Title VI Plan for Discrimination Complaints

It is the policy of the City of Littleton that no person shall on the grounds of race, color, national origin, sex, disability, or age, be excluded from participation in, be denied the benefits of, or be subjected to discrimination in any operation of the city as provided by Title VI of the Civil Rights Act of 1964 and related statutes.

This policy applies to all operations of the city, including its contractors and anyone who acts on behalf of the city. This policy also applies to the operations of any division to which the city extends federal financial assistance.

Discrimination Under Title VI of the Civil Rights Act of 1964

The City of Littleton operates its programs and services without regard to race, color, national origin, sex, age, and disability. Anyone who believes they have been excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under any city program or activity because of their race, color, national origin, age, sex, or disability may file a discrimination complaint with the city or the Colorado Department of Transportation.

Federal law requires that the city investigate, track, and report discrimination complaints. Complaints must be filed in writing and will be investigated within 60 days of submission. If you need assistance to file your complain, or need interpretation services, please contact Chris Yates, City of Littleton’s Title VI Coordinator, at 303-734-8417 or via email.

Who is Eligible to File a Complaint?

Anyone who believes they have been excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under any city program or activity because of their race, color, national origin, age, sex, or disability may file a complaint.

How to File a Complaint

Complaints must be filed in writing within 180 days from the last date of the alleged discrimination; however, you may contact City of Littleton’s Title VI Coordinator if you believe your compliant may fall outside of this deadline.

Reasonable efforts will be made to assist persons with disabilities, non-English speakers, and others unable to file a written complaint. For assistance filing a complain, please contact City of Littleton’s Title VI Coordinator (information below).

Complaints may be submitted via mail, email, or in person to:

ChrisYates
City of Littleton Title VI Coordinator
cyates@littletongov.org
303-734-8417

Mailing address:
2255 W. Berry Avenue
Littleton, CO 80120

Complaints may also be filed directly with the following agencies:

Colorado Department of Transportation
Civil Rights & Business Resources Center
4201 East Arkansas Ave., Room 150
Denver, CO 80222
Email – dot_civilrights@state.co.us
Phone – 800-925-3427
Fax – 303-952-7088

Federal Highways Administration, Colorado Division
12300 West Dakota Avenue, Suite 180
Lakewood, CO 80228
Phone – 720-963-3000
Fax – 720-963-3001

What Happens After a Complaint is Filed?

Title VI complaints must be investigated within 60 days. Investigating a complaint includes interviewing all parties involved and key witnesses. The investigator may also request relevant information such as books, records, electronic information, and other sources of information from all involved parties. You may specify if there is a particular individual or individuals who you feel should not investigate your complaint due to conflict of interest or other reasons.

In some cases, complaints will be forwarded to either the Colorado Department of Transportation or the Federal Highway Administration for investigation. If your complaint is forwarded to one of these agencies, you will be provided with the name and contact information of the employee handling your complaint.

Federal law prohibits retaliation against individuals because they have filed a discrimination complaint or otherwise participated in a discrimination investigation. Any alleged retaliation should be reported in writing to the investigator.

Title VI Complaint Form

Please complete the form to the best of your ability. If you need translation or other assistance, contact the city's Title VI Coordinator using the information provided above.

Title VI Complaint Form(PDF, 189KB)

 

Digital Accessibility Plan

Introduction

The City of Littleton is firmly committed to ensuring that all our digital services are accessible to the widest possible audience, regardless of technology or ability. Upholding our commitment to inclusivity and accessibility, we aim to provide an online experience that achieves "Level AA" conformance according to the Web Content Accessibility Guidelines v2.1 (WCAG 2.1). This goal aligns with our overarching commitment to make our digital services accessible to everyone, facilitating equal access to city information, services, and programs.

This Digital Accessibility Plan outlines our strategic approach to enhancing the accessibility of our city’s digital assets. It details our commitment, the legal standards we adhere to, the current state of our digital services, and our plan for ongoing improvement. This document serves as a testament to our dedication to digital inclusivity, ensuring that our digital services accommodate all users, fostering an environment of equality and access for individuals with disabilities.

Overview of Applicable Laws

For the City of Littleton, adhering to digital accessibility standards is not just a commitment to inclusivity but also a legal requirement. Our efforts are guided by both state and federal regulations, ensuring that all individuals, regardless of ability, have equal access to our digital services.

On June 30, 2021, the HB21-1110 Act was signed, adding significant provisions to strengthen Colorado's stance against discrimination towards persons with disabilities, especially concerning digital accessibility. This act mandates that:

  • Individuals with disabilities must not be excluded from participating in or denied the benefits of services, programs, or activities of a public entity or a state agency.
  • Public entities and state agencies are required to develop an accessibility plan and comply fully, by July 1, 2024, with accessibility guidelines established by the Office of Information Technology (OIT).
  • Colorado agencies with rule-making authority cannot enact rules that offer less protection than what is provided by the "Americans with Disabilities Act of 1990" (ADA).

The City of Littleton is committed to aligning with these provisions, along with the ADA's requirements, to ensure our digital services are accessible to everyone, including those with disabilities. By following these guidelines, we aim to not only meet legal obligations but to set a standard for digital inclusivity within our community.

Our Current Digital Services Inventory

The City of Littleton is dedicated to providing a wide range of digital services to meet the diverse needs of our community. Ensuring the accessibility of these services is paramount to our commitment to inclusivity for all users, including those with disabilities. Our inventory of digital services encompasses various platforms, each designed to enhance the way we connect with and serve our residents. Here is an overview of our primary digital platforms:

  1. Littletonco.gov – The main website serves as the central hub for city services, information, and resources.
  2. Library.Littletonco.gov – Dedicated to providing accessible library services, including digital resources and information about library programs.
  3. Museum.Littletonco.gov – Offers online access to museum exhibits, collections, and educational resources.
  4. Police.Littletonco.gov – Provides public safety information, police reports, and community policing initiatives.
  5. Billpay.Littletongov.org – Facilitates easy and accessible online bill payment for city services.
  6. Permit9.Littletongov.org– Supports the online application and management of permits and licenses.
  7. Visitlittleton.org – Promotes tourism by offering information on attractions, events, and accommodations in Littleton.

In addition to these websites, the City of Littleton utilizes a myriad of other applications and platforms designed to improve civic engagement, streamline city operations, and enhance the delivery of services to our community. Each platform is being evaluated and will be updated to ensure compliance with WCAG 2.1 Level AA standards, making our digital presence accessible to all users, regardless of their abilities.

Exclusions

  1. City customer-facing websites, mobile applications, digital screens, electronic communication, and digital documents that have been archived are not subject to the standards referenced in this policy.
  2. Syndicated content such as social media streams is excluded from this policy.
  3. The below document types can be added to our online services with the following disclaimer and a short summary under the document hyperlink: "[Insert the short summary of the document] Upon request the city will make reasonable accommodations for alternative access to the documents listed above. Submit the request here (link to accommodations form)".
  • Blueprints
  • Architectural drawings
  • Diagrams displaying information that is also provided in narrative text
  • Complex and/or atypical images and diagrams
  • Scanned historical publications
  • Handwritten correspondence
  • Technical drawings
  • Site plans, development plans, and maps
  • Complex and comprehensive tables and charts
  • Documents or document types identified by the Accessibility  Committee as having a no-to-low impact on users of assistive technology or documents that contain information that Is available in an alternative and accessible format
  • Any image with no logical methodology to create an alternate description that will make the image understandable to assistive technology.

4. Upon request the city will make reasonable accommodations for alternative access to the online technologies that are excluded from this policy.

Testing Tools and Techniques

To ensure our digital services are accessible to all users, the City of Littleton employs a comprehensive array of testing tools and techniques. Recognizing the importance of both automated and manual testing in identifying and addressing accessibility barriers, we utilize the following key tools in our digital accessibility initiatives:

  1. Allyant – For auditing our websites and applications, Allyant provides comprehensive assessments against WCAG 2.1 Level AA standards, helping us identify and rectify accessibility barriers in our digital platforms.
  2. CommonLook – Specializing in PDF and document remediation, CommonLook tools enable us to ensure all our digital documents are accessible, providing equal access to information for users with disabilities.
  3. SiteImprove – This tool is utilized for ongoing website and document auditing, offering insights into accessibility, quality assurance, and SEO. SiteImprove helps us monitor our compliance with accessibility standards and improve the user experience across our digital services.
  4. WAVE and Other Common Accessibility Tools within Chrome – To complement our toolkit, we leverage various accessibility testing tools available as Chrome extensions, such as WAVE. These tools provide immediate feedback on accessibility issues, allowing for quick and effective remediation by our development teams.

Our approach to testing encompasses both automated tools and manual evaluation to cover a wide range of accessibility concerns. By integrating these tools into our development and maintenance processes, we ensure ongoing compliance with accessibility standards and a commitment to providing inclusive and accessible digital experiences for all users.

Review Process and Results

The City of Littleton is committed to an ongoing and dynamic process of evaluating and enhancing the accessibility of our digital services. Our review process is designed to be comprehensive, inclusive of all digital assets, and iterative, ensuring continuous improvement in digital accessibility. Here’s an outline of our approach:

Inventory and Audit

  • Asset Inventory: We commence with a thorough inventory of all digital assets. This includes websites, web applications, digital documents, and any other forms of digital content provided to the public.
  • Automated Auditing: Utilizing Allyant and SiteImprove, we conduct automated audits of these assets to identify potential accessibility issues. These tools are instrumental in providing a baseline understanding of where our services stand in relation to WCAG 2.1 Level AA compliance

Documentation and Prioritization

  • Excel and Documentation: Findings from our audits are meticulously documented, primarily using Excel spreadsheets. This allows us to prioritize issues based on severity, impact, and the complexity of remediation.
  • Continuous Review Cycle: Acknowledging that digital accessibility is a moving target, our review process is ongoing. We continuously cycle through inventory, auditing, documentation, and remediation phases to adapt to new content, technologies, and changes in accessibility standards.

Remediation and Monitoring

  • Remediation Plans: For each identified issue, we develop and implement a remediation plan. These plans are crafted with the goal of not just meeting, but exceeding, WCAG 2.1 Level AA standards.
  • Monitoring and Evaluation: Post-remediation, we monitor the effectiveness of our efforts and conduct follow-up evaluations. This ensures that remediations have been successful and remain effective over time.

Reporting and Feedback

  • Accessibility Reports: Regular accessibility reports are generated and reviewed by our digital accessibility team. These reports help inform our city’s leadership about our progress and guide future accessibility initiatives.
  • Public Feedback: We actively encourage and solicit feedback from our community on the accessibility of our digital services. This feedback is invaluable, providing insights that guide our continuous improvement efforts.

The City of Littleton's review process is ingrained in our commitment to digital inclusivity. By inventorying our assets, using leading tools for auditing, meticulously documenting our findings, and engaging in continuous review and remediation, we ensure our digital services are accessible to all users, including those with disabilities.

Transition Plan

The City of Littleton’s Digital Accessibility Transition Plan is designed to ensure that all digital services comply with the Web Content Accessibility Guidelines (WCAG) 2.1 Level AA standards, in alignment with state law requirements. Our plan is structured to meet the July 1, 2024, deadline for full compliance, establishing a roadmap for auditing, remediation, and ongoing enhancement of our digital accessibility.

Timeline and Phases

  • Auditing (April through May 2024): We are currently in the auditing phase, utilizing Allyant, SiteImprove, and other accessibility tools to comprehensively assess our digital services. This phase focuses on identifying accessibility barriers across our websites, applications, and digital documents.
  • Remediation (May and June 2024): Following the completion of our initial auditing phase, we will begin the remediation phase. This involves addressing the identified accessibility issues, prioritizing them based on impact and complexity. Remediation efforts will be aimed at ensuring that all digital content and services are fully accessible and compliant with WCAG 2.1 Level AA standards.
  • Legislative Deadline - July 1, 2024: All auditing and remediation activities are aligned with the goal of achieving full compliance by July 1, 2024. This deadline is set to meet the state law requirements, ensuring that our digital services are accessible to all users, including those with disabilities.

Ongoing Auditing and Remediation

Recognizing that digital accessibility is an ongoing endeavor, the City of Littleton commits to continuous auditing and remediation efforts beyond the July 1, 2024, deadline. Digital services will be regularly reviewed for compliance, and any new services or updates will undergo accessibility evaluations before launch. This ensures not only compliance but also a commitment to providing an inclusive digital environment for all community members.

Reporting and Feedback

Progress towards our digital accessibility goals will be documented and reported regularly. These reports will provide transparency on our efforts, challenges, and successes. Additionally, we value feedback from our community and stakeholders, which will be instrumental in guiding our ongoing accessibility improvements.

Training & Awareness

The City of Littleton is committed to fostering a culture of digital accessibility within all levels of our organization. Recognizing the importance of education and awareness in achieving this goal, we have developed a comprehensive training program that caters to the varied roles and responsibilities within our city government.

Training Program Overview

  • General Awareness Training: Already underway, this training aims to raise awareness about the importance of digital accessibility across the city’s workforce. All employees are encouraged to participate in these sessions, which are designed to provide a broad understanding of accessibility principles, legal requirements, and the impact of accessibility on our community.
  • Live and Recorded Training Sessions: To accommodate diverse schedules and learning preferences, training will be offered in both live and recorded formats. These sessions will cover a wide range of topics, including digital accessibility fundamentals, document remediation techniques, and best practices for creating accessible digital content.
  • Role-Based Training: Targeted training sessions will be provided for key players within the organization, including the IT department, city webmaster, subject matter experts from each department, and other staff as necessary. These sessions will delve into the specific responsibilities and actions each role can take to contribute to the city’s digital accessibility efforts.
  • Vendor-Provided Training: In addition to in-house training, the City of Littleton will leverage the expertise of our vendors, such as Allyant, to provide specialized training sessions. These sessions will offer detailed insights into using accessibility tools and services effectively, ensuring that our team is equipped with the latest knowledge and skills.

Ongoing Training and Support

Understanding that digital accessibility standards and technologies evolve, the City of Littleton commits to offering ongoing training and support for our staff. Regular updates, refresher courses, and new resources will be made available to ensure that our team remains proficient in accessibility practices and can respond to emerging challenges and opportunities.

Engagement and Feedback

To measure the effectiveness of our training program and identify areas for improvement, we will actively seek feedback from participants. This feedback will inform the continuous development of our training offerings, ensuring they meet the needs of our staff and advance our accessibility goals. 

Documents

In alignment with our commitment to digital accessibility and in compliance with state law, the City of Littleton has established a proactive plan for the assessment and remediation of public-facing documents. Our goal is to ensure that all documents are accessible to everyone, including those with disabilities, by meeting or exceeding WCAG 2.1 Level AA standards.

Remediation Strategy

  • State Law Compliance: Initially, our focus is on remediating documents that are required by state law. This includes ensuring that essential public-facing documents meet accessibility standards as a priority. Our staff, along with potential third-party vendors, are actively working to remediate these documents.
  • Ongoing Remediation: Beyond the immediate requirements, we aim to assess and remediate additional non-mandatory documents as time and resources permit. This phased approach allows us to steadily increase the accessibility of our entire document repository.
  • Departmental Responsibility: The responsibility for document remediation lies with department staff and the city webmaster. Each department will identify documents within their purview for remediation, prioritizing those that are most frequently accessed or critical to public services.
  • Tools and Resources: To assist in the remediation process, we are utilizing CommonLook, a leading tool for document accessibility. CommonLook will be employed to review, identify, and remediate accessibility issues within our documents, ensuring compliance with the latest standards.

Training and Support

  • Staff Training: Recognizing the importance of skill development in document remediation, we are providing targeted training for department staff and the city webmaster. This training equips our team with the knowledge and tools necessary to create and maintain accessible documents.
  • Vendor Support: When necessary, we will leverage the expertise of third-party vendors to assist with complex document remediation projects. These vendors are selected based on their proficiency in creating documents that meet WCAG 2.1 Level AA standards.

Monitoring and Evaluation

  • Regular Assessments: We will conduct regular assessments of our public-facing documents to ensure ongoing compliance with accessibility standards. This includes periodic reviews of newly added or significantly altered documents.
  • Feedback Mechanism: A feedback mechanism will be established to allow users to report accessibility issues with our documents. This feedback will be invaluable in identifying and addressing any gaps in our remediation efforts.

Policies & Guidelines

To reinforce our commitment to digital accessibility and ensure consistent application across all city services, the City of Littleton has established comprehensive policies and guidelines. These policies and guidelines are designed to guide our efforts in making digital services accessible to everyone, including people with disabilities.

Digital Accessibility Policy

  • Objective: Ensure all digital services, including websites, mobile applications, and online documents, comply with WCAG 2.1 Level AA standards.
  • Scope: Applies to all city departments and third-party vendors providing digital services on behalf of the City of Littleton.
  • Responsibility: Each department is responsible for implementing these guidelines within their digital offerings, with oversight provided by the city's webmaster and IT department.

Procurement Policy

  • Objective: Guarantee that all new digital services and technologies procured meet or exceed WCAG 2.1 Level AA accessibility standards.
  • Evaluation: Vendors must demonstrate compliance with our accessibility standards as part of the procurement process.
  • Contract Language: Contracts with vendors will include clauses that require adherence to WCAG 2.1 Level AA standards, with mechanisms for accountability and remediation if services fail to meet these standards.

Document Accessibility Guidelines

  • Objective: Ensure that all digital documents are accessible, with a particular focus on those required for compliance with state law.
  • Process: Utilize CommonLook and other accessibility tools for document remediation. Train staff on creating accessible documents from the outset.

Web Accessibility Guidelines

  • Objective: Achieve and maintain WCAG 2.1 Level AA compliance for all city-owned digital platforms.
  • Monitoring and Evaluation: Regularly audit city websites and applications using SiteImprove and other relevant tools to identify and remediate accessibility issues.

Training and Awareness

  • Objective: Build and maintain a high level of accessibility awareness and expertise among city staff.
  • Implementation: Provide ongoing training for all city employees, with specialized training for staff directly involved in content creation, web development, and procurement.

Feedback and Continuous Improvement

  • Objective: Encourage feedback from the community on the accessibility of digital services and use this feedback to drive continuous improvement.
  • Mechanism: Implement an accessible feedback form on all city digital platforms, ensuring community members can easily report issues or suggest improvements.

External Applications and Vendor Agreements

Recognizing the critical role that external applications and services play in the City of Littleton’s digital ecosystem, we have implemented specific measures to ensure these external resources meet our stringent accessibility standards.

Vendor Selection and Agreements

  • Compliance Requirement: All external vendors must demonstrate their commitment to WCAG 2.1 Level AA standards. This requirement is a pivotal part of the selection process for any service or application intended for public use.
  • Accessibility Agreement: Contracts with vendors include explicit terms requiring adherence to WCAG 2.1 Level AA accessibility standards. These agreements mandate regular accessibility audits and remediation of any identified issues within agreed-upon timelines.
  • Vendor Accountability: Vendors are required to submit periodic reports on their compliance status, including details of any accessibility audits conducted and the remediation of identified issues. Failure to meet the agreed standards may result in contract termination or penalties.

Integration and Implementation

  • Accessibility Review: Before the integration of any external application or service, a thorough review is conducted by the City of Littleton’s IT department and accessibility specialists to ensure compliance with our digital accessibility standards.
  • User Testing: Where possible, applications and services are tested with a diverse group of end-users, including individuals with disabilities, to ensure that they are not only technically compliant but also user-friendly and accessible in practice.

Ongoing Monitoring and Partnership

  • Continuous Collaboration: We engage in an ongoing dialogue with our vendors to address the evolving landscape of digital accessibility. This includes discussing updates to standards, sharing best practices, and exploring new technologies to enhance accessibility.
  • Training and Resources: Vendors are encouraged to provide training and resources to city staff to ensure effective implementation and management of their services. This support is crucial for maintaining accessibility in the long term.

Moving Forward

As the City of Littleton continues to evolve and expand its digital services, our commitment to digital accessibility remains steadfast. Our future goals and plans are designed not just to comply with current standards but to set a benchmark for excellence in digital inclusivity. Here are the key milestones and initiatives we are committed to achieving: 

Website Redesign and Platform Upgrades

Objective: Ensure that any future redesigns or platform changes prioritize accessibility from the outset, aiming for WCAG 2.2 compliance.

Action Items:

  • Conduct thorough accessibility evaluations before, during, and after any major digital service overhaul.
  • Integrate accessibility considerations into the procurement process for new technologies and platforms.

In-House Digital Accessibility Program

Objective: Develop and implement an in-house digital accessibility training program by the end of 2024, focusing on equipping our staff with the knowledge and tools to maintain and improve accessibility across our digital offerings.

Action Items:

  • Create tailored training materials for different roles within the city administration, including web developers, content creators, and department heads.
  • Monitor and assess the effectiveness of the training program, making adjustments as needed to ensure it meets the evolving needs of our staff and community.

Continuous Improvement and Engagement

Objective: Foster a culture of continuous improvement and community engagement around digital accessibility.

Action Items:

  • Implement a feedback mechanism on all digital platforms to gather insights from users about their accessibility experiences.
  • Regularly review and update our digital accessibility policies and practices to reflect technological advancements and changes in accessibility standards.

Long-Term Vision

The City of Littleton envisions a future where all digital services are inherently accessible, eliminating barriers for people with disabilities and ensuring equal access for all community members. Our ongoing efforts in training, policy development, and community engagement are crucial components of this vision. By actively pursuing these goals and plans, we reaffirm our commitment to creating a more inclusive and accessible digital environment for every resident of Littleton.

 

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