 36303
334-615-4417
T6coordinator@Dothan.org

Appendix E

Table Depicting Minority Representation on Advisory Bodies

Public Board or Committee	Number of People Represented on the Committee
Public Board or Committee	Caucasian	Hispanic or Latino	African American	Asian American	Native American	Other:
Community Development Advisory Committee	3		3
Planning Commission	8		1
Board of Zoning Adjustment	6		1
Historic Preservation Commission	7		2
Parks and Recreation Board	4		3

Appendix F - Additional Title VI Information

All subrecipients must address each of the following:

1. Describe pending applications for financial assistance currently provided by other Federal agencies to the applicant.

______________________________________________________________

2. Summarize civil rights compliance reviews conducted by other local, state, or Federal agencies during the last three years. (Include the reason for review, name of the agency that performed the review, and findings or recommendations.)

______________________________________________________________

3. Is your agency considered a minority organization:  Yes  No

If yes, check the category(ies) that apply:

Black American ¨ Sub-Continent Asian-American
Hispanic American ¨ Asian-Pacific American
Native American ¨ Other

4. Does your agency provide services to minority communities? Yes  No

If yes, check the category(ies) that apply.

Black American ¨ Sub-Continent Asian-American
Hispanic American ¨ Asian-Pacific American
Native American ¨ Other

5. Did your Title VI Coordinator/EEO Officer change during the reporting period or since your last Title VI Plan was approved? If yes, please provide the name and contact information for the new Title VI Coordinator/EEO Officer.

______________________________________________________________

6. Did your organization’s projects and/or services that have Title VI, Limited English Proficiency, or Environmental Justice impacts change?  Yes  No

If yes, please complete the following items:

Provide a brief description of these projects/service changes.

______________________________________________________________

What did you do to ensure that populations affected by the project and/or service change had meaningful access to and involvement in the development process?

______________________________________________________________

What percentage of LEP populations and/or populations impacted by environmental injustice were affected by the project and/or service change?

______________________________________________________________

Appendix G - Adopting Resolution

RESOLUTION NO. ___________

WHEREAS, Agencies receiving financial assistance from federal funding, such as the Department of Housing and Urban Development (HUD), the Environmental Protection Agency (EPA), etc., are required to comply with Title VI of the Civil Rights Act of 1964 (as amended); and

WHEREAS, the City of Dothan is a recipient of such funds from the Department of Housing and Urban Development, the Environmental Protection Agency, etc.; and

WHEREAS, the City of Dothan continues to be committed to the principals that prohibit discrimination in any of its programs and activities.

NOW, THEREFORE, BE IT RESOLVED by the Board of Commissioners of the City of Dothan, Alabama as follows:

Section 1. That the Mayor is authorized to adopt the Title VI Compliance Program and implement the plan outlined in the Title VI policy statement consistent with applicable law, which said document is attached to and made a part of this resolution.

Section 2. Ms. Kelly Mierkowski, CDBG Program Administrator is named the Title VI Coordinator for the City of Dothan and that a committee be formed of representatives from each department seeking federal grant assistance who will be responsible for disseminating notices and conducting any specific public participation activities required by the grant.

Section 3. That the Mayor, through the Title VI Coordinator, will provide periodic updates to the City Commission as necessary and required.

PASSED, ADOPTED AND APPROVED on ___________________________.

_______________________________ Mayor

ATTEST:

_______________________________ Associate Commissioner District 1 _________________ City Clerk _______________________________

Associate Commissioner District 2

_______________________________ Associate Commissioner District 3

_______________________________

Associate Commissioner District 4

_______________________________

Associate Commissioner District 5

_______________________________

Associate Commissioner District 6

BOARD OF CITY COMMISSIONERS

I, Wendy Shiver, duly appointed City Clerk of the City of Dothan, Alabama, do hereby certify that the foregoing resolution was passed by the Board of Commissioners of the City of Dothan, Alabama, at a regular meeting held on _____________________.

Witness by hand and seal of the City of Dothan this ___ day of ______________, 2023.

________________________