Title
Request to Approve a Title VI Plan
PURPOSE: The purpose of this agenda item is for the Town Council to approve a Title VI Plan.
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Department
DEPARTMENT: Planning
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Contact
CONTACT INFORMATION:
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Council Direction
COUNCIL DIRECTION:
___ Race/Equity ____ Climate ____ Comprehensive Plan __X__Other
Council Direction Statement
As a federal aid recipient, the Town of Carrboro is required to develop policies, practices, and programs that ensure compliance with Title VI of the Civil Rights Act of 1964 and related federal nondiscrimination authorities. The Town’s receipt of federal funding from the USDOT through NCDOT further requires incorporation of these assurances in a Title VI Plan, which is not yet in place. This Title VI Plan (Attachment B) has been reviewed for compliance and approved by the NCDOT Office of Civil Rights. Adoption of this Title VI Plan not only fulfills legal obligations but also demonstrates the Town of Carrboro’s commitment to creating an inclusive, equitable community where all residents can participate fully and equally. Pocket questions have been prepared and are attached (Attachment C).
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Information
INFORMATION:
Background
Title VI refers to a provision of the Civil Rights Act of 1964 and related statutes that prohibit discrimination in federally funded programs, services, and activities. The 1987 Civil Rights Restoration Act has since extended nondiscrimination coverage to all programs and activities of federal aid recipients, subrecipients, and contractors, including those that are not directly federally funded.
Title VI Plan Overview
The Title VI Plan aims to establish the following Title VI Policy:
• It is the policy of the Town of Carrboro to ensure that no person shall be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program, service, or activity administered or funded by the Town of Carrboro on the basis of race, color, national origin, limited English proficiency, sex, gender identity or expression, sexual orientation, age, disability, familial status, pregnancy, income level, National Guard or veteran status, or religion, as provided by Title VI of the Civil Rights Act of 1964 and other federal nondiscrimination authorities. The Town of Carrboro requires its contractors and subrecipients to comply with this policy.
The Title VI Plan details current compliance efforts and presents an implementation plan for future compliance. It is important to note that the Town of Carrboro has made significant progress over the past five or so years to adopt plans that demonstrate compliance around many of the plan’s objectives. Given this, the Title VI Plan is heavily informed by and borrows language directly from the following documents, each of which has gone through the REAL process or had some level of equity analysis:
• Inclusive Carrboro: Communications and Community Engagement Plan (2020)
• Community Climate Action Plan (2020)
• Carrboro Connects Comprehensive Plan (2022)
• Race & Equity Action Plan: Weaving Equity in Carrboro Town Governance (2023)
• Language Access Plan (2024)
The Title VI Plan will be administered by the Title VI Coordinator, whom the Carrboro Town Manager has designated to be the Planning Director. All Town Staff, however, will play a role in fulfilling the requirements of the plan.
Implementation & Follow-Up
The Title VI Coordinator will prepare an annual compliance report that documents progress on efforts to ensure public dissemination of Title VI information, train staff and contractors on Title VI requirements, and demonstrate department-level compliance with the overall Title VI Plan. The Title VI Coordinator will also prepare an annual update to the Title VI Plan based on changes in federal laws or to reflect items discussed in the annual compliance report. The updated plan and compliance report will be presented to Town Council a year after the plan’s adoption.
By adopting this Title VI Plan, the Town of Carrboro is showing compliance towards federal requirements. While the Town of Carrboro is committed to promoting anti-discrimination, this Title VI Plan does not cover discrimination by non-governmental institutions or disputes between community members. A Town Staff workgroup has been identified to explore opportunities to exceed federal requirements and find ways to support community members whose discrimination complaints fall outside the scope of Title VI and/or Carrboro’s jurisdiction. Recommendations made through this workgroup will inform the next iteration of the Title VI Plan.
This Title VI Plan also does not cover matters of discrimination internal to the Town of Carrboro. Employees who believe they have been discriminated against in the workplace should refer to the employee grievance procedures in the Town Code or EEOC.
Requested Action
A resolution has been provided for the Town Council to adopt a Title VI Plan for the Town of Carrboro.
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Fiscal and Staff Impact
FISCAL IMPACT: There are no significant fiscal or staffing impacts anticipated with the adoption of a Title VI Plan.
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Recommendation
RECOMMENDATION: The Town Manager recommends that the Town Council approve the resolution to adopt a Title VI Plan (Attachment A).
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