HomeMy WebLinkAboutAgenda Packet 06-24-2025
CITY COMMISSION MEETING
AGENDA FOR JUNE 24, 2025
5:00 PM
CITY HALL COMMISSION CHAMBERS
300 SOUTH FIFTH STREET
Any member of the public who wishes to make comments to the Board of Commissioners is asked to fill out a Public
Comment Sheet and place it in the box located at the end of the Commissioner’s desk on the left side of the Commission
Chambers. The Mayor will call on you to speak during the Public Comments section of the Agenda.
ROLL CALL
INVOCATION
PLEDGE OF ALLEGIANCE
ADDITIONS/DELETIONS
EMPLOYEE INTRODUCTIONS Wes Banks, Planning Dept. Intern - C. GAULT
EMPLOYEE INTRODUCTIONS Alyssa Blanchard, Engineering Intern - G. GUEBERT
PRESENTATION Citizens' Academy Graduation - Cathy Bryant-Quimby
PUBLIC COMMENTS
MAYOR'S REMARKS
Items on the Consent Agenda are considered to be routine by the Board of Commissioners and will be enacted by one
motion and one vote. There will be no separate discussion of these items unless a Board member so requests, in which
event the item will be removed from the Consent Agenda and considered separately. The City Clerk will read the items
recommended for approval.
I. CONSENT AGENDA
A. Approve Minutes for June 10, 2025
B. Receive & File Documents
C. Personnel Actions
D. Approve the Job Grade Schedule for FY2026 - S. WILCOX
E. Approve the Position and Pay Schedule for FY2026 - S. WILCOX
F. City of Paducah FY2026 Title VI Program Plan Adoption - S. WILCOX
G. Employment Agreement with Matthew Wentworth - B. LAIRD
H. Authorize the City Manager to release a Request for Bids for a Non-
Exclusive Telecommunications Franchise - L. PARISH
I. Approve Contract For Services with Paducah Junior College, Inc., for the
Community Scholarship Program in the amount of $100,000.00 - D.
JORDAN
II. MUNICIPAL ORDER(S)
A. Authorize the City Manager to release a Request for Proposals for Design
and Construction Administration Services for the design of a new
Maintenance Building for the Parks and Recreation Department - A. CLARK
B. Authorize the City Manager to release a Request for Proposals for the
construction of a restroom facility at Robert Coleman Park - A. CLARK
C. School Resource Officer Agreement with Paducah Public Schools - B.
LAIRD
III. ORDINANCE(S) - ADOPTION
A. Health Insurance Fund - budget amendment for FY2025 - J. PERKINS
IV. COMMENTS
A. Comments from the City Manager
B. Comments from the Board of Commissioners
V. EXECUTIVE SESSION
June 10, 2025
At a Regular Meeting of the Paducah Board of Commissioners held on Tuesday, June 10, 2025,
at 5:00 p.m. in the Commission Chambers of City Hall located at 300 South 5th Street, Mayor
George Bray presided. Upon call of the roll by City Clerk, Lindsay Parish, the following the
following answered to their names: Commissioners Henderson, Smith, Thomas, Wilson, and
Mayor Bray (5).
INVOCATION
Commissioner Thomas led the Invocation.
PLEDGE OF ALLEGIANCE
The Mayor led the pledge.
ADDITION
The City Manager added the following item to the agenda: A Municipal Order to Approve an
Agreement with KEES for Hotel Metropolitan Executive Director Search.
PRESENTATION
Communications Manager Pam Spencer provided the following summary:
Paducah Cooperative Ministry Executive Director Lacy Boling provided an overview of various
local and state statistics regarding how a lack of housing is driving homelessness. Boling first
mentioned the number of students in the McCracken County and Paducah Public school systems
who were enrolled in McKinney-Vento programming for homeless assistance during the 2024-
2025 school year (248 in Paducah and 212 in McCracken County). Boling also pointed out the
results of the 2024 McCracken County Point in Time count which noted an increase in the
homeless population count to nearly 200. As determined by the Kentucky Housing Corporation,
McCracken County currently has a housing supply gap of 3,805. This number is expected to
increase by 39 percent by 2029. The fair market rent is $992 in McCracken County for a two-
bedroom apartment which means the estimated hourly wage that a full-time employee must earn
to afford a home at HUD’s fair market rent is $19.08. Boling then shared similar statistics for the
State of Kentucky noting the lack of a housing supply.
PUBLIC COMMENTS
Randall Barnes thanked the Commission and the Brooks Stadium Board for their work in
donating land to be used for the new Paducah Tilghman Softball facility.
Rhonda Smith spoke about Southside Public Art Update and Affordable Housing.
CONSENT AGENDA
Mayor Bray asked if the Board wanted any items on the Consent Agenda removed for
separate consideration. No items were removed. Mayor Bray asked the City Clerk to read
June 10, 2025
the items on the Consent Agenda.
I(A)Approve Minutes for the May 27, 2025, Board of Commissioners meeting.
I(B)Receive and File Documents
I(C) Reappointment of Ryan Garner and Joint Reappointment of Bill Bartleman, to the Paducah-
McCracken County Convention Center Corporation Board. These terms shall expire June 30,
2028.
I(D)Appointment of Alexis Marrs to replace Heather Coltharp, whose term expired, and Jana
Dawson, to replace Michael Campbell, who resigned, to the Historical & Architectural
Review Commission (HARC). Said terms shall expire June 10, 2028, and November 27,
2026, respectively.
I(E)Appointment of Leslie Heath to the Paducah Planning Commission, to replace Micky
Carman, who resigned. Said term shall expire August 31, 2027.
I(F)Personnel Actions
Commissioner Henderson offered Motion, seconded by Commissioner Smith, that the items
on the consent agenda be adopted as presented.
Adopted on call of the roll yeas, Commissioners Henderson, Smith, Thomas, Wilson and
Mayor Bray (5).
MUNICIPAL ORDER
APPROVE AN AGREEMENT WITH KEES (KRISTNER EDDY EXECUTIVE
SERVICES) FOR EXECUTIVE SEARCH SERVICES FOR HIRING THE HOTEL
METROPOLITAN EXECUTIVE DIRECTOR
Commissioner Smith offered Motion, seconded by Commissioner Henderson, that the Board of
Commissioners adopt a Municipal Order, entitled, “A MUNICIPAL ORDER AUTHORIZING
THE MAYOR TO EXECUTE AN AGREEMENT WITH KISTNER EDDY EXECUTIVE
SERVICES, INC. (KEES) FOR EXECUTIVE SEARCH SERVICES RELATED TO THE
HOTEL METROPOLITAN EXECUTIVE DIRECTOR POSITION.”
Adopted on call of the roll yeas, Commissioners Henderson, Smith, Thomas, Wilson and
Mayor Bray (5). (MO #3054; BK 14)
ORDINANCE ADOPTION
BUDGET ORDINANCE FY2026
Commissioner Thomas, offered Motion seconded by Commissioner Wilson, that the Board of
Commissioner adopt an Ordinance entitled, “AN ORDINANCE ADOPTING THE CITY OF
June 10, 2025
PADUCAH, KENTUCKY, ANNUAL OPERATING BUDGET FOR THE FISCAL YEAR
JULY 1, 2025, THROUGH JUNE 30, 2026, BY ESTIMATING REVENUES AND
RESOURCES AND APPROPRIATING FUNDS FOR THE OPERATION OF CITY
GOVERNMENT.” This Ordinance is summarized as follows: Adopting the City of Paducah
annual budget for Fiscal Year July 1, 2025, through June 30, 2026, by estimating revenues and
resources and appropriating funds for the operation of City Government at $137,778,934, and
summarized by fund as follows:
FUNDSAPPROPRIATIONS
1000GENERAL $51,198,934
2300MAP3,116,000
2400INVESTMENT7,887,440
2500TIF123,000
2000E9113,343,495
2200OPIOID53,096
2700COURT AWARDS112,165
2800ROOM TAX1,855,000
3000DEBT5,567,361
4000CIP11,947,805
4200BOND FUND33,795,280
5000SOLID WASTE8,052,519
5300TRANSIENT BOAT DOCK444,544
1100RENTAL 142,513
7000FLEET MAINTENANCE1,092,826
7100FLEET LEASE TRUST2,853,765
7200INSURANCE1,330,581
7300HEALTH INSURANCE4,045,470
8100PFPF 731,715
8400OTHER TRUSTS85,425
$137,778,934
Adopted on call of the roll yeas, Commissioners Henderson, Smith, Thomas, Wilson and
Mayor Bray (5). (ORD 2025-06-8847; BK 37)
ORDINANCE INTRODUCTION
FY2025 BUDGET AMENDMENT HEALTH INSURANCE FUND
–
Commissioner Wilson offered motion, seconded by Commissioner Thomas, that the Board of
Commissioners introduce an Ordinance entitled, “AN ORDINANCE AMENDING
ORDINANCE NO. 2024-06-8815, ENTITLED, “AN ORDINANCE ADOPTING THE CITY
OF PADUCAH, KENTUCKY, ANNUAL OPERATING BUDGET FOR THE FISCAL YEAR
June 10, 2025
JULY 1, 2024, THROUGH JUNE 30, 2025, BY ESTIMATING REVENUES AND
RESOURCES AND APPROPRIATING FUNDS FOR THE OPERATION OF CITY
GOVERNMENT.” This Ordinance is summarized as follows: That the annual budget for the
fiscal year beginning July 1, 2024, and ending June 30, 2025, as adopted by Ordinance No.
2024-06-8815, be amended by the following re-appropriations:
Transfer $710,000 from the Health Insurance Funds’ fund balance to the
FY2025 Health Insurance Claims Account.
OTHER BUSINESS
EMPLOYEE CONCERN APPEAL
Communications Manager Pam Spencer provided the following summary:
City of Paducah Fire Department employee, Matt Meiser, brought forth an employee concern
appeal to the Board of Commissioners as permitted in the City’s Employee Concerns Policy
regarding the City’s Progressive Discipline Policy.
DISCUSSIONS
Communications Manager Pam Spencer provided the following summaries:
Spec Building Discussion and Grant Award
Greater Paducah Economic Development President/CEO Bruce Wilcox provided a brief history
of the construction of spec buildings in Paducah and McCracken County, summarized current
spec buildings across Kentucky, and announced that the local community has been successful in
receiving a $2 million grant toward the construction of a spec building. In March, the City
approved a letter of support with the McCracken County Fiscal Court supporting GPED’s
application for grant funding through the Kentucky Product Development Initiative (KPDI) to
construct a 100,000-square-foot speculative building in Industrial Park West. The competitive
grant has been approved with an award of $2 million. Future action would be taken by the City
Commission to formally accept the grant.
Riverfront Infrastructure Improvement Project (BUILD Grant) Update
Engineering Project Manager Melanie Townsend updated the Board on the construction projects
included in the Riverfront Infrastructure Improvement Project (BUILD grant project).
Construction on this project started in November 2024. Since then there has been significant
work in the area on the river side of the floodwall near the transient dock with concrete work
th
now beginning. The reconfiguration of the Convention Center floodwall opening at North 5
Street is underway and expected to continue until August. Later this summer there will be work
thrdnd
on the intersections of 6 and Park Avenue; 3 and Madison; and 2 and Jefferson.
One of the most substantial projects included in this Riverfront Infrastructure Improvement
Project is the construction of a new riverfront excursion pier. This new landing pier will greatly
enhance the experience and accessibility for Paducah’s riverboat passengers. This week,
June 10, 2025
demolition work by Jim Smith Contracting began on the river side of the floodwall just
downstream from the Foot of Broadway in preparation for the pier’s construction. One lane of
Water Street is closed between Broadway and Jefferson.
Later this month, contractor, C.J. Mahan, will mobilize to start the pier construction with
materials and equipment arriving by barge. Crews will work Monday through Saturday on this
phase of the project which is expected to wrap up with the substantial completion of the pier and
excursion plaza by spring to summer of 2026. Crews will not be working on July 4.
Since much of the pier work will be facilitated from a barge, the Foot of Broadway, Schultz
Park, the transient dock and landmass, and the Greenway Trail (except on the river side of the
floodwall between Broadway and Jefferson Street) will remain open during construction.
Please note that part of this work will include pile driving which is planned to start at the end
June/early July. Pile driving is expected to last until early September and will be noisy. This 540-
foot pier requires numerous mooring and support piles that will be driven into the riverbed
leading to the noise. This pier will have 18 piles that are 48 inches in diameter and three mooring
dolphins of equivalent size. Furthermore, there will be dozens of smaller support piles and a
bulkhead. The machinery (a pile-driving hammer) to install these piles will be located on a barge
and held in place by a crane. The barges will be in place for the project’s duration. After the piles
are completed, the decking for the pier will be installed from the barge along with a 15-foot wide
sidewalk to connect the pier to the landing at the Broadway floodwall opening.
Paducah is using a $10.4 million grant (Better Utilizing Investments to Leverage Development
(BUILD) Grant) through the Maritime Administration along with $3.5 million in State funds to
cover the majority of the project’s construction cost.
COMMENTS:
Commissioner Henderson attended the Southside Revitalization meeting. He thanked
Planning Director Carol Gault and the Planning Department team for the presentation.
He wants to continue to make the Southside an affordable place for families to live.
Mayor Bray said he was unable to attend, but he had heard great things about the meeting
and is encouraged by the discussion.
Commissioner Smith also attended the meeting. He wishes for the City to work to
preserve the history of the Southside.
EXECUTIVE SESSION:
Commissioner Henderson offered motion, seconded by Commissioner Smith, that the Board of
Commissioners go into closed session for discussion of matters pertaining to the following
topics:
Discussions of proposed or pending litigation against or on behalf of the public agency
KRS 61.810(1)(c)
June 10, 2025
Adopted on call of the roll yeas, Commissioners Guess, Henderson, Smith, Wilson and Mayor
Bray (5)
RECONVENE IN OPEN SESSION
Commissioner Wilson offered motion, seconded by Commissioner Henderson, that the Paducah
Board of Commissioners reconvene in open session.
Adopted on call of the roll yeas, Commissioners Henderson, Smith, Thomas, Wilson, and Mayor
Bray (5).
ADJOURN
Commissioner Thomas offered Motion, seconded by Commissioner Smith, that the
meeting be adjourned.
Adopted on call of the roll yeas, Commissioners Henderson, Smith, Thomas, Wilson, and Mayor
Bray (5).
TIME ADJOURNED: 7:20 p.m.
ADOPTED: June 24, 2025
George Bray, Mayor
ATTEST:
Lindsay Parish, City Clerk
June 24, 2025
RECEIVE AND FILE DOCUMENTS:
Contract File:
1. Mutually Agreeable Staffing Agreement – TempsPlus, Inc. – MO #3033
2. Participation Addendum – NASPO ValuePoint (Xybix Systems) – MO #3040
3. Transfer of Maintenance Rights for KY 3238 (Water Street) from Commonwealth of
Kentucky to City of Paducah (ORD 2023-05-8773)
4. Communications International – purchased off previous contract – Quote – MO #3044
Financials:
1. Letter of Engagement – Williams Williams & Lentz –GPED audit
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: Approve the Job Grade Schedule for FY2026 - S. WILCOX
Category: Municipal Order
Staff Work
By: Stefanie Wilcox
Presentation
By: Stefanie Wilcox
Background Information: Each grade in the Job Grade Schedule is being increased to coincide with the
fiscal year 3% cost of living adjustment provided for all non-union positions. The schedule also creates an
Assistant Director of Planning position in the Planning Department at grade 14.
Does this Agenda Action Item align with a Commission Priority? No
If yes, please list the Commission Priority: City Staffing Needs
Communications Plan:
Account Name:
Funds Available:
Account Number:
Staff Recommendation: Approve the updated Job Grade Schedule to be effective June 26, 2025, with
recommended changes.
Attachments:
1. MO job grade schedule FY2026
2. Job Grade Schedule 06 26 2025
MUNICIPAL ORDER NO. _______
A MUNICIPAL ORDER APPROVING THE JOB GRADE SCHEDULE FOR
THE EMPLOYEES OF THE CITY OF PADUCAH, KENTUCKY FOR FISCAL
YEAR 2026
BE IT ORDERED BY THE CITY OF PADUCAH, KENTUCKY:
SECTION 1. The City of Paducah hereby adopts and approves the Job Grade
Schedule for Fiscal Year 2026 as attached hereto.
SECTION 2. This Order will be in full force and effect from and after the date of
its adoption.
__________________________________
George Bray, Mayor
ATTEST:
_____________________________
Lindsay Parish, City Clerk
Adopted by the Board of Commissioners, _______________________
Recorded by Lindsay Parish, City Clerk, ________________________
\\mo\\job grade schedule FY2026
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: Approve the Position and Pay Schedule for FY2026 - S. WILCOX
Category: Municipal Order
Staff Work
By: Stefanie
Wilcox
Presentation
By: Stefanie
Wilcox
Background Information: Approve the Position and Pay Schedule for all City personnel to include the
budgeted 3.0% cost of living adjustment effective June 26th, per negotiated terms of labor contracts with
AFSCME, Police, and Fire, as well as an adjustment for all other non-union City employees. The Position and
Pay schedule adds the following newly budgeted positions; an Assistant Director of Planning in the Planning
Department, three Firefighters in the Suppression Division of Fire, a Code Enforcement Officer in the
Prevention Division of Fire, three Right of Way Maintenance positions in the Street Division of Public Works,
and one new Recreation Specialist for the Recreation Division of the Parks Department. The Pay and Position
Schedule also includes newly filled positions, new vacancies, and other position changes over the last few
months.
Does this Agenda Action Item align with a Commission Priority? Yes
If yes, please list the Commission Priority: City Staffing Needs
Communications Plan:
Account Name:
Funds Available:
Account Number:
Staff Recommendation: Approved the recommended changes for the Fiscal Year 2026 Position and Pay
Schedule to be effective June 26, 2025.
Attachments:
1. MO Position and Pay Schedule FY2025-2026
2. Position and Pay Schedule -Jun 26 2025
MUNICIPAL ORDER NO. __________
A MUNICIPAL ORDER ADOPTING THE POSITION AND PAY SCHEDULE
FOR THE FULL-TIME EMPLOYEES OF THE CITY OF PADUCAH,
KENTUCKY FOR FISCAL YEAR 2026
BE IT ORDERED BY THE CITY OF PADUCAH, KENTUCKY:
SECTION 1. That the City of Paducah hereby adopts the FY2026 Position and
Pay Schedule for the employees of the City of Paducah as attached hereto.
SECTION 2. This Order will be in full force and effect from and after the date of
its adoption.
______________________________
George Bray, Mayor
ATTEST:
___________________________
Lindsay Parish, City Clerk
Adopted by the Board of Commissioners, _______________________
Recorded by Lindsay Parish, City Clerk, ______________________
mo/Position and Pay Schedule FY2025-2026
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: City of Paducah FY2026 Title VI Program Plan Adoption - S. WILCOX
Category: Municipal Order
Staff Work
By: Stefanie
Wilcox
Presentation
By: Stefanie
Wilcox
Background Information: The City of Paducah (City), as a federal grant recipient, is required by the
Federal Transit Administration (FTA) to conform to Title VI of the Civil Rights Act of 1964 and its
amendments with a new Program Plan Adoption each year. Section 601 of 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 participation in, be denied the benefits of, or be subjected to discrimination, under any program or activity
receiving Federal financial assistance.” Presidential Executive Order 12898 addresses environmental justice in
minority and low-income populations. Presidential Executive Order 13166 addresses services to those
individuals with limited English proficiency. The City is committed to enforcing the provisions of Title VI and
protecting the rights and opportunities of all persons associated with the agency. The city’s commitment
includes following all applicable laws and regulations that affect the region and those organizations, both public
and private, which participate and benefit through our programs. The City will take positive and realistic
affirmative steps to ensure that all persons and/or firms wishing to participate in its programs are given an equal
and equitable chance to participate. Along with the Title VI Program, a Disability Nondiscrimination Policy
and an accommodation request process will be created as well.
Does this Agenda Action Item align with a Commission Priority? No
If yes, please list the Commission Priority:
Communications Plan:
Account Name:
Funds Available:
Account Number:
Staff Recommendation: Approve and renew the City of Paducah Title VI Program Plan effective July 1,
2025.
Attachments:
1. MO Title VI Program Plan FY26
2. FINAL COP Title VI Plan FY26
MUNICIPAL ORDER NO. _______
A MUNICIPAL ORDER ADOPTING THE TITLE VI PROGRAM PLAN
FOR THE CITY OF PADUCAH FOR JULY 1, 2025 THROUGH JUNE 30,
2026
WHEREAS, the City of Paducah (City), as a federal grant recipient, is required by
the Federal Transit Administration (FTA) to conform to Title VI of the Civil Rights Act of 1964
and its amendments; and
WHEREAS, the City is committed to enforcing the provisions of Title VI and
protecting the rights and opportunities of all persons associated with the agency; and
WHEREAS, the City now wishes to approve and implement the City of Paducah
Title VI Program Plan.
NOW, THEREFORE, BE IT ORDERED BY THE CITY OF PADUCAH,
KENTUCKY:
SECTION 1. That the City of Paducah hereby approves and implements the City
of Paducah Title VI Program Plan, which shall be effective July 1, 2025, through June 30, 2026.
SECTION 2. That the Mayor is hereby authorized to execute all documents
necessary as authorized in Section 1, above.
SECTION 3. This order shall be in full force and effect from and after the date
of its adoption.
____________________________________
George Bray, Mayor
ATTEST:
_______________________________
Lindsay Parish, City Clerk
Adopted by the Board of Commissioners, __________________
Recorded by Claudia Meeks, Assistant City Clerk, _____________________
\\mo\\Title VI Program Plan FY26
TITLE VI PROGRAM PLAN
City of Paducah
July 1, 2025 June 30, 2026
Daron Jordan, City Manager
Stefanie Wilcox, Human Resources Director & Title VI Coordinator
1
TABLE OF CONTENTS
I. Glossary/Definitions .................................................................................... 3
II. Overview ..................................................................................................... 8
a. Policy Statement .................................................................................... 9
III. General Reporting ...................................................................................... 13
a. Organizational Chart ............................................................................ 18
IV. Statement of Assurances ............................................................................ 20
V. Program Review Procedures ..................................................................... 23
a. Special Emphasis Program Areas ........................................................ 23
b. Sub-Recipient Review Procedures ...................................................... 24
VI. Programs or Activities Subject to Title VI ................................................ 25
VII. Compliance ................................................................................................ 27
VIII. Environmental Justice................................................................................ 28
IX. Training ..................................................................................................... 29
X. Data Collection/Reporting Analysis .......................................................... 30
XI. Complaint Procedure ................................................................................. 31
a. CITY Title VI Investigations, Complaints and Lawsuits .................... 34
XII. Public Participation Plan ........................................................................... 35
XIII. Language Access Plan ............................................................................... 39
XIV. Minority Representation ............................................................................ 46
XV. Demographics of CITY ............................................................................ 47
XVI. Review of STA Directives ......................................................................... 49
XVII. Compliance/Noncompliance ..................................................................... 50
XVIII. Appendices ................................................................................................ 51
XIX. Board Policy Approval .............................................................................. 61
2
I. GLOSSARY/DEFINITIONS
Affirmative Action: a good-faith effort to eliminate past and present discrimination in all federally
assisted programs and to ensure future nondiscriminatory practices.
African American (Black): A person having origins in any of the black racial groups of Africa.
American Indian or Alaska Native: a person having origins in any of the original peoples of North
and South America (including Central America) who maintains cultural identification through
tribal affiliation or community attachment.
Applicant: an eligible public entity or organization that submits an application for financial
assistance under a program administered on behalf of the State.
Asian: a person having origins in any of the original peoples of the Far East, Southeast Asia, or
the Indian Subcontinent, including, for example, Cambodia, China, India, Japan, Korea, Malaysia,
Pakistan, the Philippine Islands, Thailand and Vietnam.
Assurance: a written or signed by the agency head in
which a recipient agrees to administer federally assisted programs in accordance with civil rights
laws and regulations.
Beneficiary: any person or group of people (other than states) entitled to receive benefits, directly
or indirectly, from any federally assisted program (i.e., relocated persons, impacted citizens,
communities, etc.).
CITY: shall refer to the City of Paducah, a home rule city of the Commonwealth of Kentucky.
City Manager: The City of Paducah City Manager is responsible for Title VI activities in
accordance with KYTC policies and directives as well as state/federal statute/law and state/federal
administrative regulations and have the authority to appoint Title VI Designee(s) for the City.
Complaint: a verbal or written allegation of discrimination that indicates that a federally assisted
program is operated in such a manner that it results in disparity of treatment to persons or groups
of persons because of race, color or national origin.
Compliance: a satisfactory condition wherein an applicant, recipient, or sub recipient has
effectively implemented all of the Title VI requirements or can demonstrate that every good-faith
effort toward achieving this end has been made.
Contract: a mutually binding legal relationship or any modification thereof obligating the seller to
furnish supplies or services, including construction, and obligating the buyer to pay for them.
Throughout this document, a lease is considered a contract.
Contractor: any person, corporation, partnership, organization, or incorporated association that
participates, through a contract or subcontract, in any program or activity covered by this plan
including lessees.
3
Discrimination: involves any act or inaction, whether intentional or unintentional in any program
or activity of a federal aid recipient, sub recipient, or contractor, which results in disparate
treatment, disparate impact, or perpetuating the effects of prior discrimination based on race, color,
sex, national origin, age, disability or in the case of disability, failing to make a reasonable
accommodation.
Division: one of the administrative subdivisions of an office of the Kentucky Transportation
Cabinet. The term district should be considered equivalent to division as an administrative
subdivision of an office of the KYTC.
Federal Assistance:
Grants and loans of federal funds
The grant or donation of federal property and interests in property
The detail of federal personnel
The sale and lease of, and the permission to use (on other than a casual
or transient basis), federal property or any interest in such property
without
Consideration or with nominal consideration, or with consideration
which is reduced for the purpose of assisting the recipient, or in
recognition of the public interest to be served by such sale or lease to
the recipient
Any federal agreement, arrangement, or other contract that has, as one
of its purposes, the provision of assistance
Federal Highway Administration or FHWA: agency within the U.S. Department of
Transportation that supports State and local governments in the design, construction and
federally and tribal owned lands (Federal Lands Highway Program).
Grantee: any public or private agency, institution or organization to whom federal financial
assistance is intended for any program.
Hispanic or Latino: A person of Cuban, Mexican, Puerto Rican, South or Central American or
other Spanish culture or origin, regardless of race.
Interpretation: The process of listening to something in one language and orally interpreting it in
another. The mix of LEP services under the Oral Languages Services is as follows:
Hiring bilingual staff
Hiring staff interpreters
Using telephone interpreter lines
Using community volunteers
Use of family members, friends, and other customers/passengers as interpreters
4
KentuckyTransportationCabinetorKYTC:theagencyofKentuckychargedbyitslawswiththe
responsibility for all modes of transportation.
Limited English Proficiency or LEP: Individuals who do not speak English as their primary
language and who have a limited ability to read, speak, write or understand English can be limited
English proficient.
Metropolitan Planning Organization or MPO: policy board of an organization created and
designated to carry out the metropolitan transportation planning process. MPOs are required to
represent localities in all Urbanized Areas (UZA) of populations over 50,000, as determined by
the US Census. MPOs are designated by agreement between the Governor and units of general-
purpose local government that together represent at least 75 percent of the affected population
(including the largest incorporated city, based on population, as named by the Bureau of the
Census) or in accordance with procedures established by applicable State or local law. When
submitting the transportation improvement program (described below), to the State for inclusion
in the statewide program, MPOs self-certify that they have met all federal requirements.
Minority: A person or groups of persons differing from others in some characteristics who may be
subjected to differential treatment based on race, color or national origin. Includes African
Americans, Hispanics or Latinos, American Indian or Alaska Native, Asians and Native Hawaiian
or Other Pacific Islander.
Native Hawaiian or Other Pacific Islander: A person having origins in any of the original peoples
of Hawaii, Guam, Samoa, or other Pacific Islands.
Non-compliance: the condition wherein a recipient has failed to meet prescribed requirements and
has shown a lack of good-faith effort in implementing all of the Title VI requirements.
Non-minority or non-minority group people: Caucasians
Persons: Where designation of persons by race, color or national origin is required, the following
designations ordinarily may be used: White not of Hispanic origin, Black not of Hispanic
origin, Hispanic, Asian or Pacific Islander, American Indian or Alaskan Native. Additional
subcategories based on national origin or primary language spoken may be used, where
appropriate, on either a national or a regional basis.
Primary recipient: KYTC or any department, division, or agency authorized to request federal
assistance on behalf of sub-recipients and to distribute financial assistance to sub-
contracts for carrying out a program.
Program: includes any highway, project, or activity that provides services, financial aid or other
benefits to individuals, including education or training, work opportunities, health, welfare,
rehabilitation, housing or other services, whether provided directly by the recipient of federal
financial assistance or provided by others through contracts or other arrangements with the
recipient (i.e. Planning, Environment, Design, Right-of-Way, Construction, Safety, & Research).
5
Program area officials: the officials who are responsible for carrying out technical program
responsibilities.
Public participation: an open process in which the rights of the community to be informed to
provide comments to the Government and to receive a response from the Government are met
through a full opportunity to be involved and to express needs and goals.
Recipient: Kentucky or any political subdivision or instrumentality thereof or any public or private
agency, institution, or organization or other entity; or any individual in Kentucky to whom federal
assistance is extended, either directly or through another recipient, for any program. Recipient
includes any successor, assignee, or transferee thereof. The term recipient does not include any
ultimate beneficiary under any such program. Examples of recipients include MPOs, Council of
Governments (COG), towns, cities, counties, school districts or any sub recipient.
Secretary: The chief administrative officer of the Kentucky Transportation Cabinet or KYTC.
Statewide Transportation Improvement Program or STIP: statewide transportation improvement
program (STIP) for all areas of the State covering a period of at least four years. The STIP is a
staged, multi-year, statewide intermodal program of transportation projects, consistent with the
statewide transportation plan and planning processes as well as metropolitan plans, transportation
improvement programs (TIP), and planning processes. The STIP must be developed in cooperation
with the metropolitan planning organizations (MPO), public transit providers, and any Regional
Transportation Planning Organizations (RTPO) in the State and must be compatible with the TIPs
for the metropolitan areas in the State.
Statewide Transportation Plan or STP: a long-range transportation plan that provides for the
development and implementation of the multimodal transportation system (including transit,
highway, bicycle, pedestrian and accessible transportation) for the State. This plan must identify
how the transportation s
sustainability goals for at least a 20-year planning horizon.
Sub-grantee: Any public or private agency, institution, or organization to whom federal financial
assistance is intended (through another recipient) for any program.
Title VI Officer, Coordinator or Liaison: refers to the responsible City official in matters relating
to Title VI. The Title VI Officer, Coordinator or Liaison reports to and assists the City Manager
of the City in carrying out the required Title VI responsibilities.
Title VI Program: the system of requirements developed to implement Title VI of the Civil Rights
provisions of other federal non-discrimination authorities to the extent that they prohibit
discrimination on the grounds of race, color, national origin, sex, age and disability, including
income level and Limited English Proficiency in programs or activities receiving federal financial
assistance.
Translation: Translation is the replacement of a written text from one language into an equivalent
written text in another language.
6
Transportation Improvement Programs or TIP: plan developed by Metropolitan Planning
Organization cooperation with the State and public transit providers detailing a list of upcoming
transportation projects, covering a period of at least four years. It should include capital and non-
capital surface transportation projects, bicycle and pedestrian facilities and other transportation
Strategic Highway Safety Plan. The TIP should include all regionally significant projects receiving
FHWA or FTA funds, or for which FHWA or FTA approval is required.
White: A person having origins in any of the original peoples of Europe, the Middle East, or North
Africa.
7
II. OVERVIEW
Title VI of the Civil Rights Act of 1964 is a non-discrimination statute. Specifically, Title VI
provides that no person in the United States shall, on the ground of race, color or national origin,
be excluded from participation in, be denied the benefits of, or be subjected to discrimination under
any program or activity receiving federal financial assistance (42 U.S.C. Section 2000d). Each
federal department and agency, which is empowered to extend Federal financial assistance to any
program or activity, by way of grant, loan, federal personnel or any federal agreement contract is
authorized and directed to make the provisions of Section 2000d of this title.
The City of Paducah Board of Commissioners is the governing body of the City. As a recipient of
federal funds through grant program(s), the City is subject to Title VI of the Civil Rights Act of
1964. The City works to ensure that nondiscriminatory services are offered throughout the region
thereby enhancing both the quality of life and the economic vitality.
Non-Discrimination Authorities
Title VI of the Civil Rights Act of 1964 (42 USC 2000d et seq.)
Section 162 (a) of the Federal Aid Highway Act of 1973 (23 USC 324)
Age Discrimination Act of 1975
Section 504 of the Rehabilitation Act of 1973
Americans With Disabilities Act of 1990
Civil Rights Restoration Act of 1987
49 CFR Part 21
23 CFR Part 200
U.S. DOT Order 1050.2
Executive Order #12898 (Environmental Justice)
Executive Order #13166 (Limited-English-Proficiency)
8
City of Paducah
th
300 South 5 Street
Paducah, KY 42003
(270) 444-8550
Fax: (270) 444-8515
www.paducahky.gov
The City of Paducah
The City of Paducah (CITY) is committed to a policy of non-discrimination in the conduct of its
business, including its Title VI responsibilities delivery of equitable and accessible transportation
services. CITY recognizes its responsibilities to the communities in which it operates and to the
society it serves. It is CITY
is accomplished.
Statement of Policy:
CITY as a federal grant recipient, is required by the Federal Transit Administration (FTA) to
conform to Title VI of the Civil Rights Act of 1964 and its amendments. Section 601 of Title VI
States, on the grounds of
race, color or national origin be excluded from participation in, be denied the benefits of, or be
subjected to discrimination, under any program or activity receiving Federal financial assistance.
Presidential Executive Order 12898 addresses environmental justice in minority and low-income
populations. Presidential Executive Order 13166 addresses services to those individuals with
limited English proficiency.
CITY is committed to enforcing the provisions of Title VI and protecting the rights and
opportunities of all persons associated with the agency. CITY following
all applicable laws and regulations that affect the Region and those organizations, both public and
private, which participate and benefit through our programs.
CITY will take positive and realistic affirmative steps to ensure that all persons and/or firms
wishing to participate in its programs are given an equal and equitable chance to participate.
CITY-recipients and contractors are required to prevent discrimination and ensure
nondiscrimination in all of their programs, activities and services.
CITY is responsible for providing leadership, direction and policy to ensure compliance with Title
9
VIofthe1964CivilRightsActinrespecttoitstransitservices.Anyperson(s)whofeelsthat they
have been discriminated against is encouraged to report such violations in writing to the local
office:
CITY is to:
A. Encourage local transit agencies to provide that the level and quality of public
transportation service is provided in a nondiscriminatory manner;
B. Promote full and fair participation in public transportation decision-making without regard
to race, color, or national origin;
C. Make efforts to provide meaningful access to programs and activities by persons with
limited English proficiency;
D. Identify and address, as appropriate, disproportionately high and adverse human health and
environmental effects, including social and economic effects of programs and activities on
minority populations and low-income populations;
E. Work to prevent the denial, reduction, or delay in benefits related to programs and activities
that benefit minority populations or low-income populations and to notify beneficiaries of
protections available under Title VI;
F. Adhere to the Title VI reporting requirements of the Federal Transit Administration
through the annual Certification and Assurance module in TEAM and provide written Title
VI policy documentation every three years as required in as required in FTA circular
4702.1A;
G. Provide public notification of Title VI protections in all public places were CITY conducts
business or operations.
The responsibility for carrying out CITY by the
City Manager to Stefanie Wilcox, a Title VI Compliance Officer who will receive and investigate
Title VI complaints which come through the complaint procedure. However, all managers,
supervisors and employees share in the responsibility for making CITY
success. Additional information concerning CITY
be found on the CITY www.paducahky.gov or by calling 270-444-8800.
10
City of Paducah
th
300 South 5 Street
Paducah, KY 42003
(270) 444-8800
Fax: (270) 444-8515
www.paducahky.gov
City of Paducah
Title VI Policy Statement
It is the policy of the City of Paducah (CITY) to afford equal opportunity to all persons to the end
that no person in the United States shall, on the grounds of race, color, sex, disability, age or
national origin, be excluded from participation in, be denied the benefits of, or be otherwise
subjected to discrimination under any program or activity receiving federal financial assistance
from the U.S. Government.
Program and activities to which this policy applies include, but are not limited to, the use of grants
in connection with federal-aid highway systems, the Surface Transportation and Reauthorization
& Reform Act of 2015, the Highway Safety Act of 1966 and the National Traffic and Motor
Vehicle and Safety Act of 1966, leases of real property and the grant of permits, licenses,
easements and rights of way covering real property, Urban Mass Transportation Research
Programs, and other grants for the support of basic scientific research.
This policy shall be prominently posted in all personnel office, EEO offices, and on the CITY
internal website.
Signed and approved this ________ day of June 2025.
__________________________________________
Daron Jordan
City Manager
11
12
III. GENERAL REPORTING
TITLE VI NOTICE TO THE PUBLIC
See next page for the notice that is posted in all CITY administrative reception areas and
transfer centers. The text is printed on all route and schedule guides and is stated on the CITY
website.
13
City of Paducah
th
300 South 5 Street
Paducah, KY 42003
(270) 444-8550
Fax: (270) 444-8515
www.paducahky.gov
Notifying the Public of Rights Under Title VI
City of Paducah (CITY)
The CITY operates its programs without regard to race, color and national origin in accordance with the Title
VI of the Civil Rights Act. Any person who believes she or he has been subjected to discrimination prohibited
under Title VI may file a complaint with CITY.
To request or receive additional information on CITY
a complaint, please contact the person listed below:
Stefanie Wilcox, Title VI Coordinator
City of Paducah
th
300 South 5 Street
Paducah, Kentucky 42003
Telephone: 270-444-8540 TTY 800-648-6056
Email Address: swilcox@paducahky.gov
Visit website: www.paducahky.gov
To file a discrimination complaint, the written complaint must be filed to the address above within 180 days of
the alleged discrimination. Written complaints may also be filed with the U.S. Department of
Transportation/Federal Transit Administration (FTA) no later than 180 days after the date of the alleged
discrimination, unless the time for filing is extended by FTA. Attention: Title VI Program Coordinator,
th
East Building, 5Floor-TCR, 1200 New Jersey Ave., SE Washington, DC 20590. Written complaints
may also be filed with the KYTC Office of Transportation Delivery Project Manager or Title VI
Coordinator, Kentucky Transportation Cabinet, 200 Mero Street, Frankfort, KY 40622. To
accommodate limited English proficient individuals, oral complaints to be documented and/or translated may
also be given at the above address.
If information is needed in another language, contact CITY at 270-444-8540.
14
15
City of Paducah
th
300 South 5 Street
Paducah, KY 42003
(270) 444-8550
Fax: (270) 444-8515
www.paducahky.gov
Notificación al público de los derechos bajo el Título VI
City of Paducah (CITY)
CITY opera sus programas sin tener en cuenta la raza, el color y origen nacional de acuerdo con
el Título VI de la Ley de Derechos Civiles. Cualquier persona que crea que ella o él ha sido
agraviada por cualquier práctica discriminatoria illegal bajo el Titulo VI puede presenter una
queja ante CITY.
Para más información sobre el programa de derechos civiles de CITY y los procedimientos
para presentar una queja, comuníquese con el CITY a:
Stefanie Wilcox, Coordinador Título VI
Ciudad de Paducah
300 Calle Quinta Sur
Paducah, Kentucky 42003
Teléfono: 270-247-7171 TTY 800-648-6056
Dirección de correo electrónico: swilcox@paducahky.gov
Visite el sitio web: www.paducahky.gov
Para presentar una queja por discriminación, la queja por escrito debe presentarse a la dirección antes
mencionada dentro de los 180 días de la supuesta discriminación. Las quejas por escrito también se pueden
presentar ante el Departamento de Transporte de los EE. UU. / Administración Federal de Tránsito (FTA)
a más tardar 180 días después de la fecha de la supuesta discriminación, a menos que el FTA prorrogue el
plazo de presentación. Atención: Coordinador del Programa Título VI, Edificio Este, 5to Piso-TCR,
1200 New Jersey Ave., SE Washington, DC 20590. También se pueden presentar quejas por escrito
ante el Gerente del Proyecto de Entrega de la Oficina de Transporte de KYTC o Coordinador del
Título VI, Gabinete de Transporte de Kentucky, 200 Mero Street, Frankfort, KY 40622. Para dar
cabida a personas con conocimientos limitados de inglés, las quejas orales que deben documentarse y / o
traducirse también pueden presentarse en la dirección anterior.
Si necesita información en otro idioma, comuníquese con CITY al 270-444-8540.
16
Title VI Program Coordinator or Liaison
Daron Jordan, City Manager, has overall responsibility for implementation, compliance and reporting
with respect to Title VI. Inquiries related to these activities should be directed to:
City Manager Title VI Coordinator
Daron Jordan Stefanie Wilcox
thth
300 South 5 Street 300 South 5 Street
Paducah, KY 42003 Paducah, KY 42003
(270) 444-8800 (270) 444-8800
(270) 444-8503 (270) 444-8540
djordan@paducahky.gov swilcox@paducahky.gov
Stefanie Wilcox is designated as the Title VI Coordinator and is responsible for the oversight and
coordination of CITYnce with Title VI and all related statutes, regulations and directives.
The Title VI Coordinator has direct access to the CITYCity Manager. General responsibilities of the
Title VI Coordinator include but are not limited to the following:
Coordinating Title VI program development with Metropolitan
Planning Organizations (MPOs), Local Public Agencies (LPAs) and
CITY managers and staff
Establishing procedures for processing Title VI program reviews and/or
sub-recipient/contractor reviews
Coordinating Title VI training for CITY staff, sub-
recipients/contractors and stakeholders
Preparing required reports
Providing guidance and advice on the Title VI Program to CITY staff
Annually updating CITY Plan
17
CITY OF PADUCAH TITLE VI ORG CHART
18
The summary of race and national origin for City of Paducah employees is as follows:
RACE/NATIONAL ORGIN NUMBER PERCENTAGE
White Females 75 24%
White Males 191 62%
African American Females 8 3%
African American Males 26 8%
Hispanic Females 3 1%
Hispanic Males 3 1%
Other Females 2 1%
Other Males 2 1%
Total 310 100%
19
IV. STATEMENT OF ASSURANCES
City of Paducah
th
300 South 5 Street
Paducah, KY 42003
(270) 444-8800
Fax: (270) 444-8515
www.paducahky.gov
STANDARD TITLE VI ASSURANCE
City of Paducah
The City of Paducah, (
condition to receiving any Federal financial assistance from the U.S. Department of
Transportation, it will comply with Title VI of the Civil Rights Act of 1964, 78Stat. 252, 42
U.S.C. 2000d-4 (hereinafter referred to as the and all requirements imposed by or pursuant
to Title 49, Code of Federal Regulations, U.S. Department of Transportation, Subtitle A, Office of
the Secretary, (49 CFR, Part 21) Nondiscrimination in Federally Assisted Program of the
Department of Transportation- Effectuation of Title VI of the Civil Rights Act of 1964 (hereinafter
other pertinent directives, no person in the United States
shall, on the grounds of race, color, national origin, sex, age (over 40), religion sexual orientation,
gender identity, veteran status, or disability be excluded from participation in, be denied the
benefits of, or be otherwise subjected to discrimination under any program or activity for which
the Recipient receives Federal financial assistance from the U.S. Department of Transportation,
including the Federal Highway Administration, and hereby give assurance that it will promptly
take any necessary measures to effectuate the agreement. This assurance is required by subsection
21.7(a) (1) of the Regulations.
More specifically and without limiting the above general assurance, the Recipient hereby gives the
following specifies assurances with respects to its Federal-aid Highway Program:
1. That the Recipient agrees that each and each as defined in subsections
21,23(b) and 21.23I
compliance with all requirements imposed by, or pursuant to, the Regulations.
2. That the Recipient shall insert the following notification in all solicitations for bids for
work or material subject of the Regulations made in connection with the Federal-aid
Highway Program and, in an adapted form in all proposals for negotiated agreements.
20
Statement of Assurances
Page 2 of 3
Construction Proposals
The City of Paducah, in accordance with the provisions of the Title VI of the Civil Rights
Act of 1964 (78 Stat. 252) and the regulations of the Federal Department of Transportation (49
CFR, Part 21), issued pursuant to such Act, hereby notifies all bidders that it will affirmatively
insure that the contract entered into pursuant to this advertisement will be awarded to the lowest
responsible bidder without discrimination on the grounds of race, color, national origin, sex, age
(over 40), religion, sexual orientation, gender identity, veteran status, or disability.
Agreements for Other Services
Compliance with Regulations: The Consultant shall comply with the regulations of the City
of Paducah and the Department of Highways, relative to nondiscrimination in Federally Assisted
Programs of the CITY, Department of Highways (49 CFR, Part 21) which are herein incorporated
by reference and made a part of this contract.
3. That the Recipient shall insert one of these nondiscrimination clauses in every contract
subject to the Act and the Regulations.
4. That the Recipient shall also insert into every relevant contract a clause stating that the
contractors will not discriminate against any employee or applicant for employment
because of race, color, national origin, sex, age (over 40), religion, sexual orientation,
gender identity, veteran status, or disability.
5. That where the Recipient receives Federal financial assistance to construct a facility, or
part of a facility, these assurances shall extend to the entire facility and facilities operated
in connection therewith.
6. That where the Recipient receives Federal financial assistance in the form of, or for the
acquisition of real property, these assurances shall extend to rights to space on, over, or
under such property.
7. That these assurances obligate the Recipients for the period during which Federal financial
assistance is extended to the program, except where the Federal financial assistance is to
provide, or is in the form of, personal property, real property or interest therein or structures
of improvement thereon, in which case the assurance obligates the Recipient or any
transferee for the longer of the following periods: (a) the period during which the property
is used for a purpose for which the Federal financial assistance is extended, or for another
purpose involving the provision of similar services or benefit; or (b) the period during
which the Recipient retains ownership or possession of the property.
21
Statement of Assurances
Page 3 of 3
8. The recipient shall provide for such methods of administration for the program as are found
by the Secretary of Transportation, or the delegated authority, to give a reasonable
guarantee that it, other recipients, sub grantees, contractors, subcontractors, transferees,
successors in interest, and other participants of Federal financial assistance under such
program will comply with all requirements imposed by or pursuant to the Act, the
Regulations and these assurances.
9. The Recipient agrees that the United States has a right to seek judicial enforcement with
regard to any matter arising under the Act, the Regulations, and these assurances.
These assurances are given in consideration of, and for, obtaining all Federal grants, loans,
contracts, property, discounts, and/or other Federal financial assistance extended after the date
hereof, to the Recipient by the U.S. Department of Transportation under the Federal-aid Highway
Program. The person whose signature appears below is authorized to sign these assurances on
behalf of the Recipient.
Signed and approved this day of June 2025.
__________________________________________
Daron Jordan
City Manager
22
V. PROGRAM REVIEW PROCEDURES
Each division within CITY and all its departments and program areas are responsible for the
following under Title VI:
Collecting and analyzing data on minority and low-income populations
to determine the potential impact of proposed plans, programs and
projects
Ensuring all contract documents contain the appropriate Title VI
provisions
Consulting with the Title VI Officer, Coordinator or Liaison and the
City Manager when complaints are received, prior to sending any
information to KYTC.
Ensuring that all people are treated equitably regardless of race, color or
national origin
Monitoring Title VI accomplishments, notifying the Title VI Officer,
Coordinator or Liaison of problem areas and summarizing activities for
inclusion in the Title VI Plan Update
Developing and updating internal policies and procedures to ensure
Title VI compliance during all phases of projects and activities
Ensuring that all business pertaining to the selection, negotiation, and
administration of consultant contracts and agreements is accomplished
without discrimination based on race, color or national origin
Ensuring that efforts are made to include minority and women owned
businesses in consideration for contracts
Ensuring that internal and external publications and all other relevant
communications disseminated to the public include the Title VI policy
reference
Providing reasonable accommodations, information in the appropriate
language or interpreters as needed for individuals with disabilities and
LEP persons
Special Emphasis Program Areas
The CITY
collected through program review procedures, the Title VI Coordinator will determine whether a
discrimination. The Title VI Coordinator will notify the City Manager of the CITY, who will ensure
that the program area complies with the remediation plan.
23
Sub-Recipient Review Procedures
Each sub-recipient of federal funds under grants administered by the CITY shall have a Title VI plan
which shall be available for review by CITY staff. The CITY shall periodically review all programs
funded through federal assistance for those sub-recipients who have been found by the CITY to be
in non-compliance with Title VI. Reviews will use a desk audit, self-survey, and/or onsite
inspections. Employees or grant sub-recipients who refuse to voluntarily comply with Title VI or to
take corrective actions required by the CITY shall face disciplinary action, or in the case of grant
sub-recipients, may face termination or suspension of the contractual relationship with the CITY.
Any trends, patterns of discrimination, or complaints filed against a sub-recipient will automatically
trigger the review process.
24
VI.PROGRAMS OR ACTIVITIES SUBJECT TO TITLEVI
A. Development Block Grant (CDBG),
U.S
Innovation and Opportunity Act (WIOA), funding and U.S. Health and Human Services,
Administration for Community Living programs. Funds are designated for the following
program areas:
Housing
Community Projects
Public Services
Public Facilities
Economic Development
Community Emergency Relief Fund
U.S. Department of Labor WIOA
Transportation
Aging
The U.S. Department of Housing and Urban Development (HUD) funded Community
Development Block Grant (CDBG) program for DLG, Federal Highway
Administration, Department of Labor, WIOA, and Health and Human Services,
Administration for Community Living to provide assistance to communities for use
in revitalizing neighborhoods, expanding affordable housing and economic
opportunities, providing infrastructure and/or improving community facilities,
providing workforce development to the Purchase region, and the provision of
services for our Senior Citizens.
B. The Land and Water Conservation Fund (LWCF) provides federal grant funds to protect
important natural areas, to acquire land for outdoor recreation and to development or
renovate public outdoor recreation facilities such as campgrounds, picnic areas, sports &
playfields, swimming facilities, boating facilities, fishing facilities, trail, natural areas and
passive parks.
Potential Beneficiaries: Cities and counties, state and federal agencies are eligible to apply
for funding. The maximum grant amount is $250,000. The minimum amount is $12,500. It
is a 50% matching reimbursement program.
C. The Recreational Trails Program provides grant funds to develop and renovate recreation
trails for both motorized and non-motorized use. It does not fund equipment such as
mowers and gators.
Potential Beneficiaries: Eligible applicants are city and county governments, state and
federal agencies, and non-profit organizations.
25
D. The ARC is a federal-state economic development program. To assist in the economic
development of Appalachia through a diversity of projects in the areas of public
infrastructure (water, sewer, solid waste, housing, and telecommunications), human
resource development (education/workforce development, affordable/accessible
healthcare, and leadership development) and business/entrepreneurial development.
Potential Beneficiaries Local governments, special districts, and non-profit entities that
include Kentuckys 51 most eastern and south-central Counties are eligible to apply for the
grant dollars. Thirty-two distressed counties also have access to a separate restricted
allocation of funds.
E. The National Forest Receipt-Sharing Payments -
funds to counties. The State Local Finance Officer receives notice of wire transfer
from the US Department of Agriculture Forest Service for funds to be distributed
annually to various counties.
Potential Beneficiaries: Counties.
-
State Local Finance Officer receives a check annually from the US Army Corps of
Engineers. The check is deposited with the KY State Treasurer, authorization for
payment to Counties is processed and checks are then prepared to send this money to the
Counties in accordance with the statement from the federal government which was
enclosed with the check.
Potential Beneficiaries: Counties.
The Kentucky Infrastructure Authority administers two federal grant programs from the
Environmental Protection Agency:
1. Capitalization Grants for Clean Water State Revolving Funds provides assistance for: (1)
construction of publicly owned wastewater treatment works; and (2) nonpoint source
management activities. Funds are loaned to local government entities.
2. Capitalization Grants for Drinking Water State Revolving Funds provides assistance for
infrastructure improvement projects that are needed to achieve or maintain compliance
with Safe Drinking Water Act requirements, protect public health, and assist systems with
economic need. Funds are loaned to local government entities.
26
VII. COMPLIANCE
A. The CITY shall make every effort to regulate, monitor, review, and report on the federal
programs to assure compliance.
B. Upon a finding by the CITY of noncompliance, CITY shall take the following actions
with regard to:
1. Processing
The compliance officer shall immediately notify the Responsible Official in writing of the
violations held to constitute noncompliance with Title VI and of the steps necessary to correct
these violations.
2. Reporting
The compliance officer shall notify the sub-recipient or employee found to be in noncompliance,
and corrective measures necessary to remedy the violations.
3. Resolution
The CITY shall attempt to secure voluntary compliance with Title VI. In the event that efforts to
secure voluntary compliance are not secured within a reasonable period of time, the compliance
officer will notify the Responsible Official, in writing, of the recommended corrective action.
4. Enforcement of corrective actions
The Responsible Official shall implement corrective actions within thirty (30) days of receipt and
acceptance of the notification of recommended corrective action.
Employees or grant sub-recipients who refuse to voluntarily comply with Title VI or to take
corrective actions required by the CITY shall face disciplinary action, or in the case of grant sub-
recipients, may face termination or suspension of the contractual relationship with CITY.
5. Monitoring of programs
The CITY shall undertake to periodically monitor all programs funded through federal assistance
for those sub-recipients who have been found by the CITY to be in non-compliance with Title VI.
27
VIII. ENVIRONMENTAL JUSTICE (EJ)
Executive Order (E.O. 12898) was issued to focus federal attention on the environmental and
human health conditions in minority and low-income communities to promote non-
discrimination in federal programs substantially affecting human health and the environment and
to provide minority and low-income communities access to public information on and an
opportunity for public participation in matters relating to human health or the environment.
The CITY will utilize the US Census Bureau data, the American Community survey data, and
the following checklist to identify targeted populations:
Make a list of potential demographic groups to consider for
the region or start with the required EJ populations defined
by the Executive Order and supportive guidance
Consider groups that are underrepresented in typical public
involvement and transportation decision making processes,
have limited access to the full benefits of the transportation
system or have encountered disproportionate impacts from
past transportation decisions
Decide on the level of detail required for identifying groups
spatially and identifying data sources to use to conduct a
spatial demographic profile
Engage leaders and representatives of demographic groups
to help identify target populations, spatially and non-
spatially
28
IX. AGENCY TITLE VI TRAINING PLAN
All CITY staff will be provided with the Title VI plan and will be educated on procedures and
services available. Each employee is required annually to receive and document Title VI training
clarification, if necessary. This information will also be part of the CITY orientation process
for new hires. Annual employee training will be conducted in April and/or May of 2025. Each
employee will view the training at their individual workstation. Employee will sign an
acknowledgement (see example at Appendix F) that they have understood the Title VI training
and have the responsibility of abiding by the Title VI nondiscrimination plan. Those training
records will be on file at the CITY.
Part of CITY Title VI plan is deciding what level of staff training is needed. It is important that
staff members, especially those having contact with the public, know their obligation to provide
meaningful access to information and services for Title VI covered persons. Even staff members
who do not interact regularly with Title VI covered persons should be aware of and understand the
Title VI plan. Properly training staff is a key element in the effective implementation of the Title
VI plan.
Staff and Operations staff are trained to recognize when a Title VI covered person is need of
assistance. This awareness training, which is delivered by video, is included in Reservations
Orientation and Initial On-The-Job Training.
29
X. DATA COLLECTION/REPORTING/ANALYSIS
Statistical data on race, color, national origin, sex, age, disability, and LEP of participants in and
beneficiaries of the CITY
gathered, analyzed, and maintained by the CITY to determine the transportation investment
benefits and burdens to the population, including minority and low-income populations. Each of
the CITY
gathering procedures will be reviewed regularly to ensure sufficiency of the data in meeting the
requirements of Title VI program administration. Analysis of the data collected by the program
emphasis areas may include:
The race, color, national origin, sex, age, disability, income
and LEP of the population eligible to be served
Socioeconomic Assessmen
impacts to the human environment
Persons to include in the decision-making process
Percent of benefits allocated to persons below the poverty
line vs. persons above the poverty line
Distribution of benefits (dollars, facilities, systems,
projects) to groups and communities
Projected population increases versus planned facilities and
types of facilities
Language needs assessment
Transportation needs of all persons within boundaries of
plans or projects
Strategies to address impacts
The manner in which services are or will be provided and
the related data necessary for determining whether any
persons are or will be denied such services on the basis of
prohibited discrimination
The location of existing or proposed facilities connected
with the program and related information for determining
whether the location has or will have the effect of
unnecessarily denying access to any persons on the basis of
prohibited discrimination
The present or proposed membership, by race, color,
national origin, sex, disability and age, in any planning or
advisory body which is an integral part of the program
Strategies to disseminate information
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XI. CITY TITLE VI COMPLAINT PROCEDURE
These procedures cover all complaints under Title VI of the Civil Rights Act of 1964, Executive
Low- for
Person with Limited English Pro
activity administered by City of Paducah.
Any person who believes she/he or any specific class of persons has been subjected to
discrimination or retaliation prohibited by any of the Civil Rights authorities, based upon race,
color, or national origin by City of Paducah (hereinafter referred to as CITY may file a written
complaint in accordance with the following procedure:
Who can file?
Any person who believes theyor with a specific class of personswere subjected to
discrimination on the basis of race, color, or national origin in the programs and activities of a
CITY may file a Title VI complaint.
Where can one file?
Complaints may be filed with KYTC, FHWA Division Offices, the FHWA Headquarters Office
of Civil Rights, the United States Department of Transportation (USDOT) Departmental Office
of Civil Rights, or the U.S. Department of Justice. See addresses below.
When must one file?
According to U.S. DOT regulations, 49 CFR § 21.11(b), a complaint must be filed not later than
180 days after the date of the last instance of alleged discrimination, unless the time for filing is
extended by the investigating agency.
What should a complaint look like?
Complaints should be in writing and signed and may be filed by mail, fax, in person, or e-mail.
However, the complainant may call CITY and provide the allegations by telephone, and the
agency will transcribe the allegations of the complaint as provided over the telephone and send a
written complaint to the complainant for correction and signature. A complaint should contain at
least the following information:
A written explanation of what has happened;
A way to contact the complainant;
The basis of the complaint (e.g., race, color, national origin);
The identification of a specific person/people and the respondent (e.g.,
agency/organization) alleged to have discriminated;
Sufficient information to understand the facts that led the complainant to believe that
discrimination occurred in a program or activity that receives Federal financial
assistance; and
The date(s) of the alleged discriminatory act(s). Complaint should indicate if the alleged
discrimination is on-going.
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How are complaints routed?
FHWA is responsible for all decisions regarding whether a complaint should be accepted,
dismissed, or referred to another agency. With this understanding, complaints should be routed in
the following ways:
All complaints should be routed to the FHWA Headquarters Office of Civil Rights
(HCR) for processing. HCR is responsible for all determinations regarding whether to
accept, dismiss, or transfer Title VI complaints filed against CITY.
Complaints filed with CITY will be forwarded to KYTC, KYTC will forward the
complaint FHWA Division Office, which will forward the complaint to
HCR. If a complaint is filed with KYTC, then the KYTC will forward the complaint to
FHWA Division Office, which should forward the complaint to HCR.
CITY and KYTC must log all complaints received.
When HCR decides on whether to accept, dismiss, or transfer the complaint, HCR will
notify the Complainant, the Kentucky FHWA Division Office, KYTC, and CITY.
Complaints may be sent to:
Kentucky Transportation Cabinet
Office for Civil Rights
th
200 Mero Street, 6 Floor
Frankfort, KY 40622
And/Or
US Federal Highway Administration Kentucky Division
John C Watts Federal Building
330 W Broadway St Ste 264,
Frankfort, KY 40601
Attention: Civil Rights Specialist
And/Or
Federal Highway Administration Headquarters - Office of Civil Rights
1200 New Jersey Avenue, SE HCR-40, Room E81-101
Washington, DC 20590
202-366-0693 or Fax: 202-366-1599
TTY: 202-366-5751
Additionally, complaints may be filed with the U.S. Department of Justice at:
Federal Coordination and Compliance Section - NWB Civil Rights Division
U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Washington, D.C. 20530
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What are the potential outcomes for processing a complaint?
There are four potential outcomes for processing complaints:
above), contains
sufficient information to support a claim under Title VI, and concerns matters under
the FHWA Division Office a written notice that it has accepted the complaint for
investigation.
Preliminary review: if it is unclear whether the complaint allegations are sufficient to
support a claim under Title VI, then HCR may (1) dismiss it or (2) engage in a
preliminary review to acquire additional information from the complainant and/or
respondent before deciding whether to accept, dismiss, or refer the complaint.
above), is not in writing and signed, or features other procedural/practical defects, then
HCR will send the complainant, respondent, and FHWA Kentucky Division Office a
written notice that it is dismissing the complaint.
Referral\\Dismissal: if the complaint is procedurally sufficient but FHWA (1) lacks
jurisdiction over the subject matter or (2) lacks jurisdiction over the respondent entity,
then HCR will either dismiss the complaint or refer it to another agency that does have
jurisdiction. If HCR dismisses the complaint, it will send the complainant, respondent,
and FHWA Kentucky Division Office a copy of the written dismissal notice. For
referrals, FHWA will send a written referral notice with a copy of the complaint to the
proper Federal agency and a copy to the USDOT Departmental Office of Civil Rights.
HCR is responsible for conducting all investigations of KYTC and CITY. In the case of a
complaint filed against CITY, HCR may either conduct the investigation itself, or it may
delegate the investigation to KYTC. If HCR chooses to delegate the investigation of CITY, HCR
will communicate its acceptance of the complaint to the complainant and respondent, but KYTC
will conduct all data requests, interviews, and analysis. KYTC will then create a Report of
Investigation (ROI), which it will send to HCR. Finally, HCR will review the ROI and compose
a Letter of Finding based on the ROI. All Letters of finding issued by FHWA are
administratively final.
What are the timeframes for investigations?
For FHWA, there is no regulatory timeframe for completing investigations. However, FHWA
strives to complete all tasks within 180 days from the date of acceptance. If KYTC is delegated
an investigation from FHWA, 23 CFR §200.9(b)(3) provides that KYTC must complete
investigations within 60 days of receipt (meaning the date it receives the delegated complaint
from FHWA).
Investigation files are confidential and will be maintained by KYTC. The contents of such files
will only be disclosed to appropriate KYTC personnel and federal authorities in accordance with
Federal and State laws. KYTC will retain files in accordance with records retention schedules
and all Federal guidelines.
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A. CITY TITLE VI INVESTIGATIONS, COMPLAINTS AND LAWSUITS
FTA Circular 4702.1B, Chapter III, Paragraph 7: In order to comply with the reporting requirements of 49 CFR
21.9(b), FTA requires all recipients to prepare and maintain a list of any of the following that allege discrimination
In accordance with 49 CFR 21.9(b), CITY must record and report any investigations, complaints,
or lawsuits involving allegations of discrimination. The records of these events shall include the
date the investigation, lawsuit, or complaint was filed; a summary of the allegations; the status of
the investigation, lawsuit, or complaint; and actions taken by CITY in response; and final findings
related to the investigation, lawsuit, or complaint. The records for the previous three (3) years shall
be included in the Title VI Plan when it is submitted to Kentucky Transportation Cabinet.
CITY has had no investigations, complaints, or lawsuits involving allegations of discrimination on
the basis of race, color, or national origin over the past three (3) years of calendar years 2021, 2022
and 2023. A summary of these incidents is recorded in Table 1.
Table 1: Summary of Investigations, Lawsuits, and Complaints
Date Summary Status Action(s)
(Month, Day, Year) (include basis of Taken
complaint: race,
color, or national origin)
Investigations
1. N/A N/A N/A N/A N/A
2.
Lawsuits
1. N/A N/A N/A N/A N/A
2.
Complaints
1. N/A N/A N/A N/A N/A
2.
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XII. PUBLIC PARTICIPATION PLAN
Public Involvement Plan/Community Outreach
The Public Participation Plan for CITY was developed to ensure that all members of the public,
including minorities, disabled, low income, LEP populations, are encouraged to participate in the
decision-making process. The public outreach strategies described in the Plan are designed to
provide public with effective access to information about CITY services and to provide means for
considering public comment.
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 the recipient.
As an agency receiving federal financial assistance, we have made the following community
outreach efforts:
Conduct local or regional public / information meetings as requested
Utilizing CITY Monthly Updates to reach educate and inform the public on various
programs
Conducting meetings with local officials and interested community leaders
Using e-mail distribution lists to provide information to interested persons and
agencies
Committee reports during the monthly CITY
Using the CITY Web Site, Facebook and Instagram to post
projects/information/comments and providing a link for public feedback
Address civic groups, chamber meetings, government meetings
Attending fiscal court and city council meetings
Utilize existing services / programs at the CITY to distribute information (i.e.
Housing, Aging, Workforce Investment)
Use surveys in newsletters, mail-outs, emails, Survey Monkey, etc. to gain public
input
Third Party Groups
The CITY will seek to increase public outreach to the underserved populations by contacting third
party groups and asking for their assistance in creating public awareness concerning transportation
related issues. The agencies, groups or people that wish to provide assistance can be utilized to
distribute materials pertaining to the statewide planning process. The members may be able to
utilize their brochures, newsletters, word of mouth, etc. concerning public meetings,
announcements of public review and comment periods for statewide planning documents by
sharing and distributing the information with the populations they service. These groups may
include, but not be limited to the following:
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Senior citizen centers
Public libraries
Public health departments
Public transit authorities
NAACP
Housing authorities
Post offices
United Way
Churches
Migrant education programs
Adult education programs
Chamber of commerce
Community based services
Human relations commissions
State government agencies
Disabled American Veterans
Public Meetings
The CITY will hold local or regional public information/input meetings as requested to provide
additional opportunities for public comments.
Newspapers
Information can be sent to the local newspapers in the region. While none are identified as
targeting specific traditionally underserved audiences, all have the potential to have traditionally
underserved subscribers. Information can be distributed to the newspapers relating to media
releases with announcements of meeting dates and locations, announcements of documents
available for public review and comment, and information about the statewide planning process.
Radio
Information can be sent to radio stations that serve the region. None are identified as targeting
specific traditionally underserved audiences, but all have the potential to have traditionally
served underserved listeners. Public meeting invitations can be sent to the stations along with
media releases with announcements of meeting dates and locations and information about the
statewide planning process or statewide documents available for public review and comment.
Television
Information can be sent to television stations that serve the region. This could include regular
network broadcast stations as well as local cable access channels that may be available
throughout the region. These channels can also be utilized in creating public awareness.
Traveling Exhibits
Traveling exhibits may be used to display information about public meetings, review of
statewide documents and the statewide planning process. The following locations may be
utilized to display information:
Public libraries
Post offices
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County courthouses
City halls
Community centers, meeting halls, churches
Chamber of commerce
KYTC Highway District 1 office
City of Paducah office
Schools
Public housing authorities
Senior citizen centers or housing
Malls, restaurants, shopping centers
Special event locations
Other identified locations through planning process
Coordinated Pubic Transit-Human Services Transportation Plan (Coordinated Plan)
(FAST) Act as amended by Federal and State Grants under Section 5311 Rural Area Formula
Program, Appalachian Development Transportation Assistance, Commonwealth Veterans
Transportation Program and JARC (Job Access and Reverse Commute) Programs under the
Federal Transit Act of 1964, as amended funds would be used for capital equipment and transit
st
operations. Under the requirements of Moving Ahead for Progress in the 21Century (MAP-21)
and the Enhanced Mobility of Senior and Individuals with Disabilities Program (5310) meetings
are and will be held to make improvements on a local coordinated plan for public transit.
Public Notification.
The CITY will disseminate Title VI Program information to employees, contractors, sub-
recipients and beneficiaries, as well as to the public. A variety of public notification and
participation procedures will be used to encourage the early and continuous involvement of
citizens, communities, and others interested in the planning process and decisions of the CITY.
The CITY will discuss and/or distribute Title VI information using mass media including, but not
limited to the following:
Policy statements
Inclusion of Title VI language in contracts
New employee orientation
Federal EEO posters
CITY website
Standard procedures manual
Significant publications, i.e., newspapers, brochures, and written literature
Mailings
Meetings open to the public
Events
Further notices informing the public and all employees that the CITY complies with Title VI of
the Civil Rights Act of 1964 will be displayed in a prominent place.
37
Customer Complaint Process
Citizens may call the CITY at 270-444-8540 to lodge a complaint or comment. All
complaints/comments are input into a database and then distributed to the relevant manager who
researches the complaint and responds back to the citizen.
Bilingual Outreach
Upon request CITY provides Spanish-speaking guests with information on public transit services
in Spanish. Staff will assist with outreach programs and public meetings as requested.
CITY submits an annual Section 5304 request to the Kentucky Transportation Cabinet and as part
of this process a regional coordination meeting is conducted. All meetings will seek to incorporate
minority, individuals with disabilities
Practices which will be included:
a. Scheduling meetings at times and locations that are convenient and accessible for minority and
LEP communities
b. Coordinating with community and faith-based organizations, education institutions, and other
organizations to implement public engagement strategies that reach out specifically to
members of affected minority and/or LEP communities.
c. Providing opportunities for public participation through means other than written
communications, such as personal interviews or use of audio or video recording devices to
capture oral comments.
38
XIII. LANGUAGE ACCESS PLAN
CITY
t Administration
Office of Civil Rights, dated April 13, 2007.
CITY recognizes the need to provide equal service opportunities for all individuals in the service
area. Most individuals living in the United States read, write, speak, and understand English. There
are many individuals, however, for whom English is not their primary language. The 2020 census
shows that 40.5 million individuals speak Spanish and over 10.8 million individuals speak an
Asian or Pacific Island language at home. If these individuals have a limited ability to read, write,
speak, or understand English, they are limited English proficient, or
Language for LEP individuals can potentially hinder some individuals from arranging
transportation services needed. The Federal Government funds an array of services that can be
made meaningfully accessible to otherwise eligible LEP persons. The Federal Government is
committed to improving the accessibility of these programs and activities to eligible LEP persons,
a goal that reinforces its equally important commitment to promoting programs and activities
designed to help individuals learn English.
Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq., and its implementing regulations
provide that no person in the United States shall, on the grounds of race, color, or national origin,
be excluded from participation in, be denied benefits of, or be otherwise subjected to
discrimination under any program or activity that receives Federal financial assistance. The
Supreme Court, in Lau v. Nichols, 414 U.S. 563 (1974), interpreted Title VI regulations prohibits
conduct that has a disproportionate effect on LEP persons because such conduct constitutes
national origin discrimination (page 5).
reprinted at 65 FR 50121 (August 16, 2000), directs each Federal agency to examine
the services it provides and develop and implement a system by which LEP persons can
meaningfully access those services. Federal agencies were instructed to publish guidance for their
respective recipients in order to assist them with their obligations to LEP persons under Title VI.
The Executive Order states that recipients must take reasonable steps to ensure meaningful access
to their programs and activities by LEP persons (Pages 5-6).
The U.S. DOT published revised guidance for its recipients on December 14, 2005. This document
states that Title VI and its implementing regulations require that DOT recipients take responsible
steps to ensure meaningful access to the benefits, services, information, and other important
portions of their programs and activities for individuals who are Limited English Proficient (LEP)
and that recipients should use DOT LEP Guidance to determine how best to comply with statutory
39
and regulatory obligations to provide meaningful access to the benefits, services, information, and
other important portions of their programs and activities for individuals who are LEP (page 6).
-
Dependent Guidelines for FTA Recipients which was published on April 13, 2007. Chapter IV,
Part 4 of this Circular reiterates the requirement to take responsible steps to ensure meaningful
access to benefits, services, and information for LEP persons and suggests that FTA recipients and
sub-recipients develop a language implementation plan consistent with the provisions of Section
VII of the DOT LEP guidance (page 6).
In accordance with the Executive Order, the U.S. Department of Transportation issued Policy
Guidance Concerning Recipients Responsibilities to Limited English Proficient (LEP) Persons,
which is modeled after guidance. As described in the guidance, DOT recipients are required
to take reasonable steps to ensure meaningful access to their programs and activities by LEP
persons. The guidance applies to all DOT funding recipients, which include state departments of
transportation, state motor vehicle administrations, airport operators, metropolitan planning
organizations, and regional, state, and local transit operators, among many others. Coverage
extends to a entire program or activity, i.e., to all parts of a operations. This
is true even if only one part of the recipient receives the Federal assistance. For example, if DOT
provides assistance to a state department of transportation to rehabilitate a particular highway on
the National Highway System, all of the operations of the entire state department of
transportationnot just the particular highway program or projectare covered by the DOT
guidance.
The DOT guidance outlines four factors recipients should apply to the various kinds of contacts
they have with the public to assess language needs and decide what reasonable steps they should
take to ensure meaningful access for LEP persons:
1. The number or proportion of LEP persons eligible to be served or likely to be encountered
by a program, activity, or service of the recipient or grantee.
2. The frequency with which LEP individuals come in contact with the program.
3. The nature and importance of the program, activity, or service provided by the recipient to
lives.
4. The resources available to the recipient and costs.
The greater the number or proportion of eligible LEP persons; the greater the frequency with which
they have contact with a program, activity, or service; and the greater the importance of that
program, activity, or service, the more likely enhanced language services will be needed. Smaller
recipients with more limited budgets are typically not expected to provide the same level of
suggest a balance that ensures meaningful access by LEP persons to critical services while not
imposing undue burdens on small organizations and local governments. After
completing the above four-factor analysis, recipients can determine the appropriate of LEP
services required. Recipients have two main ways to provide language services: oral
40
interpretation either in person or via telephone interpretation service and written translation. The
correct mix should be based on what is both necessary and reasonable in light of the four-factor
analysis. For instance, a motor vehicle department or an emergency hazardous material cleanup
team in a largely Hispanic neighborhood may need immediate oral interpreters available and
decide to hire full-time bilingual staff. In contrast, there may be circumstances where the
importance and nature of the activity and number or proportion and frequency of contact with LEP
persons may be low and the costs and resources needed to provide language services may be high
in which pre-arranged language services for the particular service may not be necessary. The
languages spoken by the LEP individuals with whom the recipient has frequent contact often
determine the languages into which documents will be translated and the types of interpreters
provided.
Plan for Assisting Persons of Limited English Proficiency
How to Identify an LEP Person Who Needs Language Assistance?
Below are tools to help identify persons who may need language assistance:
1. Examine records requests for language assistance from past scheduled transportation needs
to anticipate the possible need for assistance at upcoming appointments;
2. When CITY sets up at events, set up a sign-in sheet table, have a staff member greet and
understand English, ask a question that requires a full sentence reply;
3. Staff should keep lists of individuals seeking language assistances on telephones, in office
and on vehicles;
4. Post a notice of available language assistance on CITY vehicles, subcontractor vehicles and
reception area.
5. Persons who do not speak English as their primary language and who have a limited ability
These individuals may be entitled to language assistance with respect to a particular type of
service, benefit or encounter.
acquisition and the displacement of persons from their residences and business may not be
oses of this requirement,
It also does not
include transit stations, power substations, or any other project evaluated by the National
Environmental Policy Act (NEPA) process. Facilities included in the provision include, but are
not limited to, storage facilities, maintenance facilities, operations centers, etc. In order to comply
with the regulations, CITY will ensure the following:
CITY will complete a Title VI equity analysis for any facility during the planning stage with regard
to where a project is located or sited to ensure the location is selected without regard to race, color,
or national origin. City of Paducah will engage in outreach to persons potentially impacted by the
siting of the facility. The Title VI equity analysis must compare
41
the equity impacts of various siting alternatives, and the analysis must occur before the selection
of the preferred site.
When evaluating locations of facilities, CITY will give attention to other facilities with similar
impacts in the area to determine if any cumulative adverse impacts might result. Analysis should
be done at the Census tract or block group level where appropriate to ensure that proper perspective
is given to localized impacts.
If CITY determines that the location of the project will result in a disparate impact on the basis of
race, color, or national origin, CITY may only locate the project in that location if there is a
substantial legitimate justification for locating the project there, and where there are no alternative
locations that would have a less disparate impact on the basis of race, color, or national origin.
CITY must demonstrate and document how both tests are met. CITY will consider and analyze
alternatives to determine whether those alternatives would have less of a disparate impact on the
basis of race, color, or national origin, and then implement the least discriminatory alternative.
M EANINGFUL A CCESS F OUR F ACTOR A NALYSIS
(1) T HE NUMBER OR PROPORTION OF LEP PERSONS ELIGIBLE TO BE SERVED OR LIKELY
TO BE ENCOUNTERED BY A PROGRAM, ACTIVITY OR SERVICE OF THE RECIPIENT:
FROM THE U.S. CENSUS BUREAU 2019 ACS 5-YEAR ESTIMATES, 58.5 MILLION PEOPLE OF THE U.S.
POPULATION WERE HISPANIC OR LATINO ORIGIN MAKING PEOPLE OF HISPANIC ORIGIN THE
LARGEST ETHNIC OR RACIAL MINORITY. 40.7 MILLION IS THE NUMBER OF U.S.
RESIDENTS 5 AND OLDER WHO SPEAK SPANISH AT HOME IN. THIS IS A 135 PERCENT INCREASE
SINCE 1990 WHEN IT WAS 17.3 MILLION. THOSE WHO SPEAK SPANISH AT HOME CONSTITUTED
12.5 PERCENT OF U.S. RESIDENTS 5 AND OLDER. MORE THAN HALF OF THESE SPANISH SPEAKERS
SPOKE ENGLISH VERY WELL.
Kentucky Demographics: According to the U.S. Census Bureau, the American Community Survey
5-Year Estimate indicated that Kentucky was ranked 39 out of 50 by percent of population Age
5+ Spanish Speaking. The total number of Spanish Speaking in Kentucky was 113,336 out of a total
population of 4,526,154 Age 5+. According to these statistics 2.5% of Kentucky Residents Age
5+ are Spanish Speaking.
(2) THE FREQUENCY WITH WHICH LEP INDIVIDUALS COME IN CONTACT WITH THE
PROGRAM, ACTIVITY, OR SERVICE:
The numbers are clearly showing an increase in the number of foreign-born residents in Kentucky
as well as an increase in the number of Spanish Speaking residents. CITY will continue to monitor
changes in demographics as they become available through Census and Studies. CITY will also
work closely with local agencies in an effort to monitor developments in the region.
CITY will monitor the frequency with which LEP individuals come in contact with the program
and services. CITY will report all encounters with LEP persons on the OTD Section 5304 Monthly
42
Report. Reporting accuracy will improve with ongoing training and tracking measures
implemented.
(3) T HE N ATURE AND I MPORTANCE OF THE P ROGRAM, A CTIVITY, OR S ERVICE
P ROVIDED BY THE P ROGRAM:
CITY understands they play an important role in the lives of our community. The individuals
utilizing public transportation services in the region need this mobility to maintain a continued
quality of life. A LEP inability to use public transit may hinder their ability to access
health care, education or employment. CITY will continue to outreach to all individuals and
promote their efforts. This will increase their need to promote their services for individuals to
realize the service is available. When they speak to groups, they make them aware they will assist
any individual with LEP.
(4) T HE R ESOURCES A VAILABLE TO THE R ECIPIENT AND FOR LEP O UTREACH, AS WELL AS
THE COSTS ASSOCIATED WITH THAT OUTREACH:
These additional language assistance tools will be utilized to assist LEP individuals at no additional
cost:
www.freetranslation.com is used to translate Transportation Committee agendas and other
documents as necessary.
With adequate notice CITY Studies
interpreters to provide information in other languages. The ESL contact person is Weihong Gao
and may be contacted at 270/809-4103. An alternate contact for translation services is Vince
Medlock and he can be reached at 270/293-8315.
43
The University of Tennessee Martin provides a third translation option through their Office of
International Affairs. The contact person is Ms. Lori Jackson and she can be contacted at 731/881-
3582. Karli Smith is a Program Resource Specialist and she can be reached at 731/881-7420. The
International Admissions office can be reached at 731/881-7344.
The US Census 2000 Language Identification Flashcard is available to assist staff in assessing
LEP needs.
A Google Translation Browser has been added to the CITY website, so all posted documents are
available in multiple languages.
IMPEMENTATION PLAN
Staff Training
Part of CITY
staff members, especially those having frequent contact with the public, to understand the
obligation to provide meaningful access to information and services for LEP persons. Likewise,
staff members who are less likely to interact with LEP persons should also be aware of and have
a level of understanding of the resources available to CITY for assisting LEP persons. Properly
training staff is key in the effective implementation of a LEP plan. Staff will be trained annually
to recognize when a LEP person is in need of language assistance and respond by providing
information in a format that the LEP person can understand.
L ANGUAGE A SSISTANCE M EASURES
1. Staff will take reasonable steps to provide the opportunity for meaningful access to LEP
clients who have difficulty communicating in English.
2. The following resources will be available to accommodate LEP persons:
a. A list of volunteer Spanish Language interpreters will be maintained and will provide
within a reasonable time period.
b. Language interpretation will be accessed for all languages through a telephone
interpretation service for critical need situations.
3. Network with local human service organizations that provide services to LEP individuals
and seek opportunities to provide information about the transit program and services.
4.
5. Incorporate an option for machine transition into multiple languages for CITY
(www.purchaseadd.org).
Outreach Techniques
When the staff prepares a document or schedules a meeting for which the target audience is
expected to include LEP individuals, the documents, meeting notices, flyers, and agendas will be
printed in an alternative language based on the known LEP population. Interpreters will be
available as requested.
44
Monitoring and Updating the LEP Plan
This plan is designed to be flexible and is one that can be easily updated. As such, it is important
to consider whether new documents and services need to be made accessible for LEP persons, and
also to monitor changes in demographics and types of services, and to update the LEP plan when
appropriate. At a minimum, the CITY will follow the Title VI program update schedule for the
LEP plan.
Each update should examine all plan components such as:
1. How many LEP persons were encountered?
2. Were their needs met?
3. What is the current LEP population in the OTO region?
4. Has there been a change in the types of languages where translation services are
needed?
5. Determine whether local language assistance programs have been effective and
sufficient to meet the need.
6. Determine where CITY Plan
7. Determine whether complaints have been received concerning the failure to meet the
needs of LEP individuals
8. Maintain a Title VI complaint log, to include LEP issues and basis of complaints.
Safe Harbor Provision
of written materials for LEP
population. The Safe Harbor Provision stipulates that, if a recipient provides written translation of
vital documents for each eligible LEP language group that constitutes five percent (5%) or 1,000
persons, whichever is less, of the total population of persons eligible to be served or likely to be
affected or encountered, then such action will be considered strong evidence of compliance with
s. Translation of non-vital documents, if needed, can
be provided orally. If there are fewer than 50 persons in a language group that reaches five percent
(5%) trigger, the recipient is not required to translate vital written materials but should provide
written notice in the primary LEP language group of the right to receive competent oral
interpretation of those written materials, free of cost.
SPEAK
TOTALS BY COUNTY
Total Pop 5 years Speaks English Less Percentage
County
and Older Than Very Well (%)
McCracken 63,305 726 1.1
American Community Survey 5-Year Estimates (2017-2021)
As outlined in the previous chart, McCracken County does not contain a LEP group of over 1,000.
CITY will provide good faith efforts to meet the needs of the LEP population, if and when
necessary. CITY may determine, based on the Four Factor Analysis, that even though a language
group meets the threshold specified by the Safe Harbor Provision, written translation may not be
an effective means to provide language assistance measures.
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XIV. MINORITY REPRESENTATION
Title 49 CFR Section 21 5(b)(1)(vii) states that a recipient may not, on the grounds of race, color
advisory or similar body which is an integral part of the -
related, nonelected planning board, advisory councils or committees, or similar committees, the
membership of which is selected by the recipient, must provide a table depicting the racial
breakdown of the membership of those committees, and a description of efforts made to encourage
the participation of minorities on such committee.
The CITY governing body consists of five (5) board members elected by City residents. There is
a Mayor that serves a four-year term, and City Commissioners that serve two-year terms. The
highest voted for Commissioner serves as Mayor-Pro-Tem in the absence of the Mayor..
Currently the five members consist of, four (4) men and one (1) woman with four (3) Caucasians
and one (2) African American.
CITY
excluded from participation in or denied the benefits of its services. Efforts to encourage
participation of minorities on the board are a mission of the board of commissioners. As well,
CITY strives to ensure that the composition of the employee body reflects a representation of
minority participation. CITY will continue to encourage minority groups to consider employment
with the City.
46
XV. DEMOGRAPHICS OF CITY
Percent of Minority Population
Percent of Adult Population with a Disability
Percent of Population in Poverty Status
47
Percent of Population Over 65 Years of Age
Percent of Population with Limited English Proficiency (LEP)
Population Estimates, July 1, 2024 (V2024) -- Paducah city, McCracken County, KY." Quick
Facts, https://www.census.gov/quickfacts/fact/table/paducahcitykentucky,mccrackencountykentucky/PST045223.
Accessed 12 June 2025.
48
XVI. REVIEW OF STA DIRECTIVES
The CITYtes and requirements
under the law and as directed by KYTC/FHWA to accomplish the goals of the Title VI Act of 1964.
The table below is a list of resources that include laws, procedures, directives, plans and/or guidance
used by the CITY to develop and administer Title VI implementation.
DIVISION/OFFICE PROCEDURES, MANUAL, DIRECTIVE
KYTC Official Order 110248: Standard Title VI Assurance (6/27/2016)
KYTC Official Order 110249: Title VI Policy Statement (6/27/2016)
KYTC Title VI Program Plan (10/1/2021 9/30/2022)
KYTC Language Access Plan (LAP) (10/1/2020 9/30/2021)
FHWA Title VI Implementation Plan Checklist
FWHA (Video) Overview of Civil Rights Program Requirements for Local Public Agencies
United States Code Title VI 1964 Civil Rights Act
49
XVII. COMPLIANCE/NONCOMPLIANCE REPORTING
Throughout the year, the Title VI Coordinator periodically meets with the directors and the
division heads of CITY to review the policies and procedures relative to Title VI. This includes,
but is not limited to, a review of files and statistics of complaints received for investigation and
services offered to recipients and beneficiaries of CITY's services.
In the event of noncompliance with this, plan or applicable regulations and laws are determined
via a complaint investigation or through the self-survey process; the CITY will make every
effort to attain full compliance.
The Title VI Coordinator shall notify the appropriate program head in the event a complaint
investigation, compliance review or self-survey indicates noncompliance. The notification shall
state the condition of noncompliance, recommended approach to correct the situation, and the
time period for the response and corrective action. The Title VI Coordinator may conduct an
interview to consult with the program head regarding the correct approach to remedy
noncompliance.
50
1
XVIII. APPENDICES
1
Appendices A-E contain the U.S. DOT Order No. 1050.2A
51
APPENDIX A
During the performance of this contract, the contractor, for itself, its assignees and successors
1. Compliance with Regulations: The contractor (hereinafter includes consultants) will
comply with the Acts and the Regulations relative to Non-discrimination in Federally
assisted programs of the U.S. Department of Transportation, Federal Highway
Administration, as they may be amended from time to time, which are herein
incorporated by reference and made a part of this contract.
2. Nondiscrimination: The contractor with regard to the work performed by it during the
contract, will not discriminate on the grounds of race, color or national origin in the
selection and retention of subcontractors, including procurements of materials and
leases of equipment. The contractor will not participate directly or indirectly in the
discrimination prohibited by the Acts and the Regulations, including employment
practices when the contract covers any activity, project or program set forth in
Appendix B of 49 CFR Part 21.
3. Solicitations for Subcontracts, Including Procurements of Materials and
Equipment: In all solicitations either by competitive bidding, or negotiation made by
the contractor for work to be performed under a subcontract, including procurements
of materials or leases of equipment each potential subcontractor or supplier will be
Acts and the Regulations relative to nondiscrimination on the grounds of race, color or
national origin.
4. Information and Reports: The contractor will provide all information and reports
required by the Acts, the Regulations, and directives issued pursuant thereto and will
permit access to its books, records, accounts, other sources of information and its
facilities as may be determined by the Recipient or the Federal Highway Administration
to be pertinent to ascertain compliance with such Acts, Regulations, and instructions.
Where any information required of a contractor is in the exclusive possession of another
who fails or refuses to furnish the information, the contractor will so certify to the
Recipient or the Federal Highway Administration, as appropriate and will set forth what
efforts it has made to obtain the information.
5. Sanctions for Noncompliance:
nondiscrimination provisions of this contract, the Recipient will impose such contract
sanctions as it or the Federal Highway Administration may determine to be appropriate,
including, but not limited to:
52
a. withholding payments to the contractor under the contract until the
contractor complies; and/or
b. cancelling, terminating, or suspending a contract, in whole or in
part.
6. Incorporation of Provisions: The contractor will include the
provisions of paragraphs one through six in every subcontract, including
procurements of materials and leases of equipment, unless exempt by
the Acts, the Regulations and directives issued pursuant thereto. The
contractor will take action with respect to any subcontract or
procurement as the Recipient or the Federal Highway Administration
may direct as a means of enforcing such provisions including sanctions
for noncompliance. Provided, that if the contractor becomes involved
in, or is threatened with litigation by a subcontractor, or supplier because
of such direction, the contractor may request the Recipient to enter into
any litigation to protect the interests of the Recipient. In addition, the
contractor may request the United States to enter into the litigation to
protect the interests of the United States
53
APPENDIX B
CLAUSES FOR DEEDS TRANSFERRING UNITED STATES PROPERTY
The following clauses will be included in deeds effecting or recording the transfer of real property,
structures, or improvements thereon, or granting interest therein from the United States pursuant
to the provisions of Assurance 4:
NOW, THEREFORE, the Department of Transportation as authorized by law and upon the
condition that the (Title of Recipient) will accept title to the lands and maintain the project
constructed thereon in accordance with (Name of Appropriate Legislative Authority), the
Regulations for the Administration of Federal Highway Program, and the policies and procedures
prescribed by the Federal Highway Administration of the U.S. Department of Transportation in
accordance and in compliance with all requirements imposed by Title 49, Code of Federal
Regulations, U.S. Department of Transportation, Subtitle A, Office of the Secretary, Part 21, Non-
discrimination in Federally-assisted programs of the U.S. Department of Transportation pertaining
to and effectuating the provisions of Title VI of the Civil Rights Act of 1964 (78 Stat. 252; 42
U.S.C. § 2000d to 2000d-4), does hereby remise, release, quitclaim and convey unto the (Title of
Recipient) all the right, title and interest of the U.S. Department of Transportation in and to said
lands described in Exhibit A attached hereto and made a part hereof.
(HABENDUM CLAUSE)
TO HAVE AND TO HOLD said lands and interests therein unto (Title of Recipient) and its
successors forever, subject, however, to the covenants, conditions, restrictions and reservations
herein contained as follows, which will remain in effect for the period during which the real
property or structures are used for a purpose for which Federal financial assistance is extended or
for another purpose involving the provision of similar services or benefits and will be binding on
the (Title of Recipient), its successors and assigns.
The (Title of Recipient), in consideration of the conveyance of said lands and interests in lands,
does hereby covenant and agree as a covenant running with the land for itself, its successors and
assigns, that (1) no person will on the grounds of race, color or national origin be excluded from
participation in, be denied the benefits of or be otherwise subjected to discrimination with regard
2
to any facility located wholly or in part on, over or under such lands hereby conveyed \[,\] \[and\]
(2) that the (Title of Recipient) will use the lands and interests in lands and interests in lands so
conveyed, in compliance with all requirements imposed by or pursuant to Title 49, Code of Federal
Regulations, U.S. Department of Transportation, Subtitle A, Office of the Secretary, Part 21, Non-
discrimination in Federally assisted programs of the U.S. Department of Transportation,
Effectuation of Title VI of the Civil Rights Act of 1964, and as said Regulations and Acts may be
2
Reverter clause and related language to be used only when it is determined that such a clause is necessary in order
to make clear the purpose of Title VI
54
amended \[, and (3) that in the event of breach of any of the above-mentioned non-discrimination
conditions, the Department will have a right to enter or re-enter said lands and facilities on said
land, and that above described land and facilities will thereon revert to and vest in and become the
absolute property of the U.S. Department of Transportation and its assigns as such interest existed
3
prior to this instruction\].
3
Reverter clause and related language to be used only when it is determined that such a clause is necessary in order
to make clear the purpose of Title VI
55
APPENDIX C
CLAUSES FOR TRANSFER OF REAL PROPERTY ACQUIRED OR IMPROVED UNDER
THE ACTIVITY, FACILITY, OR PROGRAM
The following clauses will be included in deeds, licenses, leases, permits or similar instruments
entered into by the (Title of Recipient) pursuant to the provisions of Assurance 7(a):
A. The (grantee, lessee, permittee, etc. as appropriate) for himself/herself, his/her heirs,
personal representatives, successors in interest and assigns, as a part of the consideration
that:
1. In the event facilities are constructed, maintained or otherwise operated
on the property described in this (deed, license, lease, permit, etc.) for a
purpose for which a U.S. Department of Transportation activity, facility,
or program is extended or for another purpose involving the provision
of similar services or benefits, the (grantee, licensee, lessee, permittee,
etc.) will maintain and operate such facilities and services in compliance
with all requirements imposed by the Acts and Regulations (as may be
amended) such that no person on the grounds of race, color or national
origin, will be excluded from participation in, denied the benefits of, or
be otherwise subjected to discrimination in the use of said facilities.
B. With respect to licenses, leases, permits, etc., in the event of breach of any of the above
Non-discrimination covenants, (Title of Recipient) will have the right to terminate the
(lease, license, permit, etc.) and to enter, re-enter, and repossess said lands and facilities
thereon, and hold the same as if the (lease, license, permit, etc.) had never been made or
4
issued.
C. With respect to a deed, in the event of breach of any of the above Non-discrimination
covenants, the (Title of Recipient) will have the right to enter or re-enter the lands and
facilities thereon, and the above described lands and facilities will there upon revert to and
5
vest in and become the absolute property of the (Title of Recipient) and its assigns.
4
See footnote 9
5 Reverter clause and related language to be used only when it is determined that such a clause is necessary in order
to make clear the purpose of Title VI
56
APPENDIX D
CLAUSES FOR CONSTRUCTION/USE/ACCESS TO REAL PROPERTY ACQUIRED
UNDER THE ACTIVITY, FACILITY OR PROGRAM
The following clauses will be included in deeds, licenses, permits, or similar instruments/
agreements entered into by (Title of Recipient) pursuant to the provisions of Assurance 7(b):
A. The (grantee, licensee, permittee, etc., as appropriate) for himself/herself, his/her heirs,
personal representatives, successors in interest, and assigns, as a part of the
consideration hereof, does hereby covenant and agree (in the case of deeds and leases
color or national origin, will be excluded from participation in, denied the benefits of,
or be otherwise subjected to discrimination in the use of said facilities, (2) that in the
construction of any improvements on, over, or under such land, and the furnishing of
services thereon, no person on the ground of race, color, or national origin, will be
excluded from participation in, denied the benefits of, or otherwise be subjected to
discrimination, (3) that the (grantee, licensee, lessee, permittee, etc.) will use the
premises in compliance with all other requirements imposed by or pursuant to the Acts
and Regulations, as amended, set forth in this Assurance.
B. With respect to (licenses, leases, permits, etc.) in the event of breach of any of the above
nondiscrimination covenants, (Title of Recipient) will have the right to terminate the
(license, permit, etc., as appropriate) and to enter or re-enter and repossess said land
and the facilities thereon and hold the same as if said (license, permit, etc., as
6
appropriate) had never been made or issued.
C. With respect to deeds in the event of breach of any of the above nondiscrimination
covenants, (Title of Recipient) will there upon revert to, vest in and become the
absolute property of (Title of Recipient) and its assigns.
6 Reverter clause and related language to be used only when it is determined that such a clause is necessary in order
to make clear the purpose of Title VI
57
APPENDIX E
During the performance of this contract, the contractor, for itself, its assignees, and successors in
-
discrimination statutes and authorities; including but not limited to the following:
Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq., 78
stat. 252), (prohibits discrimination on the basis of race, color, national
origin) and 49 CFR Part 21;
The Uniform Relocation Assistance and Real Property Acquisition
Policies Act of 1970, (42 U.S.C. § 4601), (prohibits unfair treatment of
persons displaced or whose property has been acquired because of
Federal or Federal-aid programs and projects);
Federal-Aid Highway Act of 1973, (23 U.S.C. § 324 et seq.), (prohibits
discrimination on the basis of sex);
Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. § 794 et seq.),
as amended, (prohibits discrimination on the basis of disability); and 49
CFR Part 27;
The Age Discrimination Act of 1975, as amended, (42 U.S.C. § 6101 et
seq.), (prohibits discrimination on the basis of age);
Airport and Airway Improvement Act of 1982, (49 USC § 471, Section
47123), as amended, (prohibits discrimination based on race, creed,
color, national origin or sex);
The Civil Rights Restoration Act of 1987, (PL 100-209), (Broadened
the scope, coverage and applicability of Title VI of the Civil Rights Act
of 1964, The Age Discrimination Act of 1975 and Section 504 of the
Rehabilitation Act of 1973, by expanding the definition of the terms
the Federal-aid recipients, sub-recipients and contractors, whether such
programs or activities are Federally funded or not);
Titles II and III of the Americans with Disabilities Act, which prohibit
discrimination on the basis of disability in the operation of public
entities, public and private transportation systems, places of public
accommodation and certain testing entities (42 U.S.C. §§ 12131 --
12189) as implemented by Department of Transportation regulations at
49 C.F.R. parts 37 and 38;
59
The Federal Aviation Non-discrimination statute (49
U.S.C. § 47123) (prohibits discrimination on the basis of race, color,
national origin and sex);
Executive Order 12898, Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income Populations, which
ensures non-discrimination against minority populations by
discouraging programs, policies, and activities with disproportionately
high and adverse human health or environmental effects on minority and
low-income populations;
Executive Order 13166, Improving Access to Services for Persons with
Limited English Proficiency and resulting agency guidance, national
origin discrimination includes discrimination because of limited English
proficiency (LEP). To ensure compliance with Title VI, you must take
reasonable steps to ensure that LEP persons have meaningful access to
your programs (70 Fed. Reg. at 74087 to 74100);
Title IX of the Education Amendments of 1972, as amended, which
prohibits you from discriminating because of sex in education programs
or activities (20 U.S.C. 1681 ET seq).
59
APPENDIX F
Active employees will complete the training and sign an acknowledgement (example below) that they
understand the training and will abide by the Title VI nondiscrimination plan in accordance with the
training.
CITY OF PADUCAH
TITLE VI ANNUAL TRAINING
I confirm that I listened, and understood the Title VI training, also I understand that as an employee, it is my
responsibility to abide by the Title VI nondiscrimination plan, in accordance with the training.
If I have questions about the plan, or materials presented I understand it is my responsibility to seek clarification.
Employee Signature________________________________________
Date___________________________________________________________
Print name___________________________________________________
XVIII.BOARD POLICYAPPROVAL
POLICY APPROVAL BY THE GOVERNING BOARD
is made this _____ day of June 2025.
George P. Bray, Mayor
City of Paducah
Mayor Signature Date
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: Employment Agreement with Matthew Wentworth - B. LAIRD
Category: Municipal Order
Staff Work
By: Brian Laird
Presentation
By: Brian Laird
Background Information: Matt Wentworth is a retired Paducah police officer who returned to work with us
last year. He currently serves as part of our deflection team. Kentucky Retirement Systems requires an annual
contract for retired police officers to return to work.
Does this Agenda Action Item align with a Commission Priority? No
If yes, please list the Commission Priority:
Communications Plan:
Account Name:
Funds Available:
Account Number:
Staff Recommendation: Approve the employment agreement.
Attachments:
1. MO agree-employment – Matthew Wentworth – PD 2025-2026
2. 2025 Wentworth contract
MUNICIPAL ORDER NO. _______
A MUNICIPAL ORDER APPROVING AN EMPLOYMENT AGREEMENT BETWEEN THE
CITY OF PADUCAH AND POLICE OFFICER MATTHEW WENTWORTH, AND
AUTHORIZING THE MAYOR TO EXECUTE SAME
BE IT ORDERED BY THE CITY OF PADUCAH, KENTUCKY:
SECTION 1. Authorization. The Board of Commissioners of the City of
Paducah hereby approves and the Mayor of the City of Paducah, Kentucky, is hereby authorized
to execute an Employment Agreement with Police Officer Matthew Wentworth to be employed
in the Paducah Police Department.
SECTION 2. Effective Date. This Order shall be in full force and effect on and
after the date as approved by the Board of Commissioners of the City of Paducah, Kentucky.
_______________________________
George Bray, Mayor
ATTEST:
______________________________________
Claudia S. Meeks, Assistant City Clerk
Adopted by the Board of Commissioners, ______________________
Recorded by Lindsay Parish, City Clerk, _____________
\\mo\\agree-employment – Matthew Wentworth – PD 2025-2026
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: Authorize the City Manager to release a Request for Bids for a Non-Exclusive
Telecommunications Franchise - L. PARISH
Category: Municipal Order
Staff Work By: Lindsay Parish,
Michelle Smolen
Presentation By: Lindsay Parish
Background Information: This Municipal Order authorizes and directs the City Manager to issue and
advertise a Request for Proposals for non-exclusive telecommunications franchises in accordance with Code of
Ordinances Chapter 108. All recommended franchise agreements will be brought back to the City Commission
for approval and execution at the conclusion of the RFP review process.
Does this Agenda Action Item align with a Commission Priority? No
If yes, please list the Commission Priority:
Communications Plan:
Account Name:
Funds Available:
Account Number:
Staff Recommendation: Approve.
Attachments:
1. MO RFP – Telecommunications Franchise 2025
MUNICIPAL ORDER NO. _______
A MUNICIPAL ORDER AUTHORIZING AND DIRECTING THE CITY MANAGER TO
INITIATE A REQUEST FOR PROPOSALS FOR A NON-EXCLUSIVE
TELECOMMUNICATIONS FRANCHISE IN PADUCAH, KENTUCKY, IN
ACCORDANCE WITH CHAPTER 108 “TELECOMMUNICATIONS” OF THE CODE OF
ORDINANCES
BE IT ORDERED BY THE CITY OF PADUCAH, KENTUCKY:
SECTION 1. That the City Manager is hereby authorized and directed to
develop, advertise, and initiate a Request for Proposals for the purpose of soliciting non-
exclusive telecommunication franchises within the City of Paducah.
SECTION 2. This Order will be in full force and effect from and after the
date of its adoption.
______________________________
George Bray, Mayor
ATTEST:
_____________________________
Lindsay Parish, City Clerk
Adopted by the Board of Commissioners, _________________
Recorded by Lindsay Parish, City Clerk, _________________
MO\\RFP – Telecommunications Franchise 2025
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: Approve Contract For Services with Paducah Junior College, Inc., for the Community
Scholarship Program in the amount of $100,000.00 - D. JORDAN
Category: Municipal Order
Staff Work By: Claudia
Meeks, Daron Jordan
Presentation By: Daron
Jordan
Background Information: The FY2025 Budget was approved on June 11, 2024, by Ordinance No. 2024-
06-8815. The budget included payment to Paducah Junior College, Inc., for continued support of the
Community Scholarship Program , in the amount of $100,000. The Board of Commissioners is now desirous
of entering into a contract with Paducah Junion College, Inc. for FY2025 services in the amount of $100,000
payable by June 30, 2025.
Does this Agenda Action Item align with a Commission Priority? No
If yes, please list the Commission Priority:
Communications Plan:
Account Name: Investment Fund
Funds Available:
Account Number: 2400 0401 580790
Staff Recommendation: Approve Contract with Paducah Junior College, Inc., in the amount of $100,000.
Attachments:
1. mo - contract - Paducah Junior College FY25 - community scholarship
2. Contract For Services - PJC Community Scholarship FY2025
MUNICIPAL ORDER NO. ______
A MUNICIPAL ORDER OF THE CITY OF PADUCAH AUTHORIZING AN FY2025
CONTRACT FOR SERVICES WITH PADUCAH JUNIOR COLLEGE, INC., FOR THE
COMMUNITY SCHOLARSHIP PROGRAM IN THE AMOUNT OF $100,000, AND
AUTHORIZING THE MAYOR TO EXECUTE SAID CONTRACT, THE MEMORANDUM
OF UNDERSTANDING REGARDING THE COMMUNITY SCHOLARSHIP PROGRAM,
AND ANY OTHER DOCUMENTSRELATED THERETO.
SECTION 1. That the Mayor is hereby authorized to execute a contract with
Paducah Junior College, Inc. in the amount of $100,000 for the Community Scholarship
Program, which shall be payable no later than June 30, 2025. This contract shallexpire June 30,
2025. The Mayor is further authorized to execute a Memorandum of Understanding creating a
public-private educational partnership, as well as any other documents related thereto.
SECTION 2. This expenditure shall be charged to the Investment Fund, Account
No. 24000401-580790.
SECTION 3. This Municipal Order shall be effective from and after the date of
its adoption.
____________________________________
George Bray, Mayor
ATTEST:
____________________________________
Lindsay Parish, City Clerk
Adopted by the Board of Commissioners June 24, 2025
Recorded by Lindsay Parish, City Clerk, June 24, 2025
\\mo\\contract – Paducah Junior College FY25 – Community Scholarship
CONTRACT FOR SERVICES
This Contract for Services, effective this _______ day of _________, 2025, by and between the
CITY OF PADUCAH (“City”) and PADUCAH JUNIOR COLLEGE, INC. (PJC, Inc.).
WITNESSETH:
WHEREAS, promoting education to students in the Paducah/McCracken County area and
exposing them to post-secondary education serves a valid public purpose; and
WHEREAS, improving the education level of our community’s young people will both make the
Paducah workforce more attractive to investors and employersand enhance the life potential of
individual students; and
WHEREAS, the City of Paducah desires to contract with PJC, Inc., for the services to be
described herein under the terms and conditions set forth in this Contract for Services.
NOW THEREFORE, in consideration of the foregoing premises and the mutual covenants as
herein set forth, the parties do covenant and agree as follows:
SECTION 1: TERM The term of this contract for services shall be from the effective date of
the contract until June 30, 2025.
SECTION 2: TERMINATION Either party may terminate this Contract for Services upon
failure of any party to comply with any provision of this agreement provided any such party
notifies the other in writing of such failure and the breaching party fails to correct the breach
within thirty (30) calendar days of the notice.
SECTION 3: OPERATIONS PAYMENT In consideration of providing education and
training and to carry out the objectives of PJC, Inc., the City shall pay PJC, Inc., the sum of ONE
HUNDRED THOUSAND AND NO/100 ($100,000) DOLLARSin a one-time amount no later
than June 30, 2025. PJC, Inc., shall provide an invoice to the City of Paducahprior to payment
being made. In the event that this contract for services is terminated, the City shall not be
obligated to make any further payments.
SECTION 4: OBJECTIVES AND SERVICES - PJC, Inc., will guarantee Paducah and
th
McCracken County 8 graders who meet prescribed standards through their final four years of
high school, a tuition scholarship for up to sixty (60) hours of college credit at WKCTC.
SECTION 5: ACCOUNTING
(A) PJC, Inc., shall conduct all accounting, payroll, and financial management.
(B) PJC, Inc., shall supply an annual financial audit to the City within two weeks of its
completion.
(C) PJCwill provide a written financial report as of December 31st and June 30thduring the
term of this contract to the City Manager's Office by the 15th day of the 2nd month following the
reporting date. The financial report, at minimum, shall disclose the dollar amounts that the City,
County and others (each shown separately) have contributed to the PJC for the Community
Scholarship program by fiscal year and the interest earned thereon. The report shall fully disclose
how funds were used by fiscal year and purpose.
SECTION 6: ENTIRE AGREEMENT This contract for services embodies the entire
agreement between the parties and all prior negotiations and agreements are merged in this
agreement. This agreement shall completely and fully supersede all other prior agreements, both
written and oral, between the parties.
SECTION 7: WITHDRAWAL OF FUNDS Notwithstanding any other provision in this
Contract for Services, in the event it is determined that any funds provided to PJC, Inc. are used
for some purpose other than in furtherance of the services described herein, the City shall have
the right to immediately withdraw any and all further funding and shall immediately have the
right to terminate this Contract for Services without advance notice andshall have the right to all
remedies provided in the law to seek reimbursement for all monies not properly accounted.
Witness the signature of the parties as of the year and date first written above.
CITY OF PADUCAH
____________________________________
GEORGE BRAY, Mayor
PADUCAH JUNIOR COLLEGE, INC.
Name________________________________
Title_________________________________
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: Authorize the City Manager to release a Request for Proposals for Design and Construction
Administration Services for the design of a new Maintenance Building for the Parks and Recreation
Department - A. CLARK
Category: Municipal Order
Staff Work By: Amie Clark
Presentation By: Amie Clark
Background Information: Authorize the City Manager to release a Request for Proposals for the Design
and Construction Administration Services for a new maintenance building for the Parks and Recreation
Department.
Does this Agenda Action Item align with a Commission Priority? No
If yes, please list the Commission Priority:
Communications Plan:
Account Name: Maintenance Bldg Design
Funds Available:
Account Number: PA0137
Staff Recommendation: Approve
Attachments:
1. – Parks & Rec Maintenance Building Design and Management
MUNICIPAL ORDER NO. ______
A MUNICIPAL ORDER AUTHORIZING AND DIRECTING THE CITY MANAGER TO
INITIATE A REQUEST FOR PROPOSALS FOR DESIGN AND CONSTRUCTION
ADMINISTRATION SERVICES FOR A NEW MAINTENANCE BUILDING FOR THE
PARKS AND RECREATION DEPARTMENT
BE IT ORDERED BY THE CITY OF PADUCAH, KENTUCKY:
SECTION 1. That the City Manager is hereby authorized and directed to
develop, advertise, and initiate a Request for Proposals for the design and construction
management services for a new maintenance building for the Parks and Recreation
Department.
SECTION 2. This Order will be in full force and effect from and after the
date of its adoption.
______________________________
George Bray, Mayor
ATTEST:
_____________________________
Lindsay Parish, City Clerk
Adopted by the Board of Commissioners, _________________________
Recorded by Lindsay Parish, City Clerk, _________________________
MO\\RFP – Parks & Rec Maintenance Building Design and Management
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: Authorize the City Manager to release a Request for Proposals for the construction of a restroom
facility at Robert Coleman Park - A. CLARK
Category: Municipal Order
Staff Work By: Amie Clark
Presentation By: Amie Clark
Background Information: Authorize the City Manager to release a Request for Proposals for the
construction of a public restroom facility to be located in Robert Coleman Park.
Does this Agenda Action Item align with a Commission Priority? Yes
If yes, please list the Commission Priority: Southside Improvements.
Communications Plan:
Account Name: Robert Coleman Spray Ground Project
Funds Available:
Account Number: PA0134
Staff Recommendation: Approve
Attachments:
1. MO RFB – Restroom Robert Coleman Park
MUNICIPAL ORDER NO. ______
A MUNICIPAL ORDER AUTHORIZING AND DIRECTING THE CITY MANAGER TO
INITIATE A REQUEST FOR BIDS FOR THE CONSTRUCTION OF A RESTROOM
FACILITY AT ROBERT COLEMAN PARK
BE IT ORDERED BY THE CITY OF PADUCAH, KENTUCKY:
SECTION 1. That the City Manager is hereby authorized and directed to
develop, advertise, and initiate a Request for Bids for the construction of a restroom facility at
Robert Coleman Park.
SECTION 2. This Order will be in full force and effect from and after the date of
its adoption.
______________________________
George Bray, Mayor
ATTEST:
_____________________________
Lindsay Parish, City Clerk
Adopted by the Board of Commissioners, _________________________
Recorded by Lindsay Parish, City Clerk, _________________________
MO\\RFB – Restroom Robert Coleman Park
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: School Resource Officer Agreement with Paducah Public Schools - B. LAIRD
Category: Municipal Order
Staff Work
By: Brian Laird
Presentation
By: Brian Laird
Background Information: In 2021, the Paduah Police Department and Paducah Public Schools entered a
partnership for school resource officers. This agreement was funded partially by a COPS grant which has
expired. The current agreement between the City of Paducah and Paducah Public Schools expires June 30,
2025. This new one-year agreement outlines cost sharing for the continued partnership. Paducah Public
Schools will reimburse the City for 70% of the cost for each police officer.
This agreement was approved by the Paducah Public School Board on May 12, 2025.
Does this Agenda Action Item align with a Commission Priority? No
If yes, please list the Commission Priority:
Communications Plan:
Account Name:
Funds Available:
Account Number:
Staff Recommendation: Approve the agreement
Attachments:
1. MO Paducah Independent School District – Resource Officers 2025
2. sro agreement signed
MUNICIPAL ORDER NO. _______
A MUNICIPAL ORDER AUTHORIZING THE MAYOR TO EXECUTE A
SCHOOL RESOURCE OFFICER AGREEMENT BETWEEN THE CITY OF PADUCAH
AND THE PADUCAH PUBLIC SCHOOL SYSTEM FOR SCHOOL YEAR 2025
BE IT ORDERED BY THE CITY OF PADUCAH, KENTUCKY,
SECTION 1. That the City of Paducah hereby authorizes the Mayor to execute a
School Resource Officer Agreement with Paducah Public Schools, in substantially the form
attached hereto and made part hereof (Exhibit A).
SECTION 2. This Order shall be in full force and effect from and after the date
of its adoption.
______________________________
Mayor George Bray
ATTEST:
_____________________________
Lindsay Parish, City Clerk
Adopted by the Board of Commissioners, ____________________
Recorded by Lindsay Parish, City Clerk, _____________________
\\mo\\Paducah Independent School District – Resource Officers 2025
Agenda Action Form
Paducah City Commission
Meeting Date: June 24, 2025
Short Title: Health Insurance Fund - budget amendment for FY2025 - J. PERKINS
Category: Ordinance
Staff Work By: Kristi Gray, Audra Herndon,
Jonathan Perkins
Presentation By: Jonathan Perkins
Background Information: In order for the City to cover all 'health insurance fund claims' it will be
necessary for a budget amendment to be authorized by the City Commission. The FY2025 'Claims' account
will be increased by $710 thousand and fully funded by the Health Insurance Funds' fund balance for the same.
Does this Agenda Action Item align with a Commission Priority? No
If yes, please list the Commission Priority: Commission Priorities List
Communications Plan:
Account Name:
Funds Available:
Account Number:
Staff Recommendation: Approve the budget amendment
Attachments:
1. ORD budget amend FY2025 – Health Insurance
2. FY2025 Claims projection
ORDINANCE NO. 2025-_____-_______
AN ORDINANCE AMENDING ORDINANCE NO. 2024-06-8815, ENTITLED, “AN
ORDINANCE ADOPTING THE CITY OF PADUCAH, KENTUCKY, ANNUAL
OPERATING BUDGET FOR THE FISCAL YEAR JULY 1, 2024, THROUGH JUNE 30,
2025, BY ESTIMATING REVENUES AND RESOURCES AND APPROPRIATING FUNDS
FOR THE OPERATION OF CITY GOVERNMENT”
WHEREAS, in order for the City to cover all health insurance fund claims, it is
necessary for a budget amendment to be authorized by the City Commission.
NOW, THEREFORE, BE IT ORDAINED BY THE CITY OF PADUCAH,
KENTUCKY:
SECTION 1. That the annual budget for the fiscal year beginning July 1, 2024,
and ending June 30, 2025, as adopted by Ordinance No. 2024-06-8815, be amended by the
following re-appropriations:
Transfer $710,000 from the Health Insurance Funds’ fund balance to the
FY2025 Health Insurance Claims Account.
SECTION 2. This ordinance shall be read on two separate days and will become
effective upon summary publication pursuant to KRS Chapter 424.
______________________________
George Bray, Mayor
ATTEST:
___________________________
Lindsay Parish, City Clerk
Introduced by the Board of Commissioners, June 10, 2025
Adopted by the Board of Commissioners, ______________________
Recorded Lindsay Parish, City Clerk, _________________________
Published by The Paducah Sun, _______________________________
\\ord\\finance\\budget amend FY2025 – Health Insurance
5/22/2025
Claims are exceeding the FY2025 (current fiscal year) appropriated Health Insurance claims
account.
The following table is a 30K foot view of the situation:
Medical Claims – FY2025 (fiscal year NOT completed as of this writing, values are estimates or
projections)
Health Insurance Fund Current $2.394M
Appropriation – FY2025
Fiscal Year Claims paid-to-date$2.674MClaims paid through May 14, 2025
HUB Projected Total Claims for FY2025$3.100MProjections by DJ Story
Total needed to get through FY2025Need BOC budget adjustment
$0.706M
approval
JSA:
Premiums paid to City’s plan 7/1/24 – $215,207
March 31, 2025
Claims paid for JSA July 1, 2024 – March $297,946
31, 2025
’s subsidy for JSA claims through
($82,739)
March 31, 2025
Source for JSA data is DJ Story; source for HUB Projected claims through FY2025 is DJ Story with HUB
We need to ask the BOC to amend our FY2025 budget by asking for a budget amendment of
$706,000. This will hopefully cover the balance of FY2025 claims.