DATE: March 25, 2009

TO: Lowcountry Regional Transportation Authority Employees

FROM: Board of Directors

RE: Affirmative Action Program (AAP) and
Equal Employment Opportunity (EE0) Policy Statement

Lowcountry Regional Transportation Authority is committed to equal employment opportunity and will maintain an environment of both social and business responsibility that responds to the needs of our employees, applicants, customers, contractors and sub-contractors. It is our policy that recruitment, selection, placement, promotion, training, compensation, participation in social and recreation programs and continued employment shall be based on a person’s ability as related to valid job requirements, without regard to race, color, religion, age, gender, national origin, sexual orientation, ancestry or veteran status. First Transit’s policy also prohibits discrimination based on bonafide disabilities as such pertains to the American with Disabilities Act (ADA) of 1990 or any other criterion that could be found discriminatory. We strongly support our philosophy, which goes beyond the letter of the law. Lowcountry Regional Transportation Authority not only believes in EEO, we value and strive to ensure a quality work environment for all employees.

Lowcountry Regional Transportation Authority believes that the establishment of a dignified workplace provides the foundation for an environment free of discrimination and harassment. Harassment of any kind is illegal and prohibited, as is the granting or denying of employment or advancement based on the demand for sexual favors. The LRTA will not tolerate such behavior and will take immediate action to correct such inappropriate workplace behavior. Lowcountry Regional Transportation Authority will also ensure that others, including supervisory personnel, do not retaliate against individuals who come forward with harassment charges.

We believe that affirmative action and equal employment opportunity are essential to the future of Lowcountry Regional Transportation Authority. We further believe that diversity is the right thing to do and is good business. Lowcountry Regional Transportation Authority will be competitively advantaged by having a workplace where diversity and the contributions of individual employees are valued and appreciated. It is every employee’s personal duty to help create an environment which is conducive to non-discrimination and equal employment opportunity.

Applicants and employees have the right to file complaints alleging discrimination with the Equal Employment Opportunity Commission and/or with your immediate supervisor. If you have concerns or need assistance regarding our EE0 or AAP philosophy and practice, you may contact the Executive Director/EEO Officer at 843-757-5782.

Dissemination of Information
This EEO Program will be available on the LRTA website, http://www.palmettobreezetransit.com
It will also be distributed to all Board members, administrators, and LRTA employees. Printed and/or translated copies (or other necessary, accessible formats) of the Program and/or the Notice will be made available upon request.

Managers and Supervisors shall be fully informed of the agency’s policy through:
Written communication from the General Manager or their designee. Inclusion of the EEO program and policy in LTRA’s personnel and operations manual; and meetings to discuss the EEO program and its implementation.

Non-supervisory staff shall be informed of the agency’s EEO policy and program through:
Posting official EEO posters and the policy statement on bulletin boards, in the lunch room, and in the HR office. Including the EEO policy in the employee handbooks, reports, and employee manuals. Meeting with minority and female employees to get their suggestions in implementing and refining the EEO program; and presentation and discussion of the EEO program as part of the employee orientation and in all training programs.

Designation of Personnel Responsibilities
1. The Executive Director shall be the EEO Officer and the ultimate authority and responsibility for the implementation of the EEO Program. The EEO Officer shall delegate duties to achieve the policy goals as necessary.
2. The Executive Director as the EEO Officer is responsible for managing and implementing all aspects of the EEO Program.

EEO Officer duties:
Develop and recommend an EEO program, including procedures and setting goals.
Responsibilities also include, implementing, monitoring, and ensuring LRTA’s compliance with EEO regulations in the day-to-day administration and reporting requirements of LRTA’s EEO Program. Ensure that all department managers and supervisors are aware of the details of the EEO Program. Shall concur in all hires and promotions for compliance with policy. Develop long range plans with LRTA’s Board that are consistent with EEO requirements. Incorporate into the Transportation Improvement Plan (TIP) any corrective actions taken in response to deficiencies found by FTA audit. Disseminate to the LRTA Board compliance issues that must be taken into consideration during the planning process. Ensure that the LRTA planning process is conducted with equal access public participation.

All Managers duties:
Assist in identifying problem areas and establishing LRTA goals and objectives.
Being actively involved with local minority organizations, women’s and disability groups, community action organizations and community service programs designed to promote EEO. Participating actively in periodic audits of all aspects of employment in order to identify and to remove barriers obstructing the achievement of specified goals and objectives.
Holding regular discussions with other managers, supervisors, and employees to assure LRTA’s policies and procedures are being followed. Reviewing the qualifications of all employees to assure that minorities, disabled persons, and women are given full opportunities for transfers, promotions, training, salary increases, and other forms of compensation. Participate in the review and/or investigation of complaints alleging discrimination. Conduct and support career counseling for all employees; and
Participate in periodic audits to ensure that each department is in compliance (e.g., EEO posters are properly displayed on all employee bulletin boards).

Utilization Analysis
The purpose of the utilization analysis is to identify those job categories where there is an underutilization and/or concentration of minorities and women in relation to their availability in the relevant labor market. It is also to establish the framework for goals and timetables and other affirmative actions to correct employment practices that contributed to any identified absence, underutilization, or concentration.

The LRTA utilization analysis consists of a work force analysis and an availability analysis. The work force analysis requires has statistical breakdown of LRTA’s work force by each department, job category (e.g. bus operator, Tech I or II, etc.), and job title. Each of the above is cross- referenced by race, national origin, and sex. A table is attached.

An availability analysis is a comparison of the participation rates of minorities and women at various levels in the work force with their availability in relevant labor markets. A labor market has both geographic and occupational components. Different geographic areas and labor force data should be used for different job categories. As an example, professional positions would likely have a regional or national recruiting area as opposed to a local recruiting area as would be the case for less skilled jobs. Moreover, recruiting areas should reflect nearby concentrations of minority-group persons who may have been historically excluded from consideration.

Occupational data (in addition to general population and unemployment information), along with training and promotional opportunities, will be considered in determining the availability of persons for those employment opportunities from which minorities and women have traditionally been excluded. In determining availability for job categories not requiring special skills or abilities, general population or work force age data may be suitable. Community and area labor statistics by race, national origin, and sex can be obtained from the U.S. Department of Commerce, Bureau of the Census, and its publications; U.S. Department of Labor, Bureau of Labor Statistics, and the Women’s Bureau; State and local governments, especially State employment services and MPO’s. Detailed occupational data by race, national origin and sex in categories required for EEO reports (E.g., Professionals, Officials, Managers, Technicians, etc.) is available in special affirmative action data packages from many State employment services. Similar data is available from the Research and Analytical Services staff of the EEOC.

Goals & Timetables
Long-range goals will be designed to eliminate underutilization in job categories where it has been identified. Based on the utilization analysis, LRTA will need to establish goals and timetables designed to correct any identified deficiencies.

Long-range goals are usually stated as percentages, although numerical projections are recommended where feasible. Such goals should consider the fact that availability of traditionally underutilized or underemployed groups is not constant. Future projections should be taken into consideration. Generally, an EEO Program will be formulated with long- range goals to be realized within a period of 4 to 5 years.

Short-term or intermediate numerical goals should be set and pursued in order to assure accomplishment of long-range goals. Short-term goals represent the net increase in minority and/or women’s employment in a particular job category within the next 12 months. Short-term goals should be stated, both as actual numbers and percentages, and should be based on anticipated job openings, job group availability, and the long-range goals set for minorities and/or women in the particular job category. Projections of vacancies should also be established in terms of a job progression chart in order to determine which vacancies can be filled immediately by underutilized persons and the possibilities of these persons being promoted into upper-level positions in terms of long-range goals.

Monitoring and Reporting System

LRTA will adhere to the following to establish an effective and workable internal monitoring and reporting system. This system will serve the following basic purposes:
1. Assessing EEO accomplishments;
2. Enabling LRTA to evaluate the EEO program during the year and to take any necessary corrective action regarding the development and execution of programs or goals and timetables;
3. Identifying those units which have failed to achieve a goal or to implement affirmative action; and
4. Providing a precise and factual database for future projections.

The reporting system will provide documentation to support actions that affect minority and women job applicants or employees. Management will be kept informed of program effectiveness.

LRTA will analyze in detail all employment practices relating to recruitment, selection, salaries, promotions, terminations, standards of discipline, seniority, maternity/paternity leave, height and weight requirements, etc. All problems will be noted and a proposed course of remedial action will be enumerated in LRTA’s EEO program.

LRTA EEO Table – May 2016

Department Position Ethnicity Gender Citizenship
Ops Administration White (Non-Hispanic Origin) Female USA
Admin Administration Black (Non-Hispanic Origin) Female USA
Admin Administration Asian or Pacific Islander Female USA
Admin Administration White (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver White (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Male USA
Ops Bus Driver Black (Non-Hispanic Origin) Female USA
Admin Administration White (Non-Hispanic Origin) Female USA
Ops Supervisor Asian or Pacific Islander Female USA
Maint Mechanic White (Non-Hispanic Origin) Male USA
Maint Mechanic Black (Non-Hispanic Origin) Male USA
Ops Dispatcher White (Non-Hispanic Origin) Female USA
Ops Dispatcher White (Non-Hispanic Origin) Female USA
Maint Utility White (Non-Hispanic Origin) Female USA