HomeMy WebLinkAboutExhibit 1City ofWiami
Title VI/Nondiscrimination
Program Plan
City of Miami is committed to nondiscrimination and broad, inclusive access to
programs and services. In accordance with Title VI of the Civil Rights Act and
other federal and state nondiscrimination authorities, "No person in the United
States shall, on the ground of race, color, national origin, sex, age, disability
religion or family status be excluded from participation in, or be denied the
benefits of, or be subjected to discrimination under any program or activity.
Adopted by the Miami City Commission on , 2014
by Resolution No.
1•5'0463(--
444 SW 2 Ave, Miami, FL 33130
Office: (305) 416-1280 . Fax: (305) 416-2153
Website: www.miamiaov.com
City of Miami
Title VI Program
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City of Miami
Title VI Program
Contents.
Pfan Statement 1
Title VI/Nondiscrimination Information Dissemination Procedure 2
Contracts, Subcontracts and Vendor Agreements 2
Record Keeping 2
Title VI/Nondiscrimination Complaint Procedures 3
Limited English Proficiency (LEP) Plan 5
Public Participation Element 5
Service Standards 8
Appendices
Appendix A
Appendix B
Appendix C
Appendix D v
Appendix E vi
Appendix F viii
Appendix G ix
Appendix H x
Appendix I xii
City of Miami
Title VI Program
City of Miami
Title VI/Nondiscrimination Program Plan
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. • Other Federal and State authorities forbid discrimination on the
bases of gender, age, disability, religion and family status.
The City of Miami (City) is committed to ensuring that no person is excluded from
participation in, or denied the benefits of its programs and activities on the basis
of race, color, creed, religion, sex, domestic relationship status, parental status,
familial status, sexual orientation, national origin, political affiliation, gender
identity and expression, or racial profiling national origin, sex, age, disability
religion, family status as protected by Title VI and other nondiscrimination
authorities.
This plan was developed to guide the City in its administration and management
of Title VI/Nondiscrimination Program.
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City of Miami
Title VI, Program
Title VI/Nondiscrimination Information Dissemination Procedure
Title VI information posters shall be prominently and publicly displayed in public
facilities •frequented by the public, including buildings and service vehicles. The
name and contact information of the Title VI/Nondiscrimination coordinator is
available on the City's website, at www.miamigov.com. Additional information
relating to the City's nondiscrimination obligation is provided in the Appendices
of this document. The City's Notification of Title VI and related authority rights
statement is available in Appendix A. Further information can be obtained
directly from the City Title VI/Nondiscrimination Coordinator.
Title VI/Nondiscrimination Coordinator contact information
Carlos Cruz-Casas, P.E.
Title VI Coordinator
City of Miami
444 SW 2 Ave, 8th Floor
Miami, FL 33130
305-416-1280
TTY/TTD Number: 305-468-5402
ccruz-casas@miamigov.com
Contracts, Subcontracts and Vendor Agreements
Title VI/Nondiscrimination information shall be disseminated to all transit vendors
annually via personal delivery from the City to the transit operator. The form at
(Appendix B] reminds each vendor of the City statement, and of their Title
VI/Nondiscrimination responsibilities in their daily work and duties.
All professional services consultants and construction contractors shall
incorporate the Title VI/Nondiscrimination contract clauses at (Appendix C1 in all
contracts/subcontracts funded all or in by federal assistance.
Record Keeping
The Title VI/Nondiscrimination Coordinator will maintain permanent records,
which include, but are not limited to, signed acknowledgements of receipt from
the vendor indicating the receipt of the Title VI Plan, copies of Title
VI/Nondiscrimination complaints or lawsuits and related documentation, and
records of correspondence to and from complainants, and Title
VI/Nondiscrimination investigations.
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City of. Miami
Title VI.Program
Title VI/Nondiscrimination Complaint Procedures
How fo file a Title VI Complaint?
The complainant may file a signed, written complaint no later than 180 days
after the date of the alleged discrimination. The --complaint procedures- are -.--
described in detail in Appendix D. Each complaint should include the following
information:
Full name
Mailing address
Contact Information (i.e., telephone number, email address, etc.)
How, when, where and why you believe you were discriminated against.
Include the location, names and contact information of any witnesses
Other information that you consider significant
The Title VI Complaint Form [Appendix El may be used to submit the complaint
information. The complaint may be filed in writing to the City at the following
address:
City of Miami
Attention: Title VI/Nondiscrimination Coordinator
444 SW 2 Ave, 8th Floor
Miami, FL 33130
ccruz-casas@miami•ov.com
NOTE: The City encourages all complainants to certify all mail that is sent through
the U.S. Postal Service and/or ensure that all written correspondence can be
tracked easily. Complaints must be mailed to the Title VI/Nondiscrimination
Coordinator no later than 180 days after the date of the alleged discrimination.
What happens to the complaint once it is submitted?
All complaints alleging discrimination based on race, color, national origin, sex,
age, disability, religion and family status in a program, service, activity or benefit
provided by the City will be directly addressed by the Title IV/Nondiscrimination
Coordinator who shall also provide appropriate assistance to complainant(s),
including those persons with disabilities, low literacy skills, and/or who are limited
in their ability to communicate in English. Additionally, the City shall make every
effort to address all complaints in an expeditious and thorough manner.
A letter acknowledging receipt of complaint will be mailed within seven days
[Appendix F]. Please note that in responding to any requests for additional
information, a complainant's failure to provide the requested information may
result in the administrative closure of the complaint.
How will the complainant be notified of the outcome of the complaint?
The City will send a final written response letter [Appendix G1 to the complainant.
If the complaint is found to be not substantiated, [Appendix H], the complainant
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Title VI Program
is also advised of his or her right to 1) appeal within seven _calendar days_ of
receipt of the final written decision from the City, and/or 2) file a complaint
externally with the modal administrations of the __U.S. -Department._ of
Transportation and/or the U.S. Department of Justice. Every effort will be made
to" respond to Title VI/Nondiscrimination complaints within 60 working days of
receipt of such complaints, if not sooner.
Once sufficient information for investigating the complaint is received by the
City, a written response will be drafted subject to review by the City Attorney. If
appropriate, the City Attorney may administratively close the complaint. In this
case, the City will notify the complainant of the action as soon as possible.
The City maintains a list of Title VI complaints [Appendix I] that is updated as
necessary.
In addition to the complaint process described above, a complainant may file a
Title VI/Nondiscrimination complaint with the following offices:
U.S. Department of Transportation
Office of Civil Rights
1200 New Jersey Ave.
Washington D.C. 20590
202-366-4648
https://www.civilrights.dot.aov/about-docr/contact-us
U.S. Department of Justice
Office of Civil Rights
Federal Coordination and Compliance Section, NWB
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530
http://www.justice.aov/crt/about/cor/coord/titlevi.php
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City of Miami
Title VI Program
Limited English Proficiency (LEP) Plan
As of the 2010 2010 Decennial Census, Miami has an approximate total -
population of 400,000 residents. Approximately 23 percent of the City's
population .speaks only English, and 77 percent speaks a 'language other than •
English, with Spanish being the other predominant language. Of the population
that speaks a language other than English, 70 percent speak Spanish. Nearly half
of. City.residents - 44 percent - speak English less than very well.
Because of the large number of Spanish speaking residents, the City regularly
provides information in both predominant languages - English and Spanish.
Information regarding essential programs, services and activities are provided on
the City's website and in City facilities open to the public. Residents can request
translations of documents in to other commonly spoken languages. A large
portion of the City's employees are bilingual, and in most cases, City information
can be conveyed in both languages. The City regularly disseminates information
via its website, www.miamigov.com, and its television station, Channel 77, in
both English and Spanish.
The City recognizes the need to accommodate residents with limited English
proficiency and is committed to providing programs and services that are
accessible to all persons regardless of potential language barriers.
The following guidelines are used to assist persons with Limited English Proficiency:
1. Meetings, hearings and other public involvement event include bilingual
interpreters and written information, as appropriate.
2. The City Title VI/Nondiscrimination Policy and Complaint Procedures are
hosted on the City's web page in English and Spanish, and made
available in other languages as requested.
a. Understanding the Title VI/Nondiscrimination Policy and LEP
responsibilities
b. How to access Title VI/Nondiscrimination Policy and Procedures via
the City's shared server
c. Document and resolve any language assistance deficiencies
d. The procedure if a discrimination and/or LEP complaint is filed.
The City will review LEP procedures annually to determine if modifications are
needed to meet language assistance deficiencies.
Public Participation Element
The City seeks to engage the public in its planning and decision -making
processes. Members of the public may make statements at Commission
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City of Miami -
Title VI Program
meetings, which occur on alternating Thursdays, twice a month. City Commission
agendas are available for review by the public no less than five (5) days before
Commission meetings. Notices of resolutions or ordinances under Commission
consideration are announced in print in local newspapers.
The City continuously seeks innovative methods to engage the public in its
planning and decision -making processes, as well= as its outreach
activities. Recent outreach initiatives include:
• Social media communication on the City Facebook and Twitter feeds
o @CityofMiami for general City news, @MiamiTrolley for Transit
announcements
• Transit Service alert updates are posted to the Miami Trolley website
o www.miamitrolley.com
• Engaging the community in marketing and promotional efforts for transit
services, including outreach efforts through partner institutions and
departments including the Miami Downtown Development Authority, the
Neighborhood Enhancement Team, Miami -Dade Transit, South Florida
Commuter Services, the Florida Department of Transportation, etc.
• Advertising the Miami Trolley routes on electronic billboards, and ad panels
throughout the City limits
• Production and distribution of postcards depicting trolley routes, vehicles,
hours of operation, and contact information
• Inviting public inquiries about all programs, services and activities
Resolutions adopted by the City to apply for and utilize Federal and State grant
funding have been posted on thepublic hearing/meeting agenda web page
and were subject to public notice and comment procedures.
The City and its records are available to the public and the City welcomes their
input.
The City's Title VI/Nondiscrimination Complaint Procedure is available to the
public 24 hours/7days a week on our website www.miamiaov.com.
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City ot.Miami
Title VI Program
CHAPTER IV REQUIREMENTS
FOR TRANSIT PROVIDERS
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Service Standards
o Miami Trolley. Vehicle Load Standards
Vehicle
Type
Average Passenger Capacities
Seated (Includes 2
Wheelchairs)
Standing
Total
Maximum Load
Factor
33' Trolley
32
10
42
1.3
27' Trolley
22
5
27
1.2
o Vehicle Headway Standards
The Miami Trolley system operates on a headway basis. The City's service
operates every 15 to 20 minutes for the duration of the service window. On
weekends, service operates approximately every 20 minutes.
Service scheduling involves consideration of a number of factors including:
ridership productivity, land use connectivity, transportation demand
management, necessity of congestion reduction, density of transit -dependent
population and activities, and relationship to major transportation developments
o On time Performance Standards
A Miami Trolley is considered on time if it departs a scheduled time point no more
than 1 minute early and no more than five (5) minutes late. The Miami Trolley's
on -time performance objective is 90% or greater. The City of Miami continuously
monitors on -time performance to ensure adherence to these standards.
The Miami Trolley typically has few issues with on time performance. Through
additional route analysis, including GPS-based vehicle tracking, and a recently
installed Computer Aided Dispatch/Automatic Vehicle Location (CAD/AVL)
system, the City aims to increase route efficiency, and improve overall
performance. The City works continually to ensure trolleys adhere to the
expected headway spacing, so as to ensure consistent on -time performance.
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o Multimodal Service Availability
The Miami Trolley stops are located on most blocks along the City's routes, and -
no more than 3 blocks apart, encouraging the use of alternative transportation
methods such as transit, walking, and biking.
All vehicles adhere to ADA guidelines for passenger accessibility.
Service Policies
o Transit Amenities Policy
All vehicles are equipped with the following:
• Air conditioned interior
• Wheelchair lifts
• Wheelchair accessible seating
• Non-skid surface installation at entry and exit points
• Rubber edged steps to prevent slippage and injury
• Front loading bicycle racks
Through an Interlocal Agreement with Miami -Dade County the City has the
expanded the availability of transit stop amenities which includes the usage of
Miami -Dade County Metrobus benches and shelters. This allows passengers to
wait for various modes of transit at one stop.
The City has installed bus benches and shelters along routes based on the
number of passenger boardings at stops and stations along those routes.
o Vehicle Assignment Policy
Bus assignments take into account the operating characteristics of the two
trolley lengths in the City's fleet. These are in turn matched to the operating
characteristics of. the City's routes. Routes with lower ridership are generally
assigned the 27' trolleys, while routes with higher ridership are assigned the 33'
trolleys. Vehicle availability is subject to change, depending on incidents and
routine maintenance.
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City of Miami
Title VI Program
Service and Fare Changes
The City is committed to seeking public input for fare changes and system
modifications to the Miami Trolley system that exceed more than 20% change in
a route's alignment . When a Trolley question comes before the City Commission,
the item will be noticed and heard as a public hearing, enabling the public and
interested stakeholders to voice concerns about potential changes.
The City commits to adhering to the following procedures on Commission
Meeting items regarding the Miami Trolley:
"Notice of the public hearing must be made in a newspaper of general
circulation in the area and the notice must be at least 16 square inches in
size, must be in ethnic newspapers or local community bulletins, must be
posted in the affected area, and must be announced at a scheduled
meeting of the local governing body before the actual public hearing."
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Appendices
Appendix A
Notifying the Public of Rights Under Title VI and other nondiscrimination
Authorities
The City of Miami operates its programs and services free of discrimination
based on race, color, and national origin in accordance with Title VI of
the Civil Rights Act, and based on sex, age, disability, religion and family
status in accordance with other Federal and State nondiscrimination
authorities. Any person who believes she or he has been aggrieved by
any unlawful discriminatory practice under Title VI or other
nondiscrimination authorities may file a complaint with the City of Miami.
For more information on the City of Miami's civil rights program, and for
questions about the procedures to file a complaint, please contact the
City directly by one of the following:
Phone: 305-416-1280
TTY: 305-468-5402
In person: 444 SW 2nd Avenue
8th Floor
Miami, FL 33130
Online: www.miamiaov.com
A complainant may file directly with the U.S Department of Transportation
or U.S. Department of Justice by contacting one or both of the following:
U.S. Department of Transportation
Office of Civil Rights
1200 New Jersey Ave.
Washington D.C. 20590
202-366-4648
httos://www.civilrights.dot.gov/about-docr/contact-us
U.S. Department of Justice
Office of Civil Rights
Federal Coordination and Compliance Section, NWB
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530
http://www.justice.govicrt/about/cor/coord/titlevi.oho
If you require information in a language other than English, please contact 305-
416-1280.
Si usted requiere informacion en espanol por favor (lame 305-416-1280.
Si ou bezwen enfomasyon so a nan you lot long ke angle, tanpri kontakte 305-
416-1280.
Appendix B
Acknowledgement of Receipt of Title VI/Nondiscrimination Plan
I hereby acknowledge the receipt of the City of Miami Title VI/Nondiscrimination
Plan. I have read the plan and am committed to ensuring that no person is
excluded from participation in, or denied the benefits of its transit services on the
basis of race, color, or national origin, as protected by Title VI, or on the basis of
sex, age, disability, religion and family status, as required by other Federal and
State nondiscrimination authorities.
Recipient signature
Print your name
Print name of Vendor or Contractor
Date
ii
Appendix C
Title VI and Related Nondiscrimination Contract Clauses
1. During the performance of this contract, the contractor, for itself, its assignees
and successors in interest (hereinafter referred to as the "contractor") agrees as
follows:
Compliance. with Regulations: The contractor shall comply with the Acts and the
Regulations relative to Nondiscrimination in federally -assisted programs of the
U.S. Department of Transportation and other federal and state authorities as they
may be amended from time to time, which are herein incorporated by
reference and made a part of this contract.
Nondiscrimination: The contractor, with regard to the work performed by it
during the contract, shall not discriminate on the grounds of race, color, national
origin, sex, age, or disability, religion or family status in the selection and retention
of subcontractors, including procurements of materials and leases of equipment.
The contractor shall not participate either directly or indirectly in the
discrimination prohibited by the Acts and the Regulations, including employment
practices when the contract covers a program set forth in Appendix B of 49 CFR
Part 21.
Solicitations for Subcontracts, Including Procurements of Materials and
Equipment: In all solicitations either by competitive bidding or negotiation made
by the contractor for work to be performed under a subcontract, including
procurements of materials or leases of equipment, each potential subcontractor
or supplier shall be notified by the contractor of the contractor's obligations
under this contract and the Acts and the Regulations relative to
Nondiscrimination on the grounds of race, color, national origin, sex, age,
disability, religion or family status.
Information and Reports: The contractor shall provide all information and reports
required by the Acts, the Regulations and directives issued pursuant thereto and
shall permit access to its books, records, accounts, other sources of information,
and its facilities as may be determined by the Recipient, State of Florida or
Federal agency to be pertinent to ascertain compliance with such Acts,
Regulations, orders, and instructions. Where any information required of a
contractor is in the exclusive possession of another who fails or refuses to furnish
this information the contractor shall so certify to the Recipient, State of Florida or
Federal funding agency, as appropriate, and shall set forth what efforts it has
made to obtain the information.
Sanctions for Noncompliance: In the event of the contractor's noncompliance
with the Nondiscrimination provisions of this contract, the Recipient shall impose
such contract sanctions as it or the funding agency may determine to be
appropriate, including, but not limited to:
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Withholding of payments to the contractor under the contract until the
contractor complies; and/or Cancellation, termination, or suspension of the
contract, in.whole or in part.
Incorporation of Provisions: The contractor shall include the provisions of
paragraphs 1 through 6 in every subcontract, including procurements of
materials and leases of equipment, unless exempt by the Acts, the Regulations
and directives issued pursuant thereto. The contractor shall take such action
with respect to any subcontract or procurement as the Recipient of U.S.
Department of Transportation, State of Florida or other Federal funding agency
may direct as a means of enforcing such provisions including sanctions for
noncompliance. Provided, however, that in the event a contractor becomes
involved in, or is threatened with, litigation with a subcontractor or supplier as a
result of such direction, the contractor may request the Recipient to enter into
such litigation to protect the interests of the Recipient and, in addition, the
contractor may request the United States to enter into such litigation to protect
the interests of the United States.
iv
Appendix D
Title VI/Nondiscrimination Complaint Procedures
Any person who believes he or she has been discriminated against on the basis
of race, color, national origin, sex, age, disability, religion or fami;y status by the
City of Miami (herein referred to as City) may file a discrimination complaint by
completing andsubmitting the agency's Title VI/Nondiscrimination Complaint
Form. A complaint may be filed no later than 180 days after the date of the
alleged discrimination. The City or its designated Title VI/Nondiscrimination
Coordinator will process complaints that are complete.
Once the complaint is received, the Title VI/Nondiscrimination Coordinator will
review it to determine if our office has jurisdiction. The complainant will receive
an acknowledgement letter informing him/her whether the complaint will be
investigated by our office.
The City has 60 days to investigate the complaint. If more information is needed
to resolve the case, the City's Title VI/Nondiscrimination Coordinator may
contact the complainant. The complainant will have 10 business days from the
date of the letter to send the requested information to the investigator assigned
to the case. If the investigator is not contacted by the complainant or does not
receive the additional information within 10 business days, the Title
VI/Nondiscrimination Coordinator can administratively close the case. A case
can also be administratively closed if the complainant no longer wishes to pursue
their case.
After the case is investigated he/she 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 discrimination
violation and that the case will be closed. An LOF summarizes the allegations
and the interviews regarding the alleged incident, and explains whether any
disciplinary action, additional training of the staff member or other action will
occur.
If the complainant wishes to appeal the decision, he/she has 10 business days
after the date of the LOF to do so.
A person may also file a complaint directly with one or both of the following:
U.S. Department of
Transportation
Office of Civil Rights
1200 New Jersey Ave.
Washington D.C. 20590
202-366-4648
https://www.civilriahts.dot.gov/
about-docr/contact-us
U.S. Department of Justice
Office of Civil Rights
Federal Coordination and
Compliance Section, NWB
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530
http://www.justice.gov/crt/abo
ut/cor/coord/titlevi.php
v
Appendix E
Discrimination Complaint Form
If you feel you have been discriminated against, please provide the following
information in order to assist us in processing your complaint and send it to:
Carlos Cruz-Casas, P.E.
Title VI Coordinator
City of Miami
444 SW 2 Ave, 8th Floor
Miami, FL 33130
Please print clearly:
Name:
Address:
City, State, Zip Code:
Telephone Number:
Person discriminated against:
(home) (cell)
Address of person discriminated against:
City, State, Zip Code:
Please indicate why you believe the discrimination occurred:
race
color
national origin
sex
age
disability
religion
family status
other
What was the date of the alleged discrimination?
vi
Where did the alleged discrimination take place?
Please describe the circumstances as you saw it:
Please list any and all witnesses' names and phone numbers:
Please attach any documents which support the allegation. Then date and sign
this form and send to the Title VI/Nondiscrimination Coordinator at:
City of Miami
Attention: Title VI/Nondiscrimination Coordinator
444 SW 2 Ave, 8th Floor
Miami, FL 33130
Your signature
Print your name
Date
vii
Appendix F
Letter Acknowledging Receipt of Complaint
Date
Complainant's Name
Complainant's Address
Dear (Mr. /Ms.) :
This letter is to acknowledge receipt of your complaint against the City of Miami
alleging
An investigation will begin shortly. If you have additional information you wish to
convey or questions concerning this matter, please feel free to contact this
office by telephoning 305-416-1280, or write to me at this address.
Sincerely,
Carlos Cruz-Casas, P.E.
Title VI/Nondiscrimination Coordinator
City of Miami
444 SW 2 Ave, 8th Floor
Miami, FL 33130
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Appendix G
Letter Notifying Complainant that the Complaint Is Substantiated
Date
Compldiriarit`s Name
Complainant's Address
Dear (Mr. /Ms.):
The matter referenced in your letter of (date) against the City of
Miami alleging Title VI violation has been investigated.
(An/Several) apparent violation(s) of (list all applicable
nondiscrimination authorities) including those mentioned in your letter
(was/were) identified. Efforts are underway to correct these deficiencies.
Thank you for bringing this important matter to our attention. You may be
hearing from this office, or from federal authorities, if your services should be
needed during the administrative hearing process.
Sincerely,
Carlos Cruz-Casas, P.E.
Title VI/Nondiscrimination Coordinator
City of Miami
444 SW 2 Ave, 8th Floor
Miami, FL 33130
ix
Appendix H
Letter Notifying Complainant that the Complaint Is
Not Substantiated
Date
Complainant's Name
Complainant's Address
Dear (Mr. /Ms.)
The matter referenced in your complaint of (date) against the
City of Miami alleging has been investigated.
The results of the investigation did not indicate that the provisions of Title VI of the
Civil Rights Act of 1964 or other federal or state nondiscrimination authorities had
in fact been violated. As you know, Title VI prohibits discrimination based on
race, color, or national origin in any program receiving federal financial
assistance, while later and related authorities forbid discrimination on the basis of
sex, age, disability, religion and family status
The City Attorney has analyzed the materials and facts pertaining to your case
for evidence of the city's failure to comply with any of the civil rights laws. There
was no evidence found that any of these laws have been violated.
I therefore advise you that your complaint has not been substantiated, and that I
am closing this matter in our files.
You have the right to 1) appeal within seven calendar days of receipt of this final
written decision from the City, and/or 2) file a complaint externally with the U.S.
Department of Transportation and/or the U.S. Department of Justice af:
U.S. Department of
Transportation
Office of Civil Rights
1200 New Jersey Ave.
Washington D.C. 20590
202-366-4648
https://www.civilrights.dot.gov/
about-docr/contact-us
U.S. Department of Justice
Office of Civil Rights
Federal Coordination and
Compliance Section, NWB
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530
http://www.justice.gov/crt/about
/cor/coord/titlevi.php
x
Thank you for taking the time to contact us. If I can be of assistance to you in the
future, do not hesitate to contact me.
Sincerely,
Carlos Cruz-Casas, P.E., Title VI Coordinator
City of Miami
444 SW .2 Ave,.8th Floor
Miami; FL 33130
xi
Appendix I
List of Title VI and Other Discrimination Investigations, Complaints, and
Lawsuits
The City of Miami does not have any active investigations, complaints, or lawsuits
to disclose at this time. Any future disclosures will be listed under this appendix in
the Title VI/Nondiscrimination Program Plan.
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