Title VI Program

Authorities

Title VI Civil Rights Act of 1964 provides that no person in the United States shall, on the grounds of race, color, national origin, be excluded from participation in, be denied the benefits of or otherwise subjected to discrimination under any program or activity receiving federal financial assistance. 

The Civil Rights Restoration Act of 1987 broadened the scope of Title VI coverage by expanding the recipients, sub-recipients, and contractors, whether such programs and activities are federally assisted or not (Public Law 100259 [2.557] March 22, 2988). 

Environmental Justice (EJ) (Executive Order 12898) addresses disproportionate adverse environmental social and economic impacts that may exist in communities, specifically minority and low-income populations. 

Limited English Proficiency (LEP) (Executive Order 13166) addresses access to services for persons whose primary language is not English who have limited ability to read, write, speak, or understand English. 

Americans with Disabilities Act of 1990 (ADA) prohibits discrimination and ensures equal opportunity for persons with disabilities in employment, State and local government services, public accommodations, commercial facilities, and transportation. 

Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 324) prohibits discrimination based on handicap/disability. 

Title VI Policy Statement 

It is the policy of the City of Greer to comply with all federal and state authorities requiring nondiscrimination, including but not limited to Title VI of the Civil Rights Act of 1964, the Civil Rights Restoration Act of 1987, Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990 (ADA), the Age Discrimination Act of 1975 and Executive Order 12898 (Environmental Justice) and 13166 (Limited English Proficiency). The City of Greer does not and will not exclude from participation in; deny the benefits of; or subject anyone to discrimination on the basis of race, color, or national origin. Examples of the application of this policy include, but are not limited to, the following: 

No person in the United States will on the grounds of race, color, or national origin be excluded from participation in, be denied the benefit of, or be otherwise subjected to discrimination under any program or activity for which the City receives federal financial assistance from the U. S. Department of Transportation, including the SCOOT, Federal Highway Administration and the Federal Transit Administration. In addition, the City will not retaliate against any person who complains of discrimination or who participates in an investigation of discrimination. 

All federally assisted programs will be administered in a manner to guarantee that the City of Greer, other recipients, sub-recipients, contractors, subcontractors, transferees, and other participants in federal financial assistance comply with all requirements imposed by or pursuant to, civil rights acts and Department of Transportation regulations. The City of Greer’s Administration is responsible for initiating and monitoring Title VI activities, preparing required reports as required by 23 Code of Federal Regulation (CFR) Part 200 and 49 Code of Federal Regulation Part 21. 

Click on the links below for more information about Title VI Notice Procedures and Policies:

Those requiring information in alternative formats or in a language subject to City of Greer's Limited English Proficiency (LEP) Plan should contact the Title VI Coordinator.

CITY OF GREER  TITLE VI NON-DISCRIMINATION & PUBLIC PARTICIPATION PLAN

INTRODUCTION

Title VI of the Civil Rights Act of 1964, is the overarching civil rights law which prohibits discrimination based on race, color, or national origin, in any program, service or activity that receives federal assistance. Specifically, Title VI assures that, "No person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefit of, or be otherwise subjected to discrimination under any program or activity receiving federal assistance." Title VI has been broadened by related statutes, regulations and executive orders. Discrimination based on sex is prohibited by Section 

324 of the Federal-Aid Highway Act, which is the enabling legislation of the Federal Highway Administration (FHWA). The Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 prohibit unfair and inequitable treatment of persons as a result of projects which are undertaken with Federal financial assistance. The Civil Rights Restoration Act of 1987 clarified the intent of Title VI to include all programs and activities of federal-aid recipients and contractors whether those programs and activities are federally funded or not. 

In addition to statutory authorities, Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," signed in February of 1994, requires federal agencies to achieve Environmental Justice as part of its mission by identifying disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations. Environmental Justice Initiatives are accomplished by involving the potentially affected public in the development of transportation projects that fit within their communities without sacrificing safety or mobility. In 1997, the U.S. Department of Transportation (USDOT) issued its DOT Order to Address Environmental Justice in Minority Populations and Low-Income Populations to summarize and expand upon the requirements of Executive Order 12898 on Environmental Justice. Also, Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency (LEP)," provides that individuals who a limited ability to read, write and speak, or understand English are entitled to language assistance under Title VI of the Civil Rights Act of 1964. 

There are two types of illegal discrimination prohibited under Title VI and its related statutes. One type of discrimination which may or may not be intentional is "disparate treatment." Disparate treatment is defined as treating similarly situated persons differently because of their race, color, or national origin. 

The second type of illegal discrimination is "disparate impact." Disparate impact discrimination occurs when a "neutral procedure or practice" results in fewer services or benefits, or inferior services or benefits, to members of a protected group. With disparate impact, the focus is on the consequences of a decision, policy, or practice rather than the intent. 

The City of Greer's efforts to prevent such discrimination must address, but not be limited to, a program's impacts, access, benefits, participation, treatment, services, contracting opportunities, training, investigation of complaints, allocation of funds, prioritization of projects, and the overarching functions of planning, project development and delivery, right-of-way, construction, and research. 

The City of Greer shall also ensure that their sub-recipients adhere to state and federal law and include in all written agreements or contracts, assurances that the sub-recipient must comply with Title VI and other related statutes. The City of Greer, as a sub-recipient who distributes federal transportation funds, shall monitor their sub-recipients for voluntary compliance with Title VI. In the event that non-compliance is discovered, the City will make a good faith effort to ensure that the sub-recipient corrects any deficiencies arising out of complaints related to Title VI; and that sub-recipients will proactively gauge the impacts of any program or activity on minority populations and low-income populations, the elderly, persons with disabilities, all interested persons and affected Title VI populations. 

The City has developed this Title VI Plan to assure that services, programs, and activities of the City are offered, conducted, and administered fairly, without regard to race, color, or national origin of the participants or beneficiaries of federally funded programs, services, or activities. Every effort will be made to prevent discrimination in any program or activity, whether those programs and activities are federally funded or not. 

OBJECTIVES 

The primary goals and objectives of the City of Greer's Title VI Program are: 

  1. To assign roles, responsibilities, and procedures for ensuring compliance with Title VI of the Civil Rights Act of 1964 and related regulations and directives;

  2. To ensure that people affected by City programs and projects receive the services, benefits, and opportunities to which they are entitled without regard to race, color, or national origin;

  3. To prevent discrimination in the City of Greer programs and activities, whether those programs and activities are federally funded or not;

  4. To establish procedures for identifying impacts in any program, service, or activity that may create illegal adverse discrimination on any person because of race, color, or national origin; or on minority populations, low-income populations, the elderly, and all interested persons and affected Title VI populations;

  5. To establish procedures to annually review Title VI compliance within specific program areas within the City;

  6. To set forth procedures for filing and processing complaints by persons who believe they have been subjected to illegal discrimination under Title VI in City services, programs or activities.

DEFINITIONS 

Adverse Effects - The totality of significant individual or cumulative human health or environmental effects including interrelated social and economic effects, which may include, but are not limited to: 

  • Bodily impairment, infirmity, illness or death

  • Air, noise and water pollution and soil contamination

  • Destruction or disruption of man-made or natural resources

  • Destruction or diminution of aesthetic values

  • Destruction or disruption of community cohesion or community's economic vitality

  • Destruction or disruption of the availability of public and private facilities and services

  • Adverse employment effects

  • Displacement of person's businesses, farms or non-profit organizations

  • Increased traffic congestion, isolation, exclusion or separation of minority or low-income individuals within a given community or from the broader community

  • Denial of, reduction in, or significant delay in the receipt of benefits of the City programs, policies and activities

Citizen Participation - an open process in which the rights of the community to be informed, to provide comments to the Government and to receive a response from the Government are met through a full opportunity to be involved and to express needs and goals. 

Compliance - a satisfactory condition wherein an applicant, recipient, or sub-recipient has effectively implemented all of the Title VI requirements or can demonstrate that every good faith effort toward achieving this end has been made. 

Contract - a mutually binding legal relationship or any modification thereof obligating the seller to furnish supplies or services, including construction, and obligating the buyer to pay for them. Throughout this document, a lease is considered a contract. 

Contractor - any person, corporation, partnership, organization, or incorporated association that participates, through a contract or subcontract, in any program or activity covered by this plan, including lessees. 

Designee - individuals assigned to work with the Title VI Coordinator regarding designated program areas. 

Discrimination - Involves any act (or action) whether intentional or unintentional through which a person in the United States, solely because of race, color or national origin, has been otherwise subjected to unequal treatment under any program or activity receiving federal financial assistance. 

Federal Assistance - Includes grants and loans of federal funds; the grant or donation of federal property and interests in property; the detail of federal personnel, federal property or any interest in such property without consideration or at a nominal consideration or at a consideration which is reduced for the purpose of assisting the recipient, or in recognition of the public interest to be served by such sale or lease to the recipient; and any federal agreement, arrangement or other contract which has, as one of its purposes, the provision of assistance. 

Limited English Proficiency - Individuals with a primary or home language other than English who must, due to limited fluency in English, communicate in that primary or home language if the individuals are to have an equal opportunity to participate effectively in or benefit from any aid, service or benefit provided by the City. 

Low-Income - A person whose median household income is at or below the Department of Health and Human Service Poverty guidelines (see https://aspe.hhs.gov/poverty-guidelines). 

Low-Income Population - Any readily identifiable group of low-income persons who live in geographic proximity and, if circumstances warrant, geographically dispersed/transient persons (such as migrant workers or Native Americans) who will be similarly affected by a proposed City program, policy or activity. 

Minority - A person who is: 

A. African American - A person having origins in any of the black racial groups of Africa;

B. Hispanic- A person of Mexican, Puerto Rican, Cuban, Central or South American, or other Spanish culture or origin, regardless of race;

C. Asian American -A person having origins in any of the original people of the Far East, Southeast Asia, the Indian sub-continent, or the Pacific Islands; or

D. American Indian and Alaskan Native - A person having origins in any of the original people of NorthAmerica and who maintains cultural identification through tribal affiliation or community recognition.

Minority Population - Any readily identifiable groups of minority persons who live in geographic proximity and, if circumstances warrant, geographically dispersed/transient persons (such as migrant workers or Native Americans) who will be similarly affected by a proposed City program, policy or activity.

Non-Compliance - A recipient has failed to meet prescribed requirements and has shown an apparent lack of good faith effort in implementing all the requirements of Title VI and related statues. Persons - Where designation of persons by race, color or national origin is required, the following designation ordinarily may be used; "White not of Hispanic origin", "Black not of Hispanic origin", "Hispanic", "Asian or Pacific Islander", "American Indian or Alaskan Native". Additional sub-categories based on national origin of primary language spoken may be used, where appropriate, on either a national or a regional basis.

Plan – The City of Greer’s description of its Title VI Program developed to comply with Title VI of the Civil Rights Act of 1964.

Program - includes any highway, project, or activity that provides services, financial aid, or other benefits to individuals, including education or training, work opportunities, health, welfare, rehabilitation, housing, or other services, whether provided directly by the recipient of federal financial assistance or provided by others through contracts or other arrangements with the recipient.

Recipient - Any state, territory, possession, the District of Columbia, Puerto Rico, or any political subdivision, or instrumentality thereof, or any public or private agency, institution, or organization, or other entity, or any individual, in any state, territory, possession, the District of Columbia, or Puerto Rico, to whom Federal assistance is extended, either directly or through another recipient, for any program. 

Recipient includes any successor, assignee, or transferee thereof, but does not include any ultimate beneficiary under any such program. 

Significant Adverse effects on Minority and Low-Income Populations - An adverse effect that: 

A. is predominantly borne by a minority population and/or a low-income population, or

B .will be suffered by the minority population and/or low-income population and is shown to be appreciably more severe or greater in magnitude than the adverse effect that will be suffered bythe non-minority population and/or non-low-income population.

Sub-Recipient - Any agency such as a council of governments, regional planning agency, or educational institution, for example, that received Federal Highway Administration (FHWA) funds through the State DOT and not directly from the FHWA. Other agencies, local governments, contractors, consultants that receive these funds are all considered sub-recipients. 

Title VI Coordinator - the person responsible for coordinating the administration of the Title VI and related statutes, programs, plans, and assurances. 

Title VI Program - the system of requirements developed to implement Title VI of the Civil Rights Act of 1964. When appropriate, the phrase “Title VI requirements” also refers to the civil rights provisions of other federal statutes to the extent that they prohibit discrimination on the grounds of race, color or national origin in programs receiving federal financial assistance of the type subject to Title VI itself. 

PROGRAM ADMINISTRATION 

Organization and Staffing 

The City of Greer’s Title VI Plan is administered by the Human Resource Director under the direct supervision of the Assistant City Administrator. In order to ensure uniform implementation of the plan across all Departments and Programs, the City has established a Title VI Committee consisting of a Title VI Coordinator and other Title VI “Designees”. The Title VI Coordinator, on behalf of the Assistant City Administrator, shall have lead responsibility for coordinating the administration of the Title VI and related statutes, programs, plans, and assurances. The Title VI Coordinator may assign other personnel as Designee with responsibilities in designated program areas. The Department Director of each Department of the City shall serve as that Department’s Title VI Designee and shall ensure that all Federally assisted programs are administered in compliance with all requirements imposed by, or pursuant to, civil rights acts and regulations. Departmental Grant Administrators (if other than those individuals specified above) shall also serve on the Title VI Committee for the duration of the grant program which they are administering.

Title VI Coordinator Responsibilities

The Coordinator is charged with the responsibility for implementing, monitoring and ensuring the City’s compliance with Title VI Regulations. Title VI responsibilities are as follows: 

  1. In coordination with the City’s Title VI Committee, prepare an annual report of City Title VI accomplishments and upcoming goals including an annual update to the Title VI Program Plan that reflects organizational, policy and implementation changes.

  2. Conduct Title VI compliance reviews of department program area activities, consultations, contractors, suppliers, planning agencies, and other sub-recipients of federal financial assistance.

  3. Collect statistical data (race, color, or national origin) on the City’s relevant boards, commissions, and committees, and participants in and beneficiaries of the City’s programs, activities, and services.

  4. Review pre-grant and post-grant awards for compliance with Title VI requirements.

  5. Coordinate the development and implementation of a training program and conduct training programs on Title VI and other related statutes for City employees and recipients of federal grant funds.

  6. Process and maintain log of Title VI complaints.

  7. Ensure that Title VI requirements are included in policy directives and that the procedures used have built-in safeguards to prevent discrimination.

  8. Assist program personnel to correct Title VI problems or discriminatory practices or policies found when conducting self-monitoring and compliance review activities.

  9. Manage the City’s Limited English Proficiency (LEP) Program ensuring that City information and services are accessible to customers. Develop Title VI information for public dissemination, where appropriate, in languages other than English.

Data Collection/Reporting/Analysis 

Statistical data on race, color, national origin and sex of participants in, and beneficiaries of federally funded programs, (e.g., impacted citizens and affected communities), will be gathered and maintained by t h e Coordinator and Department Directors. The data gathering process will be reviewed regularly to ensure sufficiency of the data in meeting the requirements of the Title VI program administration relative to:

  1. The manner in which services are or will be provided by the program in question, and a determination of whether any persons are or will be denied services on the basis of prohibited discrimination;

  2. The population eligible to be served by race, color and national origin;

  3. Covered employment, including the use or planned use of bilingual public-contact employees where necessary to permit effective participation by LEP persons;

  4. The location of existing or proposed facilities connected with the program, and information adequate for determining whether the location will result in discrimination on a prohibited basis;

  5. The present or proposed membership, by race, color and national origin, in any planning or advisory body which is an integral part of the program;

  6. Where relocation is involved, the requirements and steps used or proposed to guard against unnecessary impact on persons on the basis of race, color or national origin.

Training 

The Coordinator will seek all opportunities to participate in education and training. Title VI training will be made available to Title VI Committee members, employees, contractors, subrecipients, and program planning area liaisons. The training will provide comprehensive information on Title VI provisions, application to program operations, identification of Title VI issues, resolution of complaints, as well as any updates and changes. A summary of the training conducted will be reported in the annual report. 

DISCRIMINATION COMPLAINT PROCEDURES

Introduction 

These procedures apply to complaints filed under Title VI of the Civil Rights Act of 1964, relating to any program and/or activity administered by City of Greer or its sub-recipients, consultants, and/or contractors. Intimidation or retaliation of any kind is prohibited by law. These procedures do not deny the right of the complainant to file formal complaints with other State or Federal agencies, or to seek private counsel for complaints alleging discrimination. These procedures are part of an administrative process that does not provide for remedies that include punitive damages or compensatory remuneration for the complainant. Every effort will be made to obtain early resolution of complaints at the lowest possible level. The option of informal mediation meeting(s) between the affected parties and the investigator may be utilized for resolution, at any stage of the process. The City of Greer will make every effort to pursue a resolution of the complaint. Initial interviews with the complainant and the respondent will include requests for information regarding specific relief and settlement options.

Filing

Any person who believes that he, she, or any specific class of persons has been subjected to discrimination or retaliation prohibited by Civil Rights authorities, based upon race, color or national origin, or disability may file a written complain to Greer’s Title VI Coordinator. A formal complaint must be filed within 180 calendar days of the alleged occurrence or when the alleged discrimination became known to the complainant. The Title VI Complaint Form may be found in Appendix D or on the City’s website at www.cityofgreer.org. The complaint must meet the following requirements: 

  • Complaints must be in writing and signed by the complainant(s).

  • Complaints must include the name, address, and telephone number of each complainant.

  • Complaints must include the date of the alleged act(s) of discrimination (date when the complainant(s) became aware of the alleged discrimination; or the date on which the conduct was discontinued or the latest instance of the conduct).

  • Complaints must present a detailed description of the issues, including names, job titles, and addresses of those individuals perceived as parties in the action complained against.

  • The allegation(s) must involve a covered basis such as race, color or national origin.

You can also file a civil rights complaint with the: U.S. Department of Homeland Security Office for Civil Rights and Civil Liberties (CRCL): 

E-mail: CRCLCompliance@hg.dhs.gov (fastest method to submit your complaint) 

Fax: 202-401-4708 or via U.S. Mail: 

U.S. Department of Homeland Security 

Office for Civil Rights and Civil Liberties 

Compliance Branch, Mail Stop #0190 

2707 Martin Luther King, Jr. Ave., SE Washington, D.C. 20528 

For additional information: www.dhs.gov/crcl Phone: 202-401-1474 Toll-Free: 1-866-644-8360 

Limited English Proficiency Accommodations 

If you need these services, please contact:awilliamson@cityofgreer.org 

The City of Greer: 

 Can provide free aids and services, such as written information in other written formats (large print, audio, I-Speak Cards, etc.), to communicate effectively with persons with disabilities. 

 Can provide free language services, such as contracted telephonic service qualified foreign language interpreters, and information written in other languages, to ensure meaningful access to programs and activities for persons with limited English proficiency. 

Disability Accommodations 

The City of Greer’s nondiscrimination policy used to ensure nondiscrimination and equal opportunity for persons with disabilities. The City of Greer’s reasonable modification procedures to participate in and benefit from programs and services are described below. 

  • The City of Greer may contact you to obtain more information about your request and to better understand your needs. 

  • The City of Greer will review your request to determine whether the requested accommodation will be effective in allowing you to participate in the activity or program in which you are seeking participation. 

  • The City of Greer will assess whether the requested accommodation is reasonable, or an equally effective alternative to the requested accommodation is available. 

    The City of Greer will determine if providing you with the requested accommodation would fundamentally alter the nature of our programs or impose undue financial or administrative burdens on the City of Greer. 

If you need a reasonable accommodation, please contact the ADA Coordinator: Email: ada@cityofgreer.org. 

Receipt and Acceptance 

Upon receipt of the complaint, the Title VI Coordinator will determine its jurisdiction and any need for additional information. The complaint will be forwarded to the City’s Title VI Committee for a determination of acceptability. The Title VI Coordinator will notify the complainant, in writing, within ten (10) business days of receipt of the complaint.The City of Greer will assume responsibility for investigating complaints against any of its subrecipients. Complaints in which The City of Greer is named as the Respondent shall be forwarded to the appropriate Federal agency for proper disposition, in accordance with their procedures. 

Dismissal 

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

  1. The complainant requests withdrawal of the complaint.

  2. The complainant fails to respond to three requests for additional information needed to process the complaint.

  3. The complainant cannot be located after reasonable attempts.

Investigation of Complaints 

In cases where the City of Greer assumes responsibility for investigation, the City will provide the respondent with the opportunity to respond to the allegations in writing. The City’s Title VI Committee will be responsible for investigating and evaluating the complaint, developing an investigative plan, conducting interviews, collecting and analyzing evidence, and preparing an investigative report. The Committee’s final investigative report will be submitted to the City Administrator within 60 days of completion of the investigation. The City Administrator will issue a final agency decision and provide written notification of the decision to the complainant and respondent. If a Title VI violation is found to exist, remedial steps as appropriate and necessary will be taken immediately. The Complainant will also receive a copy of the final report together with any remedial steps. Appeals If the City Administrator concludes that the respondent is in compliance with laws/regulations and the complainant disagrees, the complainant may, if dissatisfied, file an action in the appropriate U.S. District Court.

Complaints shall be submitted to:

City of Greer

Attention: Title VI Coordinator

301 E. Poinsett Street Greer, SC 29651

864-848-2174

awilliamson@cityofgreer.org 

PUBLIC DISSEMINATION

The goal of the City’s communications and public participation program is to ensure early and continuous public notification about, and participation in, major actions and decisions by The City of Greer. In seeking public comment and review, the City shall make a concerted effort to reach all segments of the population, including people from minority and low-income communities, and organizations representing these and other protected classes.

The Coordinator will ensure that Title VI Program information is disseminated to City employees, sub-recipients, contractors, and beneficiaries as well as the general public. Public dissemination will include the posting of public statements, inclusion of Title VI language in contracts (see Standard USDOT Title VI Assurances), and publishing the Title VI Policy Statement and announcements of hearings and meetings in newspapers having a general circulation and at locations in the vicinity of proposed projects.

The City’s Title VI Policy Statement, Title VI Plan, Complaint Procedures, Complaint Form, and Limited English Proficiency Plan (LEP) are available on the City’s website: www.cityofgreer.org, at the City Administrator’s office, and can be mailed out upon request. 

LIMITED ENGLISH PROFICIENCY (LEP)

On August 11, 2000, President William J. Clinton signed an executive order, Executive Order 13166: Improving Access to Service for Persons with Limited English Proficiency, to clarify Title VI of the Civil Rights Act of 1964. It had as its purpose, to ensure accessibility to programs and services to otherwise eligible persons who are not proficient in the English language. This executive order stated that individuals who do not speak English well and who have a limited ability to read, write and speak, or understand English are entitled to language assistance under Title VI of the Civil Rights Act of 1964 with respect to a particular type of service, benefit, or encounter. These individuals are referred to as being limited in their ability to speak, read, write, or understand English, hence the designation, "LEP," or Limited English Proficient. The Executive Order states that: 

"Each federal agency shall prepare a plan to improve access to its federally conducted programs and activities by eligible LEP persons. Each plan shall be consistent with the standards set forth in the LEP Guidance and shall include the steps the agency will take to ensure that eligible LEP persons can meaningfully access the agency's programs and activities." 

Per the American Community Survey, a U.S. Census program survey done in 2022, the number of LEP individuals eligible or likely to be served within the jurisdiction of the City of Greer is recorded as 13%. The top language spoken other than English is Spanish. 

The City of Greer meets requirements to take reasonable steps to provide meaningful access to our programs and services through our language access plan. 

Methods to provide language assistance: 

  • Written materials in languages other than English (including I-Speak Cards) 

  • Use of language applications on smart phones. 

  • Agency staff to assist in arranging for oral interpretation of LEP via a contracted service. 

  • The State of South Carolina provides interpretation services for the Police Department and Court upon request. 

  • Notification to LEP persons of the availability of free language service is provided when LEP persons request services through the process described in the non-discrimination policy statement. 

For more information regarding the City’s policies on LEP, a copy of the LEP plan can be found on its website at www.cityofgreer.org or a copy can be requested from: 

Attention: Title VI Coordinator 

City of Greer 

301 E. Poinsett Street Greer, SC 29651 

864-848-2174 

awilliamson@cityofgreer.org 

ENVIRONMENTAL JUSTICE

Compliance with Title VI includes ensuring that no minority or low-income population suffers "disproportionately high and adverse human health or environmental effect" due to any "programs, policies and activities" undertaken by any agency receiving federal funds. This obligation will be met by the City in the following ways: 

  • When planning specific programs or projects, identifying those populations that will be affected by a given program or project.

  • If a disproportionate effect is anticipated, following mitigation procedures.

  • If mitigation options do not sufficiently eliminate the disproportionate effect, discussing and, if necessary, implementing reasonable alternatives.

Disproportionate effects are those effects which are appreciably more severe for one group or predominantly borne by a single group. The City will use U.S. Census data to identify low income and minority populations.

Where a project impacts a small number or area of low income or minority populations, the City will document that: 

  • Other reasonable alternatives were evaluated and were eliminated for reasons such as the alternatives impacted a far greater number of people or did greater harm to the environment; etc.

  • The project's impact is unavoidable.

  • The benefits of the project far out-weigh the overall impacts; and

  • Mitigation measures are being taken to reduce the harm to low income or minority populations.

If it is concluded that no minority and/or low-income population groups are present in the project area, the City will document how the conclusion was reached. If it is determined that one or more of these population groups are present in the area, the City will administer potential disproportionate effects test. The following steps will be taken to assess the impact of projects on minority and/or low-income population groups:

STEP ONE: Determine if a minority or low-income population is present within the project area. If the conclusion is that no minority and/or low-income population is present within the project area, document how the conclusion was reached. If the conclusion is that there are minority population and/or low-income population groups present, proceed to Step Two.

STEP TWO: Determine whether project impacts associated with the identified low income and minority populations are disproportionately high and adverse. If it is determined that there are is proportionately high and adverse impacts to minority and low-income populations, proceed to Step Three.

STEP THREE: Propose measures that will avoid, minimize and/or mitigate disproportionately high and disproportionate adverse impacts and provide offsetting benefits and opportunities to enhance communities, neighborhoods and individuals affected by proposed project. 

STEP FOUR: If after mitigation, enhancements and off-setting benefits to the affected populations, there remains a high and disproportionate adverse impact to minority, or low-income populations, then the following questions must be considered: 

Question 1: Are there further mitigation measures that could be employed to avoid or reduce the adverse effect to the minority or low-income population? 

Question 2: Are there other additional alternatives to the proposed action that would avoid or reduce the impacts to the low income or minority populations? 

Question 3: Considering the overall public interest, is there a substantial need for the project? 

Question 4: Will the alternatives that would satisfy the need for the project and have less impact on protected populations (a) have other social, economic or environmental impacts that are more severe than those of the proposed action (b) have increased costs of extraordinary magnitude? 

STEP FIVE: Include all findings, determinations or demonstrations in the environmental document prepared for the project. 

REMEDIAL ACTION

The City, through the Title VI Coordinator, will actively pursue the prevention of Title VI deficiencies and violations and will take the necessary steps to ensure compliance with all program administrative requirements. When deficiencies are found, procedures will be promptly implemented to correct the deficiencies and to put in writing the corrective action(s). The period to determine corrective action(s) and put it/them in writing to effect compliance may not exceed 90 days from the date the deficiencies are found. 

ANNUAL REPORT

An annual report will be submitted to the City Administrator by the Coordinator. The summary will overview Title VI accomplishments achieved during the year, include the Title VI complaint log, and will also include goals and objectives for the upcoming year where applicable. The Coordinator will meet with the Title VI Planning Committee to review the annual report. 

PUBLIC PARTICIPATION PLAN

GOALS

Promoting Inclusive Public Participation 

The City of Greer strives to promote inclusive public participation in all of its efforts. The agency believes firmly that consistent communication with Greer residents, businesses, and visitors is key to the success of the City of Greer’s planning and project development efforts. To that end, The City of Greer has developed three goals for public participation: 

  1. Increase awareness of transportation projects and the public’s involvement in planning and implementation.

  2. Foster greater partnerships with local public agencies, social service organizations, and other community groups.

  3. Engage minority, low-income, and limited-English-proficiency populations to improve communication with traditionally underserved groups.

Current and Future Strategies

Digital Outreach

Via digital communication, the City of Greer’s website at www.cityofgreer.org has continued to be the best resource for information. City staff update the website consistently, ensuring that members of the public can rely on it as an accurate source of information.

To ensure further consistent dissemination of information, The City of Greer has executed request for proposals (for Web Services Providers) to continue its commitment by updating the website for an improved user experience.

The City of Greer also utilizes social media to communicate with the public. Currently, Facebook (@GreerSouthCarolina) and Instagram (@cityofgreer).

Exploring and Implementing Virtual Workshops and Partnerships With Other Agencies

For applicable projects, the appropriate workshops and partnerships with other agencies will be established for the purpose of compliance and community involvement based on the nature of the project. Partnerships may include but are not limited to county, state, federal, and tribal governments, transit providers, non-profit organizations, and community groups. The intention would be to utilize this network of partner agencies to reach members of the public who may be interested in a transportation project but may not know about the City of Greer’s role or receive the City’s other communication.

These partner agencies, especially social service organizations, will be particularly helpful in involving minority, low-income, limited-English-proficiency, and other traditionally underserved communities in The City of Greer’s plans and projects.

For more information regarding the City’s public participation initiatives, please contact: 

City of Greer

Attention: Title VI Coordinator

301 E. Poinsett Street Greer, SC 29651

864-848-2174

awilliamson@cityofgreer.org