Title VI

Notice to Public

Society for Equal Access/ILC

Title VI Notice to Public

The Society for Equal Access/ILC 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 Title VI of the Civil Rights Act of 1964, as amended. It’s objective to:

  • Ensure that the level and quality of transportation and IL service is provided without regard to race, color, or national origin;
  • Promote the full and fair participation of all affected populations in transportation decision making and IL services;
  • 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.

 The Society for Equal Access/ILC is committed to a policy of non‐discrimination in the conduct of its business, including its Title VI responsibilities and to the delivery of equitable and accessible transportation services and IL services. Any person who believes that he or she has been subjected to discrimination under Title VI on the basis of race, color or national origin may file a Title VI complaint with Society for Equal Access/ILC. Any such complaint must be in writing and submitted to the Society for Equal Access/ILC within one hundred eighty (180) days following the date of the alleged discrimination.

There are several ways to file a complaint. Complaints may be filed in writing and mailed to Manager of Human Resources and Title VI Coordinator, Society for Equal Access/ILC. A copy of the Title VI Complaint Form is available by calling (330) 343-9292 ext. 210 or you can download the form. We encourage use of the Title VI Complaint Form.

This section outlines the Title VI complaint procedures related to providing programs, services, and benefits.  However, it does not deny the complainant the right to file a formal complaint(s) with any other federal, state, or local agencies or seek private counsel for complaints alleging discrimination, intimidation, or retaliation of any kind that is prohibited by law.

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs receiving federal financial assistance.


Society for Equal Access/ILC has in place a Title VI Complaint Procedure, which outlines a process for local disposition of Title VI complaints and is consistent with guidelines found in the Federal Transit Administration Circular 4702.1A, dated May 13, 2007.

The complaint procedure must meet the following requirements outlined below:

  1. Submission of Complaint: Any person who feels that he or she, individually, or as a member of any class of persons, on the basis of race, color, national origin, age, sex, disability, religion, or low-income status has been excluded from or denied the benefits of, or subjected to discrimination under any program or activity receiving federal financial assistance through SEA may file a written complaint with the Director of Civil Rights. Such complaint must be in writing and signed by complainants(s).
    1. In cases where Complainant is unable or incapable of providing a written statement, a verbal complaint may be made.  The Director of Civil Rights will interview the Complainant and assist the person in converting verbal complaints to writing.  All complaints must, however, be signed by the Complainant or his/her representative.
    2. Include the date of the alleged act of discrimination date when the Complainants became aware of the alleged act of discrimination; or the date on which that conduct was discontinued or the latest instance of conduct.
    3. Present a detailed description of the issues, including names and job titles of those individuals perceived as parties in the complaint.
    4. Federal and state law requires complaints be filed within 180 calendar days of the alleged incident.
  2. Referral to Review: Upon receipt of the Complaint, the Director of Civil Rights in consultation with SEA’s Legal Counsel will determine its jurisdiction, acceptability, need for additional information, as well as assign the complaint to a Specialist to evaluate and investigate the merit of the complaint.  The Specialist shall complete their review no later than 45 calendar days after the date SEA received the Complaint. If more time is required, the Deputy Executive Director shall notify the Complainant of the estimated time-frame for completing the review.
  3. Upon completion of the review: The Specialist shall make a recommendation regarding the merit of the Complaint and whether remedial actions are available to provide redress. Additionally, the staff may recommend improvements to SEA’s processes relative to Title VI and environmental justice, as appropriate. The Specialist shall forward their recommendation to the Director of Civil Rights for their concurrence. If the Director of Civil Rights concurs, he shall issue SEA’s written response to the Complainant.

A complaint must meet the following criteria for acceptance:

  1. The Complaint must be filled within 180 days of alleged occurrence;
  2. The allegation must involve a covered basis such as race, color or national origin.
  3. The allegation must involve a SEA service of a Federal-aid recipient, sub-recipient or contractor.

A complaint may be dismissed for the following reasons:

  1.  The Complainant requests the withdrawal of the complaint.
  2. The Complainant fails to respond to repeated requests for additional information needed to process the complaint.
  3. The Complainant cannot be located after reasonable attempts.


  1. Documentation: The investigative report and its findings will be reviewed by the Executive Director and in some cases the investigative report and findings will be reviewed by SEA’s Legal Counsel.  The report will be modified as needed.  The Executive Director and Legal Counsel will make a determination on the disposition of the complaint.  Dispositions will be as follows:

In the event SEA is in noncompliance with Title VI regulations remedial actions will be listed.

  1. Notice of determination: A Notice of Determination will be mailed to the Complainant.  Notice shall include information regarding appeal rights of Complainant and instructions for initiating such an appeal.  Notice of Appeals are as follows:
    1. SEA will reconsider this determination, if new facts, come to light.
    2. If Complainant is dissatisfied with the determination and/or resolution set forth by SEA, the same complainant may be submitted to FTA for investigation.  Complainant shall be advised to contact the Federal Transit Administration.
  2. Request for Reconsideration: If the Complainant disagrees with the Executive Director’s response, he or she may request reconsideration by submitting the request, in writing, to the Executive Director within 10 calendar days after receipt of the Executive Director’s response. The request for reconsideration shall be sufficiently detailed to contain any items the Complainant feels were not fully understood by the Executive Director. The Executive Director will notify the Complainant of his/her decision either to accept or reject the request for reconsideration within 10 calendar days. In cases where the Executive Director agrees to reconsider, the matter shall be returned to the Director of Civil Rights to reevaluate in accordance with Paragraph 2, above.
  3. Appeal: If the request for reconsideration is denied, the Complainant may appeal the Executive Director’s response to the Complaint by submitting a written appeal to SEA’s Board of Directors no later than 10 calendar days after receipt of the Executive Director’s written decision rejecting reconsideration.