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HomeMy WebLinkAbout4.A.1. Approval of Transit Policy Plan/Manual in response to 2013 Metropolitan Council/FTA compliance audit pwiim Consent Business 4. A. 1. SHAKOPEE TO: Mayor and City Council Mark McNeill, City Administrator FROM: R. Michael Leek, Community Development Director DATE: 12/03/2013 SUBJECT: Approval of Transit Policy Plan/Manual in response to 2013 Metropolitan Council/FTA compliance audit. (D) Action Sought City Council is asked to offer and pass a motion approving the attached Transit Policy Plan/Manual. Background Early in 2013 interns for the Metropolitan Council carried out a Federal Transportation Agency (FTA) compliance audit on the alternative regional transit providers, which includes the City of Shakopee. The City received a final audit letter. The letter, including the City's responses is attached. Also in response to the comments in the audit letter, city staff has developed the attached Transit Policy Plan Recommendation The Transit Advisory Commission (TAC) reviewed this item at its November 14, 2013 meeting, and recommended to the Shakopee City Council adopt the Transit Policy Plan. The Transit Advisory Commission requested that staff communicate to the City Council its frustration with the imposition of additional and complex requirements that it will be difficult to administer and monitor. Budget Impact There is no direct budget impact from the requested action. Relationship to Vision This item relates to City Goal D. Maintain improve and create strong partnerships with other public and private sector entities. Requested Action City Council is asked to offer and pass a motion receiving the 2013 FTA compliance audit response and approving the attached Transit Policy Plan/Manual. Attachments: Transit Audit Response Transit Policy Plan Metropolitan Council Federal Compliance Review of Shakopee Transit Performed by Katie Reed and Laura Logsdon February 5th, 2013 Technical Finding 1.) Condition: Prior Lake does not have an ongoing system to ensure that contractors adhere to Federal requirements. Standards Affected: 49 CFR 18.37(b): Grantees shall: (1) Ensure that every subgrant includes a provision for compliance with this part; (2) Ensure that every subgrant includes any clauses required by Federal statute and executive orders and their implementing regulations; and (3) Ensure that subgrantees are aware of requirements imposed upon them by Federal statutes and regulations. 49 CFR 18.40(a): Monitoring by grantees. Grantees are responsible for managing the day-to- day operations of grant and subgrant supported activities. Grantees must monitor grant and subgrant supported activities to assure compliance with applicable Federal requirements and that performance goals are being achieved. Grantee monitoring must cover each program, function or activity. Recommendation: Shakopee transit must create procedures and a staffing plan to communicate and monitor FTA requirements of contractors. Response: Through this year's audit Shakopee Transits two contractors (Schmitty's and Scott County TransitLink) have been made aware of the FTA requirements. Policies are being developed to communicate these on a regular basis, and should be complete by the end of 2013. Shakopee Transit's staff is limited to a small portion of the Community Development Directors and a Senior Planners time, therefore an extensive staffing plan is not expected to be a part of these policies. ADA Findings 1.) Condition: Shakopee Transit does not have a system in place or records to demonstrate contractor monitoring for ADA Service Provisions. Standard Affected: 49 CFR 18.40 (a) Monitoring by grantees: Grantees are responsible for managing the day-to-day operations of grant and subgrant supported activities. Grantees must monitor grant and subgrant supported activities to assure compliance with Rober�Street North I St. Paud. MN r Phone 00 90 . . METROPOLITAN C O U N C I L applicable Federal requirements and that performance goals are being achieved. Grantee monitoring must cover each program, function or activity. Recommendation: Shakopee Transit must conduct monitoring of contractors for all ADA Service Provisions and keep records to demonstrate monitoring. Response: The City is in the process of developing a monitoring schedule and procedure which should be completed by the end of 2013. 2.) Condition: Shakopee Transit does not ensure that contractors have trained personnel to operate vehicles and equipment safely and/or provided sensitivity training on interacting with persons with disabilities. Standard Affected: 49 CFR 37.173: Each public or private entity which operates a fixed route or demand responsive system shall ensure that personnel are trained to proficiency, as appropriate to their duties, so that they operate vehicles and equipment safely and properly assist and treat individuals with disabilities who use the service in a respectful and courteous way, with appropriate attention to the difference among individuals with disabilities. Recommendation: Shakopee Transit must ensure that contractors have conducted personnel trainings concerning ADA equipment and sensitivity. Prior Lake should require reports of training dates, topics, and attendees. Response: The City is in the process of developing a monitoring schedule and procedure which should be completed by the end of 2013. 3.) Condition: Shakopee Transit staff is unsure of the formats of information and communications about ADA service. Standard Affected: 49 CFR 37.167(f): The entity shall make available to individuals with disabilities adequate information concerning transportation services. This obligation includes making adequate communications capacity available, through accessible formats and technology, to enable users to obtain information and schedule service. Recommendation: Prior Lake must ensure that information and communications regarding ADA service are available in accessible formats. Response: The City is in the process of developing a monitoring schedule and procedure which should be completed by the end of 2013. Maintenance Finding 1.) Condition: In a past contract, Shakopee Transit required monthly maintenance reports from its contractor, and in its current contract it requires quarterly maintenance reports. No maintenance reports were provided during audit or found onsite when requested. It is assumed that Shakopee Transit does not conduct maintenance monitoring of contractors. Standards Affected: 49 CFR 18.40 (a) Monitoring by grantees: Grantees are responsible for managing the day-to-day operations of grant and subgrant supported activities. Grantees must Page-2 1 Nmember 25,2013 1 METROPOLMAN COUNCIL monitor grant and subgrant supported activities to assure compliance with applicable Federal requirements and that performance goals are being achieved. Grantee monitoring must cover each program, function or activity. Triennial Review Program FY2012 Workbook: The grantee must have an effective mechanism to monitor subrecipients', contractors', and lessees' maintenance activities. An acceptable program would consist of periodic written reports on maintenance activities submitted to the grantee, supplemented by periodic inspections of the FTA funded vehicles and facilities. Recommendation: Shakopee Transit must conduct periodic monitoring of contractors' maintenance activities and keep written reports to demonstrate monitoring. Response: The City is in the process of developing a monitoring schedule and procedure which should be completed by the end of 2013. Safety and Security Advisory Comments 1.) Condition: Shakopee Transit does not have a transit specific safety plan. Standard Affected: Manual for the Development of Bus Transit System Safety Program Plans: The transit system should establish the System Safety Program Plan as an operating document that has been prepared for, and approved by, transit system top management. The Plan should refer to management approval either by enabling signature on the title page or equivalent means. This approval should be by the chief executive officer or the governing board. Recommendation: Shakopee should consider creating a transit specific safety plan. Response: The recommendation is noted, and as appropriate city staff will work with Shakopee Police Department in the development of such plan. 2.) Condition: Shakopee has not developed and distributed public awareness materials on safety and security. Standard Affected: TSA/FTA Action Item No. 7: Grantees are encouraged to develop and implement a public security and emergency awareness program, prominently display security awareness and emergency preparedness information materials throughout the system (e.g., channel cards, posters, fliers), incorporate general security awareness and emergency preparedness into public announcement messages (security messages and evacuation procedures), post security awareness and emergency preparedness information on the transit agency website, ensure security awareness materials and announcements emphasize the importance of vigilance and provide clear direction to the public on reporting of suspicious activities, vary the content and appearance of messages to retain public interest, increase the frequency of security/emergency awareness activities (e.g. public address announcements)as the HSAS threat advisory level is raised, issue public service announcements in local media (e.g. newspaper, radio and/or television), provide volunteer training to the public for system evacuations and emergency response. Recommendation: Shakopee should consider providing the riding public with information on recognizing and reporting suspicious or illegal activity. Page-3 1 November 25,2013 1 METROPOLITAN COUNCIL Response: The recommendation is noted, and as appropriate city staff will work with Shakopee Police Department in the development of such materials and training. Satisfactory Continuing Control Finding 1.) Condition: Shakopee does not control the use of FTA funded real property used by contractors. Standard Affected: FTA C 5010.1 D, Ch. IV, Section 3.k (3) Equipment records must be maintained by the grantee... (4)A physical inventory of equipment must be taken and the results reconciled with equipment records at least once every two years. Any differences must be investigated to determine the cause of the difference. (5)A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of project property. Any loss, damage, or theft must be investigated and documented by the grantee. Recommendation: Shakopee must create a system to control for the use of FTA funded real property by its contractors and follow this system to monitor real property use. Response: The City is in the process of developing a monitoring schedule and procedure which should be completed by the end of 2013. Drug and Alcohol Finding 1.) Following a 2011 accident in which a vehicle was towed from the scene, a post-accident drug test was administered, but the required post-accident alcohol test was not conducted. Shakopee transit does not have a system in place for monitoring drug and alcohol testing, and regular oversight of the drug and alcohol testing program has not been conducted. Standards Affected: 49 CFR 655.44: As soon as practicable following an accident not involving the loss of human life in which a mass transit vehicle is involved, the employer shall drug and alcohol test each covered employee operating the mass transit vehicle at the time of the accident unless the employer determines, using the best information available at the time of the decision, that the covered employee's performance can be completely discounted as a contributing factor to the accident. 49 CFR 18.40(a): Monitoring by grantees. Grantees are responsible for managing the day-to- day operations of grant and subgrant supported activities. Grantees must monitor grant and subgrant supported activities to assure compliance with applicable Federal requirements and that performance goals are being achieved. Grantee monitoring must cover each program, function or activity. Standards Affected: 49 CFR 40.15: As an employer, you are responsible for ensuring that the service agents you use meet the qualifications set forth in this part...You remain responsible for compliance with all applicable requirements of this part and other DOT drug and alcohol testing regulations, even when you use a service agent. Page-4 1 November 25,2013 1 METROPOLITAN COUNCIL Recommendation: A monitoring policy must be developed for all contracts and subcontracts including drug and alcohol testing sites. A clear chain of command should be established for addressing issues related to drug and alcohol testing within the transit program. Response: A policy is being developed and will be completed by the end of 2013. Procurement Finding 1.) Condition: Shakopee Transit does not have a system for administering contracts once awarded, and has not demonstrated previous monitoring of contracts. Standard Affected: 49 CFR 18.36 (b)(2) Grantees and subgrantees will maintain a contract administration system which ensures that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. Recommendation: Shakopee Transit must develop a written policy for administering contracts to ensure that contractors perform in accordance with all contract terms. Response: A policy is being developed and will be completed by the end of 2013. 2.) Condition: Shakopee Transit's current contract with Scott County does not reference applicable federal clauses. Standards Affected: 49 CFR 18.36 (i) (1-13) Contract provisions. A grantee and subgrantee's contracts must contain provisions in paragraph (i) of this section. Recommendation: Shakopee Transit must incorporate federal clauses in its agreement with Scott County. Response: To avoid confusion, Shakopee staff has requested the specific language that is required. Once that is received from the Metropolitan Council, the city will work with Scott County Transit to incorporate the appropriate, required language. Title VI None Lobbying None Page-5 1 November 25,2013 1 METROPOLITAN COUNCIL CITY OF SHAKOPEE TRANSIT POLICY MANUAL Adopted month, day,year INTRODUCTION The purpose of this Transit Policy Manual is to provide a general framework for the City of Shakopee's governance of its transit operations. More specifically,the Policy Manual is intended to help ensure compliance with all applicable federal regulations as condition to receiving federal funds for vehicles and facilities. The Policy Manual provides the mechanism to satisfactorily demonstrate the City's contracted bus service providers are also in compliance with applicable federal regulations and that the City is adequately monitoring that compliance.The Policy Manual sets the procedures to satisfactorily demonstrate that the City of Shakopee is providing adequate monitoring,oversight and control over its federally funded facilities and vehicles. The implementation of the Policy Manual will help ensure that the City's transit services and facilities are operated in safe, reliable,and cost-effective manner,and are made available to the general public regardless of race, color, national origin or disability. The Policy Manual includes the following sections: Section 1: Americans with Disabilities Act(ADA) Section 2: Drug and Alcohol Section 3: Title VI of Civil Rights Section 4: Maintenance Section 5: Procurement Section 6: Safety and Security Section 7: Satisfactory Continuing Control Section 8: Grant Management The above sections may be amended or added to from time to time as the situation dictates or as federal policies change. The date of material revisions to the Policy Manual will be recorded below: Date:_/Sections: Date:_/Sections: Date:_/Sections: Date:_/Sections: Date:_/Sections: Date:_/Sections: City of Shakopee Transit Policy Manual 1 SECTION 1: AMERICANS WITH DISABILITIES ACT(ADA) Introduction In 1990 the Americans with Disabilities Act(ADA)was enacted.This legislation ensures that persons with disabilities have access to public transportation.The City of Shakopee and its subcontractors are committed to full compliance with the Federal ADA law 49 CFR 37.1. This means all buses,services and facilities must be fully-accessible and all employees properly trained to meet the all the requirements of the law.As a result,the City of Shakopee has the following ADA policies for Shakopee Transit. Training Shakopee Transit shall require that all required personnel and contractors are trained to proficiency, as appropriate to their duties,so that they operate vehicles and equipment safely, and properly assist and treat individuals with disabilities who use the service in a respectful and courteous way,with appropriate attention to the difference among individuals with disabilities. This training will be in accordance with specified requirements of 49 CFR 37.1 Communication Shakopee Transit will make available to individuals with disabilities adequate information concerning transportation services.This obligation includes making adequate communications capacity available,through accessible formats and technology,to enable users to obtain information and schedule service. Documentation of Maintenance, Failures and Incidents Shakopee Transit and its subcontractors will document and record information related to buses and facilities: 1. When conducting routine and scheduled maintenance on ADA related equipment and facilities. 2. When making repairs to ADA related equipment and facilities. 3. When failures or defects occur related to ADA related equipment and facilities 4. When an emergency, unusual situation or accident occurs with ADA related equipment and facilities and/or with a person with a disability. 5. Contracted bus service providers will maintain monthly reports on ADA related equipment and facilities. 6. The City of Shakopee transit staff will obtain and review copies of these reports on a quarterly basis. 7. The City of Shakopee will retain the records per applicable State of Minnesota Data Practices laws. Facility and Vehicle Design Requirements All Shakopee Transit facilities and vehicles shall be designed, constructed and/or manufactured to meet or exceed the minimum requirements for accessibility per 49 CFR 37.1. Maintenance of Lifts Shakopee Shakopee Transit and its subcontractors will establish a system of regular and frequent maintenance checks of lifts sufficient to determine if they are operative. Appropriate documentation of this procedure shall occur. Contracted bus service providers will maintain City of Shakopee Transit Policy Manual 2 monthly maintenance report. Shakopee transit staff will obtain and review copies of these reports on quarterly basis. Pre-Trip Vehicle Inspection All transit vehicle operators must complete a pre-trip inspection of the entire bus including all accessibility equipment prior to leaving bus garage facilities. Specifically,activate the lift and put it through one complete cycle,check the jump seat and tie-downs. If a defect is detected or failure occurs during the pre-trip test,dispatch is to be contacted immediately to request a replacement vehicle. Drivers are to document each pre-trip test. Accessible Bus Stops Operators should use their best judgment as to whether the lift/ramp can be deployed without damaging it, at any bus stop or pick-up/drop-off location. If the lift/ramp cannot be deployed safely, politely inform the customer that they have to use another accessible stop. Immediately contact dispatch or your supervisor to inform them of the situation. Awareness and Sensitivity Operators are expected to be courteous to all customers at all times. Increased awareness and sensitivity to the needs of riders using accessible buses is required.Operators are expected to ask customers how they can help, and then provide the required assistance.This includes leaving the bus operator's seat when required. Operators are also expected to treat other customers courteously when asking them to move or otherwise accommodate a customer with a disability. Conforming Mobility Aids All people using mobility devices meeting the ADA definition of a common wheelchair shall be accommodated on Shakopee Transit services. Under certain circumstances,Shakopee Transit will allow the transportation of users of non-conforming devices. All common mobility aids shall be transported and properly secured.A common mobility aid is any class of three-or four- wheeled device that is usable indoors and designed for and used by individuals with mobility impairments. It may be operated manually or powered.A common mobility aid does not exceed 30 inches in width and 48 inches in length (measured two inches above the ground)and does not weigh more than 600 pounds when occupied.Vehicles may not be able to accommodate mobility aids exceeding these standards. Reasonable efforts shall be made to transport persons in oversized mobility aids. However,transportation cannot always be guaranteed to a person in an oversized mobility aid and suggestions for alternative transportation shall be provided upon request Wheelchair Handling Procedures Operators will be trained in and must follow proper wheelchair handling procedures.These include boarding and alighting procedures,wheelchair maneuvering, and wheelchair locking/unlocking procedures.Training specifics are addressed later in this chapter. Boarding and Alighting Using the Lift/Ramp All operators need to take special care in curbing the bus.The bus must be at least one foot, but not further than three feet from the curb with the lift/ramp in the most convenient position to the border.At the same time,operators must be aware of traffic conditions around them and be City of Shakopee Transit Polity Manual 3 careful to avoid blocking traffic flow. Shakopee Transit will make best efforts to make sure that adequate time is provided to allow individuals with disabilities to complete boarding or disembarking from the vehicle. The following guidelines for boarding lift customers may not always be applicable.Good judgment is the most important rule. 1. Lift/ramp Procedures—Customers in Wheelchairs a. Stop and secure the bus. Board customers in wheelchairs first. b. Ask the customer using the lift/ramp if they are first-time customers.Take special care with first-time users.Ask the customer what type of assistance is required. Many wheelchair-assisted customers are capable of maneuvering their chairs onto the lift/ramp and into the securement area on the bus, and securing their chairs. c. With the bus properly secured, prepare it for boarding a lift/ramp customer;jump seats may have to be cleared of customers and then lifted and locked into the upright position. If jump-seat customers refuse to move,do not try to force them. Contact dispatcher or your supervisor for assistance. d. Operators should first offer assistance, and then provide the level of assistance required or requested by the customer. Extend the lift/ramp and ensure the rider is securely strapped into his/her wheelchair.The wheelchair should normally be backed onto the lift/ramp(if a rider in a wheelchair wants to board a bus facing inward,you may allow it).Assist the customer in a wheelchair by pulling the wheelchair as close to the right side as possible.ALWAYS set the brakes on the wheelchair before moving the lift/ramp. Power chairs should be shut off as well. Release the brake and maneuver the wheelchair onto bus.Stow the lift/ramp and then go back and secure the wheelchair. Many customers in wheelchairs are capable of maneuvering their chairs onto the lift/ramp, into the securement location where they are able to secure themselves. Operators must check to insure that every wheelchair is properly secured before moving the bus. e. To stow the lift/ramp,activate both switches and return the Lift/ramp to the stow position in one continuous motion. Continue to hold the switches to the count of three after the lift is stowed to insure that the latching mechanism is in place. f. In the event of lift/ramp failure,contact dispatch or your supervisor for additional instructions. g. If the lift is stopped at any time during the stow cycle,the whole cycle will be started over. h. Anyone standing on the lift and riding it should be warned to watch head clearance. I. Driver must secure any wheelchair after the passenger boards and before continuing to the next destination. Whenever a wheelchair is secured with the tie- downs,the lap belt should also be routinely secured. However, if the customer requests that the lap belt not be used,the request will be honored. If the customer secured his or her own wheelchair on the bus,the driver is required to visibly check to be sure the chair is properly secured before the bus is moved. j. Alighting of lift/ramp assisted customers should be done in the same safe manner but in reverse order after customers who do not need assistance have alighted. k. If attendant is along, he/she may ride the lift with the disabled person and ride for free.Attendants riding with customers in wheelchairs may not know the proper City of Shakopee Transit Policy Manual 4 boarding and alighting procedures.They should be instructed as to the proper procedures. I. Attendants riding with customers in wheelchairs should not be permitted to operate the lift.Attendant or customer in wheelchair may assist in securing the wheelchair, but securement must be checked by bus operator. m. During inclement weather bus stops may not be cleared of snow or other obstacles. Therefore,operators may be required to provide extra assistance to customers with disabilities. Any bus stops that are not clear,safe and functional should be reported immediately to the Metro Transit Control Center. 2. Lift/ramp Procedures—Ambulatory Customers In addition to persons in wheelchairs,the lift/ramp may be used by ambulatory persons who request it. Operators should avoid judging whether or not a person needs the lift. Provide the lift for any customer who requests it. a. After positioning the bus for safe and convenient operation of the lift/ramp, put the bus into neutral,set the brake,turn on four-way flashers and open the door to allow customers who are able-bodied to alight from the bus. Board customers using a wheelchair before boarding able-bodied customers. b. Assist the ambulatory customer onto the lift/ramp as appropriate. Make sure customer grabs onto handrail.Advise him/her to keep arms,elbows,etc. inside handrails. c. Tell the customer the lift/ramp will be activated. d. Warn the customer about head clearance. e. After lift/ramp stops,assist the customer in walking to seat as needed. f. Assist customer with paying fare as you would a person in a wheelchair. Wheelchair Transfers to Regular Seats On occasion,a person in a wheelchair may be able to transfer from his/her wheelchair to a regular bus seat.Accommodate customers who choose this option. If the bus is able to kneel, use this feature as operators feel appropriate. In either case,the wheelchair or other mobility aid should be folded and safely stored while on the bus. If a driver encounters a situation where a disabled person attempts to board the bus with a personal assistance device that cannot be safely carried because of its size or weight,the driver should seek direction from a supervisor. When Boarding Persons in Wheelchairs Is Not Possible Sensitivity and good judgment should be exercised when faced with the decision to pick up or pass up a disabled person in a wheelchair. Being behind schedule is not an acceptable reason for not boarding a person who is disabled. Generally speaking,failing to board a disabled customer is permitted only: 1. When all wheelchair tie-down locations are filled with other persons in wheelchairs. 2. When the bus is filled to capacity with a standing load. If there are standing customers but the bus is not full, operators should make every reasonable and courteous effort to have standing customers move out of the way in order to allow a person in a wheelchair to board and be secured in a wheelchair location. If the bus is too crowded with City of Shakopee Transit Policy Manual 5 standing customers to board a person in a wheelchair, it is also too crowded to board any additional standing riders. 3. When street conditions make it unsafe or impossible to do so. 4. When the wheelchair size or design does not work on the lift or makes it impossible to tie-down, or 5. When the lift does not work. Whenever you must pass up a person in a wheelchair,stop and briefly explain to the rider why he/she cannot be picked up and when the next bus is due (keep a schedule on hand for your reference). In all circumstances, notify dispatch of the situation so the dispatcher or supervisor can make a determination about sending assistance to the passed-up customer.The following information should be given to your dispatcher or supervisor: 1. Location and direction of travel 2. Time 3. Reason for the pass-up Severe weather, extreme heat and cold are serious risks to riders,especially some disabled persons. It is especially important to board disabled customers under these conditions. Make every effort to see that they are safe. Breakdown/Defective Bus Procedures In the event of a breakdown of an accessible bus while in service,the operator should: 1. Follow established procedures to contact dispatcher or supervisor for assistance. 2. Identify yourself,and then state the bus ID number, route,run direction and location. 3. Indicate if there are lift-assisted customers on the bus so that they can receive priority consideration. 4. Describe the breakdown/defect to supervisor and follow supervisor's instructions. 5. If the lift is the problem,contact dispatcher or maintenance for troubleshooting assistance. Do not ask other customers to lift a person in a wheelchair onto or off the bus. 6. Inform passengers of the problem and keep them informed of the progress. 7. Secure the area and set out safety triangles if it is safe to do so. The bus operator will be required to assist customers transferring to the replacement bus. Emergencies, Incidents,Accidents In the event of an emergency, unusual situation or accident,operators should generally follow standard emergency procedures. Contact dispatch or supervisor immediately to ensure needed emergency assistance can be dispatched. Operators with lift-assisted riders on board should be particularly observant of them so that any illness can be detected and responded to quickly. If a bus is involved in an incident and there is no imminent danger,the operator should not remove the lift/ramp-assisted customers. If a lift/ramp-assisted rider is injured, wait for aid on City of Shakopee Transit Policy Manual 6 the bus. Remove a lift/ramp assisted customer only if it is dangerous to leave him/her on the bus. In accidents or emergencies arise requiring customers to leave the bus,first direct non-disabled riders to the exit. Operators should next safely assist disabled clients in exiting the bus. If the lift/ramp still does not work and there is no time,get the customer to the door and off the bus any way possible. It may be possible to lower a person in a standard wheelchair down the steps of the bus.Always lower a customer in a wheelchair forward down the steps of the bus.An electronically powered wheelchair is too heavy to be lowered down the steps.The customer will have to be lifted out of the wheelchair and helped off the bus. Emergency procedures for a variety of specific situations will be presented to operators in training. It is expected that such procedures will be followed.All emergencies should be properly reported to dispatch and your supervisor. Respirator or Oxygen Supply Shakopee Transit will not prohibit an individual with a disability from traveling with a respirator or portable oxygen supply,consistent with applicable Department of Transportation rules on the transportation of hazardous materials (49 CFR Subtitle b, chapter 1,subchapter c). Service Animals Shakopee Transit will permit service animals to accompany individuals with disabilities in vehicles and facilities. Announcing Stops Drivers of Shakopee Transit buses shall announce stops as follows: 1. The driver shall announce at least at transfer points with other fixed routes, other major intersections and destination points, and intervals along a route sufficient to permit individuals with visual impairments or other disabilities to be oriented to their location. 2. The driver shall announce any stop on request of an individual with a disability 3. Drivers are required to announce to persons outside the bus at stops the route number, plus the direction and destination where necessary to clearly identify the trip to waiting passengers. Passengers with Visual Impairments When waiting at a bus stop, passengers with visual impairments who use a white cane or service animal need to ensure that their cane or dog is visible to approaching bus operators.When the operator observes these aids,the operator must stop the bus,open the door,and state the route and destination of the bus. Operators pulling up to bus stops that serve multiple routes must be particularly careful to announce the route to all passengers waiting at the bus stop.The passenger must let the operator know if the bus is the one that they need to board Passengers with Hearing Impairments If a driver is aware that a customer is hearing-impaired,the driver will need to make special efforts to communicate effectively.This may include looking straight at the customer when you talk so the customer can read your lips,and writing information down. City of Shakopee Transit Policy Manual 7 Priority Seating and Reserved Seating Upon request, bus operators shall ask, but not require passengers to yield priority seating at the front of the bus to persons with disabilities and seniors. Mobility aid securement areas on buses are reserved. Passengers using common mobility aids shall be boarded if the securement areas are not otherwise occupied by a mobility device, regardless of the number of passengers on the bus. Bus operators are required to ask passengers sitting in securement areas to move to other available seats or to stand Complaint Process Customers wishing to file a complaint regarding discrimination due to disability shall contact the City of Shakopee's City Administrator to initiate the complaint process. The Federal Transit Administration (FTA) Office of Civil Rights is responsible for civil rights compliance and monitoring of public transportation,which includes ensuring that providers properly implement the Americans with Disabilities Act of 1990. As result,the City of Shakopee will follow the complaint procedures developed for and included in its Title VI Plan. All contracted providers will also be required to adopt a similar complaint process. Monitoring Compliance Shakopee Transit will take the appropriate steps to monitor and document compliance with its adopted ADA policies,including requiring that its contracted bus service provider adopt the appropriate policies and procedures to monitors compliance with the applicable sections of this ADA chapter. Compliance monitoring will include annual vehicles inspections, ride alongs,facility site visits; thorough investigation of any ADA related complaints, and the completion and submittal of the form in Appendix on a quarterly basis.On an annual basis,the contractor shall submit a report demonstrating and documenting that all required employees received the proper ADA training perthis policy. On an annual basis,Shakopee Transit will conduct service monitoring using the forms included in Appendix B to document driver compliance with ADA requirements. A sampling of drivers will be observed. SECTION 2: DRUG AND ALCOHOL Contract Requirements The Contractor shall have in place a drug and alcohol testing policy and program meeting the requirements of the Federal Transportation Administration (FTA) Final Rules,49 CFR PART 655, Prevention of Alcohol Misuse and Prohibited Drug Use in Transit Operations. Monitoring Compliance Shakopee Transit will take the appropriate steps to monitor and document compliance with the Contract Requirements. Compliance monitoring will include quarterly inspections of the Contractor's policy and any drug and alcohol testing records. City of Shakopee Transit Policy Manual 8 Reporting The Contractor must certify annually in writing to Shakopee's Authorized Representative that the company's drug and alcohol policy/program is: 1. In full compliance with the Federal Transit Administration regulations; regardless of its compliance with other rules such as general DOT and FHWA.The FTA regulations supersede the DOT and FHWA. 2. All safety-sensitive employees assigned to this Contract are subject to drug and alcohol testing. The Contractor must submit a properly completed FTA Management Information System annual report summarizing the test results for employees assigned to this Contract from the previous calendar year to Shakopee's Authorized Representative. SECTION 3: TITLE VI OF CIVIL RIGHTS Plan Statement Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving Federal financial assistance.Specifically,Title VI provides that"no person in the United States shall,on the ground 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" (42 U.S.C. Section 2000d). The City of Shakopee is committed to ensuring that no person is excluded from participation in, or denied the benefits of transit services on the basis of race,color,or national origin, as protected by Title VI in Federal Transit Administration(FTA)Circular 4702.1.A.This plan was developed to guide the City of Shakopee in administration and management of Title VI-related activities. Title VI Manager Contact information is as follows: Mark McNeill,City Administrator City of Shakopee 129 South Holmes St. Shakopee, MN 55379 Phone: 952-233-9300 Title VI Information Dissemination Title VI information posters shall be prominently and publicly displayed in the City of Shakopee's facilities and on their revenue vehicles.The name of the Title VI Manager is available on the website,at www.shakopeegov.com. Additional information relating to nondiscrimination obligations can be obtained from the Title VI Coordinator. Title VI information shall be disseminated to the City of Shakopee employees annually via internal memorandum.This memo will remind employees of The City of Shakopee's policy statement, and of their Title VI responsibilities in their daily work and duties. City of Shakopee Transit Policy Manual 9 During New Employee Orientation, new employees shall be informed of the provisions of Title VI, and the City of Shakopee's expectations that employees will perform their duties accordingly. All employees shall be provided a copy of the Title VI Plan and are required to sign the Acknowledgement of Receipt(see Appendix Q. Subcontracts and Vendors All subcontractors and vendors who receive payments from the City of Shakopee where funding originates from any federal assistance are subject to the provisions of Title VI of the Civil Rights Act of 1964 as amended. Written contracts shall contain non-discrimination language, either directly or through the bid specification package which becomes an associated component of the contract. Record Keeping The Title VI Manager will maintain permanent records,which include, but are not limited to, signed acknowledgements of receipt from the employees indicating the receipt of the of Title VI Plan,copies of Title VI complaints or lawsuits and related documentation, and records of correspondence to and from complainants, and Title VI investigations. Title VI Complaint Procedures A complainant may file a signed,written complaint up to one hundred and eighty(180)days from the date of the alleged discrimination.The complaint should include the following information: 1. Contact information including: Name, mailing address,telephone number,cell phone number and email address 2. Description of the incident including how,when,where and why you believe you were discriminated against. Names and contact information for all witnesses. 3. Other relevant information A complainant may use the Complaint Form in Appendix D for this purpose. Title VI complaints are to be submitted in writing to the Title VI Manager at the following address: Mark McNeill, City Administrator City of Shakopee 129 South Holmes St. Shakopee, MN 55379 Phone:952-233-9300 It is the responsibility of the complainant to certify all mail that is sent through the U.S. Postal Service and/or ensure that all written correspondence can be tracked. For complaints originally submitted by facsimile,an original, signed copy of the complaint must be mailed to the Title VI Manager as soon as possible, but no later than 180 days from the alleged date of discrimination. City of Shakopee Transit Policy Manual 10 All complaints alleging discrimination based on race,color or national origin in a service or benefit provided by the City of Shakopee will be directly addressed by the City of Shakopee. The City shall provide appropriate assistance to complainants, including those persons with disabilities, or who are limited in their ability to communicate in English. Additionally,The City of Shakopee shall make every effort to address all complaints in an expeditious and thorough manner. The City of Shakopee will,within seven (7)working days or receipt of a complaint, mail a letter to the address provided by a complainant,which letter will acknowledge receipt of the complaint. In the event that the City of Shakopee requests additional information from a complainant and the complainant fails to provide the requested information,the City of Shakopee shall reserve the right to administratively close the complaint. All complaints will be thoroughly investigated.The investigation will be conducted in a full,fair and impartial manner by the Title VI Manager. Results of the investigation will be presented to the Shakopee City Council for a determination. Every effort will be made to respond to Title VI complaints within 60 working days of receipt of such complaints. Complaints will be determined to be substantiated, not substantiated or inconclusive. Following the investigation,the City of Shakopee will send a final written response letter to the complainant identifying the final determination. In the letter notifying complainant of the City's determination,the complainant will be advised of his or her right to: 1. Appeal within seven(7)calendar days of receipt of the final written decision from, and/or 2. File a complaint externally with the U.S. Department of Transportation and/or the PTA. In addition to the complaint process described above, a complainant may file a Title VI complaint with the following offices: Federal Transit Administration Office of Civil Rights Attention:Title VI Program Coordinator East Building, 5th Floor—TCR 1200 New Jersey Ave.,SE Washington, DC 20590 Limited English Proficiency(LEP) Plan The City of Shakopee has developed this Limited English Proficiency Plan(LEP)to help identify reasonable steps to provide language assistance for LEP persons seeking meaningful access to Shakopee services including express and summer circulator and shuttle transportation services as required by Executive Order 13166. A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read,speak, write,or understand English. This plan details procedures on how to identify a person who may need language assistance,the ways in which assistance may be provided,training staff, how to notify LEP persons that assistance is available,and information for future plan updates. In developing the plan,the City City of Shakopee Transit Policy Manual 11 of Shakopee undertook a U.S. Department of Transportation four factor LEP analysis which considered the following: 1. Number or proportion of LEP persons eligible in the City of Shakopee service area who may be served or likely to encounter a The City of Shakopee program,activity,or service; 2. Frequency with which LEP individuals come in contact with The City of Shakopee services; 3. Nature and importance of the program, activity or service provided by The City of Shakopee to the LEP population;and 4. Resources available to The City of Shakopee and overall cost to provide LEP assistance.A brief description of these considerations is provided in the following section. See Appendix E for copy of LEP Plan. Community Outreach As an agency that may from time to time receive federal financial assistance,the City of Shakopee has made or will be making the following community outreach efforts to engage the public in planning and decision-making processes, as well as its marketing and outreach activities: 1. The public will be invited to participate in the process whether though public meetings or surveys. 2. When a change to an existing service or addition of new service is proposed,the City of Shakopee may convene a public meeting to discuss feasibility and to welcome suggestions. 3. Citizens and passengers may call the City of Shakopee at 952-233-9300 to lodge a complaint or comment. All complaints/comments are input into a database and then distributed to a designated City of Shakopee employees to research and respond to the complaint. SECTION 4: MAINTENANCE Contract Requirements Specific maintenance requirements for Shakopee Transit buses are outlined in the contracts between the City of Shakopee and Schmitty and Sons Transportation, Inc., and Scott County Transit. Monitoring Compliance Shakopee Transit will take the appropriate steps to monitor and document compliance with the Contract Requirements. Compliance monitoring will include visual inspections of the Quarterly Reports for each bus outlining the following: 1. Vehicle miles; 2. Mechanical failures—Major,defined as failures of the engine,transmission or drive axel; 3. Mechanical failures—Other; 4. Gallons of fuel used; City of Shakopee Transit Policy Manual 12 5. Number of repeat repair orders; 6. Engine overhauls or replacement; 7. Transmission overhauls or replacement; 8. Number of services performed.This report is to state whether or not the number of services performed was within the mileage and timeframe specified; 9. Vehicles serviced.This report is to include the mileage,date of last service,service type (level), and the labor hours to perform service; 10. Accident/Incident Summary Report—This report shall summarize all accidents and Incidents during the preceding month.This shall include, but not be limited to, all road calls, missed trips, late trips, and passenger Incidents and/or complaints. Road calls shall be as defined by the National Transit Database reporting system; 11. Repair orders.This report is to include the mileage,the type of repair performed, and the labor hours to perform the repair; 12. Any corrections completed based on outstanding audit reports; 13. Vehicle Wash list-interior and exterior, detail; 14. Breakdown log; and 15. Warranty issues. Out-of-Service Report An out-of-service report must be provided to Shakopee detailing the reason a vehicle(s)is out- of-service,what is being done to fix it and when the vehicle is expected back in service. SECTIONS: PROCUREMENT Introduction The purpose of this Procurement policy Statement is to set forth the general procurement policy that will govern the conduct of the procurement activities of the City of Shakopee when Federal Transit Administration (FTA)grant funds are involved for construction projects related to Shakopee Shakopee Transit transit facilities.Note; If the City of Shakopee receives federal funding for a specific project through the Minnesota Department of Transportation's Office of Metro State Aid,the application and implementation of this chapter may vary from what is stated below. American Institute of Architects(AIA)documents and contracts will be used for projects managed through Minnesota Department of Transportation's Office of Metro State Aid. Policy Action and Compliance All procurement transactions, regardless of whether by sealed bid or by negotiation,and without regard to dollar value,shall be conducted in a manner that provides maximum open and free competition,consistent with applicable regulations of the Federal Transit Administration ("FTA"), including but not limited to"Third Party Contracting Guidelines," regulations of the Department of Transportation at 49 CFR Part 18, and State of Minnesota laws. It is the City of Shakopee's federal transit procurement policy for transit facilities to ensure open and free competition wherever possible,to maximize competitive opportunities, and to encourage a competitive environment for contractors and vendors competing for City of Shakopee Transit transit contracts. As part of this Procurement Policy Statement, placing unreasonable requirements on contractors and vendors in order for them to qualify to do City of Shakopee Transit Policy Manual 13 business with the City of Shakopee shall not be advanced as a way to restrict fair and open competition. All federally funded construction projects exceeding$100,000 in value will be procured via a sealed bid process awarding the contract to the lowest responsive bidder. A"Project Manual" will be developed with all the appropriate instructions,clauses,forms, certifications, specifications, drawings, and contract that will comprise the bid documents. The project will be advertised per applicable federal and state laws. If applicable,the bidding documents will include information and requirements related to the following Federal clauses: 1. Fly America Requirements 2. Buy America Requirements 3.Charter Bus and School Bus Requirements 4. Cargo Preference Requirements 5. Seismic Safety Requirements 6. Energy Conservation Requirements 7. Clean Water Requirements 8. Bus Testing 9. Pre-Award and Post Delivery Audit Requirements 10. Lobbying 11. Access to Records and Reports 12. Federal Changes 13. Bonding Requirements 14. Clean Air 1S. Recycled Products 16. Davis-Bacon and Copeland Anti-Kickback Acts 17. Contract Work Hours and Safety Standards Act 18. Reserved 19. No Government Obligation to Third Parties 20. Program Fraud and False or Fraudulent Statements and Related Acts 21.Termination 22. Government-wide Debarment and Suspension(Nonprocurement) 23. Privacy Act 24. Civil Rights Requirements 25. Breaches and Dispute Resolution 26. Patent and Rights in Data 27.Transit Employee Protective Agreements 28. Disadvantaged Business Enterprises (DBE) 29. Reserved 30. Incorporation of Federal Transit Administration (FTA)Terms 31. Drug and Alcohol Testing SECTION 6: SAFETY AND SECURITY Introduction The purpose of this chapter is to set forth a general safety and security policy that will govern the safety and security activities of the City of Shakopee related to transit services. The goal of this policy is to achieve the highest practical level of safety and security for all aspects of its City of Shakopee Transit Policy Manual 14 transit services and facilities that is accordance with all applicable FTA suggested practices. In order to protect passengers, employees,contractors, revenues,and property,transit systems need to develop and implement a proactive system safety program plan. The City of Shakopee supports these efforts by implementing the components listed below designed to prevent public transportation fatalities, injuries, property damage and system interruption, and to ensure the capability to respond effectively to those accidents,security incidents, and emergencies that do occur. Rider Awareness and Preparedness for General Safety and Security As a resource,transit employees provide a wealth of specialized knowledge and on-the-job experience. Likewise,transit passengers contribute to the security equation by providing extra eyes and ears capable of identifying possible life-threatening situations. When transit employees and transit passengers pool these resources,the result is a highly-effective first line of defense against a potential natural or man-made disaster.As a result,Shakopee Transit will ask riders to be alert, informed, and prepared by providing them with the awareness and preparedness tips listed in Appendix F of this policy. The tips are included on the BlueXpress website,and will be place on the buses as a flyer from time-to-time. Safety and Security Plans by Contracted Bus Providers The Contracted Bus Provider shall submit a Safety plan to the City. This plan shall be attached to the approved contract documents. Cell Phone Policy Use of cell/mobile phones or other handheld devices by City of Shakopee employees is strictly prohibited while operating transit vehicles. SECTION 7: SATISFACTORY AND CONTINUING CONTROL Introduction The purpose of this Satisfactory Continuing Control policy is to set forth the general policy to ensure the City of Shakopee will maintain control over real property,facilities,and equipment used in transit service. Use of Project Property, Facilities and Equipment The City of Shakopee agrees to maintain continuing control of the use of grant funded property, facilities and equipment to the extent satisfactory to FTA. For the rest of this section,the federally funded property,facilities and equipment will be referred to as the "asset'. Asset is to be used in the programs or project for the purpose it was acquired as long as needed, whether or not the program or project continues to be supported by Federal funds. The City of Shakopee further agrees to notify FTA immediately when any asset is withdrawn from project use or when any asset is used in a manner substantially different from the representations the City of Shakopee has made in its Application or in the Project Description for the Grant Agreement or Cooperative Agreement for the Project. The City of Shakopee agrees it will not execute any transfer of title, lease, lien, pledge, mortgage, encumbrance,third party contract,subagreement,grant anticipation note, alienation, innovative finance arrangement,or any other obligation pertaining to project asset, City of Shakopee Transit Policy Manual is that in any way would affect the continuing Federal interest in that project asset,without written FTA approval. Maintenance The City of Shakopee agrees to maintain project asset in good operating order, in compliance with any applicable Federal laws and regulations in accordance with applicable Federal directives, except to the extent that FTA determines otherwise in writing. Records The City of Shakopee agrees to keep satisfactory records or databases pertaining to the use of the asset, and submit to FTA upon request such information as may be required to assure compliance. Asset records or database will include: 1. Description of the asset, 2. Identification number, 3. Source of property(the grant project number under which it was procured), 4. Acquisition date, 5. Cost, 6. Percentage of Federal participation in the cost, 7. Location, 8. Use and condition, 9. Useful life, 10. Any disposition data, including the date of disposal and sale price,or,where 11. Applicable, method used to determine its fair market value,and 12. Who holds title to the asset. A physical inventory of assets must be taken and the results reconciled with equipment records at least once every two years. Any differences must be investigated to determine the cause of the difference. Contracted bus providers are required to adopt a maintenance plan that addresses the process for handling non-routine repairs to buses as the result accidents and other incidents including documentation of the matter. Provider must inform the City how the incident or accident affects the asset in terms of intended use and useful life. FTA Approval of Changes in Real Property Ownership. The City of Shakopee agrees it will not dispose of, modify the use of,or change the terms of the real property title or any other interest in the site and facilities used without permission and instructions from FTA. Useful Life of Project Property FTA provides a useful life policy for rolling stock,trolleys,ferries,facilities,and some equipment. Where a useful life policy has not been defined by FTA,the grantee, in consultation with the FTA regional or metropolitan office shall "make the case' by identifying a useful life period for all equipment and facilities with an acquisition value greater than$5,000 to be procured with Federal funds. City of Shakopee Transit Policy Manual 16 Disposition or Replacement at End of Minimum Useful Life Project property to be disposed of or replaced must have achieved at least the minimum useful life. In some cases, FTA interest may still prevail.Therefore,the City must consult with Council Grant staff to ensure that FTA interest is met. Disposition before the End of Useful Life Any disposition of project property before the end of its useful life requires prior FTA approval. FTA is entitled to its share of the remaining Federal interest.The Federal interest is determined by calculating the fair market value of the project property immediately before the occurrence prompting the withdrawal of the project property from appropriate use. SECTION 8: GRANT MANAGEMENT Introduction The purpose of this section is to set forth the general policy that will govern (where applicable) the City of Shakopee financial and technical management of FTA Grants consistent with FTA Circular 5010.1D when the City of Shakopee is a direct recipient of FTA Grant funds. Policy Action and Compliance FTA Circular 5010.11)is provides guidance for post-award grant administration and project management activities for all applicable Federal Transit Administration (FTA)grant programs. This revision incorporates provisions of the Safe,Accountable, Flexible, Efficient Transportation Equity Act:A Legacy for Users(SAFETEA—LU),and includes the most current guidance for the Federal public transportation program as of the date of the publication. These requirements are intended to assist grantees in administering FTA-funded projects and in meeting grant responsibilities and reporting requirements. Grantees have a responsibility to comply with regulatory requirements and to be aware of all pertinent material to assist in the management of federally assisted grants. Financial Management Moody's Investors Service has assigned an Aa2 rating to the City of Shakopee. The Aa2 rating reflects the City's moderately-sized tax base,above average socioeconomic indicators,and healthy financial operations including maintenance of a strong General Fund balance The City of Shakopee Finance Department provides financial management and accounting services for all City operations. This includes the daily financial operation of processing of accounts payable,accounts receivable, utility billing, and risk management. The department also controls the collection of revenues and investment of funds,assists in the issuance of bonds and other indebtedness of the City,and prepares periodic and annual financial and budget reports. Each year,the Finance Department prepares an Annual Financial Report. The report is prepared in accordance with generally accepted accounting principles (GAAP)as established by the Governmental Accounting Standards Board and meets the requirements of the State Auditor's Office. City of Shakopee Transit Policy Manual 17 The independent audit of the financial statements of the City is part of a broader,federally mandated "Single Audit"designed to meet the special needs of federal grantor agencies. The standards governing Single Audit engagements require the independent auditor to report not only on the fair presentation of the financial statements, but also on the audited government's internal controls and compliance with legal requirements,with special emphasis on internal controls and legal requirements involving the administration of federal awards.These reports are available in the City's separately issued Single Audit Report. The City's annual reports are posted at http://www.ci.shakopee.mn.us. In the 2012 report,the independent auditor: 1. Issued and unqualified opinion on the City's financial statements; 2. Reported no deficiencies in the City's internal control overfinancial reporting that were considered material weaknesses; 3. Reported the results of testing disclosed no instances of noncompliance required to be reported under Government Auditing Standards; and 4. Reported no findings based on their testing of the City's compliance with Minnesota laws and regulations. Technical Management The following points demonstrate the City of Shakopee has the technical expertise to not only effectively and efficiently manage all aspects of transit, but any FTA grants that it might be awarded as well: 1. The City of Shakopee established Shakopee Transit in the mid-1980s under the Replacement Transit Service Demonstration legislation commonly referred as"opt-out" transit. 2. The City contracts with transit companies to provide the transit service. 3. The Scott County Transit Review Board consisting of elected representatives of Scott County,the City of Shakopee,the City of Savage,the City of Prior Lake,and others conducts transit planning for the Scott County area. The TRB completed a Unified Transit Management Plan in 2005,and updated the plan in 2008,for adoption by Scott County communities. 4. The City of Shakopee and the City of Prior Lake jointly operate BlueXpress(route 490) commuter express service to and from Minneapolis utilizing 30 trips. The commuter service utilizes two park-and-ride lots,operated jointly by Scott County,the City of Shakopee and the City of Shakopee. A third park and ride lot is under construction and is scheduled to open in 2014. 5. The BlueXpress service has seen a 254%increase in riders since it began operating in July, 2007. 6. The express bus fleet consists of ten coach buses. 7. Presently, BlueXpress averages 750 riders per day. 8. Riders cite the following reasons why they use BlueXpress: convenient service,faster commute than driving, hassle free commute, economical,environmentally friendly, Guaranteed Ride Home program,and great customer service. City of Shakopee Transit Policy Manual 18 Quarterly Capital Reporting The City of Shakopee completes the quarterly capital reporting forms developed by the Metropolitan Council for all capital projects funded through that organization regardless the origin of the capital funding. NTD Reporting The City of Shakopee annually submits NTD information to Metropolitan Council based on the Shakopee Transit operations. City of Shakopee Transit Policy Manual 19 MONTHLY ADA REPORT BY TRANSIT PROVIDER Reporting Month: Name of Provider: Person Completing Report: Service or Contract: Number of pre-trip lift inspections this month: 1. List and describe any lift failures: 2. List and describe any routine maintenance of lifts: 3. List and describe any non-routine maintenance or repairs of lifts: 4. List and describe any customer related ADA complaints: 5. List and describe violations committed by employees of not following the ADA policy: 6. List and describe any ADA related emergency,incident,or accident: City of Shakopee Transit Policy Manual Appendix A 20 SHAKOPEE SHAKOPEE TRANSIT ADA Driver Compliance Monitoring Date Route Trip#and/or Time Bus ID# Driver ID#or Description (CIRCLE ONE RESPONSE FOR EACH ITEM BELOW) Calling Out'Streets/Stops I All Some None Requirement: Driver to call out all bus stop locations,park-and-rides and controlled intersections. COMMENTS: Service Animals None Observed Allowed Denied Requirement., Driver must allow a service animal to board with a rider. COMMENTS., Wheelchair Rider r None Observed Allowed Denied Requirement., Driver cannot disallow or pass-up a rider in wheelchair device along the route or at a stop unless the ramp or lift cannot be deployed due to mechanical reasons,bus stop conditions, or the bus is full to capacity. Driver must stop to inform rider of the situation and immediately notify dispatch. COMMENTS: Lift or Ramp Deployment None Observed Deployed Denied Requirement: Driver must deploy lift or ramp to any rider who requests it to be deployed. COMMENTS: Wheelchair Securement None Observed Provided Not Provided Requirement: It is Metro Transit policy that the driver must assist with and ensure that all mobility devices are property secured. COMMENTS: Boarding Time None Observed Adequate Not Adequate Requirement: Driver must allow adequate time forpersons with disabilities to board or disembark the bus. COMMENTS: Respirators&Portable None Observed Allowed Denied Oxygen Requirement. Drivers cannot deny service to riders using respirators or portable oxygen. COMMENTS: Priority Seating None Observed Allowed Denied Requirement: When requested by a rider with a disability, a driver shall request that other non-disable riders vacate the seats signed"priority seating for persons with s disability or elderly". Driver does not have to enforce the request. COMMENTS: Observation Completed By: City of Shakopee Transit Policy Manual Appendix B 21 TITLE VI PLAN ACKNOWLEDGEMENT OF RECEIPT I am an employee of the City of Shakopee and have received and read the City of Shakopee Title VI Plan. I understand this policy may be amended from time to time to address new concerns or legal issues. I understand I may contact my Department Head, the Assistant City Manager or the City Manager with any questions or concerns. NAME: SIGNATURE: DATE: City of Shakopee Transit Policy Manual Appendix C 22 City of Shakopee Discrimination Complaint Form Note: The following information is needed to assist in processing your complaint.Allegations received by telephone will be reduced to writing and provided to complainant for confirmation or revision before processing. Complainant Information: Name: Address: City: State: Zip Code: Telephone Number(Home): Telephone Number(Other): Email Address: Person Discriminated Against(if someone other than the Complainant): Name: Address: City: State: Zip Code: Telephone Number(Home): Telephone Number(Other): Email Address: Which of the following best describes the reason you believe the discrimination took place? • Race/Color(Specify) • National Origin(Specify) • Sex/Gender ❑ Religion • Age • Disability On what date(s) (d/m/yr) did the alleged discrimination take place? Please explain below as briefly and clearly as possible what happened and how you believe you were discriminated against. Indicate who was involved.Describe in what way you believe other persons were treated differently than you and why you believe these events occurred. Please use additional sheets if necessary and attach a copy to written material pertaining to your case. City of Shakopee Transit Policy Manual Appendix D 23 List names and contact information of persons who may have knowledge of the alleged discrimination. Name: Address: City: State: Zip Code: Telephone Number(Home): Telephone Number(Other): Email Address: Name: Address: City: State: Zip Code: Telephone Number(Home): Telephone Number(Other): Email Address: Name: Address: City: State: Zip Code: Telephone Number(Home): Telephone Number(Other): Email Address: City of Shakopee Transit Policy Manual Appendix D 24 Have you filed this complaint with any other federal, state, or local agency, or with any federal or state court?Check all that apply. • Federal agency ❑ State court • Federal court ❑ Local agency • State agency ❑ Other If a complaint was filed elsewhere,please provide information about a contact person at the agency/court where the complaint was filed. Name: Address: City: State: Zip Code: Telephone Number(Home): Telephone Number(Other): Email Address: Please describe how this/these issue(s)can be resolved to your satisfaction. If an advisor will be assisting you in the complaint process,please provide the advisor's name and contact information. Name: Organization: Address: City of Shakopee Transit Policy Manual Appendix D 25 City: State: Zip Code: Telephone Number(Home): Telephone Number(Other): Email Address: Please sign below. You may attach any written materials or other information that you think is relevant to your complaint. This Discrimination Complaint Form and your written complaint statement must be signed and dated for allegation(s)to be addressed. Additionally,you will need to sign a Consent/Release Form to disclose your name, if necessary, in the course of the inquiry. A Consent/Release Form is attached for your convenience. If you are filing a complaint of discrimination on behalf of another person,this person must also sign a Consent/Release Form to consent to name disclosure in order to proceed. I certify that to the best of my knowledge the information I have provided is accurate and the events and circumstances are as I have described them.As a complainant, I also understand that if I indicated I will be assisted by an advisor on this form, my signature below authorizes the named individual to receive copies of relevant correspondence regarding the complaint and to accompany me during the investigation. Complainant Signature: Date: Attachments: Yes No Submit completed and signed Discrimination Complaint Form, Consent/Release Form(s)and any additional information to: City of Shakopee, 129 S. Holmes St, Shakopee, MN 55379 Phone: 952-233-9300 Fax: 952-233-3802 Email: mleek @ci.shakopee.mn.us City of Shakopee Transit Policy Manual Appendix D 26 Consent/Release Form for Discrimination Complaints Name: Address: City: State: Zip Code: Telephone Number(Home): Telephone Number(Other): Email Address: As a complainant, I understand that in the course of an investigation it may become necessary for the City of Shakopee, hereafter referred to as the"City", to reveal my identity to persons at the organization or institution under investigation. I am also aware of the obligations of the City to honor requests under the Freedom of Information Act. I understand that it may be necessary for the City to disclose information, including personally identifying details, which it has gathered as part of its investigation of my complaint. In addition, I understand that as a complainant I am protected by the City policies and practices, from intimidation or retaliation for having taken action or participated in action to secure rights protected by nondiscrimination statutes and regulations which are enforced by the City. Please check one of the two boxes below: ❑ I CONSENT and authorize to have the City, as part of the investigation,reveal my identity to persons at the organization,business or institution,which has been identified by me in my formal complaint of discrimination. I also authorize the City to discuss,receive and review materials and information about me from the same and with appropriate administrators or witnesses for the purpose of investigating this complaint. In doing so,I have read and understand the information in this form. I also understand that the material and information received will be used for authorized civil rights compliance activities only. I further understand that I am not required to authorize this release, and do so voluntarily. ❑ I DENY CONSENT to have the City reveal my identity to persons at the organization, business or institution under investigation. I also deny consent to have the City disclose any information contained in this complaint with any witnesses I have mentioned in the complaint. In doing so,I understand that I am not authorizing the City to discuss,receive nor review any materials and information about me from the same. In doing so,I have read and understand the information at the beginning of this form. I further understand that my decision to deny consent may impede this investigation and may result in the unsuccessful resolution of my case. Signature: Date: Submit completed and signed Consent/Release Form(s)with the Discrimination Complaint Form and any additional information to: City of Shakopee, 129 S. Holmes St, Shakopee,MN 55379 Phone: 952-233-9300 Fax: 952-233-3802 Email: mleek @ci.shakopee.mn.us City of Shakopee Transit Policy Manual Appendix D 27 City of Shakopee/Shakopee Transit Limited English Proficiency Plan This Limited English Proficiency Plan has been prepared to address the City of Shakopee's responsibilities as a potential recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills accessing the services offered by Shakopee Transit.The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964,42 U.S.C. 2000d,et seq, and its implementing regulations,which states that no person shall be subjected to discrimination on the basis of race,color or national origin. Executive Order 13166,titled Improving Access to Services for Persons with Limited English Proficiency, indicates that differing treatment based upon a person's inability to speak, read,write or understand English is a type of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to all state and local agencies which receive federal transit funds, including the City of Shakopee where applicable relating to Shakopee Transit services and facilities. The City of Shakopee has developed this Limited English Proficiency Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency[LEP]who wish to access services provided by the transit authority.As defined in Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read,speak,write or understand English. This plan outlines how to identify a person who may need language assistance,the ways in which assistance may be provided,staff training that may be required,and how to notify LEP persons that assistance is available. In order to prepare this plan,The City of Shakopee undertook the U.S. DOT four-factor LEP analysis which considers the following factors: 1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a The City of Shakopee program,activity or service. 2. The frequency with which LEP persons come in contact with The City of Shakopee programs, activities or services. 3. The nature and importance of programs, activities or services provided by The City of Shakopee to the LEP population. 4. The resources available to The City of Shakopee and overall cost to provide LEP assistance. Four-Factor Analysis: 1. The number or proportion of LEP persons in the service area who maybe served or are likely to encounter a City of Shakopee program,activity or service. City of Shakopee Transit Policy Manual Appendix E 28 The City of Shakopee staff reviewed the United States Census Bureau Quick Facts and American Fact Finder Reports and determined that 38,744 persons lived in the City of Shakopee. A total of 2756 persons indicated they speak English "less than very well." In the City of Shakopee, 20.6%of persons 5 years old or older speak a language other than English at home. The frequency with which LEP persons come in contact with The City of Shakopee programs,activities or services. The City of Shakopee assessed the frequency with which staff and drivers have,or could have,contact with LEP persons.This includes documenting phone inquiries and surveying vehicle operators.To date, the City of Shakopee has had no requests for interpreters and no requests for translated Shakopee Transit documents. Staff and vehicle operators have reported that,as a whole,they have contact with less than 1 LEP rider per month. 2. The nature and importance of programs,activities or services provided by The City of Shakopee to the LEP population. The overwhelming majority of the population in the City of Shakopee speaks only English.There are social services, professional and leadership organizations within the Scott County service area that focus on outreach to LEP individuals.The City of Shakopee works closely with these organizations.The City of Shakopee provides two transportation services: express service to downtown Minneapolis,and a fixed route circulator that operates only within the City of Shakopee. 3. The resources available to the City of Shakopee and overall cost to provide LEP assistance. The City of Shakopee assessed its available resources that could be used for providing LEP assistance, including determining how much a professional interpreter and translation service would cost on an as- needed basis,which of its documents would be the most valuable to be translated if the need should arise, and taking an inventory of available organizations that the City of Shakopee could partner with for outreach and translation efforts. In past years the City of Shakopee has proactively translated its bus service schedules into Russian and Spanish to serve those populations in the City. The amount of staff and vehicle operating training that might be needed was also considered. Based on the four-factor analysis,the City of Shakopee developed its LEP Plan as outlined in the following section. Limited English Proficiency[LEP] Plan Outline The City of Shakopee will develop several options to be available to assist LEP individuals to utilize transportation services. These options include: • Provide translator services on request. • Continue to monitor LEP persons and reevaluate LEP plan as population changes. Language Assistance Measures Although there is a very low percentage in the City of Shakopee of LEP individuals,the City of Shakopee will ensure that the following measures are in place: City of Shakopee Transit Policy Manual Appendix E 29 • The City of Shakopee Title VI Policy and Limited English Proficiency Plan will be posted on the agency website,www.ci.shakopee.mn.us. • When an interpreter is needed, in person or on the telephone,staff will attempt to determine what language is required and then access language assistance services. Staff Training The following training will be provided to City of Shakopee employees that are directly involved with the Shakopee Transit services: • Information on the City of Shakopee Title VI Policy and LEP responsibilities. • Description of language assistance services offered to the public. • Documentation of language assistance requests. • Use of language line service. • How to handle a potential Title VI/LEP complaint. Outreach Techniques Due to the small local LEP population,the City of Shakopee will initiate an outreach procedure as of 2015.Translation resources are also very limited in this region. However,when and if the need arises for LEP outreach,The City of Shakopee will consider the following options: • When staff prepares a document,or schedules a meeting,for which the target audience is expected to include LEP individuals,then documents, meeting notices,flyers, and agendas will be printed in an alternative language based on the known LEP population. • Bus schedules, maps,and other transit publications will be made available online in an alternative language when and if a specific and concentrated LEP population is identified. Monitoring and Updating the LEP Plan The City of Shakopee will update the LEP as required by U.S. DOT.At a minimum,the plan will be reviewed and updated when more detailed data from the 2010 U.S.Census is available,or when it is clear that higher concentrations of LEP individuals are present in the City of Shakopee service area. Updates will include the following: • The number of documented LEP person contacts encountered annually. • How the needs of LEP persons have been addressed. • Determination of the current LEP population in the service area. • Determination as to whether the need for translation services has changed. • Determine whether local language assistance programs have been effective and sufficient to meet the need. • Determine whether transit system's financial resources are sufficient to fund language assistance resources needed. • Determine whether the City of Shakopee has fully complied with the goals of this LEP Plan. City of Shakopee Transit Policy Manual Appendix E 30 • Determine whether complaints have been received concerning the agency's failure to meet the needs of LEP individuals. Dissemination of the City of Shakopee LEP Plan A link to the City of Shakopee LEP Plan and the Title VI Plan will be included on the Shakopee Transit website,www.cityofpriorlake.com. Any person or agency with internet access will be able to access and download the plan from The City of Shakopee website.Alternatively,any person or agency may request a copy of the plan via telephone, fax, mail,or in person,and shall be provided a copy of the plan at no cost. LEP individuals may request copies of the plan in translation which the City of Shakopee will provide, if feasible. Questions or comments regarding the LEP Plan may be submitted to the City of Shakopee as follows: Mark McNeill, City Administrator City of Shakopee 129 S. Holmes St. Shakopee, MN 55379 Phone:952-233-9300 City of Shakopee Transit Policy Manual Appendix E 31 Rider Safety& Security Awareness Program BE INFORMED AND HAVE A TRANSIT PLAN OF ACTION: 1. Familiarize yourself with station entrances 2. Locate emergency telephones to report suspicious packages or activities 3. Remain calm and listen for station,train or bus announcements 4. Follow transit authority instructions in a speedy but orderly fashion 5. Do not block train or bus doors from closing 6. Assist fellow passengers and follow the Golden Rule:Watch out for the safety of others just as you would have them watch out for your safety BE ON THE ALERT FOR SUSPICIOUS... Packages If you spot an unattended package, look for the following: • Placement in an out-of-the-way location • Individuals in the act of abandoning the package and hastily departing the area • Unusual attached batteries,wires,tanks, bottles or bags that might contain chemicals • An attached message • A suspicious cloud, mist,gas,vapor, odor or seeping fluid • Nearby individuals showing signs of illness or distress Behavior If you spot any suspicious individuals engaged in questionable activity,look for the following: • Visible signs of nervousness • Excessive sweating • Sprayer bottles or aerosol canisters • Inappropriate clothing that is excessively baggy or too heavy in warm weather Recommended course of action: • Do not confront suspicious individuals. • Contact a transit employee or the police immediately. • In the event of a suspicious package, do not use a cellular phone until you are a safe distance away. BE PREPARED: 1. Create a plan for maintaining contact with family members if separated as a result of an emergency 2. Create a plan for maintaining contact with close friends and colleagues during an extended emergency period 3. Keep a record of all contact and emergency information and update it regularly as needed 4. Select a location outside your home as a family meeting point should your home need to be evacuated 5. Identify alternate routes and means of reaching your meeting point in the event your main route is impassable 6. Keep a local map handy for reference 7. Make sure your emergency information and contact numbers are with you at all times City of Shakopee Transit Policy Manual Appendix F 32