COORDINATED TRANSPORTATION PLAN

HUMAN SERVICES

COORDINATED TRANSPORTATION PLAN

Confederated Tribes of Sile

Indians

2026-2030

Draft for Public Review, Advisory Commi ee Recommendation, and Tribal Council

Adoption

Lead agency

Confederated Tribes of Sile

Planning Department / Sile

Indians

Tribal Transit System

201 SE Swan Avenue, Sile , Oregon 97380

541-444-2532

Prepared March 2024 - September 2026

INTRODUCTION

The Confederated Tribes of Sile

Indians (CTSI), in cooperation with the Oregon

Department of Transportation (ODOT) and Association of Oregon Counties, is

updating its Coordinated Human Services - Public Transportation Plan (Coordinated

Plan). Originally adopted in 2009, the Coordinated Plan focuses Tribal and regional

resources on ensuring that public transportation efficiently and effectively gets people

to important destinations, such as jobs and medical appointments.

Unlike other types of transportation plans that focus on how the transportation system

functions, a Coordinated Plan engages public transportation providers and the human

and health service communities in collaboratively identifying and addressing how best

to match public transportation services to human and health services, and vice-versa.

Tribal transportation is funded, in part, through Federal Transit Administration (FTA)

and State funds. FTA and ODOT require recipients of FTA Section 5310 program funds

and State Special Transportation Funds (STF) to engage in a coordinated planning

process. The goal is to broaden the dialogue and support coordination among public

transportation providers and human and health service providers to ensure that

appropriate public transportation services support special needs populations. FTA

Section 5310 and STF funds provide operating assistance to transportation providers

and programs that serve these targeted populations. Projects submi ed for FTA and

STF funding must be included in the Coordinated Plan. Coordinated Plans are

updated every five years.

The purpose of the Coordinated Plan is to support coordination between public

transportation and human and health services, focusing on older adults, people with

disabilities and people of low income.

Independent of this effort, Lincoln County has recently updated its Coordinated Plan.

Public transportation services in Lincoln County, including regional connections, are

detailed in the County’s Coordinated Plan, which is incorporated by reference into this

Plan. Similarly, public transportation services available to Tribal members in Benton

and Linn Counties are described in the 2017 Benton County and Linn County

Coordinated Plans, respectively.

Lincoln County is also currently developing a Transit Development Plan (TDP) and the

Confederated Tribes are anticipating updating their Transportation System Plan (TSP),

with accompanying Safety Plan, in the near future. A Coordinated Plan is distinct from

both a TDP and a TSP. A TDP focuses on transit service improvement alternatives over

a 20-year period; a TSP addresses all components of the transportation system in the

County -- roads, bicycle/pedestrian facilities, public transportation, air, rail, etc. – also

over a 20-year period. A Coordinated Plan, on the other hand, is intended to engage

public transportation and human health service providers in collaboratively identifying

and responding to the public transportation needs of special needs populations -- older

adults, persons with disabilities, low-income persons, veterans, and minority

populations -- over a 5 to 10-year timeframe.

Coordination means the efficient and effective use of public transportation resources for

ge ing people to important destinations, such as jobs and medical appointments. Public

transportation means all forms of transportation available for public use, including

transit, demand response services, taxis, technology service companies such as Uber,

shu les, private bus lines such as Greyhound, Amtrak, etc.

The Coordinated Plan identifies critical transportation needs, available resources, and

strategies to create efficiencies, reduce redundancy, and ensure the continuation of

high-quality transportation services. In addition to supporting the long-term needs for

transportation services for all Tribal members, the Coordinated Plan specifically focuses

on matching public transportation to the needs of special populations -- older adults,

persons with disabilities, and low-income persons. It includes:

•

Stakeholder input (see Section B.1).

•

Updated demographics and information on existing transportation services. This

component defines the service market, highlights gaps in transportation services, and

identifies the transportation needs of target populations.

•

A description of the progress made in addressing the needs and implementing

the strategies identified in the 2009 Coordinated Plan.

•

Strategies for transportation services, projects, investments and other actions to

expand or improve services and for coordination between CTSI and transportation

providers and the human and health service communities.

Coordination planning and the federal and state expectations for Coordinated Plans

consistently evolve. Among Plan elements that are new or expanded from the 2009

Coordinated Plan are recognition of the role that public transportation plays in

emergency preparedness; an overall vision for Tribal transportation services; inclusion

of health service providers as key partners in coordination of public transportation and

human services; and be er linkage between strategies and transportation needs through

combination of needs, strategies and actions into a single section of the Plan.

CTSI, Lincoln County Transit and other transportation providers will use the

Coordinated Plan to select the highest-priority strategies that match available resources

and related timeframes. The Coordinated Plan also supports ongoing coordination

among regional transportation providers by documenting a clear and open planning

process, identifying funding priorities, and identifying opportunities for ongoing and

future partnerships.

The intent of the Coordinated Plan is to be a “living” document identifying needs and

investment priorities. The Sile

Tribes will use the plan to allocate funding and, along

with local partners, will use the plan to develop and enhance tribal transportation

services.

Executive Summary

The Confederated Tribes of Sile

Indians (CTSI or the Tribe) adopts this Human

Services Coordinated Transportation Plan to improve mobility for Tribal members and

the public, with focused a ention to older adults, individuals with disabilities, people

with low incomes, veterans, youth, and people who need transportation to health and

human services. The plan covers October 1, 2026 through September 30th, 2030 and is

designed to serve as the Tribe’s locally developed coordinated public transit-human

services transportation plan for Federal Transit Administration (FTA) Section 5310

purposes and as a qualifying Oregon “Local Plan” for Statewide Transportation

Improvement Fund (STIF) planning.

CTSI provides transportation through Tribally owned vans and buses for scheduled

activities, congregate elder meals, medical appointments, and other needs when other

service is not readily available. These services operate as needed in Lincoln County and

through the Tribe’s Portland, Salem, and Eugene area offices. CTSI also coordinates

with Lincoln County Transit for scheduled public service along key Lincoln County

corridors, with Tribal members eligible to ride participating county service without fare

when showing Tribal identification. [T1]

The mobility challenge is geographic and institutional. Tribal members live across a

large service territory, essential destinations are dispersed, rural trips are long, and

riders often must cross county, transit-district, health-care, and funding boundaries.

Lincoln County’s 2025 population estimate is 50,636; 34.6 percent of residents are age 65

or older, 17.2 percent of people under age 65 report a disability, and 16.3 percent of

residents live in poverty. These indicators show unusually high potential need for

accessible, affordable, coordinated mobility in the Tribe’s home county. [D1]

Plan outcomes

•

Maintain reliable, safe, accessible Tribal transportation before adding service that

cannot be sustained.

•

Provide convenient access to health care, Tribal services, employment, education,

food, cultural activities, and community life.

•

Close temporal, geographic, information, affordability, and accessibility gaps,

especially for rural riders and long-distance medical trips.

•

Coordinate trips, schedules, referrals, vehicles, training, procurement, data, and

emergency operations with public and human-service partners.

•

Create a defensible, transparent basis for selecting Section 5310, STIF, Tribal

Transit, and other grant projects.

•

Measure outcomes by mobility gained and gaps closed, not only by vehicle miles

or spending.

PLAN DEVELOPMENT PROCESS

Overall Process

This update of the 2009 Sile

Tribes Coordinated Plan is part of an effort by ODOT to

update all Coordinated Plans in the state. Under the umbrella of a region-wide Central

Willame e Valley Coordinated Human Services-Public Transportation Plan (Regional

Coordinated Plan), ODOT Public Transit is assisting CTSI in preparing this Tribalspecific component of the regional Coordinated Plan. To facilitate its preparation and to

ensure consistency among the county “chapters” of the regional Coordinated Plan,

ODOT Public Transit contracted with the Association of Oregon Counties and its

subconsultants Cogan Owens Greene, LLC and Nelson Nygaard to prepare this Plan

and to advise and assist on the planning process.

A separate regional chapter of the Regional Coordinated Plan will address regional

travelshed issues, needs and strategies. While adoption by the Tribes and the counties

will not be required, review and endorsement will be sought.

CTSI regularly reaches out to Tribal members via the Tribal newspaper, a confidential

newsle er (members only), a Tribal website, regular surveys, and the Planning

Department holds community outreach meetings in Sile

offices” (Portland, Salem, and Eugene) and the Sile

and in each of the 3 “area

Tribal Community Center. Plan

development has included periodic meetings with CTSI staff for purposes of

information collection, advice on process, and iterative review of draft Plan sections.

Stakeholder interviews with public transportation providers, human and health service

community representatives, local governments and others has also been a critical part of

the process.

Regional Stakeholder Input

Regional and Lincoln County-specific input is summarized in the Lincoln County

Coordinated Plan. Input relevant to services provided in the Lincoln County portion of

the Tribes’ service area follows:

What works well in terms of transportation services? Is service consistent?

Stakeholders indicate that current services are generally reliable and consistent and are

appreciated by consumers. Nearly all interviewees mentioned that available public

transportation services be er meet the needs of persons who live in larger communities

(Lincoln City and Newport), than for those who live in smaller cities such as Sile ,

unincorporated communities, and rural areas. A number of interviewees mentioned

that the Oregon Cascade West Council of Governments role as the transportation

brokerage for non-emergence Medicaid transportation (NEMT) works well and is

effective.

What is not working well in terms of transportation services?

Respondents indicate that increasing demand and lack of resources to meet the varied

needs of special needs populations and other public transportation users, especially in

rural and isolated areas, are the major factors in what is not working well with existing

transportation service. They also cite a general lack of knowledge about what public

transportation services are available and li le to no knowledge of how they are funded.

This lack of acknowledge about available services extends to both human and health

service providers and clients. While public transportation users may be aware of the

specific services that they utilize, unless they are taking advantage of such, they have

li le to no knowledge of connecting services or of transportation opportunities within

the travel shed. Select comments include:

•

Limited hours of operation and frequency of service are most frequently cited as

the major barriers to the use of public transit. Gaps in mid-day and evening service are

particularly problematic. Length of time between buses is a discouragement towards

ridership, both current and new.

•

Transit service is not coordinated with class schedules at South Coast

Community College.

•

Poor connections, as well as limited hours of operation, make longer trips

difficult. Many potential users live in outlying areas yet the most accessible services are

in Newport and Lincoln City.

•

Expanded Medicaid services have put excessive demand on the system as a

whole.

•

Clients doing shift work, especially in service industries, are challenged to access

employment because of limited public transportation.

•

Public transportation can be difficult for older adults and people with disabilities

to access. Older adults and persons with disabilities living outside Lincoln City and

Newport are not served by public transportation.

What are the primary barriers to use of available services?

The lack of resources/funding is frequently cited as the greatest barrier to being able to

accommodate the full range of transportation needs. Interviewees also frequently

identify key barriers to include a lack of service outside of incorporated areas and

services being inadequate or inconvenient to meet the needs of special populations.

Geographic/demographic barriers are the most frequently mentioned barriers,

especially transportation in rural, isolated areas.

The key information barrier is identified as the lack of public information about

available services. Stakeholders observe that the existing public transportation system is

simply not well understood.

In terms of legal/regulatory barriers, several respondents note that each of the three

counties in the region receives STF funding and creates its own program; they suggest

that be er integration of county-specific programs into a regional system region would

help create a more seamless system.

How well are regional (town-to-town) transit needs being met?

Connections between the coast and the Valley are identified as being fairly good,

although scheduling and frequency of service could be improved. Conversely, smaller

communities are identified as having poor or no connections.

What are future trends that will modify the demand for transportation services?

Regional population growth; aging of the Baby Boomers; growth in the number of

medical facilities and senior residences; and technological changes, advances and

opportunities are among the key trends interviewees expect to impact future

transportation needs. There is increasing need for special transportation for individuals

with mobility and cognitive impairments, including the State’s Employment First

program which requires all individuals with developmental disabilities to get a job.

What are the highest priorities that should be pursued to address gaps or limitations in

service?

Most interviewees felt that addressing small community and rural area transportation

needs is the most urgent need. Another high priority is for coordination among service

providers, among the counties and between transportation planners and the housing

and health care sectors.

What would make public transportation services more efficient?

Scheduling efficiencies and enhanced use of technology, provision of travel training and

travel navigator programs, increased coordination among providers, and exploration of

private partnership opportunities are all identified as ways to improve the effectiveness

of public transportation. Among the specific suggestions:

Consider how vanpooling and carpooling can integrate with public transportation to

reach underserved areas.

Provide transit training; offer free days to ride with trainers. (It was also mentioned

several times that individuals with behavioral, cognitive and other special needs could

benefit from personal assistance, such as Travel Navigators.)

More coordination between health and social services providers. Duplication occurs

now because of lack of coordination. Need more partnerships with non-profits.

Need more streamlined public education. More information translated into Spanish and

more consumer-friendly information on buses.

More funding for volunteer programs such as Senior Companion program.

Save energy by using smaller, more efficient buses on routes with low ridership.

How can coordination/partnering among providers be improved?

Despite a number of suggestions for improvements in coordination, stakeholders

generally feel that coordination among regional transportation providers within Lincoln

County and between Lincoln and Benton counties is very good. Oregon Cascades West

Council of Governments (COG) is seen as communicating well with its members and

providing expertise relative to public transportation services. The benefits in having

management of both senior services and the transportation brokerage within the COG

are specifically noted.

Most participants indicate increased efforts in partnering would be beneficial.

Partnerships between treatment programs and counties, the Coordinated Care

Organization (CCO), human service agencies, and universities are expected to help in

understanding and meeting transportation needs.

Stepping back, what is your dream for public transportation in the region?

Interview participants have numerous ideas about the design of a transit system for the

region. In summary, most feel a system that is accessible and dependable, easily

understood, and meet the needs of the community is the ideal.

CTSI Input

Input from CTSI members is another critical element in Plan preparation. Staff indicates

that input on transportation needs is collected on a regular basis, including through the

Tribe’s STF Advisory Commi ee, annual community outreach meetings sponsored by

the Planning Department and through outreach to other Tribal offices through monthly

gatherings. Participants indicate that they are generally happy with Tribal

transportation services.

Input on this draft Plan will be solicited by Planning Department staff through the STF

Advisory Commi ee, the annual Planning Department Tribal Community outreach

meetings in Sile , Eugene, Salem and Portland, via tribal member surveys, feedback

from Departments serving the Tribal membership, and from the STTS (Sile

Transit System/STF Commi ee.)

Tribal

Notable issues include:

•

Transit provides an important social safety net;

•

The Tribal membership residing in Lincoln County is grateful for the existing

contracted services with Lincoln County Transit;

•

Elders want a comfortable, quality transit experience;

•

Connection to Grand Ronde and Salem is valued;

•

Meeting the transportation needs of Veterans is important;

•

Assistance with rides to medical appointments is a need that is growing as the

population ages;

•

Evening return service to Sile

so that working people and GED students can

a end Oregon Coast Community College classes.

Participation in other planning processes, such as the Lincoln County Transit

Development Plan and Coastal Connector projects (such as a Yachats – Florence service

pilot project), provides additional opportunities to identify and develop strategies to

address Tribal transportation needs.

DEMOGRAPHICS

Approved by Congress in September 1980, the Sile

Reservation was originally

composed of 39 separate parcels of land in Lincoln County, Oregon, in and near the city

of Sile . Sile

was the site of the administrative headquarters for the original Sile

Reservation established by Executive Order in 1855. Sile

remains the location for

tribal government and administrative services and is also the location of the Bureau of

Indian Affairs (BIA) Sile Agency. The Tribe also maintains satellite offices in

Portland, Salem, and Eugene to serve tribal members in these areas.

The city of Sile

lies about eight miles inland from the Pacific Ocean. The nearest

coastal communities include Lincoln City, a 25-mile drive to the north; Toledo, about six

miles south, and Newport, a 15-mile drive to the southwest.

Of the total tribal land base, 142 acres are in fee, 72 are in trust, and 3,989 are declared

Reservation. Most of the reservation lands are in sca ered parcels east of the city of

Sile . The Tribe also has land holdings in several other communities. These include

industrial land in Toledo, a casino and residential property in Lincoln City, and

commercial property in Depoe Bay and in Salem, which is located in the Willame e

Valley east of Sile .

Sile

tribal members are concentrated in Lincoln County, though members live

throughout northwestern Oregon. Figure 1 shows the general areas where Sile

tribal

members live, important destinations, and transportation services available.

Document Status and Required Adoption Actions

Status of this draft

This document is complete as a policy and implementation plan, but it is not an

approved coordinated plan until CTSI completes and documents the public

participation process, obtains a recommendation from the Tribal transit/STIF advisory

commi ee, adopts the plan through Tribal Council action, and inserts the final records

in Appendix C and Appendix G.

Action Required evidence Status / date

Release accessible public-review draft

paper formats

Dated notice; draft available in electronic and

________________

Targeted outreach Invitations to Elders, people with disabilities (including wheelchair

users), low-income riders, providers, and public

________________

Public participation Meeting records, survey summary, wri en comments, and

response matrix

________________

Advisory Commi ee review

project list

Agenda, minutes, recommendation, and prioritized

________________

Tribal Council adoption

Signed resolution and adoption date

________________

ODOT submission Final plan transmi ed to ODOT Public Transportation Division

________________

STIP/TIP programming

Selected federally funded projects incorporated as applicable

________________

Certification of Local Development and Participation

Upon completion of the actions above, the Tribal Council certifies that this plan was

locally developed and approved through a process that included active participation by

older adults; individuals with disabilities, including people who use wheelchairs;

representatives of public, private, and nonprofit transportation providers; human

service providers; low-income individuals and their advocates; and other members of

the public. Comments were explicitly considered and responses are documented in

Appendix C. This certification is intended to support 49 U.S.C. 5310(e), FTA Circular

9070.1H, and ODOT program requirements.

Certification Name / title Signature

Tribal Council Chair

________________

Planning Director / plan lead

Advisory Commi ee Chair

Contents

Primary purpose

________________

________________

Transit Coordinator ________________

Section

Date

________________

________________

________________

________

________

________

________________

________

Executive Summary Decision summary and priority actions

1. Purpose, Authority, and Plan Scope

Legal basis, geography, populations, and

planning horizon

2. Governance and Planning Process

Roles, participation, advisory commi ee, and

adoption

3. Community and Target-Population Profile

4. Existing Transportation Resources

Demographic and destination analysis

Public, private, nonprofit, and human-service

inventory

5. Transportation Needs and Service Gaps

6. Coordination Framework

Documented barriers and unmet needs

Interagency structure and anti-duplication methods

7. Goals, Policies, and Standards Tribal policy direction

8. Prioritized Strategies and Projects

Funding-eligible program of strategies

9. Funding and Financial Strategy Section 5310, STIF, Tribal Transit, and match

10. Implementation and Performance Management

Work program, measures, and

reporting

11. Civil Rights, Accessibility, and Equity

ADA, Title VI, LEP, equity, and

complaints

12. Safety, Emergency Management, and Continuity Safety and disaster mobility

13. Grant Administration and Subrecipient Oversight Uniform Guidance and state

accountability

14. Adoption, Amendment, and Plan Maintenance

Appendices A-J

Compliance matrices, templates, project sheets, and certifications

Highest-priority strategies

Priority

Approval and change control

Strategy

2026-2030 result

1

Preserve core Tribal transportation and replace vehicles at the appropriate

lifecycle point

2

No avoidable loss of essential trips; safe and reliable fleet

Create one coordinated ride-access and mobility-management function

Single

entry point, warm referrals, travel training, and cross-program trip matching

3

Improve non-emergency medical and behavioral-health transportation

Fewer

missed appointments and clearer coordination with Medicaid/NEMT resources

4

Expand accessible demand response and regional connections

More

wheelchair-accessible capacity and be er connections to Lincoln City, Newport, Salem,

Eugene, and Portland

5

Implement rider information, reservations, dispatch, and performance data tools

Accessible information and reliable trip-level reporting

6

Build a trained volunteer-driver and backup-driver program More flexible rural

trips without displacing qualified providers

7

Formalize interagency coordination and emergency transportation protocols

Reduced duplication and dependable continuity during disruptions

8

Improve stops, transfer points, pedestrian access, and passenger amenities Safer,

more dignified access for riders of all abilities

9

Provide practicable student mobility and youth access Documented response to

STIF student-service priority and Tribal youth needs

10

Advance low/no-emission fleet and resilient facilities when lifecycle- and cost-

effective

Lower operating risk and resilient energy for essential service

Funding eligibility rule

A project may be funded with Section 5310 only if it is included in this adopted plan

and selected through the applicable recipient process. A STIF Formula project must also

appear in an adopted Local Plan and be described in a current STIF Plan with the

project-specific information required by OAR 732-042-0015. Appendix I supplies the

required STIF project and expenditure tables; it must be completed with the actual

biennial allocation, budgets, advisory recommendation, and adoption record before

submission.

1. Purpose, Authority, and Plan Scope

1.1 Purpose

This plan establishes a coordinated, culturally responsive mobility framework that

connects transportation with health, aging, disability, employment, education, housing,

food access, veterans services, cultural participation, and emergency management. It

identifies existing services, evaluates needs and gaps, defines coordination strategies,

and prioritizes projects for implementation and funding.

1.2 Legal and program authority

Authority

Plan response

49 U.S.C. 5310(e)

Projects are tied to a locally developed coordinated plan created

and approved with participation by the federally named stakeholder groups.

FTA Circular 9070.1H, Ch. V

Includes provider inventory, needs assessment,

strategies, priorities, participation process, and equivalent-service commitment.

23 CFR Part 450

Requires coordination with statewide/metropolitan planning and

programming selected projects in the STIP/TIP as applicable.

OAR 732-040-0005 Meets the definition of a Local Plan: four-year horizon,

demographic/destination analysis, service inventory, priorities, and coordination

opportunities.

OAR 732-040-0030 and -0035

Establishes advisory commi ee roles, public

documentation, diverse representation, and the minimum three-member standard for a

Tribe.

OAR 732-042-0015 Provides a crosswalk and a completion-ready supplement for

project-level STIF Plan content.

OAR 732-044 Provides a framework for discretionary STIF eligibility, application

content, commi ee review, accountability, and capital assets.

2 CFR Part 200 and 2 CFR Part 1201

Commits federal awards to uniform

administrative, cost, procurement, audit, property, and closeout requirements as

applicable.

Federal civil-rights and transit regulations

Commits the Tribe and applicable

contractors/subrecipients to Title VI, ADA/Section 504, DBE, drug and alcohol, charter,

school-bus, accessibility, and related award conditions as triggered.

This plan is a planning and project-eligibility document. It does not replace grant

agreements, the FTA Master Agreement, annual Certifications and Assurances, ODOT

agreement terms, procurement procedures, civil-rights plans, fleet plans, safety plans,

or the Oregon STIP/TIP. If a requirement changes or a specific award imposes a stricter

condition, the stricter current requirement controls.

1.3 Planning horizon and geography

The planning horizon is October__ , 2026 through October ____ 2030. The core planning

area is the Tribe’s area of responsibility in and around Sile

and Lincoln County,

together with transportation connected to the Portland, Salem, and Eugene area offices

and regional destinations used by Tribal members. Coordination extends beyond Tribal

lands whenever a trip, transfer, provider, funding stream, or essential destination

crosses jurisdictional boundaries.

1.4 Target populations

Population

Planning definition and focus

Older adults People age 65 or older for federal and Oregon demographic analysis,

while honoring any broader Tribal elder eligibility definition for Tribal programs.

Individuals with disabilities

People with physical, sensory,

intellectual/developmental, cognitive, or behavioral-health disabilities, including

wheelchair users and people whose disabilities are not apparent.

Low-income individuals/households

For Oregon STIF analysis, households at or

below 200 percent of the HHS poverty guidelines, consistent with OAR 732-040-0005;

program-specific eligibility may differ.

Veterans

Veterans needing access to VA and community care, including long-

distance medical trips.

Youth and students Young people needing safe access to education, work, services, and

Tribal activities, including grades 9-12 for the STIF priority.

Rural and transportation-disadvantaged residents

People without a reliable vehicle,

driver’s license, broadband connection, or nearby fixed route; residents needing crosscounty travel.

1.5 Sovereignty and non-waiver

CTSI adopts this plan in the exercise of Tribal self-government. Compliance

commitments stated here apply to the extent required by an accepted grant, contract,

law, or validly incorporated program condition. Nothing in this plan waives the Tribe’s

sovereign immunity, consents to jurisdiction, or modifies treaty, statutory, or

governmental rights. Any waiver must be explicit and authorized through the Tribe’s

established legal process.

2. Governance and Planning Process

2.1 Lead and governing bodies

Body Role

Tribal Council

Governing body; adopts the plan, approves material amendments,

establishes policy, and accepts awards.

Planning Department / Sile

Tribal Transit System

Lead planning entity; maintains

the plan, coordinates outreach, administers projects, and reports performance.

STTS / STIF Advisory Commi ee Advises on needs, coordination, project evaluation,

prioritization, and STIF recommendations; operates under wri en bylaws.

CTSI departments and programs Identify client needs, coordinate referrals/trips,

safeguard information, and help measure outcomes.

ODOT Public Transportation Division

State/designated-recipient partner for

applicable Section 5310 and STIF processes, agreements, oversight, and STIP

programming.

Regional partners

Coordinate schedules, transfers, eligibility, information, emergency

response, and project development.

2.2 Advisory Commi ee

Under current Oregon rules, a Qualified Entity that is an Indian Tribe must appoint an

advisory commi ee of at least three members, each able to represent the public

transportation needs of individuals served by the Tribe. The commi ee must reflect

diverse interests, perspectives, geography, and population demographics. Wri en

bylaws must address purpose, membership, appointments, terms, schedule, duties,

public notice, engagement, applicable public meeting and record practices, proposal

review, and decision criteria. Commi ee notices, bylaws, and minutes must be made

available for timely public review and retained as required. [O2] [O3]

As of September 12, 2026, CTSI’s public transit webpage identifies the STTS Commi ee

as the advisory body and lists representatives from Planning, GSA, Clinic/medical

transportation, Tribal programs, CARE, Elders, and Lincoln County Transit, with the

Tribal Veterans Coordinator invited. The webpage states that the commi ee meets

quarterly and as needed. Membership shall be reverified before adoption and whenever

a STIF Plan or grant application is submi ed. [T1]

Representation to preserve or recruit

Older adults / Tribal Elders

Minimum action

Maintain a voting representative or document

targeted recruitment and direct participation.

Individuals with disabilities, including wheelchair users

Add or maintain a voting

member with lived experience or a qualified disability advocate.

Low-income riders Add or maintain representation and include accessible

participation options.

Public/human-service transportation

health, and human-service participation.

Maintain Tribal transit, county/regional transit,

Geographic diversity

Include Sile /Lincoln County and invite area-office

perspectives from Portland, Salem, and Eugene.

2.3 Public-participation standard

Participation must be active and consequential. Providing notice or collecting opinions

without showing that input was considered is insufficient under FTA guidance. CTSI

will provide reasonable opportunities at key decision points, document the comments

received, state how each material comment affected the plan or why it did not, and

allow stakeholder participation in development and approval. [F1]

2.4 Required participation program

Stage Required actions

Scoping

Record

Invite federally required groups and Tribal programs; offer paper, phone,

online, and in-person participation.

Invitation list, notice copies, distribution log

Needs assessment Use accessible rider survey, provider inventory, interviews/focus

groups, trip data, and GIS/destination review. Survey instrument/results, interview

notes, maps/data

Strategy development

Hold workshop to test needs, develop solutions, identify

coordination opportunities, and flag privacy/cultural concerns.

Workshop record

and draft strategies

Prioritization Use published scoring criteria; commi ee deliberates in noticed meeting;

disclose conflicts.

Scores, minutes, recommendation

Draft review Provide at least 30 days when practicable; accessible formats; nonelectronic alternatives; assistance on request.

Notice, draft access locations, comments

Response and adoption

Publish response matrix; commi ee recommendation; Tribal

Council hearing/action.

Response matrix, minutes, resolution

2.5 Accessibility and culturally responsive engagement

•

Hold meetings at accessible locations reachable by transit or provide no-cost

transportation upon advance request.

•

Offer telephone, mail, online, and in-person participation; do not rely exclusively

on the Internet.

•

Provide large print, accessible electronic documents, sign-language

interpretation, language assistance, and other reasonable accommodations when

requested.

•

Use plain language, protect personally identifiable health and eligibility

information, and avoid requiring participants to publicly disclose disability or income

status.

•

Coordinate outreach through Elders, Clinic, Community Health, Vocational

Rehabilitation, 477 Self-Sufficiency, Veterans, Housing, Education/Youth, Behavioral

Health, area offices, and community partners.

•

Recognize Tribal schedules, cultural events, and community trust; use small-

group and one-on-one options when they produce be er participation.

3. Community and Target-Population Profile

3.1 Service context

The Tribe’s transportation system serves a dispersed population whose trips frequently

extend beyond a single city or transit district. The Sile

area is rural, the coast and

Coast Range create long and constrained travel corridors, and specialized medical,

behavioral-health, education, employment, and administrative destinations are often

located in Newport, Lincoln City, Corvallis, Salem, Eugene, Portland, and other

regional centers. The three area offices further connect Tribal programs with members

outside Lincoln County.

3.2 Public demographic baseline

Indicator

Lincoln County

Planning implication

Population estimate (July 1, 2025) 50,636 A county-scale system with rural dispersion

and regional trip needs.

Age 65 or older

34.6% High need for accessible, understandable, reliable, and

medically oriented service.

Disability, under age 65

17.2% High need for accessible vehicles, reasonable

modifications, door-to-door options, and travel assistance.

Persons in poverty 16.3% Affordability, fare relief, and access to employment/services

are central.

Veterans (2020-2024)

4,862 VA/community-care transportation and regional

coordination are important.

Language other than English at home

9.0% Language-access monitoring and

assistance are needed.

Broadband subscription

91.0% of households

Digital tools are useful but cannot

be the only way to obtain information or book rides.

Source: U.S. Census Bureau QuickFacts, Lincoln County, Oregon, accessed September

12, 2026. Estimates and percentages have different reference periods as shown in the

source. [D1]

3.3 Tribal administrative data protocol

Because county-level data do not describe Tribal members adequately, CTSI will

maintain a privacy-protective annual mobility profile using aggregated program and

transit data. No public table will disclose small cells, protected health information,

enrollment records, or individual eligibility. At minimum, the internal profile will

summarize the following by broad geography and target population when reliable:

•

Enrolled-member and service-user distribution by Sile /Lincoln County,

Portland metro, Salem/Mid-Willame e, Eugene/Lane County, and other areas.

•

Requested, completed, denied, cancelled, and no-show trips; trip purpose;

booking lead time; origin/destination zone; accessibility accommodation; and transfer

required.

•

Vehicle availability, accessible seating, lift/ramp incidents, spare ratio, mileage,

useful life, downtime, and preventive maintenance.

•

Missed medical appointments or unmet essential trips a ributable to

transportation, using only aggregated data and approved data-sharing practices.

•

Households without reliable vehicle access and riders reporting cost, schedule,

information, mobility-device, language, or safety barriers.

3.4 High-percentage low-income communities

For STIF purposes, CTSI defines a low-income household as one with total income at or

below 200 percent of the HHS poverty guideline, consistent with OAR 732-040-0005. A

“community with a high percentage” is a census tract, block group, Tribal housing

development, service-program catchment, or other defensible geography whose share

of such households exceeds the Oregon statewide share or the share for the relevant

county, or that is identified through Tribal administrative data as having concentrated

transportation disadvantage. CTSI GIS will update the analysis with the latest ACS fiveyear data and HHS guidelines before each STIF cycle. Qualitative evidence may

supplement, but not silently replace, the documented quantitative method.

3.5 Essential destinations

Destination class

Examples to inventory and map Service requirement

Tribal government and programs Sile

sites

administrative campus; area offices; program

Reliable arrival windows and coordinated program schedules

Health and behavioral health

Tribal clinics, pharmacies, hospitals, specialists,

dialysis, dental, MAT, counseling Accessible, confidential, appointment-timed trips;

return-trip flexibility

Food and basic needs

USDA distribution, grocery, meal sites, social services

Capacity for packages and mobility devices; recurring access

Employment and training Major employers, 477 services, vocational rehabilitation,

colleges

Early/late trips and cross-boundary connections

Housing and community Tribal housing, senior housing, community centers, cultural

events First/last-mile access and evening/weekend planning

Regional connections

Lincoln County Transit, POINT/intercity, Amtrak, Cherriots,

LTD, TriMet Timed transfers, shared information, disruption protocols

4. Existing Transportation Resources

4.1 CTSI services

Service/resource

Current function

Tribally owned vans and buses

Coordination opportunity

As-needed transportation for scheduled group

activities, elder meals, medical appointments, and destinations where other service is

not readily available.

Unified dispatch/referral rules; fleet sharing; trip grouping;

performance reporting.

Tribal NEMT scheduling Published phone access for Tribal non-emergency medical

transportation.

Warm referral with Medicaid broker/health providers; after-hours

message and return-trip protocols.

Area-office transportation As-needed service connected to Portland, Salem, and

Eugene area offices. Coordinate with TriMet, Cherriots, LTD, regional medical

providers, and intercity options.

Lincoln County Transit partnership

Contracted scheduled public service along

important Sile -Toledo-Newport-Lincoln City corridors; Tribal-ID fare arrangement.

Service standards, ridership reporting, transfer protection, joint outreach, and

emergency continuity.

Tribal programs

Elders, Clinic, Community Health, 477, VR, Veterans, Education,

Culture, Housing, and others generate or arrange trips.

Common intake fields,

consent-based referrals, and coordinated scheduling.

4.2 Regional provider inventory

The inventory below identifies provider categories and principal coordination

relationships. CTSI will validate operating hours, eligibility, accessibility, fares,

reservation rules, and contacts annually; current schedules control over this summary.

Provider / category Area or role Key coordination questions

Lincoln County Transit

Sile

County public transit and intercommunity connections

frequency, timed transfers, accessibility, fare policy, service interruptions,

reporting

Cascades West Ride Line / Medicaid NEMT brokerage Eligible Oregon Health Plan

medical transportation in the region

Eligibility, advance booking, denials,

urgent/after-hours trips, Tribal coordination, appeals

Oregon Cascades West Council of Governments / ADRC

Aging, disability, mobility

information and regional coordination Referral protocols, travel options counseling,

volunteer resources, data trends

Cherriots

Salem/Keizer and regional transit Area-office access, medical/employment

connections, paratransit eligibility and visitor status

Lane Transit District / RideSource Eugene-Springfield fixed route and accessible services

Area-office access, ADA paratransit, Medicaid/other coordination

TriMet / LIFT and regional partners

paratransit

Portland metro fixed route and ADA

Area-office and medical access, visitor eligibility, accessible transfers

ODOT POINT and intercity carriers

Intercity connections along Oregon corridors

Schedule compatibility, accessible booking, rural first/last mile

Veterans transportation resources VA and community-care access

Eligibility, long-

distance trips, escorts, same-day changes

Private taxi/TNC/NEMT providers

capacity

Supplemental, contracted, or on-demand

Accessible supply, rural coverage, procurement, insurance, rates, service

quality

Nonprofit/faith/community providers

Volunteer and client transportation

Driver

screening, insurance, reimbursement, referral, non-duplication

School and education transportation

Student transportation and activity access

Eligible public student service, trip timing, non-duplication with exclusive

school-bus operations

4.3 Inventory fields and annual verification

•

Service type and public/client-only status; geographic coverage; days/hours;

eligibility; reservation window; fare/cost; wheelchair accessibility; personal-carea endant/companion rules; service animal policy; reasonable-modification process;

language assistance; capacity; funding source; contact; complaint/appeal process;

emergency availability.

•

CTSI will record unused capacity, overlapping trips, recurring denials, transfer

failure, vehicle downtime, and opportunities for shared procurement or training.

•

A provider’s inclusion in this inventory does not guarantee eligibility,

availability, or funding and does not constitute a procurement selection.

5. Transportation Needs and Service Gaps

5.1 Needs-assessment method

The needs assessment combines rider and caregiver experience, provider knowledge,

commi ee deliberation, service and trip data, demographic and GIS analysis, and

review of prior Tribal priorities. Before final adoption, CTSI will insert the actual

participation results and response matrix in Appendix C. The gap framework

distinguishes whether a trip is unavailable, unaffordable, inaccessible, unreliable,

unknown to the rider, or administratively blocked.

5.2 Priority gaps

Gap

Who is most affected

Evidence to monitor

Long-distance and cross-county trips

Required response

Patients, veterans, area-office users, rural riders

Denials, trip length, transfers, missed appointments

Broker/provider

agreements; trip grouping; regional connectors

Limited evening/weekend/short-notice service Workers, behavioral-health patients,

caregivers, event participants

Requests outside service span; same-day denials

Pilot extended hours and flexible contracted capacity

Wheelchair and high-assistance capacity Wheelchair users, riders needing doorthrough-door assistance

Accessible-vehicle denials; lift failures; securement time

Accessible replacement/expansion; equivalent service; driver training

Information fragmentation New riders, elders, people with disabilities, LEP users

Misrouted calls; abandoned requests; survey feedback Single mobility contact;

accessible materials; warm referrals

Return-trip uncertainty

Medical and behavioral-health riders

riders; appointment overruns

Wait time; stranded

Will-call protocols and backup provider options

Affordability Low-income riders and households without vehicles Fare burden;

foregone trips

Fare relief, no-cost Tribal arrangements, benefit coordination

First/last-mile and stop access

Rural riders, wheelchair users, people with low vision

Unsafe paths/stops; missed boarding

Accessible stops, shelters, lighting,

pickup points

Driver and vehicle availability

All riders, especially during peaks/emergencies

Vacancies, overtime, downtime, spare ratio

Recruitment, cross-training,

volunteer/backup pool, preventive maintenance

Data and privacy barriers Programs coordinating client trips

Duplicate intake,

incomplete outcomes, privacy concerns Minimum necessary data, consent, common

definitions, secure aggregation

Emergency continuity

People without vehicles, electricity-dependent riders,

isolated communities

Unreachable riders, road closures, fuel/comms outages

Accessible evacuation, manifests, fuel/power redundancy, mutual aid

5.3 Need statements used for project eligibility

1.

CTSI needs dependable base operations and lifecycle replacement so essential

service is not lost through vehicle failure or unstable funding.

2.

Riders need one understandable way to learn about, request, and connect among

Tribal, public, Medicaid, veterans, private, and nonprofit transportation.

3.

Older adults and people with disabilities need accessible service comparable in

response time, fares, trip purpose, hours, geography, and capacity to service offered to

other riders.

4.

Low-income Tribal members need affordable access to work, education, health

care, food, and Tribal services without requiring ownership of a private vehicle.

5.

Tribal and regional providers need formal coordination practices that reduce

duplicate trips while protecting eligibility, privacy, safety, and rider choice.

6.

The transportation system needs trained staff, reliable data, resilient

communications, and emergency operating capability.

6. Coordination Framework

6.1 Coordination principles

•

Rider first: coordination must make the trip easier, safer, and more dignified.

•

No wrong door: staff provide a warm referral and, with consent, transfer the

minimum necessary information.

•

Use existing capacity before duplicating service, unless existing service is

unavailable, inappropriate, unsafe, inaccessible, or not cost-effective.

•

Preserve program eligibility and confidentiality; never share protected

information merely for administrative convenience.

•

Coordinate at the level that creates value: information, scheduling, dispatch,

procurement, maintenance, training, facilities, data, funding, or emergency response.

•

Do not use coordination to restrict lawful competition or predetermine a

procurement award.

6.2 Operating structure

Level Participants Cadence

Outputs

Policy Tribal Council; Planning; program directors; advisory commi ee

grant-cycle

Annual and

Policy, priorities, adoption, funding direction

Mobility coordination

Transit Coordinator; dispatch; program transportation

contacts; regional partners Quarterly; monthly during pilots Referral map,

schedule/transfer fixes, trip-sharing opportunities

Case/trip coordination

Authorized dispatch and program staff As needed

Consent-based trip arrangement and escalation

Emergency transportation Transit, Emergency Management, Public Works, health,

public safety, partner agencies

Exercises and activations Accessible evacuation,

continuity, fuel/comms, mutual aid

Data/performance Planning/GIS, finance, transit, programs Quarterly

Dashboard,

gaps, corrective action, grant reports

6.3 Coordination tools

•

Memoranda of understanding defining roles, referral procedures, data limits,

liability, reimbursement, emergency use, performance, and termination.

•

Coordinated schedules and timed-transfer protocols; shared disruption alerts;

common public information.

•

Brokerage and purchased-transportation agreements procured under applicable

standards.

•

Shared driver training, vehicle inspection, maintenance resources, accessible

securement training, and emergency exercises.

•

Technology interoperability using common trip fields and accessible rider

interfaces without requiring a smartphone.

•

Joint grant development, le ers of support, STIP/TIP coordination, and capital

planning.

6.4 Non-duplication test

Before creating or funding a new service, CTSI will document: the need and affected

population; existing provider(s); whether existing service is available, accessible,

affordable, timely, culturally appropriate, and permi ed for the trip; whether unused

capacity can be purchased or coordinated; the cost and rider impact of alternatives; and

the reason the selected approach is the most effective feasible response.

7. Goals, Policies, and Standards

Goal 1 - Essential mobility

Maintain dependable access to health care, food, Tribal programs, employment,

education, and community life.

•

Protect core operations and preventive maintenance.

•

Prioritize trips whose failure creates health, safety, housing, employment, or

food-security consequences.

•

Use transparent service priorities when demand exceeds capacity.

Goal 2 - Accessibility and dignity

Provide safe and equitable mobility for older adults and people with disabilities.

•

Operate and procure accessible vehicles appropriate to demonstrated need.

•

Provide reasonable modifications and equivalent service as required.

•

Train personnel in disability etique e, securement, service animals,

communication, and assistance.

Goal 3 - Affordability and equity

Reduce cost and administrative barriers for low-income and transportationdisadvantaged riders.

•

Maintain or expand no-cost/low-cost options when sustainable.

•

Define high-percentage low-income communities using current data.

•

Evaluate benefits and burdens before changing fares, routes, or eligibility.

Goal 4 - Coordination

Reduce fragmentation and use public resources efficiently.

•

Maintain a complete provider inventory and referral network.

•

Coordinate with human-service, county, regional, state, Tribal, private, and

nonprofit partners.

•

Document the non-duplication test for new services.

Goal 5 - Regional connection

Make cross-boundary travel understandable and dependable.

•

Improve connections to regional medical, employment, education, and intercity

networks.

•

Develop timed-transfer and disruption protocols.

•

Include selected projects in the STIP/TIP as required.

Goal 6 - Safety and resilience

Protect riders, workers, assets, and continuity of operations.

•

Maintain safety, maintenance, incident, and emergency procedures.

•

Plan accessible evacuation and continuity for people without vehicles.

•

Invest in resilient communications, facilities, fuel, and energy.

Goal 7 - Accountability

Manage grants, contracts, assets, and data lawfully and transparently.

•

Use wri en controls and risk-based subrecipient monitoring.

•

Report outputs and outcomes on time.

•

Correct deficiencies promptly and document closeout.

8. Prioritized Strategies and Projects

8.1 Prioritization method

Projects are scored on a 100-point scale. The advisory commi ee may recommend a

lower-scoring project only with wri en findings explaining the compelling need,

funding restriction, emergency, readiness, or portfolio balance. Conflicts of interest

must be disclosed and managed under Tribal and grant requirements.

Criterion

Points Scoring question

Need/gap severity 20

How serious and well documented is the unmet need?

Benefit to older adults and people with disabilities

20

Does it materially improve

15

Does it reduce cost or

mobility, including for wheelchair users?

Benefit to low-income and other underserved riders

access barriers in identified communities?

Coordination/non-duplication

15

Does it use capacity efficiently and reduce

fragmentation?

Feasibility/readiness

10

Can it be delivered with available authority, partners,

10

Are capital, operating, match, and lifecycle costs

Safety/resilience/quality

5

Does it improve safety, reliability, or continuity?

Measurable outcomes

5

Are outputs, outcomes, baseline, and data owner

staff, and timeline?

Financial sustainability

supportable?

clear?

8.2 Prioritized program of strategies

ID / priority Project or strategy Scope Potential sources

Core measures

P1 / 1 Core service preservation and accessible fleet lifecycle Operations; preventive

maintenance; replacement/rehabilitation of buses and vans; spare ratio; accessible

equipment. 5310 traditional where eligible; Tribal Transit/5311; STIF; Tribal; other

Trips completed; denials; on-time performance; road calls; accessible capacity

P2 / 2 Coordinated mobility management and one-call access

Mobility manager;

provider directory; eligibility navigation; warm referrals; travel training; outreach.

5310; STIF; 5311; human-service partners

Referrals resolved; riders trained;

previously unmet trips completed

P3 / 3 Medical and behavioral-health access initiative Improve NEMT coordination,

return trips, escorts/a endants, long-distance grouping, and backup capacity.

5310

where eligible; Medicaid/OHA; IHS/Tribal health; VA; STIF Missed appointments;

return wait; denials; cost per completed trip

P4 / 4 Accessible demand-response and regional connection expansion

Pilot

additional span/geography, accessible same-day service, and connections to regional

networks.

5310 other/traditional as eligible; STIF; 5311; local

geographic coverage; accessible trips; transfer success

Service hours;

P5 / 5 Rider information, reservations, dispatch, and data modernization Accessible

website/print/phone information; scheduling/dispatch; GTFS/alerts as applicable;

performance dashboard.

5310 mobility/capital; STIF; Tribal Transit

Call

abandonment; booking time; data completeness; rider satisfaction

P6 / 6 Volunteer and backup driver program

Program design, screening, training,

insurance, mileage reimbursement, dispatch, and quality controls. 5310; STIF; Older

Americans Act/partner; Tribal

Active drivers; trips; rural coverage; safety events

P7 / 7 Regional coordination agreements and shared capacity

MOUs, purchased

service, timed transfers, joint training/procurement, and emergency mutual aid. 5310;

STIF; partner contributions Agreements; shared trips; avoided duplication; transfer

reliability

P8 / 8 Accessible stops, transfer points, and passenger amenities

ADA-accessible

boarding areas, lighting, shelter, seating, wayfinding, and first/last-mile improvements.

5310 other; STIF; BIA TTIP; local/capital grants Stops improved; barrier

removals; safety/access findings

P9 / 9 Student and youth mobility program

Public, practicable access for grades 9-12

and Tribal youth to school-related, workforce, and community destinations.

Tribal; education/workforce

STIF;

Student rides; destinations; allocation share;

practicability findings

P10 / 10

Low/no-emission and resilient transportation facilities Lifecycle-based

clean vehicles, charging/fueling, backup power, communications, and protected

fleet/operations space.

STIF; 5339; Tribal Transit; energy/emergency grants

Availability; energy/fuel savings; outage operating hours

8.3 Section 5310 consistency

The projects above are intentionally stated at a level that allows FTA/ODOT project

selection while preserving a clear connection to identified gaps. Traditional Section 5310

projects must be planned, designed, and carried out to meet the special needs of older

adults and people with disabilities when public transportation is insufficient,

inappropriate, or unavailable. Other eligible projects must exceed ADA requirements,

improve access to fixed route and reduce reliance on complementary paratransit, or

provide transportation alternatives for older adults and people with disabilities. The

selecting recipient will determine final eligibility, match, and category. At least 55

percent of each recipient’s apportionment must be used for traditional projects; that

portfolio rule does not mean every local project is traditional. [F1]

8.4 Equivalent service

CTSI’s objective is a 100 percent accessible demand-response fleet for service that may

be used by the public or by eligible riders with disabilities. If any demand-response fleet

is less than fully accessible, CTSI will document and maintain equivalent service for

people with disabilities with respect to response time, fares, geographic area, service

hours/days, trip purpose restrictions, availability of information/reservations, and

capacity constraints. The responsible manager will test equivalency at least annually

and before a material service change.

8.5 Project sheets

Appendix F contains implementation-ready project sheets. A grant application may

refine scope, quantity, schedule, or cost without a plan amendment if the project

remains within the adopted need, strategy, population, and priority. A new strategy or

material change in beneficiaries requires the amendment process in Section 14.

9. Funding and Financial Strategy

SourcePrincipal use Key condition

FTA Section 5310

Capital, mobility management, purchased transportation, and

eligible operating projects benefiting older adults and people with disabilities.

Project in adopted coordinated plan; recipient selection; program eligibility;

match and federal requirements.

STIF Formula

Public transportation improvements and eligible

maintenance/operations consistent with an adopted Local Plan.

Current STIF Plan,

advisory review, project detail, reporting, accountability, and OAR compliance.

STIF Discretionary / Intercommunity

intercommunity connections.

Competitive improvements and

ODOT application, eligibility, match, review,

measurable outcomes, and agreement terms.

FTA Tribal Transit / Section 5311 Rural public transportation and Tribal Transit

projects.

Current FTA/ODOT requirements; maximum feasible coordination with

federally assisted transportation.

FTA Bus and Bus Facilities / other grants Vehicles, facilities, technology, and associated

capital.

Program-specific NOFO and federal requirements.

Medicaid/Oregon Health Plan

Eligible non-emergency medical transportation.

Medicaid eligibility, medical-purpose rules, brokerage/provider requirements,

and no duplicate billing.

IHS, VA, Older Americans Act, vocational rehabilitation, workforce, and human-service

funds Eligible client transportation or coordinated access.

Program eligibility, cost

allocation, payer-of-last-resort and supplanting rules as applicable.

Tribal funds and partner contributions Match, gap service, operations, planning, and

local priorities.

Tribal authorization and sustainable lifecycle commitment.

9.1 Cost principles and match

All costs charged to a federal award must be necessary, reasonable, allocable,

consistently treated, adequately documented, and allowable under the award, 2 CFR

Part 200, DOT regulations, and applicable program guidance. CTSI will verify the

current federal share and eligible match for each project. Federal funds generally may

not be used as match for another federal award unless expressly authorized. In-kind

contributions will be valued and documented under applicable rules and used only

with recipient approval when required.

9.2 Fiscal sustainability test

•

Identify full acquisition, implementation, staffing, maintenance, insurance,

software, facility, energy/fuel, and replacement costs.

•

Identify commi ed, reasonably anticipated, and contingent sources separately.

•

Do not expand recurring service without a credible plan for at least the grant

period and an exit or continuation strategy.

•

Maintain reserves or programmed replacement resources appropriate to the fleet

and equipment lifecycle.

•

Prevent duplicate payment by assigning each trip or cost to one allowable

funding source and documenting any approved cost allocation.

9.3 Planning-level investment bands

The following bands guide sequencing; they are not grant budgets. Actual costs must be

supported by current quotes, wage assumptions, indirect-cost treatment, useful-life

analysis, and the project-specific budget in Appendix I or the relevant grant application.

Band Planning range

Typical use

Small Up to $100,000

Planning, outreach, travel training, small technology or stop

improvements

Medium

$100,001-$500,000

Mobility management, service pilots, accessible vans,

dispatch systems

Large $500,001-$2,000,000 Multi-vehicle replacement/expansion, substantial operations,

facility phases

Major Over $2,000,000

Facility, fleet, resilient energy, or multi-year regional

program

10. Implementation and Performance Management

10.1 Four-year work program

Period Major actions

FY 2027-28

Adopt plan; complete provider MOUs; establish mobility-management

function; baseline measures; prioritize accessible fleet and core service; launch

information improvements; complete student-service practicability decision.

FY 2028-29

Implement medical-access and regional-connection pilots; launch

volunteer/backup driver program; procure priority vehicles/technology; improve initial

stops/transfer points.

FY 2029-30

Evaluate pilots; adjust span/geography; expand successful coordination;

advance resilient facility/energy phase; refresh demographic and gap analysis.

FY 2030-31

Complete plan evaluation; conduct new participation process; adopt

successor plan; program replacement and continuation funding.

10.2 Performance framework

Outcome

Measure

Reporting frequency

Responsible function

Mobility provided One-way passenger trips by program and target population where

reportable

Quarterly/annual

Gaps filled

People and trips receiving an option that otherwise would not be available

Annual

Access expanded

Mobility manager

Service hours, geographic coverage, accessible capacity, and new

connections Quarterly/annual

Reliability

Transit / programs

Transit / Planning

On-time pickup; missed trips; road calls; completed preventive

maintenance Monthly/quarterly Operations / fleet

Equity and affordability

Fare burden, no-cost rides, service in identified low-income

communities Annual

Planning / GIS / finance

Medical access

Completed medical trips, missed appointments a ributable to

transportation, return wait Quarterly

Health / transit, aggregated

Coordination Warm referrals, shared trips, agreements, avoided duplicate service

Quarterly

Mobility manager

Customer experience

Complaints, commendations, satisfaction, reasonable-

modification timeliness

Quarterly/annual

Transit / civil rights

Safety Preventable events, injuries, securement/lift events, training completion

Monthly/quarterly Safety / operations

Financial performance

Quarterly

Budget-to-actual, cost per trip/hour, match, questioned costs

Finance / grants

10.3 Corrective action

When performance materially deviates from the approved plan, grant agreement,

budget, schedule, or civil-rights/safety requirement, the responsible manager will

document the condition, immediate risk control, root cause, corrective action, owner,

deadline, validation method, and whether ODOT/FTA notification or plan amendment

is required. If three or more STIF quarterly reports within two years show substantial

noncompliance, the next STIF Plan will include the remediation strategies required by

OAR 732-042-0015(2)(h).

11. Civil Rights, Accessibility, and Equity

11.1 Nondiscrimination

CTSI will provide federally assisted transportation without discrimination prohibited

by Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, the Americans

with Disabilities Act, and other applicable federal civil-rights requirements. The Tribe

will maintain current notices, complaint procedures, language-access practices, service

standards/policies when required, records, and subrecipient/contractor clauses

appropriate to its recipient status and awards.

11.2 ADA and Section 504 operating commitments

•

Do not deny service because a vehicle or stop is inaccessible; deploy accessible

capacity or equivalent service as required.

•

Maintain lifts/ramps and accessibility features in operative condition; repair

promptly; accommodate riders when equipment is unavailable.

•

Transport wheelchairs and other mobility devices within regulatory vehicle and

safety limits; use securement and occupant restraints consistently with law and policy.

•

Permit service animals; allow personal care a endants and companions under

applicable fare and capacity rules.

•

Provide reasonable modifications to policies, practices, and procedures unless a

valid regulatory basis supports denial; document and communicate decisions.

•

Make information and communications accessible and provide effective

communication.

•

Train operators and personnel to proficiency and respectful assistance.

11.3 Title VI and language access

CTSI will evaluate meaningful access using the number/proportion of persons with

limited English proficiency, frequency of contact, nature/importance of the service, and

available resources/costs. Vital information will be translated or interpreted when

required. Service changes, facility siting, fares, and projects will be evaluated for

discriminatory effects using the current FTA civil-rights framework applicable to the

Tribe and recipient relationship.

11.4 Complaints and requests

Process

Standard

Civil-rights complaint

Accessible wri en and oral intake; prompt

acknowledgement; impartial review; records; notice of outcome and appeal/referral

rights.

ADA reasonable modification

Request may be made in advance or when a barrier is

encountered; timely decision; individual assessment; reasons stated for denial.

Service complaint

Track category, location, provider, response, corrective action, and

trend without retaliation.

Language/format request Provide qualified assistance and accessible formats

appropriate to need; do not require a rider to bring an interpreter.

11.5 Tribal data governance

Transportation data involving Tribal members will be managed under Tribal law and

policy, applicable health/privacy requirements, grant reporting rules, and data-sharing

agreements. Public reporting will use aggregation and suppression appropriate to small

populations. Partners receive only the minimum information necessary for an

authorized purpose.

12. Safety, Emergency Management, and Continuity

12.1 Safety management

•

Maintain operator qualification, licensing, screening, training, hours, incident

reporting, vehicle inspection, preventive maintenance, securement, and emergency

procedures appropriate to each service.

•

Apply 49 CFR Parts 40 and 655 drug-and-alcohol requirements when the service,

employee, vehicle, and funding trigger those rules; maintain separate compliant

program documentation.

•

Coordinate any required Public Transportation Agency Safety Plan or equivalent

internal safety program with the Tribal safety and emergency-management structure.

•

Require contractors to meet applicable passenger-transportation, insurance,

safety, maintenance, accessibility, and reporting requirements.

12.2 Emergency transportation mission

CTSI transportation may support evacuation, shelter movement, supply delivery

incidental to passenger operations, continuity of health and human services, and

recovery. Emergency assignments will occur through the Tribe’s incident-management

structure and will account for older adults, people with disabilities, mobility devices,

service animals, medications, communication needs, and people without private

vehicles.

12.3 Continuity priorities

Capability

Minimum preparation

Accessible evacuation

Accessible vehicles, trained drivers, pickup assistance,

destination accessibility, manifests that protect privacy.

Fleet/fuel/energy

Fuel and charging strategy, preventive maintenance, protected

parking, backup power where feasible.

Communications

Redundant dispatch communications, accessible public alerts,

partner contacts, paper backup procedures.

Staffing

Recall roster, cross-trained backup/volunteer drivers, fatigue controls,

family-support considerations.

Routes and transfers

Alternate routes, landslide/flood/wildfire closures,

rendezvous points, mutual-aid procedures.

Continuity of essential trips

Prioritized dialysis, medical, food, shelter, and

medication access during disruptions.

13. Grant Administration and Subrecipient Oversight

13.1 Internal controls

CTSI will maintain wri en controls that provide reasonable assurance of compliance,

safeguard assets, support accurate reporting, and prevent fraud, waste, abuse, conflicts,

and duplicate billing. Duties will be separated to the extent practicable among

authorization, procurement, receipt, payment, asset custody, and reconciliation.

13.2 Procurement

•

Use the procurement standards applicable to the award, including documented

procedures, competition, cost/price analysis, conflict controls, required clauses, and

records.

•

Do not use the coordinated planning process to select a contractor. Participation

in planning does not bar a provider from later competing.

•

Verify suspension/debarment status and required responsibility criteria; apply

DBE requirements and transit-vehicle-manufacturer certification when triggered.

•

For federally assisted vehicle/equipment procurement, use current FTA and

ODOT specifications, pre-award/post-delivery requirements, Buy America

requirements, and accessibility standards as applicable.

13.3 Financial management and records

•

Maintain award-specific accounts and reconcile expenditures to source

documentation and approved budgets.

•

Charge only allowable costs and allocate shared costs using a consistent,

documented method.

•

Track match by source and prevent federal-to-federal match unless expressly

authorized.

•

Retain financial, procurement, property, civil-rights, safety, and performance

records for the longest applicable federal, state, Tribal, agreement, litigation, claim, or

audit period.

•

Complete required audits and cooperate with ODOT/FTA compliance reviews.

13.4 Asset management

•

Maintain an inventory including description, identification, source, title,

acquisition date/cost, federal participation, location, use/condition, useful life, and

disposition data.

•

Use assets for the authorized public transportation purpose, maintain them in a

state of good repair, insure/protect them appropriately, and obtain approval before

transfer or disposition when required.

•

Conduct physical inventory at the required interval and reconcile results;

investigate loss, damage, and theft.

•

Maintain vehicle replacement and facility lifecycle plans tied to condition,

mileage, age, maintenance cost, reliability, accessibility, and service need.

13.5 Subrecipient and contractor oversight

Stage Control

Pre-award

Eligibility, legal/managerial/financial capacity, risk, debarment, civil

rights, insurance, safety, and project readiness.

Agreement

Scope, budget, match, milestones, data, records, clauses, asset use, access,

audit, remedies, termination, and repayment.

Monitoring Invoices, performance, site/desk review, vehicle/asset records, civil rights,

procurement, and corrective actions.

Deficiency response Wri en finding, risk control, corrective-action plan, deadline,

technical assistance, withholding/suspension when authorized.

Closeout

Final reconciliation, deliverables, property status, records, continuing

obligations, and release only when complete.

13.6 STIF accountability

For STIF, CTSI will comply with applicable OAR Chapter 732 Divisions 40, 42, and 44,

including accounting, reporting, commi ee, project, agreement, contractor,

audit/compliance-review, and capital-asset requirements. Subrecipient agreements will

flow down applicable requirements and allow CTSI to address deficiencies and recover

funds. Eligibility will be confirmed before and during the period of assistance.

14. Adoption, Amendment, and Plan Maintenance

14.1 Adoption

7.

Complete and document required public and stakeholder participation.

8.

Publish the comment-response matrix and revised final draft.

9.

Obtain a formal advisory commi ee recommendation and prioritized project list.

10.

Obtain Tribal Council approval by resolution.

11.

Insert signed records in the appendices and transmit the plan to ODOT as

required.

12.

Coordinate selected federally funded projects with the STIP/TIP process before

award.

14.2 Amendment classes

Class Examples

Approval

Administrative correction Contact, schedule reference, typographical correction,

updated provider inventory, current demographic value

Planning Director or

designee; log change

Minor amendment Scope refinement or cost/funding update within an adopted

strategy and target population

Advisory commi ee review; Tribal administrative

approval; ODOT concurrence if required

Major amendment New strategy, removal/reordering of priority, material service-area

or beneficiary change, or change affecting public input

Public notice and

participation proportionate to change; advisory recommendation; Tribal Council

adoption

STIF Plan amendment

Change to an approved STIF Plan/project

Follow OAR

and ODOT agreement/amendment process; do not rely solely on this local-plan

procedure

14.3 Annual review

Each year, CTSI will review provider inventory, demographics, ridership and unmet

trips, complaints, accessibility/equivalency, performance, project status, funding,

commi ee membership, civil-rights requirements, fleet condition, and coordination

agreements. A comprehensive update will begin early enough for adoption before June

30, 2030 or sooner if required by ODOT, FTA, a material service change, or funding

cycle.

-

add the following major sections and exhibits to CTSI_20262030_Human_Services_Coordinated_Transportation_Plan.docx

New Section 3.6 - Existing Transportation Network Mapping

Map 1 - CTSI Transportation Service Area

Show:

•

Sile

Tribal Headquarters

•

Tribal housing areas

•

Government campus

•

Sile

•

Elder Center

•

Transit Operations Facility

•

Portland Office

•

Salem Office

•

Eugene Office

•

Lincoln City

•

Newport

Clinic

•

Toledo

•

Depoe Bay

•

Corvallis

•

Salem

•

Eugene

•

Portland

GIS layers:

•

Tribal trust lands

•

Road network

•

Major destinations

•

Lincoln County Transit routes

•

CTSI service coverage area

Narrative:

CTSI transportation services operate across one of the largest geographic tribal service

areas in Oregon. While the governmental center is located in Sile , Tribal members

access services throughout Lincoln County, the Willame e Valley, and the Portland

metropolitan region. The transportation system therefore functions as both a local

mobility provider and a regional connector.

New Section 3.7 - Transportation Corridors

Map 2 - Regional Mobility Corridors

Highlight:

Corridor A

Sile

→ Toledo → Newport

Primary destinations:

•

Samaritan Pacific Communities Hospital

•

Government services

•

Shopping

•

Employment

Corridor B

Sile

→ Lincoln City

Primary destinations:

•

Employment centers

•

Chinook Winds area

•

Medical clinics

•

Retail services

Corridor C

Sile

→ Salem

Primary destinations:

•

Specialty medical services

•

State agencies

•

Higher education

Corridor D

Sile

→ Portland

Primary destinations:

•

Area office

•

Veterans services

•

Specialty care

•

Airport connections

New Section 5.4 - GIS Accessibility Analysis

Create maps showing:

Elder Population Density

Display:

•

Residents aged 65+

•

Tribal elder concentrations

•

Senior housing

Disability Density Mapping

Display:

•

Census disability indicators

•

Tribal program demand

•

Wheelchair-accessible trip origins

Low-Income Community Mapping

Show:

•

STIF-qualified low-income areas

•

Transit-dependent households

•

Areas with limited transportation access

This will greatly strengthen future STIF and 5310 applications.

New Section 5.5 - Fixed Route Transit Feasibility Analysis

This should become one of the most important additions to the plan.

Proposed CTSI Fixed Route Pilot

Route Name

Sile

Tribal Connector

Alignment

Sile

Government Campus ↓ Chinook Winds Area ↓ Lincoln City ↓ Otis ↓ Lincoln City

Outlets ↓ Samaritan North Lincoln Hospital ↓ Return to Sile

Alternative alignment:

Sile

↓ Toledo ↓ Newport

Preferred Initial Route

Sile

– Toledo – Newport Connector

Reasons:

•

Highest medical demand

•

Links government services

•

Connects to Lincoln County Transit

•

Connects to Samaritan Hospital

•

Connects to shopping destinations

•

Strongest ridership potential

Potential Stops:

1.

Sile

Tribal Administration

2.

Clinic

3.

Elder Center

4.

Sile

5.

Toledo Downtown

6.

Toledo Transit Center

7.

Walmart Newport

Valley Schools

8.

Samaritan Hospital

9.

Newport Transit Center

New Section 5.6 - Fixed Route Benefits Analysis

Benefits include:

Medical Access

Reduces missed appointments.

Employment Access

Provides reliable transportation to major employers.

Student Mobility

Serves Tribal youth a ending educational programs.

Elder Transportation

Creates predictable service compared to demand-response scheduling.

Tourism and Public Ridership

Allows participation by non-tribal riders.

New Priority Project P11 - CTSI Fixed Route Transit Implementation

New table entry:

Category

Description

Project ID

P11

Priority

3

Title

CTSI Fixed Route Transit Service

Type Service Expansion

Funding

STIF, Tribal Transit, Section 5311

Area Sile , Toledo, Newport, Lincoln City

Goal Establish scheduled fixed-route public transit service

Objectives:

•

Launch one fixed route by 2028

•

Operate 5 days per week minimum

•

Connect with Lincoln County Transit

•

Establish transfer agreements

•

Collect boarding and ridership data

•

Expand based on demand

New Section 12.4 - Emergency Transportation and EOC Integration

Since CTSI has a mature emergency operations capability, add:

Transportation Emergency Operations Center Integration

The CTSI transportation network will integrate directly into the Tribal Emergency

Operations Center through:

•

Roundtable Conference Room

•

Emergency Operations Center

•

Communications Room

•

Redundant radio systems

•

GIS Laboratory

•

Incident Command System coordination

•

Wildfire evacuation transport

•

Tsunami evacuation support

•

Medical surge transportation

•

Senior evacuation assistance

This ties transportation directly to tribal resilience planning and strengthens future

FEMA, USDOT, and Homeland Security grant applications.

Recommended Photo Program

Include full-page photos throughout the plan:

Existing Transportation

•

CTSI transit vehicles

•

Elder transportation services

•

Tribal transportation staff

•

Medical transportation activities

Community Destinations

•

Sile

Tribal Government Campus

•

Sile

Clinic

•

Sile

Valley

•

Lincoln City Transit Center

•

Newport Transit Center

•

Toledo Downtown

•

Samaritan Pacific Communities Hospital

•

Tribal Elder Center

Transportation Infrastructure

•

Bus stops

•

Passenger shelters

•

ADA facilities

•

Transfer locations

•

Tribal roads and highways

Emergency Transportation

•

EOC

•

Communications Room

•

GIS Lab

•

Emergency vehicle staging

•

Disaster transportation exercises

The biggest improvement I would make is elevating the fixed-route concept from a

small project within Section 8 to a central plan initiative. A scheduled Sile -ToledoNewport Connector Route has the strongest justification, ridership potential, and grant

competitiveness, and should be one of the top three priorities of the 2026-2030 plan

rather than being embedded within demand-response expansion. [CTSI_2027...ation_Plan | Word]

Appendix A. Federal Compliance Matrix

This matrix distinguishes plan-development requirements from award/operating

requirements. “Triggered” means applicability depends on the funding source,

recipient status, service type, vehicle, project, contract, or current award terms. The

current statute, regulation, Master Agreement, Certifications and Assurances, ODOT

agreement, and legal review control.

Citation

Applicability Requirement Plan location

49 U.S.C. 5310(e); FTA C 9070.1H Ch. V Required

Locally developed coordinated

plan; named stakeholder participation; service inventory; needs; strategies; priorities;

equivalent service if fleet is not fully accessible. Sections 2, 4, 5, 8; Apps. C-H

49 U.S.C. 5310(b)

Required for 5310 portfolioEligible project categories and recipient

selection; at least 55% of apportionment for traditional projects.

Sections 8-9

23 CFR Part 450; 49 U.S.C. 5303/5304

Required as applicable

statewide/metropolitan planning; selected projects in STIP/TIP.

2 CFR Part 200; 2 CFR Part 1201

Consistency with

Sections 1, 6, 14

Award-wide Internal controls, allowable costs,

procurement, property, subawards, records, audit, closeout. Sections 9, 10, 13

49 CFR Part 21; Title VI

Award-wide Race, color, national-origin nondiscrimination;

program-specific Title VI implementation.

Section 11

49 CFR Part 27; Section 504 Award-wide Nondiscrimination on disability and program

accessibility. Section 11

49 CFR Part 37

Service-triggered

ADA transportation service, complementary

paratransit where applicable, reasonable modification, equipment maintenance,

training.

Sections 8, 11

49 CFR Part 38

Vehicle/facility-triggered

transportation vehicles.

49 CFR Part 26

Accessibility specifications for

Sections 8, 11, 13

Award/procurement-triggered

DBE program/goal/contract

requirements and transit vehicle manufacturer rules as applicable. Section 13

49 CFR Parts 40 and 655

Safety-sensitive/FTA-funding-triggered Drug and alcohol

testing program for covered employees and operations.

49 CFR Part 604

Service-triggered

Section 12

Charter service restrictions and exceptions.

Operations compliance

49 CFR Part 605

Service-triggered

School bus operations restrictions; public

student service must not be impermissible exclusive school bus service.

Project P9 /

operations

49 CFR Part 625

Asset/recipient-triggered Transit asset management and state of

good repair; participation in appropriate TAM plan.

49 CFR Part 630

Reporting-triggered National Transit Database reporting as

applicable to recipient/service.

49 CFR Part 673

Sections 10, 13

Section 10

Recipient/service-triggeredPublic Transportation Agency Safety

Plan when applicable; maintain safety program regardless.

Section 12

49 CFR Part 20; 2 CFR Part 200

Award-triggered

disclosures, conflicts, and award integrity.

Lobbying restrictions,

Section 13

2 CFR Part 1200; SAM exclusions Award/procurement-triggered

Nonprocurement

suspension/debarment and verification of excluded parties. Section 13

49 U.S.C. 5323(j) and implementing requirements

Procurement-triggered

Buy

America/domestic preference for federally assisted procurements. Section 13

49 U.S.C. 5333(b)

Project/funding-triggered Transit employee protections where

applicable; Section 5310 treatment follows FTA/DOL rules.

Grant file

FTA Master Agreement and annual Certifications and Assurances

Award-wide

Current cross-cu ing federal conditions, certifications, and flow-down clauses.

Grant compliance file

Appendix B. Oregon OAR Compliance Matrix

Rule Requirement Plan response

OAR 732-040-0005(18)(a)

Local Plan horizon of at least four years. 2026-2030 horizon;

Sec. 1.3

OAR 732-040-0005(18)(b)(A)

Current/forecast demographics and transit-dependent

populations. Sec. 3; annual GIS/data protocol

OAR 732-040-0005(18)(b)(B)

Housing, employment, medical/social services,

destinations. Sec. 3.5; mapping protocol

OAR 732-040-0005(18)(b)(C)

Inventory of current and connectable services. Sec. 4;

App. D

OAR 732-040-0005(18)(c)

Prioritized improvements and capital projects. Sec. 8; App. F

OAR 732-040-0005(18)(d) Coordination inside/outside tribal area to improve efficiency

and reduce gaps.

Sec. 6

OAR 732-040-0005(20)

guideline.

Secs. 1.4, 3.4

Low-income household at or below 200% HHS poverty

OAR 732-040-0030 Advisory commi ee appointment, bylaws, records, coordination,

duties, notice.

Sec. 2; Apps. C, G, I

OAR 732-040-0035(1)

of people served.

Tribal commi ee at least three members representing needs

Sec. 2.2

OAR 732-040-0010 to -0025 STIF use, audit/compliance, accounting, and reporting.

Secs. 9, 10, 13; App. I

OAR 732-042-0015(1)

Wri en STIF Plan, biennium(s), area needs, low-income

method, suballocation method.

OAR 732-042-0015(2)

App. I completion tables

Projects, expenditures, prior/current projects, commi ee,

accountability, remediation, adoption.

OAR 732-042-0015(3)

App. I

Project funding, scope, maintain/expand, outcomes, local-

plan origin, recipient, budget, phasing, categories, OPTP consistency, student service.

App. F and App. I

OAR 732-042-0020 to -0055 Commi ee review, OTC approval, reporting, assets,

amendments, contractor compliance.

Secs. 2, 10, 13, 14; App. I

OAR 732-044-0015 Discretionary application scope, schedule, budget, outcomes,

phasing, match, property control, qualifications.

Apps. E-F; project grant file

OAR 732-044-0020 Recipient legal/managerial/operational capacity and ongoing

compliance. Sec. 13

OAR 732-044-0025 Qualified Entity/advisory review and wri en recommendation.

Secs. 2, 8; App. I

OAR 732-044-0035 to -0050 Agreements, reporting, repayment/withholding, capital

assets. Sec. 13

Appendix C. Public Participation and Adoption Record

Completion requirement

Replace the blank fields and a ach or incorporate the actual records before final

adoption. Do not sign the federal participation certification until all federally required

groups had a meaningful opportunity to participate and their input was explicitly

considered.

C.1 Outreach log

Date Method/location

Audience invited

a endance

Record link

________

________________

Accessible options Responses /

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

________

________________

________________

C.2 Required-group participation check

Required group

Outreach used

Older adults / Elders

Actual participation Follow-up if low

________________

________________

________________

Individuals with disabilities, including wheelchair users

________________

________________

________________

Public transportation providers

________________

________________

Private transportation providers ________________

________________

________________

________________

Nonprofit transportation providers

________________

________________

________________

Human-service providers ________________

Low-income individuals/advocates

________________

________________

________________

________________

________________

Other members of the public

________________

________________

________________

C.3 Comment-response matrix

ID

Comment / source Plan section Response and change

___

____________________________

________

Disposition

____________________________

Accepted / modified / not accepted

___

____________________________

________

____________________________

Accepted / modified / not accepted

___

____________________________

________

____________________________

Accepted / modified / not accepted

___

____________________________

________

____________________________

Accepted / modified / not accepted

___

____________________________

________

____________________________

Accepted / modified / not accepted

___

____________________________

________

Accepted / modified / not accepted

____________________________

___

____________________________

________

____________________________

Accepted / modified / not accepted

___

____________________________

________

____________________________

Accepted / modified / not accepted

___

____________________________

________

____________________________

Accepted / modified / not accepted

___

____________________________

________

____________________________

Accepted / modified / not accepted

C.4 Final participation finding

The Advisory Commi ee and Tribal Council find that the participation process

provided reasonable and accessible opportunities at key decision points; included the

groups named in 49 U.S.C. 5310(e); did not rely exclusively on electronic

communication; explicitly considered and responded to input; and informed the final

needs, strategies, priorities, and adoption decision.

Appendix D. Provider Inventory and Rider-Needs Instruments

D.1 Provider inventory form

Field Response

Provider/legal name

____________________________________________________________

Public, private, nonprofit, Tribal, or human-service

____________________________________________________________

Service/contact/web ____________________________________________________________

Service area and connection points

____________________________________________________________

Days/hours and holidays

____________________________________________________________

Public or client-only; eligibility

____________________________________________________________

Trip purposes/restrictions

____________________________________________________________

Reservation and cancellation rules

____________________________________________________________

Fare/rate and payment source

____________________________________________________________

Accessible vehicles/capacity

____________________________________________________________

Assistance, PCA, companion, service animal

____________________________________________________________

Language/accessible information

____________________________________________________________

Annual trips/capacity/denials

____________________________________________________________

Funding sources

____________________________________________________________

Coordination opportunities

____________________________________________________________

Emergency role

____________________________________________________________

Complaint/appeal process

____________________________________________________________

D.2 Rider/caregiver survey

13.

Where do you need to travel, from what general area, how often, and at what

times/days?

14.

Which trips are hardest or impossible: medical, behavioral health, work,

education, food, Tribal services, legal, cultural, social, or other?

15.

What transportation do you use now, and where does it fail?

16.

Have you missed or declined an essential trip in the past 12 months because of

transportation? Why?

17.

Do you need a wheelchair-accessible vehicle, assistance to/from the door, a

personal care a endant, accessible communication, language assistance, or another

accommodation?

18.

Are cost, advance-booking rules, return-trip uncertainty, transfers, trip length,

safety, weather, or lack of information barriers?

19.

Would travel training, a volunteer driver, mileage reimbursement, a regional

transfer, same-day service, evening/weekend service, or a one-call coordinator help?

20.

How should CTSI contact you about services and changes? Participation may be

anonymous; do not provide medical details.

Appendix E. Project Nomination and Evaluation Form

Field Required entry

Project title and sponsor

____________________________________________________________

Need/gap and affected population

____________________________________________________________

Older adult/disability benefit

____________________________________________________________

Low-income/equity benefit

____________________________________________________________

Existing providers and non-duplication analysis

____________________________________________________________

Scope and deliverables

____________________________________________________________

Service area and schedule

____________________________________________________________

Accessibility/equivalent service

____________________________________________________________

Partners and roles ____________________________________________________________

Potential funding and match

____________________________________________________________

Planning-level capital/operating/lifecycle cost

____________________________________________________________

Readiness and risks ____________________________________________________________

Outputs and outcomes

____________________________________________________________

Data owner/reporting

____________________________________________________________

Local Plan section/project ID

____________________________________________________________

E.1 Score sheet

Criterion

Maximum

Need/gap severity 20

Score Finding

___

Older adult/disability benefit

________________________

20

___

________________________

Low-income/underserved benefit 15

___

________________________

Coordination/non-duplication

15

___

________________________

Feasibility/readiness

10

___

________________________

Financial sustainability

10

___

________________________

Safety/resilience/quality

5

___

________________________

Measurable outcomes

5

___

________________________

TOTAL

________________________

100

___

Appendix F. Detailed Project Sheets

P1. Core service preservation and accessible fleet lifecycle

Element

Plan direction

Priority

1

Need addressed

Base-service instability, vehicle downtime, inaccessible or aging

assets.

Eligible planning scope

Operations; preventive maintenance;

replacement/rehabilitation of buses and vans; spare ratio; accessible equipment.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

5310 traditional where eligible; Tribal Transit/5311; STIF; Tribal;

other

Core measures

Trips completed; denials; on-time performance; road calls;

accessible capacity

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P2. Coordinated mobility management and one-call access

Element

Plan direction

Priority

2

Need addressed

Fragmented information, eligibility, reservations, and referrals.

Eligible planning scope

Mobility manager; provider directory; eligibility navigation;

warm referrals; travel training; outreach.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

5310; STIF; 5311; human-service partners

Core measures

Referrals resolved; riders trained; previously unmet trips

completed

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P3. Medical and behavioral-health access initiative

Element

Plan direction

Priority

3

Need addressed

Missed, delayed, or difficult medical and behavioral-health trips.

Eligible planning scope

Improve NEMT coordination, return trips,

escorts/a endants, long-distance grouping, and backup capacity.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

5310 where eligible; Medicaid/OHA; IHS/Tribal health; VA; STIF

Core measures

Missed appointments; return wait; denials; cost per completed trip

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P4. Accessible demand-response and regional connection expansion

Element

Plan direction

Priority

4

Need addressed

connection gaps.

Geographic, temporal, wheelchair-capacity, and regional-

Eligible planning scope

Pilot additional span/geography, accessible same-day

service, and connections to regional networks.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

5310 other/traditional as eligible; STIF; 5311; local

Core measures

Service hours; geographic coverage; accessible trips; transfer

success

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P5. Rider information, reservations, dispatch, and data modernization

Element

Plan direction

Priority

5

Need addressed

Unclear information, manual workflows, weak alerts, and

incomplete performance data.

Eligible planning scope

Accessible website/print/phone information;

scheduling/dispatch; GTFS/alerts as applicable; performance dashboard.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

5310 mobility/capital; STIF; Tribal Transit

Core measures

Call abandonment; booking time; data completeness; rider

satisfaction

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P6. Volunteer and backup driver program

Element

Plan direction

Priority

6

Need addressed

Driver shortages and low-density rural trips that fixed service

cannot efficiently meet.

Eligible planning scope

Program design, screening, training, insurance, mileage

reimbursement, dispatch, and quality controls.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

5310; STIF; Older Americans Act/partner; Tribal

Core measures

Active drivers; trips; rural coverage; safety events

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P7. Regional coordination agreements and shared capacity

Element

Plan direction

Priority

7

Need addressed

Duplicated or disconnected services and weak transfer/emergency

agreements.

Eligible planning scope

MOUs, purchased service, timed transfers, joint

training/procurement, and emergency mutual aid.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

5310; STIF; partner contributions

Core measures

Agreements; shared trips; avoided duplication; transfer reliability

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P8. Accessible stops, transfer points, and passenger amenities

Element

Plan direction

Priority

8

Need addressed

Unsafe or inaccessible boarding, transfer, and first/last-mile

conditions.

Eligible planning scope

ADA-accessible boarding areas, lighting, shelter, seating,

wayfinding, and first/last-mile improvements.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

5310 other; STIF; BIA TTIP; local/capital grants

Core measures

Stops improved; barrier removals; safety/access findings

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P9. Student and youth mobility program

Element

Plan direction

Priority

9

Need addressed

Youth access needs and STIF grades 9-12 priority.

Eligible planning scope

Public, practicable access for grades 9-12 and Tribal youth to

school-related, workforce, and community destinations.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

STIF; Tribal; education/workforce

Core measures

Student rides; destinations; allocation share; practicability findings

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

P10. Low/no-emission and resilient transportation facilities

Element

Plan direction

Priority

10

Need addressed

Operating risk from fuel/energy disruption, exposed fleet, and

aging technology.

Eligible planning scope

Lifecycle-based clean vehicles, charging/fueling, backup

power, communications, and protected fleet/operations space.

Primary beneficiaries

Older adults, individuals with disabilities, low-income

riders, Tribal members, and the public as defined by the funded service.

Potential sources

STIF; 5339; Tribal Transit; energy/emergency grants

Core measures

Availability; energy/fuel savings; outage operating hours

Implementation conditionsConfirm eligibility, public/commi ee input, non-duplication,

accessibility, cost, procurement, match, useful life, operating sustainability, and

required STIP/TIP or STIF programming.

Appendix G. Tribal Council Resolution Template

RESOLUTION NO. __________

A RESOLUTION ADOPTING THE CONFEDERATED TRIBES OF SILETZ INDIANS

2026-2030 HUMAN SERVICES COORDINATED TRANSPORTATION PLAN

WHEREAS, the Confederated Tribes of Sile

Indians is a federally recognized Indian

Tribe exercising inherent sovereign authority; and

WHEREAS, 49 U.S.C. 5310 requires projects selected for Enhanced Mobility funding to

be included in a locally developed coordinated public transit-human services

transportation plan developed and approved with participation by older adults,

individuals with disabilities, representatives of public, private, and nonprofit

transportation and human-service providers, and other members of the public; and

WHEREAS, Oregon Administrative Rules define Local Plan content and establish STIF

advisory, planning, project, accountability, and reporting requirements applicable to

participating Qualified Entities; and

WHEREAS, CTSI provided notice and meaningful, accessible opportunities for

participation, explicitly considered comments, and received a recommendation from its

advisory commi ee on __________;

NOW, THEREFORE, BE IT RESOLVED that the Tribal Council adopts the 2026-2030

Human Services Coordinated Transportation Plan; authorizes the Chair or designee to

submit the plan and certifications to ODOT/FTA recipients as appropriate; authorizes

administrative and minor amendments consistent with Section 14; and requires major

amendments to return for Tribal Council action.

Vote / certification Entry

Adoption date

____________

Yes / No / Abstain

____________ / ____________ / ____________

Chair signature

________________________________________

Secretary certification

________________________________________

Non-waiver: Nothing in this resolution or plan waives sovereign immunity or consents

to jurisdiction except through a separate, explicit, duly authorized action.

Appendix H. Section 5310 Project Certification Template

CTSI certifies that the project identified below is included in the adopted 2026-2030

Human Services Coordinated Transportation Plan and was developed and approved

through the participation process documented in Appendix C.

Item Entry

Project title / ID

____________________________________________________________

Applicant / subrecipient

____________________________________________________________

Coordinated-plan strategy and page/section

____________________________________________________________

Need/gap addressed

____________________________________________________________

Older adult/disability benefit

____________________________________________________________

Traditional or other 5310 category (recipient determination)

____________________________________________________________

Adoption date and resolution

____________________________________________________________

Selection process / date

____________________________________________________________

STIP/TIP reference if applicable

____________________________________________________________

Certifying official / signature / date

____________________________________________________________

Appendix I. STIF Plan Completion Supplement

Use of this appendix

Complete this appendix for the applicable STIF biennium(s) using ODOT’s current

forms and instructions. The adopted coordinated plan supplies the Local Plan

foundation, but the STIF Plan is not complete without actual allocation amounts, project

budgets, prior expenditures, advisory recommendation, accountability information, and

governing-body documentation.

I.1 Plan period and area

Required item

Entry

STIF biennium(s)

________________

Area of responsibility

________________

Needs of people residing in or traveling into/out of area

See Sections 3-5; add cycle-

specific findings: __________________

High-percentage low-income method

Section 3.4; latest datasets/date:

__________________

Suballocation method and development process

________________

I.2 Planned expenditures

Project ID

Recipient/subrecipient

FY

STIF requested

Other funds Total

___

________________

20__

________

________

________

___

________________

20__

________

________

________

___

________________

20__

________

________

________

___

________________

20__

________

________

________

___

________________

20__

________

________

________

___

________________

20__

________

________

________

___

________________

20__

________

________

________

___

________________

20__

________

________

________

I.3 Prior two-fiscal-year expenditures

Improvement category

Prior FY 1

Prior FY 2

Narrative

Increased frequency in high-percentage low-income communities

$_______

________________

$_______

Expanded routes/services to high-percentage low-income communities

$_______

$_______

________________

Fare reduction in high-percentage low-income communities $_______

$_______

________________

Low/no-emission buses in areas of 200,000+

$_______

$_______

________________

Improved intercommunity frequency/reliability

$_______

$_______

________________

Provider coordination/reduced fragmentation $_______

$_______

________________

Grades 9-12 student transit $_______

$_______

________________

I.4 Project-detail checklist

OAR 732-042-0015(3) field Required entry

Funding level and use of STIF money

____________________________

Improve/expand or maintain; maintenance amount/percent and rationale

____________________________

Benefits and discrete measurable outcomes

____________________________

Amounts allocated to each statutory improvement category

____________________________

Local Plan and approving body

Recipient/subrecipient

____________________________

____________________________

Full budget, sources, and funding decision timing

Multi-phase schedule, budget, and sources

____________________________

____________________________

Consistency with Oregon Public Transportation Plan ____________________________

Student-service project and >=1% allocation, or wri en practicability finding

____________________________

I.5 Advisory commi ee and adoption

Required item

Entry

Member list and represented interests

________________

Public location of bylaws/notices/minutes

Meeting and consultation dates

________________

________________

Recommendation and prioritized projects

________________

Difference between recommendation and governing-body action, with explanation

________________

Governing-body approval document

Resolution __________ dated __________

Joint-management documentation, if applicable

N/A or __________________

I.6 Accountability and remediation

CTSI will use the controls in Sections 10 and 13 for recipient and subrecipient

accountability, including wri en agreements, monitoring, corrective action,

audits/compliance reviews, accounting, reporting, and capital assets. Cycle-specific

additional controls: ________________________________.

Three-or-more noncompliant quarterly reports in prior two years? Yes ___ No ___. If

yes, a ach remediation strategy, responsible official, milestones, and validation method.

Appendix J. Authorities and Sources

ID

SourceURL

F1

Federal Transit Administration, Circular 9070.1H, Enhanced Mobility of Seniors

and Individuals with Disabilities Program Guidance and Application Instructions,

effective Nov. 1, 2024.

h ps://www.transit.dot.gov/sites/fta.dot.gov/files/2024-

10/C9070.1H-Circular-11-01-2024.pdf

F2

49 U.S.C. 5310, Enhanced mobility of seniors and individuals with disabilities.

h ps://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title49-

section5310

O1

Oregon Secretary of State, OAR Chapter 732, Public Transportation Division,

current rules.

h ps://secure.sos.state.or.us/oard/displayChapterRules.action?selectedChapter=1

07

O2

OAR 732-040-0030, Advisory Commi ees.

h ps://secure.sos.state.or.us/oard/view.action?ruleNumber=732-040-0030

O3

OAR 732-040-0035, Advisory Commi ee Composition.

h ps://secure.sos.state.or.us/oard/view.action?ruleNumber=732-040-0035

O4

OAR 732-042-0015, STIF Plan Contents.

h ps://secure.sos.state.or.us/oard/view.action?ruleNumber=732-042-0015

O5

ODOT, 2025-2027 Federal Formula Grant Solicitation, Section 5310 Program

Guidance.

h ps://www.oregon.gov/odot/RPTD/RPTD%20Document%20Library/2025-275310-Program-Guidance.pdf

T1

CTSI, Transit Program Services, accessed Sept. 12, 2026.

h ps://ctsi.nsn.us/transit-program-services/

T2

CTSI/OCWCOG, Sile

Tribe Coordinated Plan summary of 2021 priorities.

h ps://ctsi.nsn.us/wp-content/uploads/2025/01/CTSI-Coordinated-Plan.pdf

D1

U.S. Census Bureau, QuickFacts: Lincoln County, Oregon, accessed Sept. 12,

2026. h ps://www.census.gov/quickfacts/fact/table/lincolncountyoregon/PST045225

R1

Electronic Code of Federal Regulations, Title 49, Transportation.

h ps://www.ecfr.gov/current/title-49

R2

Electronic Code of Federal Regulations, Title 2, Grants and Agreements.

h ps://www.ecfr.gov/current/title-2

Source-control note

Legal and grant requirements can change. Before adoption, application, procurement,

or award execution, CTSI will verify current versions of the Oregon rules, FTA circulars,

Master Agreement, Certifications and Assurances, ODOT program guidance,

solicitation, and agreement terms. This plan is not legal advice and should be reviewed

by Tribal counsel and the responsible ODOT regional transit coordinator.

Transit Statistics Summary and Planning Findings

Blue Line Transit System Performance Summary (2021-2026)

Analysis of CTSI and the Lincoln County Transit Blue Line transit operations

demonstrates the continued importance of public transportation as a critical mobility

resource for Tribal members, older adults, individuals with disabilities, veterans, lowincome households, and the broader Lincoln County community. Service demand

throughout the planning period of 2021-2026 confirms that transportation remains one

of the most significant determinants of access to healthcare, employment, education,

food services, Tribal programs, and community participation. At this time we have

found that the Blue Line does not adequately suffice for the myriad of services that the

Tribal Membership needs.

The Blue Line system functions as both a local mobility provider and a regional

connector linking Sile , Toledo, Newport, Lincoln City, and regional destinations.

Ridership pa erns indicate mixed demand for trips associated with medical care,

government services, shopping, employment, and social services. Existing service

carried out through various CTSI programs meet that majority of the Tribal needs at

this time. Wherein Tribally funded programs have identified mass transit shortfalls and

provide the necessary services. The Blue Line supports regional mobility while

reducing transportation barriers, but the majority of the needs of the Tribe have gone

unmet.

Without essential services offered through Tribal Programs membership would

otherwise result in missed appointments, reduced employment opportunities, and

social isolation.

Major Findings

Finding 1: Medical Transportation Remains the Highest Priority Need

Transportation demand continues to be heavily influenced by access to healthcare

services. Trips to hospitals, clinics, specialty medical providers, pharmacies, behavioral

health services, and rehabilitation facilities represent a significant share of system

utilization. Continued investment in medical transportation coordination should

remain a primary objective of CTSI transit services.

Finding 2: Regional Connectivity Is Essential

Many Tribal members must travel beyond Sile

for employment, education, healthcare,

government services, and commercial activity. Service connections between Sile ,

Toledo, Newport, Lincoln City, Salem, Eugene, and Portland remain essential for

maintaining equitable access to opportunities and services.

Finding 3: Demand Exists for Scheduled Fixed-Route Service

Observed travel pa erns indicate recurring movement between the same major

destinations throughout the year. This pa ern supports implementation of a pilot fixedroute transit service that complements existing demand-response operations.

Finding 4: Older Adults and Individuals with Disabilities Depend on Transit

The transportation system serves a critical mobility function for elders and riders with

disabilities. Accessible vehicles, predictable scheduling, passenger assistance, and

coordinated transportation services remain necessary to support independent living

and community participation.

Finding 5: Transit Supports Economic Opportunity

Transit service directly contributes to workforce participation by providing

transportation to employment centers, educational institutions, training programs, and

government services. Reliable transportation improves economic self-sufficiency and

workforce development outcomes.

Fixed Route Transit Recommendation

Based on existing trip pa erns, destination analysis, and regional transportation needs,

CTSI should elevate fixed-route development as a major transportation initiative during

the 2026-2030 planning period.

Recommended Pilot Route

Sile

- Toledo - Newport Connector

Primary destinations include:

•

Sile

Tribal Government Campus

•

Sile

Clinic

•

Tribal Elder Center

•

Sile

Valley Schools

•

Sile

to Toledo Downtown

•

Toledo Transit Center

•

Newport Transit Center

•

Samaritan Pacific Communities Hospital

•

Retail and employment centers

Expected Benefits

•

Increased medical access

•

Reduced missed appointments

•

Improved employment mobility

•

Enhanced student transportation opportunities

•

Greater transit reliability for elders

•

Stronger coordination with Lincoln County Transit

•

Expanded public transportation access for Tribal and non-Tribal riders

Future Transportation Priorities

1.

Preserve and expand existing Blue Line services.

2.

Implement the Sile -Toledo-Newport Fixed Route Connector.

3.

Increase accessible transportation capacity.

4.

Improve transit technology and dispatch systems.

5.

Expand transportation coordination with regional partners.

6.

Improve bus stops, shelters, and passenger amenities.

7.

Strengthen emergency transportation capabilities.

8.

Utilize GIS-based transit planning and performance monitoring.

9.

Pursue additional STIF, Section 5310, Tribal Transit, and Federal Transit

Administration funding opportunities.

10.

Continue annual performance monitoring and mobility gap analysis.

Coordinated Transportation Plan Conclusion

The CTSI transportation system represents a foundational element of Tribal health,

economic development, emergency preparedness, and community resilience.

Continued investment in coordinated transportation services will improve quality of

life, increase access to opportunity, strengthen regional connectivity, and support longterm community sustainability. The findings of this plan strongly support preservation

of existing demand-response services while advancing development of a fixed-route

transit network that will serve as the next phase of mobility enhancement for Tribal

members and the communities of Lincoln County.

Confederated Tribes of Sile

Indians

Title VI Civil Rights Plan for Transit and Transportation Programs

1. Introduction and Policy Statement

The Confederated Tribes of Sile

Indians (CTSI) is commi ed to ensuring

that all transportation and transit services, programs, and projects are operated in full

compliance with Title VI of the

Civil Rights Act of 1964, and related nondiscrimination statutes and regulations...

2. General Title VI Assurances

As a recipient of federal funds through the U.S. Department of Transportation and

the Oregon Department of Transportation, CTSI assures nondiscrimination, compliance,

responsibility, and contractor/subrecipient compliance.

3. Title VI Coordinator and Responsibilities

The Title VI Coordinator for CTSI is designated within the Planning Department.

Responsibilities include monitoring compliance, processing complaints, collecting

demographic data, coordinating training, and preparing Title VI reports.

4. Complaint Procedures

Any person who believes they have been subjected to discrimination under Title VI may

file a wri en

complaint within 180 days. Complaints will be investigated within 60 days, and

findings communicated in writing. Appeals may be made to

the Tribal Council or directly to the FTA Office of Civil Rights.

5. Public Participation Plan

CTSI will ensure proactive strategies for meaningful access to planning, including

public notices,

comment periods, newsle ers, outreach, and accessible public meetings.

6. Limited English Proficiency (LEP) Plan

Consistent with Executive Order 13166, CTSI will provide reasonable steps to ensure

LEP individuals can access programs through language assistance, translations, and

staff training.

7. Environmental Justice and Equity Analysis

In accordance with Executive Order 12898, CTSI will consider impacts on

low-income and minority populations, ensuring fair distribution of benefits and

burdens of transportation investments.

8. Data Collection and Monitoring

CTSI will collect and maintain demographic and ridership data, and participation

records, to ensure compliance and equitable service delivery.

9. Training and Compliance

Staff and contractors will receive annual Title VI training. Contractors must certify

compliance,

and periodic compliance reviews will be conducted.

10. Reporting and Program Updates

CTSI will prepare a Title VI Program Submission every three years (or as required by

FTA)

with policy statements, complaint logs, participation and LEP plans, and equity

analysis.

11. Tribal Sovereignty Statement

The Confederated Tribes of Sile

Indians recognize their sovereign status.

Implementation

of this plan respects Tribal self-determination and decision-making authority while

complying with federal requirements.

Title VI Complaint Form Template

Title VI Complaint Form

----------------------Name: ________________________________

Address: _____________________________

Phone/Email: _________________________

Date of Incident: _____________________

Description of Complaint:

______________________________________

______________________________________

Signature: ___________________________

Date: ________________________________