Introduction

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color and
national origin in programs and activities receiving Federal financial assistance.
Sound Generations is committed to ensuring that no person is excluded from participation in, or
denied the benefits of its transit services on the basis of race, color, or national origin, as protected
by Title VI in Federal Transit Administration (FTA) Circular 4702.1.B. If you believe you have been
subjected to discrimination under Title VI, you may file a complaint.

Title VI Complaint Procedures

How to file a title VI Complaint:

You may file a signed, written complaint up to one hundred and eighty (180) days from the date
the complainant became aware of the incident. The complaint should include the following
information:

• Your name, mailing address, and how to contact you (i.e., telephone number, email address, etc.)
• How, when, where and why you believe you were discriminated against. Include the
  location, names and contact information of any witnesses.
• Other information that you deem significant

A form is available at our administrative offices, located at 2208 2nd Avenue, Suite 100, Seattle,
WA 98121 or by calling the Chief Operating Officer at 206-448-57575 or emailing
info@SoundGenerations.org if you need it mailed or sent electronically.

The complaint may also be filed in writing with the Chief Operating Officer at the following
address: Sound Generations, 2208 2nd Avenue, suite 100, Seattle, WA 98121

NOTE: Sound Generations encourages all complainants to certify all mail that is sent through the
U.S. Postal Service and/or ensure that all written correspondence can be tracked easily. For
complaints originally submitted by facsimile, an original, signed copy of the complaint must be
mailed to the Title VI Coordinator as soon as possible, but no later than 180 days from the date
the complainant became aware of the incident.

What happens to your complaint after it is submitted?

All complaints alleging discrimination based on race, color or national origin in a service or
benefit provided by Sound Generations will be directly addressed by our Chief Operating Officer.
Sound Generations shall also provide appropriate assistance to complainants, including those
persons with disabilities, or who are limited in their ability to communicate in English. We will
acknowledge receipt of the complaint within 3 days.

In instances where additional information is needed for investigation of the complaint, Sound
Generations will speak with you in person, interview the staff who were involved with the
incident that caused your complaint and any other persons who might have information that
would help with our investigation. Once sufficient information for investigating the complaint is
received by our Chief Operating Officer, Sound Generations will review all the information and
respond within two weeks.

How you will be notified of the outcome of your complaint

The Chief Operating Officer will issue one of two letters to the complainant: a closure letter or a
letter of finding. 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 summarizes the allegations and
the interviews regarding the alleged incident, and explains whether any disciplinary action,
additional training of the staff member or other action will occur. If you are not in agreement
with the outcome, Sound Generations will advise you of your right to 1) appeal the Chief
Operating Officer’s decision with our CEO and/or 2) file a complaint externally with the U.S.
Department of Transportation and/or the Federal Transit Administration. You will have two
weeks to appeal our decision

In addition to the complaint process described above, a complainant may file a Title VI complaint
with the following offices:

Washington State Department of Transportation
Public Transportation Division
Attn: Title VI Coordinator
PO Box 47387
Olympia, WA 98504-7387

Federal Transit Administration Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5th Floor – TCR
1200 New Jersey Ave., SE
Washington, DC 20590

United States Department of Justice
Civil Rights Division
Coordination and Review Section – NWB
950 Pennsylvania Avenue NW
Washington DC, 20530

Investigations, Complaints or Lawsuits

This section is blank because there are no investigations, complaints or lawsuits at this time. If
complaints are received in the future, Sound Generations will follow its record retention policy,
which requires the organization to hold onto documents related to the complaint for six (6)
years.

No complaints as of July 2025

Limited English Proficiency (LEP) Plan

Sound Generations is committed to breaking down language barriers by implementing
consistent standards of language assistance across its service area.

The United States is home to millions of national origin minority individuals who are
Limited English Proficiency (LEP). That is, their primary language is not English and they cannot
speak, read, write or understand the English language at a level that permits them to interact
effectively with recipients of Federal financial assistance.

Because of language differences and the inability to effectively speak or understand English,
persons with LEP may be subject to exclusion from programs or activities, experience delays or
denials of services. These individuals may be entitled to language assistance with respect to a
particular type of service. The federal government and those receiving assistance from the
federal government must take reasonable steps to ensure that LEP persons have meaningful
access to the programs, services, and information those entities provide. This will require
agencies to establish creative solutions to address the needs of this ever-growing population of
individuals, for whom English is not their primary language.

Analysis of Factors:

Factor No. 1: The number or proportion of LEP persons in the service area

The number of LEP
persons in our service area is 234,797. The top 4 languages are Spanish (59,333), Chinese
(45,999), Vietnamese (21,747) and Korean (11,377). Source: C16001: Language Spoken at Home
for … – Census Bureau Table

Based on the most recent U.S. Census and LEP.gov data for King County, the following languages
have over 1,000 individuals with limited English proficiency:

• German or other West Germanic – 1,041
• Russian, Polish, or other Slavic languages – 17,236
• Korean – 11,377
• Chinese – 45,999
• Vietnamese – 21,747
• Tagalog – 8,986
• Arabic – 3,807

While these languages exceed 1,000 LEP individuals, none meet or exceed the 5% threshold of
the total King County population, as outlined in FTA Title VI guidance for translation of vital
documents. This confirms that full translation of all critical documents into the languages of
Spanish, Chinese, Vietnamese, Korean, and Arabic.

This updated analysis also reflects the expanded Hyde Shuttle service area, which now includes
the Eastside cities of Bellevue, Redmond, and Kirkland. These areas were not part of our
operating footprint in the previous Title VI plan and are now included in our LEP data review.

Given that Sound Generations is a non-profit organization operating on limited funds, this data
supports our current approach of providing translations upon request and continuing targeted
outreach through culturally specific partners and multilingual marketing materials, rather than
translating all critical documents into every LEP language identified.

Sound Generations will continue to review LEP data annually to ensure compliance with Title VI
requirements and will revise our language assistance measures if any language meets or
exceeds the 5% threshold or exceeds 1,000 LEP individuals in the future.

Label	Estimate	Percent of Total Population
Total:	2,142,301	100.00%
Speaks only English	1,496,730
Spanish:	150,694
Speaks English “very well”	91,361
Speaks English less than “very well”	59,333	2.76%
French, Haitian, or Cajun:	13,992
Speaks English “very well”	11,449
Speaks English less than “very well”	2,543	0.12%
German or other West Germanic Languages:	9,845
Speaks English “very well”	8,804
Speaks English less than “very well”	1,041	0.05%
Russian, Polish, or other Slavic languages:	43,949
Speaks English “very well”	26,703
Speaks English less than “very well”	17,236	0.80%
Other Indo-European languages:	91,614
Speaks English “very well”	71,391
Speaks English less than “very well”	20,223	0.94%
Korean:	23,980
Speaks English “very well”	12,603
Speaks English less than “very well”	11,377	0.53%
Chinese (incl. Mandarin, Cantonese)	104,344
Speaks English “very well”	58,345
Speaks English less than “very well”	45,999	2.15%
Vietnamese	37,881
Speaks English “very well”	16,134
Speaks English less than “very well”	21,747	1.02%
Tagalog (incl. Filipino)	28,110
Speaks English “very well”	19,124
Speaks English less than “very well”	8,986	0.42%
Other Asian and Pacific Island languages	79,168
Speaks English “very well”	54,336
Speaks English less than “very well”	24,832	1.16%
Arabic	10,795
Speaks English “very well”	6,988
Speaks English less than “very well”	3,807	0.18%
Other and unspecified languages	51,209
Speaks English “very well”	33,536
Speaks English less than “very well”	17,673	0.82%

Factor No. 2: The frequency with which LEP individuals come into contact with the service

All contacts with Sound Generations are made through our call center or in the case of our
nutrition transportation service through a meal site coordinator who speaks the language of the
rider. We serve LEP persons daily via our nutrition transportation program. Our reservationists
(call takers) only speak English and engage our Language Line when the caller needs a translator.
All of our call center staff receive training upon hire about how to engage the language line. We
also work with meal site coordinators to set up group rides for people who are not English
Speaking. In many cases a family member, who is fluent in English contacts us to arrange
transportation. Last year, our call center received 48,327 calls and the number that required
translation was 158.

Translated Language	Frequency
Albanian	2
Amharic	1
Arabic	33
Cantonese	17
Hindi	4
Mandarin	11
Russian	17
Spanish	51
Ukrainian	1
Tigrigna	1
Vietnamese	20

Factor No. 3: The nature and importance of service provided by

Sound Generations provides vital demand-response community shuttle and volunteer
transportation services that are essential to the daily lives of older adults, people with disabilities,
and other transportation-disadvantaged residents throughout King County, including recent
service expansions to Bellevue, Redmond, and Kirkland.

Most trips are to critical destinations such as medical appointments, pharmacies, grocery stores,
and senior nutrition programs. Riders can also schedule trips to senior centers, banks,
hairdressers, and other community locations that support independence, health, and social
connection.

Given that many clients served, especially those in LEP and BIPOC communities, have limited
mobility options, our services are often their primary or only means of accessible transportation.
This is underscored by the fact that demand has grown in key service areas, such as the Eastside,
Auburn, Federal Way, and Seattle.

Factor No. 4: The resources available to the recipient of the federal funds to assure meaningful access to the service by LEP persons.

Sound Generations current in-house language capabilities is limited to English amongst the Hyde
Shuttle Staff. The Language Line is used when someone calls who can’t speak English. The
Language line can handle any language we need translation for. Our Title VI policy is translated
into Spanish, Chinese, Vietnamese, Arabic and Korean because these are the top 5 languages
spoken amongst the LEP population in King County. The following vital documents are
translated into the five languages: ADA/Rider Guide, Title VI Statement and Public Notice and
Complaint Form and are attached to this plan.

Sound Generations operates as a nonprofit organization with limited financial and staffing
resources. As such, we focus our LEP outreach strategies on high-impact, cost-effective
approaches that maximize our ability to connect with and serve linguistically diverse
communities across King County, including the recently added Eastside service areas of
Bellevue, Redmond, and Kirkland.

Our resources for LEP engagement include:

• Community Engagement Officer dedicated to building partnerships with BIPOC-led organizations, attending community events, conducting presentations, and establishing advisory councils that reflect the voices of minority and LEP populations.
• Outreach Specialist who spends 100% of their time in the community distributing multilingual rack cards (available in 10 languages), speaking to groups, and engaging in one-on-one conversations.
• Virtual education opportunities through the Elder Education Institute, which allow for remote engagement on health, wellness, and transportation resources, accessible to LEP individuals with internet access.
• Language interpretation services through our contracted language line to support real-time communication with riders who speak limited English.
• Partnerships with senior centers, community dining programs, and cultural organizations that help extend outreach efforts into specific LEP and immigrant communities.

While financial constraints limit our ability to produce translations in every language, a 2025
analysis confirmed that no LEP language group in King County meets or exceeds the 5%
threshold but did have LEP language groups that exceeded 1,000 people, identifying the need
for an additional critical document translation at this time in Arabic, in addition to vital
documents already translated.

Implementation Plan:

Sound Generations currently has implemented its plan and will review it annually, including any
contacts with the LEP persons to determine the frequency of contacts, the language used, and
how the contacts were handled.

We identify LEP persons in the service area by having partnerships with organizations that serve
LEP persons, such as SeaMar, ACRS, IDIC, Filipino Community Center, Ukrainian Community
Center, El Centro de la Raza, First Tongans, Eritrean Association, East African Senior Center
Program (which we operate), Hmong/Lao Senior Program and are in the process of setting up
additional relationships.

We employ: Some of our drivers come from LEP communities and where possible we place
them on routes that match their cultural and language background.

In order to comply with 49 CFR 21.9(d), Sound Generations and its sub-recipients must provide
information to beneficiaries regarding their Title VI obligations and inform beneficiaries of the
protections against discrimination afforded them by Title VI. Sound Generations has established
a statement of rights and a policy statement.

Notifying Beneficiaries of Their Rights Under Title VI

1. We post a notice of their rights on our website.
2. We have a notice of their rights at our administrative offices.
3. Our rack cards include language about Title VI rights.

Analysis of Construction Projects

Over the last three years Sound Generations has had no projects, nor will we ever have
projects requiring an environmental assessment (EA) or environmental impact statement
(EIS).

Inclusive Public Participation

Community Outreach is a requirement of Title VI. Recipients and sub-recipients shall seek out
and consider the viewpoints of minority and low-income populations in the course of
conducting public outreach. Recipients have wide latitude to determine what specific measures
are most appropriate and should make this determination based on the composition of the
affected population, the public involvement process, and the resources of Sound Generations.
Sound Generations engages the public in its planning, decision-making, and outreach through
the following strategies:

1. Senior Center Connections – Our senior centers serve as trusted community hubs where older adults, caregivers, and community leaders naturally connect with our programs.
2. Community Presentations – Staff conduct presentations in neighborhoods and community spaces, building relationships and awareness in targeted service areas.
3. Multilingual Materials – Program rack cards are available in ten languages and distributed at locations throughout King County to ensure accessibility for limited English proficient residents.
4. Community Engagement Officer – In 2024, we created a dedicated Community Engagement Officer position to lead advocacy, partnerships, and outreach. This role has:
   • Partnered with the Build Your Tax Code Coalition to advance policies benefiting low-income residents and seniors.
   • Worked with the Seattle Senior Services Coalition to advocate for increased City
     of Seattle funding for senior centers.
   • Expanded outreach to immigrant and refugee communities, including Afghan
     elders through a partnership with the Porsesh Research Institute.
   • Facilitated technology workshop opportunities for seniors by partnering with TMobile.
   • Established a partnership with the National Asian Pacific Center on Aging to host
     older adult community service trainees through the Senior Community Service
     Employment Program (SCSEP).
5. BIPOC Partnership Development – A staff member dedicated to BIPOC outreach has built relationships with 19 BIPOC-led organizations and helped form an Elder’s Council to provide ongoing advisory input on programs and services.
6. Culturally Specific Dining Programs – Our Community Dining program provides culturally relevant meals and engagement for Tongan, Eritrean, East African, Ethiopian, Polynesian, Filipino, and Vietnamese older adults.
7. Public Meetings – We participate in public meetings organized by funders and community partners to ensure our clients’ perspectives are represented in broader planning processes.

Through these coordinated strategies, Sound Generations ensures the voices of minority, low-income, and limited-English proficient populations are meaningfully considered in the design
and delivery of our services.

Virtual Outreach through Elder Education Institute:

Sound Generations incorporates virtual outreach as part of its Title VI engagement strategy
through the Elder Education Institute (EEI). EEI offers live and recorded online classes,
workshops, and discussion groups covering a variety of topics relevant to older adults, including
health, wellness, financial security, technology skills, and cultural programming.

These virtual programs:

• Engage a broad audience across King County, including individuals who face transportation barriers or live in rural areas.
• Offer accessible participation for minority, low-income, and LEP populations by providing captions, clear language, and user-friendly technology instructions.
• Serve as a feedback channel, as EEI instructors and facilitators regularly collect participant questions, comments, and suggestions during sessions, which are shared with program leadership to inform planning and decision-making.
• Collaborate with culturally specific partners, inviting guest speakers from BIPOC-led organizations to co-present and share culturally relevant content.
• Promote inclusivity by offering outreach for EEI sessions through partner organizations, multilingual flyers, social media, and email newsletters, ensuring diverse community representation.

Through EEI’s online presence, Sound Generations can reach individuals who may not be able to
attend in-person events, expanding our ability to meet Title VI requirements for inclusive and
equitable community engagement.

Outcome Measurement: In addition to measuring satisfaction with our annual survey, we collect
demographic information to determine how successful our outreach efforts to BIPOC and LEP
communities have been. We compare how well we are doing to the percentage of BIPOC and
LEP individuals in King County. We monitor to see how many unknowns are reflected in our
demographic data and remind staff to collect information about race whenever possible.
We compare use of the language line over the years to determine how well we are reaching LEP
individuals. If these numbers are trending in the wrong direction, we determine what we can do
to improve our services.

Major Service Change. We expanded service into Eastside cities, including Bellevue, Redmond,
and Kirkland. This expansion has created new connections for seniors and people with
disabilities in culturally diverse areas and has resulted in increased ridership from East Asian,
South Asian, and Russian-speaking communities, as reflected in our demographic tracking.
Partnerships with Eastside senior centers and cultural organizations have been critical in
introducing these communities to our services. In 2024 alone, the Eastside expansion resulted in
538 new riders and 4,591 one-way trips. Partnerships with Eastside senior centers and cultural
organizations have been critical in introducing these communities to our services.

Ongoing Engagement:

We continue to conduct targeted outreach through presentations, distribution of multilingual
rack cards, and community events. The creation of our Community Engagement Officer role has
strengthened our ability to build partnerships, particularly with BIPOC-led organizations, and
establish advisory bodies such as the Elders Council. These efforts have directly supported
awareness and ridership growth in newly served areas.

Since 2021, the number of clients we serve who are considered Limited English Proficient (LEP)
has increased by 19%, a direct result of our Title VI engagement strategies and targeted
outreach to culturally and linguistically diverse communities. This growth is also tied to our
Eastside service expansion into Bellevue, Redmond, and Kirkland, which has allowed us to reach
new populations and better meet the transportation needs of LEP residents in these areas.

Fare Increase. We don’t charge our riders. We only collect donations.

Travel Training Class. We don’t provide this service.

Customer Complaint Process. This was already described earlier in this document

General Awareness and Phone Surveys. We are not resourced to do phone surveys and most of
our awareness raising is targeted to geographic or cultural communities where we need to
increase ridership. We send out surveys once per year to all riders to obtain feedback on how
we are doing. Our website and rack cards are the main strategies we employ and our outreach
specialist.

Bilingual Outreach. This was already described earlier in this document.

Membership of Non-Elected Committees

Sound Generations values the viewpoints of minority, LEP and low-income participants and
relies on our funders (City of Seattle, King County) to organize advisory boards and committees
that meaningfully involve these individuals. We rely on what is learned by these boards and
advisory committees when operating our transportation program. We participate in the KC
Mobility Coalition, facilitated by Hope Link and utilize surveys and outreach efforts that they
engage in to improve our service.

We have a board of directors which connects the organization to the community. The
membership of our board is 47% white; 12% African American; 18% Asian; 6% Hispanic and 12%
Middle Eastern. Meetings are every other month on the first Wednesday of the month.

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