Equal Employment Opportunity (EEO) Program

Section1: Equal Employment Opportunity (EEO)Policy Statement


UlsterCountyAreaTransit, includingits sub recipients and contractors (UCAT), affirms its commitment to treat all applicants for employment and employees equallywithout regard to race, religion, creed, color, national origin, sex, age, disability, veterans’status, marital status orother class prohibited bylocal, StateorFederal law.UCATis an Equal Employment Opportunityemployer.  It is prohibited for UCATor anyofits employees to discriminateagainst an applicant for employmentor anotheremployeeon thebasis of race,color, andreligious creed, sex, age, nationalorigin, oranyotherbasisprohibited by local, StateorFederal law, orto be excluded from participation in, ordenied thebenefits of, orbesubject to discrimination under anyproject, program, oractivityfunded in whole orin part through Federal financial assistance.


UlsterCountyAreaTransit (UCAT)supports the concept ofan activeaffirmative action program consistent withFederal laws,court decisions, Executive Orders, and regulations, including goals and timetables, in orderto overcomethe effects ofpast discrimination on minorities and women.


The UlsterCountyExecutiveis recognized as thepoint of final authorityand responsibilityfor UCATs EEOPlan.The DirectorofPublic Transportation has immediate and continuingadministrativeresponsibilityand authority, which is delegated bythe UlsterCountyExecutive, in matters relatedto the UCAT’s total equal employment affirmativeaction obligations.


The responsibilityfortheimplementationofthe EEOProgram is assigned to the Director ofPublic Transportation,as EEO Director.All UCATmanagersand supervisors sharein the responsibilityof ensuringcomplianceis achieved through understanding, communicating,and activeinvolvement in thesupport ofthis policy.Performance evaluations ofmanagersand supervisors shall include evaluatingthesuccess ofthe EEO program in thesamemanner as performanceon othergoals.


UCATis committed to undertakean affirmativeaction program to includethe development ofgoals and timetables to help guidetheimplementation ofthe EEO program and measureprogress.  Thesuccessful achievement of EEOgoals will provide benefits to UCATthrough fullerutilization and development ofpreviouslyunderutilized human resources.


Applicants and employees havethe right to file complaints allegingdiscrimination with the DirectorofPublic Transit, UlsterCountyPersonnel Officer, Supervisors, Managers, Federal orStateCivil Rights Commissions, and the EEOC.


This policyextends to all areas of employment includingrecruitment, selection and placement, compensation, promotion, transfer, discipline, demotion, lay-off, termination,

training, dailyworking conditions, benefits and all otherterms and conditions of employment.




Guiding Legislation


Equal PayAct of1963, 29 U.S.C. 201


TitleVIoftheCivil Rights Act of1964, 42 U.S.C. 2000d


TitleVIIoftheCivil Rights Act of1964, as amended, 42 U.S.C. 2000e


UMT Act of1964, asamended, 49 U.S.C. 1601


Age Discrimination in Employment Act of1967,29 U.S.C. 633a


TitleIXofthe Education Amendments of1972, PublicLaw92-318


Section 504 oftheRehabilitation Act of1973, 29 U.S.C. 794


28 CFR Part 42, Subpart F, Coordination of Enforcement ofNondiscrimination in FederallyAssisted Programs”


29 CFR Part 1605, “Guidelines on Discrimination BecauseofReligion”


29 CFR Part 1606, “Guidelines on Discrimination BecauseofNational Origin”


29 CFR Part 1607, “Uniform Guidelines on EmployeeSelection Procedures”


29 CFR Part 1620, “TheEqual PayAct”


29 CFR Part 1625, AgeDiscrimination in Employment Act”


49 CFR Part 21, “Nondiscrimination in FederallyAssisted Programs ofthe Department ofTransportation-Effectuation of TitleVIoftheCivil RightsAct of 1964”


49 CFR Part 27, “Nondiscrimination on theBasisof Handicap inFinancial AssistancePrograms”


DOT Order1000.12, Implementation ofthe Department of Transportation TitleVI Program,”dated 1-19-77


PartII, Section 110(a)oftheFTAStandard Grant Contract, dated 9-87


This policywill beupdated at least once every3years.Supervisorsand managerswill meet semi-annuallyto discuss compliance with this program and EEOimplementation progress.  UCAT will meet annuallywith minorityand femaleemployees toobtain suggestions on EEOprogram implementation.  All UCAT employees arereceiving DiversityAwareness Trainingannuallyas part ofUlsterCountysemployeetraining program.A copyofthis policycan be found in the employeepersonnel policies and procedures manual, on employeenoticeboards,recruiting application packages, and posted on UCAT’s website.





UCAT exceeds established threshold criteriagoverningEqual EmploymentOpportunity (EEO)program requirements and reportingprocesses.  Accordingto theU.S. Department of TransportationsUMTAC 4701.1 circulardated July26, 1988, publictransit agencies receiving Federal fundingassistancein excess of$1 million in theprevious Federal

Fiscal Yearand employing50 ormoretransit-related employees must prepare, implement and evaluatea formalized EEOprogram plan.


Formalized communication mechanisms havebeen established to publicize and disseminate UCAT’s EEOPolicy, as well as appropriate elements oftheprogram, to its employees, applicants,and thegeneral public.Formalized communication mechanisms

havebeen divided into two primarycategories: External Dissemination andInternal Dissemination.



To ensurethat all members ofthestaffarecognizant ofour equal employment opportunitypolicyand theirindividual responsibilities in carryingout this policy, the followingcommunication efforts will bemade:


TheCountysemployment application forms contain anoticeinformingprospective employees that discrimination becauseof race,color, religion, national origin orsexis prohibited and that theymaynotifytheappropriatelocal, StateorFederal

agencyiftheybelievetheyhavebeen thevictimsof discrimination.


Appropriatenotices havebeen posted informingapplicants and employeesthat Ulster CountyArea Transit is an Equal OpportunityEmployerand oftheirright to notifyan appropriatelocal, StateorFederalagencyiftheybelievetheyhavebeenthe victims of discrimination.  A copyofthis policycan be foundin the employeepersonnel policies and procedures manual, on employeenoticeboards, recruitingapplicationpackages, and posted on UCAT’s website.


We will seek the cooperation ofunions to help implement our EEOprogram and all union contracts containanondiscrimination clause.


External Dissemination


The EEOPlan will bedisseminated undertheguidanceofthe UCAT DirectorofPublic Transit. Thegeneralguidelines for external dissemination shall be:



Appropriatemedia (particularlythoseservingspecificgroups, i.e. minoritygroups, womenand disabled);



Public and private employment agencies; and



Schools, colleges,and trainingorganizations.


The followingis alist ofmedia contacted orutilized when issuingpress releases and/or postingpublicinformation and notices:


UCATWeb Site

ThePost Star Newspaper

Kingston Times

Kingston DailyFreeman& Las Noticias

Saugerties Times

Shawangunk Journal

Woodstock Times




Southern Post Pioneer

Times Herald Record

Mid Hudson News Network


UlsterCountyPress ReleaseWes Site

WAMC Radio (7 state region)

Associated Press

Cable6 News (TimeWarner)

EmpireState News Network (Statewide)


NYS Association ofCounties Press




WBPM Radio

All Cumulus Radio Stations in theMarket

All ClearChannel RadioStations

UlsterCountyWeb Site HomePage


Inaddition, all advertisements for employment will contain the following statement, "Minorities, women anddisabled encouraged to applyand "Equal Opportunity Employer" at thebottom ofthe advertisement.EEOposters, areposted onapermanent basis in the administration office,employeebreakroom, and prominentlydisplayed in the visitor waitingarea.


The followingis alist ofpublic and private employment agencies that werenotified by letter regardingthe EEOPolicy:



UlsterCountyPersonnel Department


New York StateDepartment ofLabor






The followingis alist ofschools, colleges, and trainingorganizations in UlsterCounty that werenotified oftheEEOpolicyvialetter:









Internal Dissemination



Each Division Headwill be responsible forhis/herdivision's part ofthe EEOPolicy and will be evaluated ontheir contribution to EEO as part oftheirperformance appraisal.



Non-supervisorystaff will beinformed ofthe EEOpolicyand program.



As part ofthejob, employees are required to attend DiversityAwareness Trainingon an annual basis beginningOctober2009.



Anyemployees whoareinvolved in organization and/or community groupswhich havespecial contacts with minorities and women's groupsareencouraged to report to the DirectorofPublic Transportation about the existenceofsuchgroups.  Information collected about thesegroups will bepassed on to other employeesat staffmeetings and employeenewsletters.



The DirectorofPublic Transportation, in cooperation with the UlsterCounty Personnel Department, will conduct semi-annualmeetings with all managers and supervisors to provide anupdateon EEOimplementation progress and explain EEO- related rules and regulations and UCAT's responsibilities undertheselaws,as well as theirindividual responsibilities, as necessary.



EEO-related posters areposted on all employeebulletin boards along with a copyof the EEOPolicyStatement.

Section3: DesignationofResponsibility


The UlsterCountyExecutiveis recognized as thepoint of final authorityand responsibilityfor UCATs EEOPlan.The DirectorofPublic Transportation has immediate and continuingadministrativeresponsibilityand authority, which is delegated bythe UlsterCountyExecutive, in matters relatedto the UCAT’s total equal employment affirmativeaction obligations.Each UCATdivision head will be responsible within his/her respectivedivision for EEOprogram implementation and progress.


The DirectorofPublic Transportation will coordinate and administertheday-to-day operation ofthe EEOPlan.  All UCATmanagersand supervisors sharein the responsibilityof ensuring complianceis achieved through understanding, communicating,and activeinvolvement in thesupport ofthis policy.Performance evaluations ofmanagersand supervisors shall include evaluatingthesuccess ofthe EEO program in thesamemanner as performanceon othergoals. Theresponsibilities ofthe DirectorofPublic Transportation include, but arenot limited to, the following:



To maintain and amend the written EEOpolicystatement and EEOPlan.



Reportingsemi-annuallyto the UlsterCountyExecutiveon EEOissues andprogress.



Assuringthatcurrent legal information affectingaffirmativeaction is communicated to responsibleofficials (e.g. CountyAttorney, CountyPersonnel Officer).



Thedesign, implementation, and monitoringofaninternal EEO audit andreporting system.



Develop recruitingstrategies to increasethehiringofminorities, females,and the disabled.



Act as aliaison betweenminority,females, and disabled within UCAT who encounter problems internal to, orthat interface with, UCAT.



Prepareand submit EEO reports to theFTA and otheragencies, asrequired.



Closelycoordinate EEOtrainingprograms with the UlsterCountyPersonnel Department.



Concurringon all hires and promotions and process all discrimination complaints.


Section4:Recent Success


UCAThas achieved several notable EEOsuccesses overthepast threeyears, which includethe following:



In 2018,UCATemployed 61 employees.  Ofthisamount, 25 werefemaleand 19 wereofminority group status.Thestaffhasgrown to 66, wenowhave27females and 17 areminority group status.


UCATdid meet itsgoal ofmaintainingthe29 to 81 age range.It is currently29 to




In theyears 2016-2018,UCAThired 18 employees.Ofthis amount, 4 werefemale, 4 wereofminority group status.



As ofNovember2018, the ProfessionalandOffice&Clerical totals 7, 6 females and 1 male exceedingutilization rates inthosejobtitles and exceedingourgoalof40%of our workforceby35%.



All UCAT employees attend aone-daymandatoryseminaron DiversityAwareness sponsored bythe UlsterCountyPersonnel Department. This trainingwill continue for all UCAT employees on an annual basis.



UCAT exceeded itsgoalofmaintainingits minorityworkforceto 8%ofour workforce and is nowat 31%ofthe workforce.


Section5: GoalsandTimetables


UCAT’s Equal Employment Opportunity(EEO)program has been verysuccessfulin ensuring adiverseworkforce, however, morework is needed.  In 2018,UCAT employed atotal of25females, whichis approximately 41%of thetotal workforce.  Duringthe sameyear, UCAT employed 19 persons ofminority group status, which isapproximately 31% ofthetotal workforce.Unfortunately, UCATemployed zero personswith disabilities in 2018.Atotal of61 transit-related employeeswereemployed byUCATin 2018.


Year2010 Census dataindicates that theoverall percentageoffemalesage18 orolderin UlsterCountyis 73,613or40.3%ofthepopulation segment.Thetotal numberofmales age18 orolderis slightlyless at 72,064 or39.5%.  Incomparison, UCAT’sworkforce populationformalesandfemalesis 59%and 41%,respectively, whichisconsiderably lessbalancedthanthegeneralUlsterCountypopulation.  Whilewehaveincreasedthenumbers from 2018we still have a ways to go.  UCAT isactivelyrecruiting females to help increasethefemaleworkforce.


Goal 1:UCATs goal is to increasethenumber of employed females to 40%of thetotal workforcebyYear 2018.


Theminority group population percentage employed byUCATis significantlyhigher than thepercentageof UlsterCountys minority group population.Accordingto Year 2010 Census data, 15,909 or8.7%of UlsterCountys population was ofminority group status.Thetotal and minority group populations aged 18 oroverin UlsterCountyin 2010 were145,677and 10,570, respectively.Therefore, theminority grouppopulation aged 18 orover was 7.25%ofthetotal UlsterCountypopulation.  In 2018,UCAT’s total minorities employed totaled 19 or31%ofthetotalworkforce.Thenumberof UCAT’s minoritygroup personsemployed exceeded UlsterCountys proportional minority group population byapproximately24%.  UCAT’s abilityto recruit persons ofminority group status has been verysuccessful.

Goal 2:UCATs goal is to maintain the minoritygroup workforcepopulation above30% through theYear 2018.


UCAT employed zero disabled persons in 2018.  It maybeverydifficult orimpossibleto employpersons with disabilities either as bus operators orto work with maintenancestaff in thebus garage.  Persons with disabilities are encouraged toapplyfor available positions within UCAToffices.


Goal 3:UCATs goal is to increasethenumber of disabled persons working within UCAT offices fromzero to onebyYear 2018.


In 2018,UCAT’s workforceagerangewas between 29 and 73years ofage.


Goal 4:UCATs goal is to broaden our agerangefrom29 to 81 throughYear 2018.


Monitoring and Reporting System


UCAThas in placean effectiveinternal EEOmonitoringand reportingsystem. EEO progress is reviewed semi-annuallyamongUCATmanagement. This process allows UCATto take correctiveaction in its EEOpractices throughout theyear, ifnecessary.


Thesystem is set up asfollows:


On asemi-annual basis the Director and all supervisorystaff will assess accomplishments orshortfalls.


The Director and staff will look at employees in each job categorybyrace,national origin, and sexwho haveapplied forpromotion ortransfervs. thosepromoted or transferred.


Disciplinaryactions andterminations byrace, national origin and sexwill also be assessed fornegativepatterns.


This will enable UlsterCountyArea Transit to identifyunits that arenon-compliant or have failed toembracethepolicy.




UlsterCountyAreaTransit an entityof UlsterCountyand is regulated bya collective bargainingagreement betweentheCountyof Ulster and its employees.Allrecruitment, positiondescriptions, interviewprocedures, wage and salarystructure, seniority, layoff,termination,disciplinaryactionsandtransfersarenegotiatedandspelledout specifically within the unioncontract attached in Appendix  J.  All employment practicesstaticallydataisavailablein AppendixN.  UlsterCountyisalsoguidedbyNew York State Civil Service rules for selection standards, procedures and interview rules.






Section7: EEO Complaint Process

Anyemployeeorapplicant allegingto besubjected to discrimination, unfairpracticeor retaliation on thebasis ofanyoftheprotected classifications noted in the EEOPolicy Statement, mayfilea written complaint within 30days ofthe alleged violation to the DirectorofPublic Transportation located at 1 DannyCircle,Kingston, NY, 12401, orby telephone at 845-340-3333.Upon filingthe complaint of alleged discrimination, the DirectorofPublic Transportation will proceed with an investigation to determineifthere has been aviolation ofthis Policy.  Decisions andfindingwill be conveyedto theCounty Executive, who is the final point of authority


Ifforsomereasonan employeeor applicant doesnot want to bringacomplaint to the DirectorofPublic Transportation, then the employeeor applicant should contact the UlsterCountyPersonnel Officer concerningthe complaint.The UlsterCountyPersonnel Officer can be contacted bywritingto the UlsterCountyPersonnel Department, 5thFloor,

P.O. Box1800, 244 FairStreet, Kingston, NY12402-1800 orbytelephoning845-340- 3535.  The UlsterCountyPersonnel Officer will communicate and providethe results of herinvestigation to theCountyExecutive, who is the final point of authority,and the DirectorofPublic Transportation.


Confidentialitywill bemaintained to the extent practical to conducta full investigation to makeadetermination. All employeesarerequiredto fullycooperateduring the courseof an investigation.


Ifit is determined that aviolation ofthis Policyhas occurred, UCATwill takeimmediate action to remedythesituation.  Anyemployee who is found to haveviolated this Policy maybesubject to disciplinaryaction, up to and includingtermination fromemployment.


Inaddition to the complaint procedures describedabove, complaints maybe filed with the New York State Division of Human Rights orthe UnitedStates EqualEmployment OpportunityCommission.


A reasonableaccommodation policyhandout isgiven to each new employee explaining his orher rights and thecomplaint process.  (Seeattachment K)





WorkforceAnalysisandGoals byJob Title and Group


EEOJob Categories at UCAT


Job TitlesIncludedin Grade withSalaryStructure




UCAT Organizational Chart


UCAT EEO-4 Report


Signed UCATPolicyonEEO


U.S. CensusLabor forceand Employment


EEO-1 AggregateReport for Kingston


Collective BargainingAgreement withCSEA Unit 8950


ReasonableAccommodation PolicyHandout


Examples ofExternalDissemination


CountyofUlsterStandards ofConduct edited showingEEOcontent only



Employment Practices Statistical DataExamples


Click Here for Full Document & Appendices