Title VI Program
SOUTH CENTRAL INDUSTRIES
Title VI Program
Date filed with ODOT Office of Mobility and Public Transit Programs:
Updated 2/5/2026
Table of Contents
D. Procedure for Filing a Title VI Complaint 5
F. Public Participation Plan 8
G. Language Assistance Plan 11
K. Equity Analysis of Facilities 18
L. System-Wide Service Standards and Policies 21
Attachment 1 – Agency Information a
Attachment 2 – Title VI Complaint Form b
- Introduction
South Central Industries agrees to comply with all provisions prohibiting discrimination on the basis of race, color, or national origin of Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. 200d et seq., and with U.S. DOT regulations, “Nondiscrimination in Federally-Assisted Programs of the Department of Transportation – Effectuation of Title VI of the Civil Rights Act,” 49 CFR part 21.
South Central Industries assures that no person shall, as provided by Federal and State civil rights laws, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity. South Central Industries further ensures every effort will be made to ensure non-discrimination in all programs and activities, whether those programs and activities are federally funded or not.
South Central Industries meets the objectives of the FTA Master Agreement which governs all entities applying for FTA funding, including South Central Industries and its third-party contractors by promoting actions that:
- Ensure that the level and quality of transportation service is provided without regard to race, color, or national origin.
- Identify and address, as appropriate, disproportionally high and adverse effects of programs and activities on minority populations and low-income populations.
- Promote the full and fair participation of all affected Title VI populations in transportation decision making.
- Prevent the denial, reduction, or delay in benefits related to programs and activities that benefit minority populations or low-income populations.
- Ensure meaningful access to programs and activities by persons with Limited English Proficiency (LEP).
- Agency Information
- Mission of TRANSIT AGENCY
| South Central is dedicated to providing superior quality vocational rehabilitation training and employment in the community, residential service to people with developmental disabilities and their families. A majority of the mission of this organization is to provide possibilities to these individuals and their families, to be safe, productive, and reach their full potential. Specifically, it is this organization’s mission to offer a wide range of daily living skills, socialization, vocational, recreational, community involvement and self-advocacy. |
- History (including year started)Regional Profile (regional population; growth projection)Population served (in relation to regional population)
| South Central Industries began in 1981 as South Central Sheltered Workshop. In 1996, the name change was made to be more politically correct. South Central currently serves close to 40 adults with IDD, providing housing, jobs and as of 2005, transportation. |
- Service area (include map, with any routes utilized)
| South Central does not have specific routes or an area map. South Central is not public transportation and transports our Peeps (People Experiencing Exceptional Purpose)to meet their needs. |
- Governing body make-up (include terms of office)
| South Central Industries has a board of 10 local professionals. The Board meets every third Friday of the month. |
- Notice to the Public
| NOTIFYING the PUBLIC of RIGHTS UNDER TITLE VI(NAME OF TRANSIT AGENCY)The South Central Industries operates its programs without regard to race, color, and national origin in accordance with Title VI of the Civil Rights Act. Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with (South Central Industries).For more information on the South Central Industries civil rights program, and procedures to file a complaint, contact (405-275-2851); email (irina@southcentralind.com); or visit our administrative office at (204 N. Louisa Ave. Shawnee, OK 74801)A complainant may file a complaint directly with the Oklahoma Department of Transportation by filing a complaint with the Contract Compliance Division, Attention: Contract Compliance Division Manager, 200 NE 21st Street, Oklahoma City, OK 73105-3204. |
*LIST OF LOCATIONS
– This is where you tell us all the locations where the Title VI notice is posted.
Title VI notices are posted in each of the 5310 vehicles, in the hall of our Administration Offices, in our group homes and in our workshop hall.
- Procedure for Filing a Title VI Complaint
Filing a Title VI Complaint
The complaint procedures apply to the beneficiaries of South Central Industries programs, activities, and services.
RIGHT TO FILE A COMPLAINT: Any person who believes they have been discriminated against on the basis of race, color, or national origin by South Central Industries may file a Title VI com-plaint by completing and submitting the agency’s [Title VI Complaint Form]. Title VI complaints must be received in writing within 180 days of the alleged discriminatory complaint.
HOW TO FILE A COMPLAINT: Information on how to file a Title VI complaint is posted on our agency’s website, and in public areas of our agency.
You may download the South Central Industries Title VI Complaint Form at http://southcentralindustriesinc.com/, or request a copy by writing to P.O Box 3766 Shawnee Ok 74802. Information on how to file a Title VI complaint may also be obtained by calling South Central Industries at405-275-3851.
You may file a signed, dated complaint no more than 180 days from the date of the alleged incident. The complaint should include:
- Your name, address and telephone number.
- Specific, detailed information (how, why and when) about the alleged act of discrimination.
- Any other relevant information, including the names of any persons, if known, the agency should contact for clarity of the allegations.
Please submit your complaint form to South Central Industries P.O. Box 3766 Shawnee, Ok 74802.
COMPLAINT ACCEPTANCE:South Central Industries will process complaints that are complete.
Once a completed Title VI Complaint Form is received, South Central Industries will review it to determine South Central Industries has jurisdiction. The complainant will receive an acknowledgement letter informing them whether or not the complaint will be investigated by South Central Industries.
INVESTIGATIONS: South Central Industries will generally complete an investigation within 90 days from receipt of a completed complaint form. If more information is needed to resolve the case, Irina Pakhomova, Title VI Coordinator, may contact the complainant. Unless a longer period is specified by Irina Pakhomova , the complainant will have ten (10) days from the date of the letter to send requested information to South Central Industries investigator assigned to the case.
If the requested information is not received within that timeframe the case will be closed. Also, a case can be administratively closed if the complainant no longer wishes to pursue the case.
LETTERS OF CLOSURE OR FINDING: After the Title VI investigator reviews the complaint, the Title VI investigator will issue one of two letters to the complainant: a closure letter or letter of finding (LOF).
- A closure letter summarizes the allegations and states that there was not a Title VI violation and that the case will be closed.
- A Letter of Finding (LOF) summarizes the allegations and provides an explanation of the corrective action taken.
If the complainant disagrees withSouth Central Industries determination, the complainant may request reconsideration by submitting the request in writing to the Title VI investigator within seven (7) days after the date of the letter of closure or letter of finding, stating with specificity the basis for the reconsideration.South Central Industries will notify the complainant of the decision either to accept or reject the request for reconsideration within ten (10) days. In cases where reconsideration is granted,South Central Industries will issue a determination letter to the complainant upon completion of the reconsideration review.
A person may also file a complaint directly with the Federal Transit Administration, at the FTA Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC 20590.
- Monitoring Title VI Complaints, Investigations, Lawsuits and Documenting Evidence of Agency Staff Title VI Training
Documenting Title VI Complaints/Investigations
All Title VI complaints will be entered and tracked in South Central Industries complaint log. Active investigations will be monitored for timely response on the part of all parties. The agency’s Title VI Coordinator shall maintain the log.
Agency Title VI Complaint Log
| Date complaint filed | Complainant | Basis of complaint R-C-NO | Summary of allegation | Pending status of complaint | Actions taken | Closure Letter (CL) | Letter of Finding (LOF) | Date of CL or LOF |
Documenting Evidence of Agency Staff Title VI Training
South Central Industries staff is given Title VI training, and agency can answer affirmatively to all the following questions:
- Are new employees made aware of Title VI responsibilities pertaining to their specific duties?
- Do new employees receive this information via employee orientation?
- Is Title VI information provided to all employees and program applicants?
- Is Title VI information prominently displayed in the agency and on any program materials distributed, as necessary?
Public Participation Plan
Goal
The goal of the Public Participation Plan is to have significant and ongoing public involvement, by all identified audiences, in the public participation process for major agency outreach efforts.
| ObjectivesTo understand the service area demographics and determine what non-English languages and other cultural barriers exist to public participation.To provide general notification of meetings and forums for public input, in a manner that is understandable to all populations in the area.To hold public meetings in locations that are accessible to all area stakeholders, including but not limited to minority and low income members of the community.To provide methods for two-way communication and information and input from populations which are less likely to attend meetings.To convey the information in various formats to reach all key stakeholder groups. |
Identification of Stakeholders
Stakeholders are those who are either directly or indirectly affected by an outreach effort, system or service plan or recommendations of that plan. Stakeholders include but are not limited to the following:
- Board of Directors – the governing board of the agency. The role of the Board is to establish policy and legislative direction for the agency. The Board defines the agency’s mission, establishes goals, and approves the budget to accomplish the goals.
- Advisory Bodies – non-elected advisory bodies review current and proposed activities of the agency, and are encouraged to be active in the agency’s public participation process. Advisory bodies provide insight and feedback to the agency.
- Agency Transit riders and clients
- Minority and low income populations, including limited English proficient persons
- Local jurisdictions and other government stakeholders
- Private businesses and organizations
- Employers
- Partner agencies
Elements of the Public Participation t Plan
It is necessary to establish a public participation plan that includes an outreach plan to engage minority and limited English proficient (LEP) populations.
Elements of the Public Engagement Plan include:
- Public Notice
- Official notification of intent to provide opportunity for members of the general public to participate in public engagement plan development, including participation in open Board/council meetings, and advisory committees.
- Public Engagement Process/Outreach Efforts:
- Public meetings
- Open houses
- Rider forums
- Rider outreach
- Public hearings
- Focus groups
- Surveys
- Services for the Disabled (Notices of opportunities for public involvement include contact information for people needing these or other special accommodations.)
Events such as public meetings and/or open houses are held at schools, churches, libraries and other non-profit locations easily accessible to public transit and compliant with the Americans with Disabilities Act.
- Public Comment
- Formal public comment periods are used to solicit comments on major public involvement efforts around an agency service or system change.
- Comments are accepted through various means:
- Dedicated email address.
- Website.
- Regular mail.
- Phone calls to Customer Service Center [405-275-2851]
- Response to Public Input
All public comments are provided to the Board of Directors prior to decision making. A publicly available summary report is compiled, including all individual comments.
Title VI Outreach Best Practices
South Central Industries ensures all outreach strategies, communications and public involvement efforts comply with Title VI. South Central Industries Public Participation Plan proactively initiates the public involvement process and makes concerted efforts to involve members of all social, economic, and ethnic groups in the public involvement process. Aligned with the above referenced communication tactics, South Central Industries provides the following:
- Public notices published in non-English publications (if available).
- Title VI non-discrimination notice on agency’s website.
- Agency communication materials in languages other than English (subject to Safe Harbor parameters).
- Services for Limited English Proficient persons. Upon advance notice, translators may be provided.
2022- 2024 Title VI Program Public Participation Process
South Central Industries [has conducted] a Public Participation Process for the 2022-2024 Title VI Program. This process includes Community Meetings to seek input, provide education, and highlight key components of the Title VI Plan. Materials have been created to explain Title VI policies as well as provide education on how they relate to minority populations.
South Central Industries [has provided] briefings to the Board of Directors and Advisory Bodies.
South Central Industries [has conducted] a 30 day public comment period to provide opportunities for feedback on the 2022 – 2024 Title VI Program.
Comments are accepted during the public outreach period via:
- Phone
- In person
Summary of 2022 – 2024 Public Outreach Efforts
- Language Assistance Plan
South Central Industries Limited English Proficiency Plan
This limited English Proficiency (LEP) Plan has been prepared to address South Central Industries responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964; Federal Transit Administration Circular 4702.1B, dated October 1, 2012, which states that the level and quality of transportation service is provided without regard to 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 discriminations do not take place. This order applies to all state and local agencies which receive federal funds.
| Service Area Description: South Central Industries only provides transportation services to our clients with disabilities that live and/or work here. We are not a public transportation service. Our vehicles are used to transport our clients to meet their needs, i.e., doctors appointments, groceries and other services. |
South Central Industries has developed this LEP Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency who wish to access services provided by South Central Industries. 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, and the ways in which assistance may be provided.
In order to prepare this plan, South Central Industries undertook the four-factor LEP analysis which considers the following factors:
Four Factor Analysis
1. The number and proportion of LEP persons eligible to be served or likely to be encountered in the service area:
A significant majority of people in the South Central Industries service area are proficient in the English language. Based on 2010 Census data, [__0_%] of the population five years of age and older speak English “less than very well” – a definition of limited English proficiency
| LEP Population in South Central Industries Service Area | |||||
| Population 5 years and over by language spoken at home and ability to speak English | Service Area Sector [1] | Service Area Sector [1] | Service Area Sector [1] | Service Area Total | Percentage of Population 5 Years and Older |
| Population 5 Years and Over | |||||
| Speak English “less than very well” | |||||
| Spanish | |||||
| Speak English “less than very well” | |||||
| Other Indo-European | |||||
| Speak English “less than very well” | |||||
| Asian and Pacific Island | |||||
| Speak English “less than very well” | |||||
| All Other | |||||
| Speak English “less than very well” | |||||
2. Frequency of Contact by LEP Persons with South Central Industries Services:
The TRANSIT AGENCY staff reviewed the frequency with which office staff, dispatchers and drivers have, or could have, contact with LEP persons. To date, South Central Industries has, on average, 0 reasons for an interpreter. South Central Industries averages [__0_] phone calls per month.
| LEP Staff Survey FormSouth Central Industries is studying the language assistance needs of its riders so that we can better communicate with them if needed.How often do you come into contact with passengers who do not speak English or have trouble understanding you when you speak English to them? 0 What languages do these passengers speak? N/AWhat languages (other than English) do you understand or speak? N/AWould you be willing to serve as a translator when needed? N/A |
| Frequency of Contact with LEP Persons | |
| Frequency | Language Spoken by LEP Persons |
| Daily | |
| Weekly | |
| Monthly | |
| Less frequently than monthly | |
3. The importance of programs, activities or services provided by South Central Industries to LEP persons:
Outreach activities, summarized in South Central Industries Title VI Public Engagement Plan, include events such as public meetings and/or open houses held at schools, churches, libraries and other non-profit locations, and include specific outreach to LEP persons to gain under-standing of the needs of the LEP population, and the manner (if at all) needs are addressed.
| Outside Organization LEP SurveyOrganization: __________________What language assistance needs are encountered?What languages are spoken by persons with language assistance needs?What language assistance efforts are you undertaking to assist persons with language assistance needs?When necessary, can we use these services? |
4. The resources available to South Central Industries and overall cost to provide LEP assistance:
Strategies for Engaging Individuals with Limited English Proficiency include:
- Language line. Upon advance notice, translators can be provided.
- Language identification flashcards.
- Written translations of vital documents (identified via safe harbor provision)
- One-on-one assistance through outreach efforts.
- Website information.
- To the extent feasible, assign bilingual staff for community events, public hearings and Board of Directors meetings and on the customer service phone lines.
As applicable: Based on our demographic analysis (Factor 1) South Central Industries has determined that no language group(s) within its service area meets Safe Harbor criteria requiring written translated “vital documents” by language group(s).
South Central Industries will provide assistance and direction to LEP persons who request assistance.
Staff LEP Training
The following training will be provided to South Central Industries staff:
1. Information on South Central Industries Title VI Procedures and LEP responsibilities.
2. Description of language assistance services offered to the public.
3. Use of Language Identification Flashcards.
4. Documentation of language assistance requests.
Monitoring and Updating the LEP Plan
The LEP Plan is a component of South Central Industries Title VI Plan requirement.
South Central Industries will update the LEP plan as required. At minimum, the plan will be reviewed and updated when it is clear that higher concentrations of LEP individuals are present in the South Central Industries service area. Updates include the following:
1. How the needs of LEP persons have been addressed.
2. Determine the current LEP population in the service area.
3. Determine as to whether the need for, and/or extent of, translation services has changed.
4. Determine whether local language assistance programs have been effective and sufficient to meet the needs.
5. Determine whether South Central Industries financial resources are sufficient to fund language assistance resources as needed.
6. Determine whether South Central Industries has fully complied with the goals of this LEP Plan.
7. Determine whether complaints have been received concerning South Central Industries failure to meet the needs of LEP individuals.
- Advisory Bodies
Table Depicting Membership of Committees, Councils, By Race
| Committee [examples] | Caucasian | Latino | African American | Asian American | Native American | Total |
| Board of Directors | 50% | 8.5% | 8.5% | 33% | 100% | |
| Access Committee | 100% | |||||
| Citizens Advisory Council | 100% |
Description of efforts made to encourage minority participation on committees:
- Extended invitations to two African American males. They declined the offer.
- Minority participation also includes individuals w/special needs. We included 4
- Individuals in 2024.
- Subrecipient Assistance
OPTION A
South Central Industries does not have any subrecipients.
OPTION B
Primary recipients should provide subrecipients:
- Sample public notices, Title VI complaint procedures, and the recipient’s Title VI complaint form.
- Sample procedures for tracking and investigating Title VI complaints filed with a subrecipient.
- Direction regarding obtaining demographic information of population served by subrecipients.
- Technical assistance.
- Reviews of Title VI Programs; follow-up as necessary.
- Subrecipient Monitoring
OPTION A
South Central Industries does not have any subrecipients.
OPTION B
Primary recipients must monitor subrecipients.
- Non-compliant subrecipient means primary recipient is also non-compliant.
Primary recipients shall:
- Document process for ensuring all subrecipients are complying with the general and specific requirements.
- Collect and review subrecipients’ Title VI Programs.
- At FTA’s request, the primary recipient shall request that subrecipients who provide transportation services verify that their level and quality of service is equitably provided.
- Equity Analysis of Facilities
OPTION A
South Central Industries has not constructed any storage facilities, maintenance facilities, or operations centers in the last three years.
OPTION B1
South Central Industries performed an equity analysis of [a new facility] [new facilities] per Title VI regulations.
South Central Industries developed demographic data and mapped minority/low-income levels as a proportion to overall population. Similarly, South Central Industries mapped current locations of residences and businesses in the proposed facilities locations.
| Demographic data and mappingGuidance may be obtained from regional Metropolitan Planning Organization. |
Regarding the location of applicable projects, no persons were displaced from their residences and/or businesses on the basis of race, color, or national origin.
OPTION B2
South Central Industries performed an equity analysis of [a new facility] [new facilities] per Title VI regulations.
South Central Industries developed demographic data and mapped minority/low-income levels as a proportion to overall population. Similarly, South Central Industries mapped current locations of residences and businesses in the proposed facilities locations.
| Demographic data and mappingGuidance may be obtained from regional Metropolitan Planning Organization. |
Regarding the location of applicable projects, the “two-test” exercise was conducted and it was determined that the facility [facilities] could proceed, despite disparate impact, due to a “substantial legitimate justification” to meet a goal that is integral to the agency’s institutional mission. In addition, no comparable effective alternative location(s) would result in less disparate impact.
TITLE VI COMPLAINT FORM –
The South Central Industries is committed to ensuring that no person is excluded from participation in or denied the benefits of its services on the basis of race, color, or national origin, as provided by the Title VI of the Civil Rights Act of 1964, as amended. The Title VI complaints must be filed within 180 calendar days from the date of the alleged discrimination.
Date of Filing: Name: Address:
City, State, Zip Code: Work Phone:
Home Phone:
E-mail Address:
South Central Industries
P.O Box 3766
Shawnee, Oklahoma 74802
405-275-3851
Indicate on what ground(s) you believe you have been discriminated against (check all that apply):
Race
Color
National Origin
Indicate the person(s) who you believe discriminated against you:
Name(s):
Work Location (if known):
Work Phone:
Date of alleged incident
If you have an attorney representing you concerning the matters raised in this complaint, please provide the following:
Name: Address: Work Phone:
E-mail Address:
Have you filed or do you intend to file a charge or complaint concerning the matters raised in this complaint with any other agencies (Federal, State, or local):
Yes
No
If so, please provide the following information:
Agency:
Address:
Name of Investigator (if known): Phone Number:
E-mail Address:
Date Filed:
Status of case:
I confirm that I have read the above charge(s) and it is true to the best of my knowledge.
Print or typed name of complainant:
Signature Date
Completed forms must be submitted to the South Central Industries.
If you require any assistance in filling out this form please contact the Title VI Coordinator at
405-275-3851.
TheSouth Central Industries ensures that no person or groups of persons shall, on the grounds of race, color, sex, religion, national origin, age, disability, retaliation or genetic information, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any and all programs, services, or activities administered bSouth Central IndustriesTo request an accommodation please contact the ADA Coordinator at 405-275-3851.