HomeMy WebLinkAbout5.5 Adoption of the City of Dublin Title VI Program
STAFF REPORT
CITY COUNCIL
Page 1 of 2
Agenda Item 5.5
DATE: September 16, 2025
TO: Honorable Mayor and City Councilmembers
FROM: Colleen Tribby, City Manager
SUBJECT:
Adoption of the City of Dublin Title VI Program
Prepared by: Sarah Monnastes, Human Resources Director
EXECUTIVE SUMMARY:
The City Council will consider adopting the City of Dublin Title VI Program in accordance with a
statue provision of the Civil Rights Act of 1964 that prohibits discrimination in any program or
activity receiving federal financial assistance. The Title VI Program ensures compliance
through a public notice of rights, complaint procedures, designation of a Title VI Coordinator,
and ongoing reporting to the California Department of Transportation, which is responsible for
distributing Federal Highway Administration funds to local agencies.
STAFF RECOMMENDATION:
Adopt the Resolution Adopting the City of Dublin Title VI Program.
FINANCIAL IMPACT:
There is no direct financial impact associated with adopting the Title VI Program. Compliance
with Title VI is a condition of receiving federal funding.
DESCRIPTION:
Background
Title VI of the Civil Rights Act of 1964, signed into law by President Lyndon B. John son,
prohibits discrimination on the basis of race, color, national origin, sex, disability, or age in any
program or activity receiving federal financial assistance. To ensure that federal dollars do not
subsidize discrimination, federal agencies were directed to establish enforcement regulations.
Because the Federal Highway Administration (FHWA) distributes funding through the
California Department of Transportation (Caltrans), local public agencies that receive federal -
aid highway funds must comply with Title VI as a condition of funding. Caltrans, acting as
FHWA’s designated recipient, is responsible for reviewing and monitoring the Title VI
Programs of subrecipients, including cities and counties.
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Accordingly, local agencies are required to adopt and maintain a Title VI Program that meets
both federal and Caltrans standards. A compliant program includes a public notice of rights,
complaint procedures for individuals who believe they have been subjected to discrimination,
the designation of a Title VI Coordinator, and ongoing compliance reporting to Caltrans for
review and approval.
City of Dublin Title VI Program
The City’s Title VI Program affirms the City’s commitment to equity and nondiscrimination in
the delivery of services. Adoption of the Program ensures the City remains eligible to receive
federal funds and aligns with best practices for transparency and accountability.
The Program designates the Human Resources Director as the City’s Title VI Coordinator,
responsible for implementing the Program, monitoring compliance, and reporting to the City
Manager and federal agencies, as required.
Next Steps
Upon adoption, the Program will be submitted to the appropriate oversight agencies and
posted on the City’s website and at customer service counters, ensuring residents, program
participants, and employees have clear access to their rights and responsibilities under Title
VI.
STRATEGIC PLAN INITIATIVE:
None.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
The City Council Agenda was posted.
ATTACHMENTS:
1) Resolution Adopting the City of Dublin Title VI Program
2) Exhibit A to the Resolution – City of Dublin Title VI Program
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Attachment 1
Reso. No. XX-25, Item X.X, Adopted 09/16/2025 Page 1 of 2
RESOLUTION NO. XX – 25
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
ADOPTING THE CITY OF DUBLIN TITLE VI PROGRAM
WHEREAS, Title VI of the Civil Rights Act of 1964 provides that no person in the United
States shall, on the grounds of race, color, national origin, sex, disability, or age in any program
or activity receiving federal financial assistance; and
WHEREAS, the Federal Highway Administration (FHWA) distributes federal-aid highway
funds through the California Department of Transportation (Caltrans), which requires local public
agencies to establish and maintain a Title VI Program as a condition of receiving such f unds; and
WHEREAS, as the City of Dublin is a recipient of federal-aid highway funds through
Caltrans and is therefore required to adopt and maintain a Title VI Program to ensure compliance
with federal law; and
WHEREAS, the City of Dublin’s Title VI Program provides for a public notice of rights,
complaint procedures, designation of a Title VI Coordinator, and compliance reporting to Caltrans,
thereby ensuring equitable access to services, programs and activities funded with federal
assistance; and
WHEREAS, adoption of the City of Dublin Title VI Program affirms the City’s commitment
to equity, nondiscrimination, and transparency in the delivery of public services and maintains
eligibility for federal funding.
WHEREAS, the City Council of the City of Dublin has reviewed the proposed Title VI
Program and finds it consistent with federal requirements.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Dublin does
hereby adopt the City of Dublin Title VI Program, attached hereto as Exhibit A.
BE IT FURTHER RESOLVED that the City Manager, or designee, is authorized to submit
the Title VI Program to the appropriate federal and state agencies as required by law .
BE IT FURTHER RESOLVED that the City Manager, or designee, is authorized to make
any non-substantive changes required by law or by Caltrans as part of its oversight
responsibilities.
{Signatures on the next page}
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Reso. No. XX-25, Item X.X, Adopted XX/XX/2025 Page 2 of 2
PASSED, APPROVED AND ADOPTED this 16th day of September 2025, by the following
vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
______________________________
Mayor
ATTEST:
_________________________________
City Clerk
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Attachment 2
Exhibit A to the Resolution – City of Dublin Title VI Program
City of Dublin
TITLE VI PROGRAM
September 16, 2025
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Table of Contents
I. Non-Discrimination Policy Statement .................................................................................................. 3
II. Organization, Staffing, and Structure ................................................................................................... 4
III. Notice of Rights ............................................................................................................................... 4
IV. Non-Discrimination Authorities ...................................................................................................... 4
V. Title VI Complaint Procedures ........................................................................................................ 5
VI. Public Participation ......................................................................................................................... 6
VII. Data Collection ................................................................................................................................ 7
VIII. Training ........................................................................................................................................... 7
IX. Reporting Requirements ................................................................................................................. 7
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I. Non-Discrimination Policy Statement
It is the policy of the City of Dublin that no person shall on the grounds of race, color, national origin,
sex, disability, or age, be excluded from participation in, be denied the benefits of, or be subjected to
discrimination in any operation of the City of Dublin as provided by Title VI of the Civil Rights Act of
1964 and related statutes.
This policy applies to all operations of the City of Dublin, including its contractors and anyone who acts
on behalf of the City. This policy also applies to the operations of any department or agency to which
the City extends federal financial assistance. Federal financial assistance includes grants, training, use
of equipment, donations of surplus property, and other assistance.
Prohibited discrimination may be intentional or unintentional. Seemingly neutral acts that have
disparate impacts on individuals of a protected group and lack a substantial legitimate justification are
a form of prohibited discrimination. Harassment and retaliation are also prohibited forms of
discrimination.
Examples of prohibited types of discrimination based on race, color, national origin, sex, disability, or
age include: Denial to an individual any service, financial aid, or other benefit; Distinctions in the
quality, quantity, or manner in which a benefit is provided; Segregation or separate treatment;
Restriction in the enjoyment of any advantages, privileges, or other benefits provided; Discrimination
in any activities related to highway and infrastructure or facility built or repaired; and Discrimination in
employment.
Title VI compliance is a condition of receipt of federal funds. The Title VI Coordinator is authorized to
ensure compliance with this policy, Title VI of the Civil Rights Act of 1964, 42 U.S.C § 2000d and related
statutes, and the requirements of 23 Code of Federal Regulation (CFR) pt. 200 and 49 CFR pt. 21.
Colleen Tribby, City Manager Date
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II. Organization, Staffing, and Structure
The City Manager is ultimately responsible for assuring full compliance with the provisions of Title VI of
the Civil Rights Act of 1964 and related statutes and has directed that non-discrimination is required of
all City employees, contractors, and agents pursuant to 23 CFR Part 200 and 49 CFR Part 21.
The Human Resources Director/Risk Manager has been appointed by the City Manager to serve as the
Title VI Coordinator. The Title VI Coordinator provides guidance and technical assistance on Title VI
matters and has overall program responsibility for preparing reports and developing program
procedures.
The Title VI Coordinator is responsible for:
• Submitting a Title VI plan and required annual reports on the agency’s behalf;
• Developing procedures for the prompt processing and disposition of complaints;
• Investigating complaints, compiling a complaint log, and reporting to the California Department
of Transportation (Caltrans);
• Developing procedures for the collection and analysis of statistical data;
• Developing a program to conduct Title VI reviews of program areas;
• Conducting annual Title VI assessments of pertinent program areas;
• Developing Title VI information for dissemination; and
• Establishing procedures for resolving deficiency status and reducing to writing the remedial
action agreed to be necessary.
The Public Works Director oversees implementation of the City’s Title VI program as it relates to
consultants and contractors and ensures that Title VI Assurances are included in all sub-contracts with
federal funds – specifically including Appendix A of the Title VI Assurances in the “MASTER
AGREEMENT - ADMINISTERING AGENCY-STATE AGREEMENT FOR FEDERAL-AID PROJECTS”.
III. Notice of Rights
The City will display the “Notice of Rights” (Exhibit A) for public view at customer service counters in
various City facilities, field locations and on the City’s website. The notice states that the City is
committed to complying with Title VI and ensuring that no person is excluded from participating in, be
denied the benefits of or be otherwise subjected to discrimination under any of the City’s programs,
activities, or services.
IV. Non-Discrimination Authorities
Title VI, 42 U.S.C. § 2000d (race, color, and national origin)
23 U.S.C. § 324 (sex)
42 U.S.C. § 6101 (age)
42 U.S.C. § 12131; 29 U.S.C. § 794 (disability)
49 CFR Part 21
23 CFR Part 200
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V. Title VI Complaint Procedures
Federal law prohibits discrimination on the basis of race, color, national origin, age, sex, or disability in
any City of Dublin program or activity. This prohibition applies to all branches of City of Dublin, its
contractors, consultants, and anyone else who acts on behalf of the City of Dublin.
Any person who believes they have been subject to discrimination within the City’s programs or
activities because of their race, color, national origin, or other protected status may file a Title VI
complaint by completing and submitting the City’s Title VI Complaint Form with the Title VI Coordinator
within 180 days of the alleged incident. The City’s Title VI Complaint Form is available through Human
Resources at 100 Civic Plaza, Dublin, CA and online at www.dublin.ca.gov.
The City’s Title VI Coordinator will only process complaints that are complete and include the following
information:
• Complainant’s contact information
• Date(s) of alleged discriminatory act(s)
• Details of alleged discrimination
• Identification of the City Department responsible for the alleged discrimination
• Basis of the complaint (e.g. race, color, or national origin)
• Signature of the complainant or complainant’s representative
Once the Title VI complaint is received, the Title VI Coordinator will forward the complaint to Caltrans,
to be submitted to the FHWA Division Office. The Title VI Coordinator will also begin processing the
complaint by entering said complaint into the City’s Title VI Discrimination Complaint Log and
conducting an internal investigation. Once a finding has been determined/received, the City’s Title VI
Coordinator will provide said findings to the complainant within 10 business days via letter and/or
email.
Complaints Processed Under the Federal Highway Administration (FHWA):
Title VI complaints filed with Caltrans in which Caltrans is named as the Respondent will be forwarded
to the FHWA Division Office. The Complainant will receive an acknowledgement letter informing them
that the complaint has been received and forwarded to the FHWA.
Per the FHWA Guidance Memorandum, Processing of Title VI Complaints, dated June 13, 2018, all Title
VI complaints received by a sub-recipient (City of Dublin) are to be forwarded to Caltrans to be
submitted to FHWA Division Office. Complaints should be sent within one business day of receipt via
email to Title.VI@dot.ca.gov. If Caltrans Office of Civil Rights (HCR) determines a Title VI complaint
against a sub-recipient can be investigated by Caltrans, HCR may delegate the task of investigating the
complaint to Caltrans.
OCR Investigation Process:
If OCR is delegated the responsibility of performing an investigation, OCR has 90 days to investigate the
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complaint. If additional time is needed, OCR will call the Complainant and inform them.
If more information is needed to resolve the case, the OCR investigator may contact the Complainant.
The Complainant has ten 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 ten business days, OCR can administratively close the case. A case can be administratively closed
also if the complainant no longer wishes to pursue their case.
OCR will consult with HCR regarding the disposition of the complaint. Disposition of Title VI complaints
will be undertaken by HCR, through either (1) informal resolution or (2) issuance of a Letter of Finding.
A copy of the Letter of Finding will be sent to all parties via the Division Office.
A person may also file a complaint directly with the FHWA and/or Caltrans by the following contact
information:
Federal Highway Administration
U.S. Department of Transportation Office of Civil Rights
1200 New Jersey Avenue, SE 8th Floor E81-105
Washington, DC 20590
California Department of Transportation
Office of Civil Rights
Attention: Title VI Branch
PO Box 942874, MS 79, Sacramento, CA
Title.VI@dot.ca.gov
Should a complaint be filed with the City of Dublin and one with a federal or state agency
simultaneously, the federal/state complaint will supersede the City’s complaint and the City’s
complaint procedures will be suspended pending the federal/state agency’s findings.
VI. Public Participation
The City of Dublin is committed to engaging residents, businesses, and stakeholders in an inclusive and
transparent manner. Public participation ensures that City projects, programs, and services are
delivered equitably and are responsive to the diverse nee ds of the community.
The City will:
• Provide opportunities for public input at City Council and Commission meetings, workshops,
and community forums.
• Use a variety of outreach methods, including the City website, social media, newsletters, and
postings in public facilities, to share information broadly.
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• Offer translation or interpretation services, as needed, to ensure meaningful access for
individuals with limited English proficiency.
• Make outreach materials available in alternative formats upon request to ensure accessibility
for persons with disabilities.
• Document and consider public feedback in the planning, design, and implementation of City
programs and services.
Through these efforts, the City seeks to ensure that all voices are heard and considered, particularly
those from underrepresented or historically disadvantaged groups.
VII. Data Collection
The City will review and analyze data collected regularly to ensure the effectiveness of outreach
methods in meeting the objectives of the Title VI program and to ensure that no group is intentionally
excluded in the decision-making process or is not given the opportunity to voice their opinions or
concerns. Sources of demographic information may include data collected by City staff and/or federal,
state and local government agencies such as the U.S. Bureau of Labor Statistics, U.S. Census Bureau,
U.S. Bureau of Economic Analysis, California Department of Finance, California Department of Labor,
the California Employment Development Department, the Association of Bay Area Governments, or
the Metropolitan Transportation Commission.
VIII. Training
Title VI training will be provided to managers, supervisors, and staff with frequent public contact in the
administration of federal-aid programs every two years. Trainings may be offered online or through an
instructor-led class. The following components will be covered:
• Review of City’s Title VI Policy
• How to handle a potential complaint
• Where to seek assistance for Title VI questions and concerns
IX. Reporting Requirements
The City of Dublin will comply with all reporting requirements established by federal funding agencies
in connection with Title VI of the Civil Rights Act of 1964. The City will submit Title VI reports, updates,
or accomplishment and goal reports when directed by a federal or state funding agency as a condition
of funding. Title VI compliance documentation will be made available upon request.
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Exhibit A
Your Rights Under Title VI of the Civil Rights Act of 1964
Title VI of the Civil Rights Act of 1964 requires that no person in the United States, on the grounds of
race, color or national origin be excluded from, be denied the benefits of, or be subjected to
discrimination, under any program or activity receiving federal financial assistance.
Any person who believes they have been subjected to discrimination may file a written complaint with
the City of Dublin. Federal and State law require complaints to be filed within one hundred eighty (180)
calendar days of the last alleged incident. Additional information and the Title VI Complaint Forms can
be found on the City’s Website at www.dublin.ca.gov or can be obtained by contacting the Title VI
Coordinator at (925) 833-6650 or hr@dublin.ca.gov.
The complaint procedure and form can also be obtained by writing to the Title VI Coordinator.
To file a written Title VI complaint, please use the following information:
City of Dublin – Human Resources/Risk Manager
Title VI Coordinator
100 Civic Plaza, 2nd Floor
Dublin, CA 94568
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Appendix A
Master Agreement Administering Agency-State Agreement for
Federal Aid Projects & Title VI Assurances
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