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Title VI Program

Recertification Document


Title VI of the 1964 Civil Rights Act, Section 601 Specific to Federal Transit Administration Programs


March 19, 2020


Northwestern Indiana Regional Planning Commission 6100 Southport Road

Portage, Indiana 46368

Phone (219) 763.6060

Fax (219) 762.1653

    1. ail: nirpc@nirpc.org

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      2020

      Northwestern Indiana Regional Planning Commission Title VI Program Certification Document


      Table of Contents


      NIRPC’S RESOLUTION ADOPTING TITLE VI PLAN

      IDENTIFICATION OF DESIGNATED RECIPIENT, DIRECT GRANTEE, AND SUBRECIPIENTS 1

      PART I. NIRPC GENERAL REPORTING REQUIREMENTS 2

      REQUIREMENT TO PROVIDE AN ANNUAL TITLE VI CERTIFICATION AND ASSURANCES 2

      REQUIREMENT TO DEVELOP TITLE VI COMPLAINT PROCEDURES 2

      REQUIREMENT TO RECORD TITLE VI INVESTIGATIONS, COMPLAINTS, & LAWSUITS 2

      REQUIREMENT TO PROVIDE MEANINGFUL ACCESS TO LIMITED ENGLISH PROFICIENCY (LEP) PERSONS

      ............................................................................................................................................. 2

      REQUIREMENT TO NOTIFY BENEFICIARIES OF PROTECTION UNDER TITLE VI 3

      PUBLIC PARTICIPATION PLAN & SUMMARY OF PUBLIC OUTREACH AND INVOLVEMENT ACTIVITIES 3

      MINORITY REPRESENTATION ON PLANNING AND ADVISORY BODIES 9

      MONITORING SUBRECIPIENTS 13

      REQUIREMENT TO CONDUCT EQUITY ANALYSIS TO DETERMINE SITE OR LOCATION OF FACILITIES 14

      PART II. MPO REQUIREMENTS 15

      DEMOGRAPHIC PROFILE 15

      ENVIRONMENTAL JUSTICE BENEFITS AND BURDENS ANALYSIS 15

      DESCRIPTION OF PROCEDURES WITHIN PLANNING PROCESS 18

      DEMOGRAPHIC MAPS SHOWING IMPACTS OF STATE AND FEDERAL FUNDS 20

      A DESCRIPTION OF THE PROCEDURES THE MPO USES TO PASS THROUGH FTA FINANCIAL ASSISTANCE TO SUBRECIPIENTS IN A NON-DISCRIMINATORY MANNER 24

      A DESCRIPTION OF THE PROCEDURES THE MPO USES TO PROVIDE ASSISTANCE TO POTENTIAL SUBRECIPIENTS APPLYING FOR FUNDING, INCLUDING ITS EFFORTS TO ASSIST APPLICANTS THAT WOULD SERVE PREDOMINANTLY MINORITY POPULATIONS 24

      PART III. NIRPC RECERTIFICATION ATTACHMENTS 26

      ATTACHMENT #1: NIRPC’S TITLE VI COMPLAINT PROCEDURES 27

      ATTACHMENT #2: LIMITED ENGLISH PROFICIENCY STRATEGY 33

      ATTACHMENT #3: LIMITED ENGLISH PROFICIENCY BY CENSUS TRACT – DEMOGRAPHIC PROFILE 41

      ATTACHMENT #5: MINORITY AND LOW-INCOME POPULATION DISTRIBUTION CHART 44


      Northwestern Indiana Regional Planning Commission 6100 Southport Road

      Portage, Indiana 46368


      Phone (219) 763.6060

      Fax (219) 762.1653

      e-mail: nirpc@nirpc.org


      Ty Warner AICP Executive Director

      Identification of Designated Recipient, Direct Grantee, and Subrecipients


      Recipient: Northwestern Indiana Regional Planning Commission (NIRPC) 6100 Southport Road, Portage, IN 46368-6409

      FTA Grantee: 1193 Subrecipients:

      City of East Chicago, IN (East Chicago Transit)

      North Township, Lake County, IN (North Twp. Dial-a-Ride) South Lake County Community Services, Inc.

      Opportunity Enterprises, Inc. (OE Express) Porter County Aging & Community Services, Inc. City of Valparaiso, IN (V-Line & ChicaGo Dash) City of La Porte, IN (TransPorte)


      NIRPC also functions as the cognizant Designated Recipient and executes supplemental agreements for the following transit operator, which is itself a direct grantee of Federal Transportation Administration (FTA) funds:


      Northern Indiana Commuter Transportation District (NICTD) (South Shore Commuter Rail)

      FTA Grantee: 1201


      NICTD will be submitting their own Title VI Certification to FTA. Please see their submitted document.

      Part I. NIRPC General Reporting Requirements


      The information contained in this report reflects the Title VI requirement per Federal Transit Administration (FTA) Circular 4702.1B of October 1, 2012. The Northwestern Indiana Regional Planning Commission (NIRPC) functions as a Metropolitan Planning Organization (MPO): FTA direct grantee that passes through funding to seven (7) different transit operators; and as the “cognizant” Designated Recipient for a commuter rail provider. As a recipient of FTA funds, NIRPC submits the following information under General Reporting Requirements of Chapter III of the Circular.


      Requirement to Provide an Annual Title VI Certification and Assurances

      The Northwestern Indiana Regional Planning Commission (NIRPC) submitted the FY 2017 Certifications and Assurances on TRAMS on January 9, 2017.


      Requirement to Develop Title VI Complaint Procedures

      In 2010 NIRPC updated its Title VI complaints procedures. This update included the addition of a complaint form and was approved by the Indiana Department of Transportation (INDOT) in May of 2010. NIRPC’s Title VI Complaint Procedures (see Attachment #1) are posted on the bulletin board in NIRPC’s reception area and are available for the public to download from NIRPC’s website.


      Requirement to Record Title VI Investigations, Complaints, & Lawsuits

      NIRPC has no active lawsuits or complaints alleging discrimination on the basis of race, color, or national origin with respect to service or other transit benefits.


      Requirement to Provide Meaningful Access to Limited English Proficiency (LEP) Persons

      NIRPC’s Public Participation Plan was updated and adopted in August 2019. NIRPC receives federal financial assistance from the US Department of Transportation (US DOT). For this reason, it is subject to the US DOT’s Limited English Proficiency Guidance, issued on December 14, 2005. NIRPC has elected not to prepare a formal Limited English Proficiency (LEP) Plan. In 2020 NIRPC completed the LEP Four Factor Analysis (see Attachments #2 & Attachment #3). NIRPC has elected not to update the four-factor analysis at this time. This is due to the low number of LEP persons historically accessing NIRPC services, and the low frequency at which LEP persons encounter NIRPC’s services. NIRPC will update the four-factor analysis and revisit the possibility of creating a formal Limited English Proficiency Plan upon the release of more detailed data. The conclusions to the four-factor analysis have been updated to reflect the steps taken and the future steps that will be taken to expand NIRPC’s access to LEP populations (See Attachment #3).

      Requirement to Notify Beneficiaries of Protection Under Title VI

      NIRPC’s Title VI Complaint Procedures (see Attachment #1) are posted on the bulletin board in NIRPC’s reception area and are available for the public to download from NIRPC’s website. NIRPC staff updated its Non-Discrimination Statement in 2010 to fulfill the INDOT ADA review. A Request for Alternate Formats statement was developed in 2010. It is NIRPC’s policy to incorporate both the Non-Discrimination and Request for Alternate Format Statements into all public documents. Below are the Non-Discrimination and Request for Alternate Format Statements.


      Non-Discrimination Statement


      The Northwestern Indiana Regional Planning Commission (NIRPC) prohibits discrimination in all its programs and activities on the basis of race, color, sex, religion, national origin, age, disability, marital status, familial status, parental status, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual's income is derived from any public assistance program.


      Request for Alternate Formats


      Requests for alternate formats please Allen Hammond at NIRPC at (219)254-2500 or ahammond@nirpc.org. Individuals with hearing impairments may contact us through the Indiana relay 711 service by calling 711 or (800) 743-3333.


      Public Participation Plan & Summary of Public Outreach and Involvement Activities


      NIRPC’s Public Participation Plan, Engage NWI was updated and adopted on August 15, 2019. Engage NWI is the federally required “Public Participation Plan” that enables Northwestern Indiana Regional Planning Commission (NIRPC) staff to ensure that it is meeting all federal requirements for public participation, but more importantly, a guide that enables the public to engage with regional planning.


      Engage NWI promotes a meaningful exchange of ideas, identification of regional issues and solutions, as well as advancing initiatives to achieve the vision for Northwestern Indiana (NWI). Most importantly, through trial and error, Engage NWI provides a blueprint for methods that work for public engagement in a world that has moved on from traditional outreach methods – going beyond the traditional public meeting. Please see NIRPC’s Public Participation Plan submitted along with this document as well as located on NIRPC’s website.


      Several steps have been taken since the last Title VI submission in 2017 to ensure that the general public, including underrepresented communities, are involved in and have meaningful access to NIRPC activities and events. These steps include, but are not limited to:

      • Adopting a new Public Participation Plan on August 15, 2019. The Plan includes many improvements, including how to engage with regional planning.


      • Appointing a staff member as the Public Participation Planner to oversee the development and implementation of the Public Participation Plan as well as all agency outreach and engagement activities.

      • Engaging in a large number of public workshops and public outreach events in multiple locations throughout the region. This includes organizing and attending events in underrepresented communities.


      • Hosting public meetings, public hearings, out and abouts, open houses, pop-up events, and focus groups, throughout the region, including underrepresented communities, for the NWI 2050 Plan, Coordinated Transit Plan, Transportation Improvement Program and Engage NWI.


      • Broadcasting information regarding NIRPC activities and public involvement opportunities through radio, social media, newspaper, and television. This activity ranged from press releases to special appearances and feature articles. This includes monthly appearances on “Green Fleets,” a local radio show hosted by NIRPC planning partner South Shore Clean Cities.


      • Posting NIRPC activities, information, publications and events on NIRPC’s website, weekly newsletter, and social media pages.


      • NIRPC provides public notice through media notices, public service announcements, web site meeting calendar, and announcements at monthly policy board and stakeholder meetings. Notices of regularly scheduled meetings are sent out and posted at least 48 hours in advance. A notice is also sent prior to January for the entire years’ worth of meetings. Notices of formal public hearings are done 30 days in advance of the hearing.


      • Providing alternatives formats and accommodations upon request at least 72 hours in advance of meetings and events.


      • Releasing various draft plans, programs and other documents for public comment, following the guidelines as established in the 2019 Public Participation Plan.


      • NIRPC has established a social media presence that includes Facebook, LinkedIn, Instagram, YouTube, and Twitter as additional tools for outreach and engagement.


      • NIRPC launched a redesigned web page in January of 2017 to further improve upon the user experience.


In addition to the above steps, the following (Figure 1-4) is a summary of specific public outreach and involvement activities undertaken since the submission of the last Title VI certification in 2017.

Figure 1: Agency Engagement Efforts Timeline 2018 – 2019


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Figure 1 depicts the agency’s outreach and engagement efforts from 2018-2019 in regards to the NWI 2050 Plan. Outreach activities began in April 2018 and concluded in May 2019 with the adoption of the new plan. There were four engagement periods that took place to obtain feedback from the public.


Figure 2: NWI 2050 Plan Outreach & Engagement Summary

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Figure 2 describes the traditional and non-traditional outreach and engagement methods that took place during the NWI 2050 Plan process, such as: public meetings and hearings, out and abouts, and pop-up events.

Figure 3: Coordinated Transit Plan Outreach & Engagement Summary


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Figure 3 describes the outreach and engagement activities of the Coordinated Transit Plan which took place in the Fall of 2018. The Coordinated Transit Plan utilized outreach methods such as traditional public meetings, field work, committee meetings, and a survey.

Figure 4: Engage NWI, Public Participation Plan Outreach & Engagement Summary


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Figure 4 describes the process of the development and implementation of Engage NWI, the newly adopted Public Participation Plan.


Additional opportunities to engage with NIRPC to provide input and feedback on plans and programs were also available via the NIRPC website via the public comment opportunities section located here.


Environmental Public Outreach

NIRPC’s Environmental Department provides public education as part its air quality programming. To promote cleaner air throughout the region the Environmental Department assists partners to promote the annual Partners for Clean Air Award Luncheon and Asthma Awareness Day at Gary RailCats baseball games. The luncheon is open to the public and NIRPC distributes free tickets at the baseball games and health clinics throughout the region, with a focus on those in the urban and minority communities. In 2017, a regional air quality and transit campaign was conducted by NIRPC to encourage modal shifts.


An air quality study was completed for NIRPC in 2017 to determine Northwest Indiana residents’ knowledge of air quality issues, the relative importance they place on air quality, their sources of information about air quality, and their awareness of and opinions on specific air quality campaigns. The study entailed a statistically representative telephone survey of Northwest Indiana residents as well as two focus groups in Merrillville and Valparaiso. This information has been used to guide public outreach efforts.

Air quality public outreach is also done by NIRPC at community and partner events throughout the year. Additionally, NIRPC purchases billboard, newspaper, and radio space to educate the public on air quality and to promote events. This has included space in Que Viva, Northwest Indiana’s Spanish speaking newspaper. NIRPC maintains air quality outreach materials on its website including materials that have been translated to Spanish.


Minority Representation on Planning and Advisory Bodies


In order to determine minority representation on NIRPC boards and committees; staff developed a voluntary survey to distribute to NIRPC leadership. This survey was distributed in November 2019, and later redistributed in March 2020 to demonstrate a good faith effort to boost survey participation as much as possible.

The survey asked three questions: 1) The respondent’s name. Participants were informed that their data would remain anonymous. Their name only be used to establish who has taken the survey, and who still needs to complete it. 2) Their racial or ethnic identification. The categories provided were identified from the Association of Institutional Research. Additionally, the categories were shared with the 2010 Census and American Community Survey, so that respondents’ answers could be quantified against regional trends. 3) Lastly, respondents were asked to indicate what committees they served on and the year of their service. This question’s answers pertained to NIRPC’s Commission and Executive Board; Finance and Personnel Committee; Legislative Committee; Local Government Assistance Committee; Outreach Committee; Technical Planning Committee (TPC); and five TPC subcommittees; and if the individual served in 2017, 2018, or 2019.

Membership on the NIRPC Board is made under the NIRPC Enabling Legislation (P.L.165-2003, and as amended by P.L. 2-2007) that states the following:

IC 36-7-7.6-4


Commission Membership

Sec. 4. (a) The following members shall be appointed to the commission:

(I) A member of the county executive of each county described in section I of this chapter, to be appointed by the county executive.

  1. A member of the county fiscal body of each county described in section I of this chapter, to be appointed by the county fiscal body.

  2. The county surveyor of each county described in section I of this chapter.

  3. For a county having a population of not more than four hundred thousand (400,000), one (1) person appointed by the executive of each of the eleven (11) largest municipalities.

  4. For a county having a population of more than four hundred thousand (400,000) but less than seven hundred thousand (700,000), one (1) person appointed by the executive of each of the nineteen (19) largest municipalities.

  5. Beginning July 1, 2007, one (1) person appointed by the trustee of each township that:

    1. Is located in a county described in section 1 of this chapter;

    2. Has a population of at least eight thousand (8,000); and

    3. Does not contain a municipality.

      1. One (1) voting member of the commission shall be appointed by the governor. The member appointed under this subsection may not vote in a weighted vote under section 9 of this chapter.

      2. A member of the commission who is a county surveyor may not vote in a weighted vote under section 9 of this chapter.

        As added by P.L.165-2003, SEC.6. Amended by P.L.169-2006, SEC.57.

        IC 36-7-7.6-5

        Sec. 5. (a) All commission members must be elected officials.


        NIRPC’s Board of Commissioners established a new Committee structure of NIRPC to ensure diverse and equal representation and function of all the agency’s Committees. Membership includes representation from minority agencies and organizations, transportation, environmental, environmental justice, economic development, universities and representatives from the Urban Core Communities, including Gary, Hammond, East Chicago and Michigan City.


        According to the Federal Register 23 CFR 450, NIRPC MPO policy committees, such as the Technical Planning Committee, shall consist of the following, “each MPO that serves a TMA shall consist of local elected officials, public transportation agencies or appropriate State officials on their policy boards”. NIRPC’s Board of Commissioners selects the representation on the Technical Planning Committee.


        The following survey data represents a good faith effort in demonstrating NIRPC leadership’s racial and ethnic make- up. The data is limited based on entirely on voluntary participation and is listed by year giving the percent of received responses by committee.

        Table 1: 2017 NIRPC Committee Membership Broken Down by Race Based on 2010 Census for the NIRPC Region of Lake, Porter and LaPorte Counties


        Body

        White alone

        Black or African American alone

        American Indian and Alaska Native alone

        Asian alone

        Native Hawaiian and Other Pacific Islander alone

        Some Other Race alone

        Two or More Races

        Hispanic or Latino

        2010 Population

        65.60%

        18.40%

        0.20%

        1.10%

        0.00%

        0.10%

        1.30%

        13.30%

        NIRPC Commission

        80.00%

        13.30%

        -

        -

        -

        -

        -

        6.66%

        NIRPC Executive Board

        85.72%

        -

        -

        -

        -

        -

        -

        14.30%

        Finance and Personal Committee

        60.00%

        20.00%

        -

        -

        -

        -

        -

        20.00%

        Legislative Committee

        100%

        -

        -

        -

        -

        -

        -

        -

        Local Government Assistance Committee

        100.00%

        -

        -

        -

        -

        -

        -

        -

        Outreach Committee

        No Responses

        -

        -

        -

        -

        -

        -

        -

        Transportation Resources and Oversight Committee

        87.50%

        12.50%

        -

        -

        -

        -

        -

        -

        Technical Planning Committee

        87.50%

        12.50%

        -

        -

        -

        -

        -

        -

        Environmental Management Policy Committee

        88.88%

        5.55%

        -

        5.55%

        -

        -

        -

        -

        Ped, Pedal, and Paddle Committee

        95.45%

        -

        -

        -

        -

        -

        -

        4.54%

        Land Use Committee

        71.43%

        14.30%

        -

        -

        -

        -

        -

        14.30%

        Transit Operators Round Table

        75.00%

        25.00%

        -

        -

        -

        -

        -

        -

        Surface Transportation Committee

        80.00%

        20.00%

        -

        -

        -

        -

        -

        -

        2017


        NIRPC Commission – 51 received survey, 15 responded (29.4% response) NIRPC Executive Board – 11 received survey, 7 responded (63.6% response)

        Environmental Management Policy Committee (EMPC) – 41 received survey, 18 responded (43.9% response) Surface Transportation Committee (STC) – 29 received survey, 5 responded (17.2% response)

        Transit Operators Roundtable (TOR) – 12 received survey, 4 responded (33.3% response) Land Use Committee – 39 received survey, 7 responded (15.4% response)

        Transportation Resource Oversight Committee (TROC) - 41 received survey, 8 responded (19.5% response) Finance and Personnel Committee - received survey 9, 5 responded (55.6% response)

        Technical Planning Committee (TPC) - 23 received survey, 8 responded (34.9%)

        Ped, Pedal, & Paddle Committee (3PC) – 23 received survey, 22 responded (95.7% response) Local Government Assistance Committee – 37 received survey, 4 responded (10.8% response)


        Table 2: 2018 NIRPC Committee Membership Broken Down by Race Based on 2010 Census for the NIRPC Region of Lake, Porter and LaPorte Counties


        Body

        White alone

        Black or African American alone

        American Indian and Alaska Native alone

        Asian alone

        Native Hawaiian and Other Pacific Islander alone

        Some Other Race alone

        Two or More Races

        Hispanic or Latino

        2010 Population

        65.60%

        18.40%

        0.20%

        1.10%

        0.00%

        0.10%

        1.30%

        13.30%

        NIRPC Commission

        82.35%

        11.76%

        -

        -

        -

        -

        -

        5.88%

        NIRPC Executive Board

        75.00%

        12.50%

        -

        -

        -

        -

        -

        12.50%

        Finance and Personal Committee

        50.00%

        25.00%

        -

        -

        -

        -

        -

        25.00%

        Legislative Committee

        100.00%

        -

        -

        -

        -

        -

        -

        -

        Local Government Assistance Committee

        100.00%

        -

        -

        -

        -

        -

        -

        -

        Outreach Committee

        -

        -

        -

        -

        -

        -

        -

        100.00%

        Transportation Resources and Oversight Committee

        90.00%

        10.00%

        -

        -

        -

        -

        -

        -

        Technical Planning Committee

        88.89%

        11.11%

        -

        -

        -

        -

        -

        -

        Environmental Management Policy Committee

        88.88%

        5.55%

        -

        5.55%

        -

        -

        -

        -

        Ped, Pedal, and Paddle Committee

        94.44%

        -

        -

        -

        -

        -

        -

        5.88%

        Land Use Committee

        71.40%

        14.30%

        -

        -

        -

        -

        -

        14.30%

        Transit Operators Round Table

        85.71%

        14.30%

        -

        -

        -

        -

        -

        -

        Surface Transportation Committee

        66.67%

        33.33%

        -

        -

        -

        -

        -

        -

        2018

        NIRPC Commission – 50 received survey, 19 responded (38.0% response) NIRPC Executive Board – 11 received survey, 8 responded (72.7% response)

        Environmental Management Policy Committee (EMPC) – 41 received survey, 18 responded (43.9% response) Surface Transportation Committee (STC) – 29 received survey, 3 responded (10.3%)

        Transit Operators Roundtable (TOR) – 12 received survey, 6 responded (50.0% response) Land Use Committee – 39 received survey, 7 responded (15.4% response)

        Transportation Resource Oversight Committee (TROC) - 41 received survey, 10 responded (24.3% response) Finance and Personnel Committee – received survey 9, 4 responded (44.4% response)

        Technical Planning Committee (TPC) – 23 received survey, 9 responded (39.13% response) Ped, Pedal, & Paddle Committee (3PC) – 23 received survey, 18 responded (78.3% response) Local Government Assistance Committee – 37 received survey, 3 responded (8.1% response)


        Table 3: 2019 NIRPC Committee Membership Broken Down by Race Based on 2010 Census for the NIRPC Region of Lake, Porter and LaPorte Counties


        Body

        White alone

        Black or African American alone

        American Indian

        and Alaska Native alone

        Asian alone

        Native Hawaiian and Other Pacific Islander alone

        Some Other Race alone

        Two or More Races

        Hispanic or Latino

        2010 Population

        65.60%

        18.40%

        0.20%

        1.10%

        0.00%

        0.10%

        1.30%

        13.30%

        NIRPC Commission

        78.94%

        15.79%

        -

        -

        -

        -

        -

        5.26%

        NIRPC Executive Board

        75.00%

        12.50%

        -

        -

        -

        -

        -

        12.50%

        Finance and Personal Committee

        50.00%

        25.00%

        -

        -

        -

        -

        -

        25.00%

        Legislative Committee

        83.34%

        16.67%

        -

        -

        -

        -

        -

        -

        Local Government Assistance Committee

        100.00%

        -

        -

        -

        -

        -

        -

        -

        Outreach Committee

        87.50%

        -

        -

        -

        -

        -

        -

        12.50%

        Transportation Research and Oversight Committee

        92.30%

        7.69%

        -

        -

        -

        -

        -

        -

        Technical Planning Committee

        83.34%

        16.67%

        -

        -

        -

        -

        -

        -

        Environmental Management Policy Committee

        89.47%

        5.26%

        -

        5.26%

        -

        -

        -

        -

        Ped, Pedal, and Paddle Committee

        94.12%

        -

        -

        -

        -

        -

        -

        5.88%

        Land Use Committee

        75.00%

        12.50%

        -

        -

        -

        -

        -

        12.50%

        Transit Operators Round Table

        66.67%

        33.33%

        -

        -

        -

        -

        -

        -

        Surface Transportation Committee

        83.34%

        16.67%

        -

        -

        -

        -

        -

        -


        2019

        NIRPC Commission – 51 received survey, 8 responded (15.6% response) NIRPC Executive Board – 11 received survey, 8 responded (72.7% response)

        Environmental Management Policy Committee (EMPC) – 41 received survey, 19 responded (46.3% response) Surface Transportation Committee (STC) – 29 received survey, 6 responded (20.6% response)

        Transit Operators Roundtable (TOR) – 12 received survey, 6 responded (50.0% response) Land Use Committee – 39 received survey, 8 responded (20.5% response)

        Transportation Resource Oversight Committee (TROC) - 41 received survey, 13 responded (31.7% response) Finance and Personnel Committee – received survey 9, 4 responded (44.4% response)

        Technical Planning Committee (TPC) – 23 received survey, 12 responded (52.3% response) Ped, Pedal, & Paddle Committee (3PC) – 23 received survey, 17 responded (73.9% response) Local Government Assistance Committee – 37 received survey, 1 responded (2.7% response) Outreach Committee – 37 received survey, 4 responded (10.8% response)

        Monitoring Subrecipients

        NIRPC conducts Biennial Reviews of all Subrecipients, which includes addressing Title VI Federal Requirements. The purpose of a Biennial Review is to assess the subrecipient’s management practices and program implementation to evaluate compliance with federal requirements. The Biennial Review consists of two stages. The first stage is a desk review conducted at NIRPC to review documentation pertaining to the subrecipient. The second stage is a site visit for NIRPC to discuss any outstanding items, examine FTA- funded facilities and equipment, and review any additional documents.


        The review package details the information needed for the Biennial Review Site Visit, most of which is provided in advance. This information request is organized into three parts: Subrecipient Profile, Requested Documents and Questions for the Review. The Biennial Reviewers may request additional information during the site visit.

        A draft report is issued at the end of the process, describing any deficiencies in the subrecipient’s program that have been identified and the necessary corrective actions. In order to enable NIRPC to make these determinations during the site visit, the subrecipient must submit the information requested, and written responses to the questions.


        Requirement to Conduct Equity Analysis to Determine Site or Location of Facilities

        No such projects requiring land acquisition or the displacement of persons from their residences and businesses was conducted during this reporting period.

        Part II. MPO Requirements


        As a recipient of Federal Transit Administration (FTA) funds, NIRPC submits the following information under the Metropolitan Transportation Planning Organizations Reporting Requirements of Chapter VI of the Circular.


        Demographic Profile

        Northwest Indiana’s population of just over 770,000 people is concentrated mostly in and around the Urbanized Areas as designated by the US Census. This means that Northwestern Indiana residents are primarily concentrated in northern and central Lake County; north and central Porter County; and split between the Cities of Michigan City and La Porte in LaPorte County. Outside of these core population centers; Northwestern Indiana is largely rural and not densely populated.


        Even though, the population of Northwestern Indiana is spread widely over a three-county area, people who are a minority group or low-income are much more concentrated. According to the most recently available Census data, the 2015 American Community Survey, residents who are an ethnic or racial minority are concentrated primarily in north Lake County within the Cities of Hammond, East Chicago, and Gary. In these communities the majority of census blocks include a population of greater than 50% minority. In many instances, the concentration is greater than 79%. There is also a significant concentration of people who are considered a minority within the City of Michigan City in LaPorte County.


        Similarly, people who are low-income closely mirror the same distribution of residents who are a minority, however overall there is less of a concentration. Relatively few Census blocks within the region exceed 70% of households that are low income. However, Census blocks of 44% (or greater) of households that are low income make up the majority of blocks within communities that already have a concentration of people who are considered to be a minority.


        Individuals with limited-English proficiency, are less prominent throughout the Region. For instance, the regional average of individuals with limited-English proficiency make up approximately less than 3% of the regional population. However, these individuals are primarily concentrated in and around East Chicago and Hammond with concentrations within some Census blocks of up to 30%, albeit in relatively few Census blocks overall.


        As illustrated in the corresponding transit service area maps, the concentrations of people who are considered to be a minority, low income, or limited-English proficiency are a priority for regional transit service. Most of these communities, with some exceptions, are serviced by fixed-route transit: either as an inter-city commuter service with connections to Chicago, or as typical fixed-route with complementary paratransit as seen in East Chicago, Gary, Hammond, Merrillville, and Michigan City. Broader swaths of the Region are covered and connected by demand- response transit operators. With some exceptions, demand-response operators in Northwestern Indiana primarily serve to connect rural communities with each other and with the urban communities as well.


        Environmental Justice Benefits and Burdens Analysis

        According to Executive Order #12898 and FTA Circular 4702.1B, NIRPC as a Metropolitan Planning Agency helping to administer federal transportation funding must demonstrate that it has an analytical framework in place to ensure that minority and low-income populations (defined as the Environmental Justice population) are not disproportionately burdened by the transportation projects that the federal transportation funds benefit. In adopting the NWI 2050 Plan for the Northwestern Indiana Region, NIRPC

        expands the definition of the Environmental Justice population to include those Census Block Groups in the region that have a lower level of English proficiency, have more persons with disabilities, have more senior citizens aged 65 or older, have more households without access to a vehicle, and have more veterans in addition to having more minorities and low-income households compared with the region average.


        The analytical framework that NIRPC uses in order to track if the transportation projects benefiting from federal funding are disproportionately burdening the Environmental Justice population hinges on 6 performance measures:

        1. Population within Environmental Justice Census Block Groups that are in fixed route transit service areas in 2017 baseline year of the NWI 2050 Plan

        2. Population within Environmental Justice Census Block Groups within fixed route transit service areas as a percentage of total Environmental Justice population compared with total regional population within fixed route transit service areas as a percentage of total regional population in 2017 baseline year of the NWI 2050 Plan

        3. Annual weekday person hours of delay per capita in Environmental Justice Census Block Groups compared with annual weekday person hours of delay per capita in the entire region in the 2017 baseline year of the NWI 2050 Plan

        4. Forecasted annual weekday person hours of delay per capita in Environmental Justice Census Block Groups compared with forecasted annual weekday person hours of delay per capita in the entire region in the 2050 horizon year of the NWI 2050 Plan assuming a complete buildout of all fiscally constrained planned transportation projects in the NWI 2050 Plan

        5. Percent change in annual weekday person hours of delay per capita in Environmental Justice Census Block Groups from 2017 to 2050 compared with percent change in annual weekday person hours of delay per capita for the entire region assuming a complete buildout of all fiscally constrained planned transportation projects in the NWI 2050 Plan

        6. Percent change in annual weekday person hours of delay per capita in Environmental Justice Census Block Groups in 2050 from assuming no federal projects are built from 2017 to 2050 to assuming a complete buildout of all fiscally constrained planned transportation projects in the NWI 2050 Plan compared with percent change in annual weekday person hours of delay per capita for the entire region in 2050 from assuming no federal projects are built from 2017 to 2050 to assuming a complete buildout of all fiscally constrained planned transportation projects in the NWI 2050 Plan


      Performance Measure Results

      Table 4: Performance Measures Used for Analyzing Benefits and Burdens of Federally Funded Transportation Projects on Environmental Justice Population


      Performance Measure (See previous for the numbers the Performance Measures Correspond to)

      Number

      Sources

      1.


      112,890

      OnTheMap, U.S. Census Bureau, Center for Economic Studies, 2017 and 2013-

      2017 American Community Survey 5- Year Estimates Tables B01003,

      B28007

      2.


      48.5%

      vs. 26.2%

      OnTheMap, U.S. Census Bureau, Center for Economic Studies, 2017 and 2013-

      2017 American Community Survey 5- Year Estimates Tables B01003,

      B28007

      3.

      54.6 hours vs.

      42.3 hours

      NIRPC Travel Demand Model

      4.

      55.4 hours vs.

      42.6 hours

      NIRPC Travel Demand Model

      5.

      1.5% increase in

      delay vs. 0.7% increase in delay

      NIRPC Travel Demand Model

      6.

      13.0% decrease in delay vs. 9.2% decrease in delay

      NIRPC Travel Demand Model


      Table 1 shows that nearly half of the Environmental Justice population in the Northwestern Indiana Region lives within fixed route transit service areas (performance measure #2). This is significantly higher than the just over one quarter of the regional population in general that lives within fixed route transit service areas, indicating that NIRPC is helping to administer federal transportation funding for fixed route transit in such a way that disproportionately benefits the Environmental Justice population. On the other hand, Table 1 shows that the average person traveling on the transportation network within an Environmental Justice Census Block Group experiences significantly more delay on weekdays over the course of the year than the average person traveling on the transportation network anywhere in the region (performance measures #3 and #4). At first glance, this would indicate that NIRPC administers federal transportation funding in such a way that burdens the Environmental Justice population. However, this is not a reasonable conclusion for a couple key reasons. First, as performance measure #6 shows, implementing the federally funded transportation projects in the year 2050 results in a greater reduction in delay for the transportation network within Environmental Justice Census Block Groups than the reduction in delay forecasted on the transportation network in general across the region versus a hypothetical year 2050 where no additional federally funded transportation projects are implemented. This means that NIRPC is in fact planning, programming, and implementing federally funded transportation projects in such a way that will benefit the

      Environmental Justice Census Block Groups more than will benefit the regional population in general. Second, the Environmental Justice Census Block Groups tend to be clustered closer to the Chicago Central Business District than the Northwestern Indiana Region in general, so a significant portion of the travelers on the transportation network within Environmental Justice Census Block Groups are likely travelers originating from non-Environmental Justice Census Block Groups commuting to and from Chicago. This means that it is primarily the geographic location of the Environmental Justice Census Block Groups that is causing more delay rather than the result of planning, programming, or implementing federally funded transportation projects.


      NIRPC is committed to continuously monitoring the performance measures in Table 1 in addition to the 98 performance measures found in the NWI 2050 Plan in order to ensure that the Environmental Justice population is not unduly burdened by decisions related to federal transportation funding. Based on the most current analysis of the performance measures, NIRPC finds no evidence that planning, programming, or implementing federally funded transportation projects in the Northwestern Indiana Region is disproportionately burdening the Environmental Justice population.


      Description of Procedures Within Planning Process

      A five-year Transportation Improvement Program (TIP) for 2020-2024 has been developed in tandem with the NWI 2050 Plan. The TIP represents the fiscally-constrained list of federally-aided transportation projects scheduled for implementation in Lake, Porter and LaPorte Counties and represents the short-range investment portfolio for this plan.


      Projects are solicited for the TIP by NIRPC every two years through a Notice of Funding Availability (NOFA). Previous NOFA cycles were periodic and unpredictable, focusing on a specific funding category and selected independently of other funding avenues. Although somewhat straightforward in approach, this process did not link programs fully with the regional priorities highlighted in previous long-range plans.


      To effectively match funding with priorities, better identify desired outcomes, and quantify performance benefits, an enhanced programming approach was needed. This approach was introduced and implemented during the latest NOFA cycle from September 2018 to January of 2019. The enhanced approach first identified specific investment programs based on the 77 project types that are federally eligible for funding from FHWA and FTA funds. This exercise represented the first time all federal transportation funding categories allocated to NWI were considered during a single NOFA cycle. Based on the type of eligible projects, thirteen investment programs were identified, and applications for funding were developed accordingly.


      These thirteen programs were then assigned to one of the five NIRPC committees in place at the time of this document, using a 1-100 scoring system. The committees scored project types from assigned programs according to their direct and indirect impacts on each of the sixteen critical paths identified in the plan. This represented 80% of the final score. Additional scoring was assigned for the project type’s direct and indirect impact on the “possible futures” identified in the NWI 2050 Plan, (12% of its final score) and an investment difficulty factor (8% of its final score). The easier a project type was to implement, the higher its priority. From this robust exercise, each project type targeted a logical funding amount based on a three-tiered priority system. Those projects selected in Tier 1 were given priority in their assigned program category, and thus received the most allocated funding. For the 2020- 2024 TIP NOFA process, almost all Tier 1 projects were targeted for funding and 35% of Tier 2 projects were targeted for funding when the NOFA was initiated. Due to limited funds no Tier 3 projects were targeted for federal

      funds as part of this NOFA. However, some legacy projects with preconstruction phases included in the prior TIP were prioritized for continued funding to see those projects through to completion. Funding to sustain our existing transportation system (such as improvements to roadways) was heavily weighted within this new approach.


      With the funding targets established, NIPRC committees were then charged with assigning project selection criteria for each program. These criteria were divided between nine categories, and these categories assigned a point value based on the importance to the program. All program categories equaled 100 points.


      With the funding targets and evaluation criteria established, the NOFA was published following Executive Board approval sought at the November, 2018 meeting. Applications tailored to the thirteen funding programs were offered, and even if funding was not available or targeted to all programs, all project types remained eligible for federal funding, and such applications were considered if funds remained available. Each application was self- scored by the applicant, reviewed by NIRPC staff for proper adherence to the instructions, and then scored by NIRPC staff. The NIRPC committees resolved any outstanding conflicts between the self-score of the project applicant and score given to the application by NIRPC staff.


      The majority of the thirteen investment programs are not relevant to this document. However, all road-type projects and transit projects used improvements to the urban core communities as an indicator of a viable project. These urban core communities are where the highest concentrations of people who are considered minorities, low-income, or have limited-English proficiency are concentrated. By proving that a project would have a benefit to the people living in these areas, a project could receive priority for funding.

      Demographic Maps Showing Impacts of State and Federal Funds

      image

      Transit Operator Service Areas (NIRPC Subrecipients) Figure 4: Fixed Route Transit Operators in Northwest Indiana

      Figure 5: Demand Response Transit Operators in Northwest Indiana


      image


      image

      21 | P ag e

      Table 5: Transit Operator Funding and Estimated Expenditures by Minority/Non-Minority Population


      Population Within Service Area

      Federal Funds Awarded (Dollars)

      Funding by Minority Status within Service Area

      Transit Operator

      Total Population

      Non- Minority

      Minority

      % Minority

      2017

      2018

      2019

      Total

      Total Population Per Capita

      Non-Minority Funding Totals

      Minority Funding Totals

      East Chicago Transit

      95,699

      29,045

      66,654

      69.65%

      686,524

      743,766

      347,507

      1,777,797

      18.58

      539,567.96

      1,238,229.04

      North Township DAR

      157,356

      70,464

      86,892

      55.22%

      588,578

      484,784

      192,812

      1,266,174

      8.05

      566,992.58

      699,181.42

      SLCCS

      253,922

      186,673

      67,249

      26.48%

      343,999

      392,000

      356,584

      1,092,583

      4.30

      803,222.04

      289,360.96

      OE

      248,483

      187,711

      60,772

      24.46%

      108,374

      111,551

      105,972

      325,897

      1.31

      246,191.70

      79,705.30

      PCACS

      167,391

      140,547

      26,844

      16.04%

      196,106

      212,849

      150,637

      559,592

      3.34

      469,851.88

      89,740.12

      Valparaiso Transit

      50,700

      44,523

      6,177

      12.18%

      493,757

      518,778

      550,169

      1,562,704

      30.82

      1,372,313.02

      190,390.98

      TransPorte

      8,048

      6,415

      1,633

      20.29%

      222,136

      236,527

      254,838

      713,501

      88.66

      568,726.26

      144,774.74

      All NIRPC

      Subs:

      981,599

      665,378

      316,221

      32.21%

      2,639,474

      2,700,255

      1,958,519

      7,298,248

      7.44

      4,566,865.44

      2,731,382.56

      NICTD

      766,924

      495,349

      271,575

      35.41%

      34,820,839

      37,645,121

      40,643,321

      113,109,280

      147.48

      73,056,220.51

      40,053,059.73

      GPTC

      223,844

      65,260

      158,584

      70.85%

      4,002,485

      4,331,808

      4,302,543

      12,636,836

      56.45

      3,684,172.54

      8,952,663.46

      Michigan City Transit / Transit Triangle

      36,081

      22,611

      13,470

      37.33%

      1,232,304

      1,503,888

      1,513,065

      4,249,257

      117.77

      2,662,895.98

      1,586,361.02

      Non-NIRPC

      Direct Recipient:

      1,026,849

      583,220

      443,629

      43.20%

      40,055,628

      43,480,817

      46,458,929

      129,995,373

      126.60

      79,403,289.03

      50,592,084.21

      All Transit Operators:

      2,008,448

      1,248,598

      759,850

      37.83%

      42,695,102

      46,181,072

      48,417,448

      137,293,621

      68.36

      83,970,154

      53,323,467



      image

      22 | P ag e



      Ratio of Funding by Minority Population

      Non-Minority

      Minority

      Subrecipient Ratio of Non-Minority / Minority Funding:

      $7

      $9

      Direct Recipient Ratio of Non-Minority

      / Minority Funding:

      $68

      $57

      Reginal Ratio of Non-Minority / Minority Funding:

      $67

      $70



      The following transit service area maps demonstrate a clear commitment to providing transit to populations considered to be a minority, low-income, or limited-English proficiency.


      As illustrated in the corresponding transit service area maps, the concentrations of people who are considered to be a minority, low income, or limited-English proficiency are a priority for regional transit service. Most of these communities, with some exceptions, are serviced by fixed-route transit: either as an inter-city commuter service with connections to Chicago, or as typical fixed-route with complementary paratransit as seen in East Chicago, Gary, Hammond, Merrillville, and Michigan City. Broader swaths of the Region are covered and connected by demand- response transit operators. With some exceptions, demand-response operators in Northwestern Indiana primarily serve to connect rural communities with each other and with the urban communities as well. Additionally, when the maps and service areas are paired with demographic data it’s clear that NIRPC’s distribution of transit funds (to service areas that directly serve the highest concentrations of people who are minorities or low-income), that even within those service areas transit funding for people who are minorities or low-low income is out-pacing funding for those who are not. Currently people who are a minority within the service area are being funded at a $9 to $7 ratio; and people who are low income are being funded at an $11 to $9 ratio.


      Analysis of Transportation System Investments

      From the previously demonstrated mapping and funding analyses, there are no disparate impacts based on race, color, or national origin.


      The attached maps indicate a clear concentration of service in the urban core areas where most of the people considered to be minorities, people who are low income, and people with limited-English proficiency live.

      Additionally, when those service areas are matched with an analysis of how federal funds were spent between 2017

      - 2019, NIRPC and its subrecipients spent $11 on individuals who are low income, as compared to the $9 spent to people in the service area who are not low income. Additionally, looking at the population of people who are considered to be in the minority, for every $9 spent on a minority-resident of the service area, NIRPC only spent $11 on every non-minority.



      image

      A description of the procedures the MPO uses to pass through FTA financial assistance to subrecipients in a non-discriminatory manner.

      NIRPC serves as both the MPO and the direct recipient for seven transit subrecipients of federal transit funding. While NIRPC has some oversight in how projects are selected, and how the service is administered, NIRPC does and does not operate public transit nor make requirements of subrecipients day-to-day operations outside of what is specifically-required by FTA.


      All transit operators (the seven NIRPC subrecipients and three direct recipients), participate in the development of NIRPC plans, policies and procedures. First and foremost, all transit operators have a technical working group that reports to the Technical Planning Committee: The Transit Operator’s Roundtable. The Roundtable provides valuable insight on transit issues related to funding, coordination, technical capacity, public outreach, and other topics to members of the committee and to the Technical Planning Committee directly. During the development of planning documents required by the MPO, such as the long-range plan, TIP, or public participation plan, input is sought directly from the transit operators. Furthermore, transit operators are required to be six of the 20 voting-members of the Technical Planning Committee. This way transit operators have direct input into nearly any planning work related to NIRPC, but specifically related to funding from FTA.


      Even after providing input into the planning process of the long-range plan and the TIP, subrecipients are still required to submit projects into the NOFA. This helps maintain an objective set of transit programming by ranking projects of similar types against each other with criteria like how the service connects individuals to jobs, important destinations, but most importantly how it connects to communities of people considered to be minorities, low income, and with limited-English proficiency. The details of how projects are scored and how the public is involved throughout the process is detailed earlier, in the “Description of Procedures Within Planning Process.” All new projects and project- changes of $100,000 or greater function as a TIP amendment and are subject to a 21-day public comment period where the public or other transit operators can comment on the nature of the project and flag it if it is perceived to be discriminatory. These comments are packaged and prepared ahead of any TIP amendment before Commission approval finalizes the changes.


      A description of the procedures the MPO uses to provide assistance to potential subrecipients applying for funding, including its efforts to assist applicants that would serve predominantly minority populations.

      NIRPC is both the MPO and the direct recipient and does not operate public transit. Procedurally, NIRPC includes all known private providers of transit in the distribution of the TIP call for projects. The solicitation notes the need to establish eligibility for non-public operators as a condition of participation in the grant process. The solicitation is distributed to the four major daily papers, multiple radio stations, and posted on NIRPC’s website and Facebook page. Three of the major daily papers serve areas with concentrations of minority and low-income persons.


      When an inquiry is received about accessing federal transit funds, an opportunity to meet with staff is always offered, regardless of where the service may be provided. Staff reviews the proposed services based on project eligibility, financial capacity of operator, and long-term sustainability of the service.


      The first meeting is to exchange information about the proposed service, and about the federal funding programs. If a potential provider has prepared documents (usually a business plan) the staff will review them with the provider. Staff provides information on FTA, its funding opportunities, and oversight requirements. If appropriate, staff will recommend contacting a specific public operator to determine

      image

      partnership opportunities, particularly in areas underserved by existing transit. Staff will help identify project weaknesses and recommend solutions, if possible.


      Follow-up meetings and inspection of facilities are scheduled if the proposed service is found eligible and the operator is interested in proceeding. More detailed information on the operator’s past experience and financial capacity to manage federal funds is generally the subject of the first follow-up meeting. Staff will maintain close contact with the operator for as long as the operator wishes to pursue a grant. Staff will continue to provide technical assistance as needed as is done for all of the transit operators in the MPO planning area.

      Part III. NIRPC Recertification Attachments


      Attachment #1: NIRPC’s Title VI Complaint Procedures Attachment #2: Limited English Proficiency Strategy

      Attachment #3: 2010 Limited English Proficiency Demographic Profile Attachment #4: Minority & Low-Income Population Distribution Maps Attachment #5: Minority & Low-Income Population Distribution Chart

      Attachment #1: NIRPC’s Title VI Complaint Procedures

      NIRPC Procedures for Tracking and Investigating Civil Rights Complaints


      Title VI of the Civil Rights Act of 1964, as amended, prohibits discrimination on the basis of race, color, or national origin in programs and services funded, in whole or part, by financial assistance from the United States Government. NIRPC extends this prohibition to individuals on the basis of disability, religion and gender. Section 504 of the Rehabilitation Act of 1973 (Section 504) and the Americans with Disabilities Act (ADA) prohibit discrimination on the basis of disability.


      All services and programs operated or sponsored by the Northwestern Indiana Regional Planning Commission, 6100 Southport Road, Portage, Indiana, 46368 are subject to the requirements and obligations of Title VI, Section 504 and the ADA. It is the intention of the Northwestern Indiana Regional Planning Commission (NIRPC) to comply fully with Title VI, Section 504 and the ADA.


      Under the provisions of Title VI, Section 504 and the ADA, persons who believe that they have experienced or witnessed any act or inaction, intentional or otherwise, in any program, service, or activity operated by or sponsored by the NIRPC that results in or may result in disparate treatment or impact, or perpetuates the effects of prior discrimination on the basis of race, color, national origin, gender, religion, or disability may file a written complaint with the NIRPC or directly with the U.S. Federal Transit Administration (FTA), the Federal Highway Administration (FHWA), or the Indiana Department of Transportation (INDOT).


      Complaints filed directly with FTA must be mailed within 180 days of any alleged discrimination. Complaints should be mailed to:


      Federal Transit Administration Office of Civil Rights Attention Title VI Program Coordinator

      East Building, 5th Floor – TCR 1200 New Jersey Ave., SE Washington, D. C, 20590


      Complaints filed directly with FHWA must be mailed within 180 days of any alleged discrimination. Complaints should be mailed to:


      Federal Highway Administration Office of Civil Rights Attention: Title VI Program Coordinator

      1200 New Jersey Ave. SE Washington, D.C. 20590


      Complaints filed directly with INDOT must be mailed within 180 days of any alleged discrimination. Complaints should be mailed to:


      Indiana Department of Transportation Attention Title VI Program Coordinator 100 N. Senate Ave. Room 750

      Indianapolis, Indiana 46204

      Or via the INDOT website at: http://www.in.gov/indot/div/legal/dbe/titlesix.htm#complaints


      How to File a Complaint to NIRPC


      A person with a Title VI or ADA complaint may also submit the complaint to NIRPC using the following procedures:


      1. A complaint may be submitted in writing and must include the person’s name and contact information, the date of the incident, and the identity of the person or department or service that caused the complaint. Complaints may be sent via mail, email, fax, or hand delivered and shall be addressed to the NIRPC Compliance Manager 6100 Southport Road, Portage, IN 46368. ahammond@nirpc.org


      2. A complaint may be taken verbally and must include the person’s name and contact information, the date of the incident, and the identity of the person, department or service that caused the complaint.


      3. Persons with a complaint may request a neutral third party to hear a verbal complaint or assist with a written complaint. The selection of the neutral third party shall be made cooperatively between NIRPC and the person filing the complaint.


      4. All complaints shall be addressed to the NIRPC Compliance Manager.


      NIRPC Complaint Procedure


      1. The person filing a complaint on the basis of discrimination based on race, color, gender, religion, national origin or disability will be informed that the complaint may be either filed directly with the FTA, FHWA, INDOT or with NIRPC. It shall be the responsibility of the Compliance Manager of NIRPC, or his designee, to track, investigate and document Title VI, Section 504, and ADA complaints.


      2. If the person opts to file the complaint with NIRPC, the complaint will be directed by the Compliance Manager to the appropriate department manager for a fact-finding review. The manager will prepare a written response to the complaint and submit it to the NIRPC Compliance Manager.


      3. If the NIRPC Compliance Manager determines that the fact-finding review substantiated the complaint, he shall report the same to the NIRPC Executive Director, who will order, or authorize the Compliance Manager to order, corrective action be taken as warranted.


      4. The person who filed the complaint will be consulted as to the adequacy of the proposed remedy. If acceptable, the matter is concluded.


      5. If the proposed remedy is not acceptable, the person who filed the complaint may appeal and request a hearing with the NIRPC Finance and Personnel Committee for purposes of stating their complaint and identifying an appropriate remedy.

      6. The Finance and Personnel Committee will issue a response and recommend a remedy within ten days of the hearing.


      7. If acceptable, the matter is concluded. If not, the person is again advised of the appropriate steps to appeal the complaint with the FTA, FHWA or INDOT.


      8. The NIRPC Compliance Manager shall maintain the files and records of the NIRPC relating to the complaints filed verbal and written for a period of three years.


      Requests for this document in alternate format or assistance in preparing a complaint may be directed to NIRPC staff Allen Hammond at ahammond@nirpc.org, or by phone at 219-254-2500. TTY users may utilize the Relay Indiana Service by calling 711 or (800) 743-3333.

      CONFIDENTIAL


      The Northwestern Indiana Regional Planning Commission

      COMPLAINT FORM

      All written complaints about any matter relating to civil rights, shall be submitted on this form. NIRPC will assist those who submit verbal complaints to transfer these complaints onto this written form. You are required to complete all sections. Before completing this form, please ensure that you have read NIRPC’s Procedures for Tracking and Investigating Civil Rights Complaints. You should expect an acknowledgement within 10 working days and will be informed of the outcome of your complaint within 90 days, unless NIRPC notifies you that the investigation will need additional time.

      This form should be sent to the Compliance Manager of the Northwestern Indiana Regional Planning Commission

      Please keep a copy of this form for your records, plus any material you submit.


      SECTION A - YOUR DETAILS



      Title ..….… Name(s).………………………………………..….. Address

      ..………………………………………………………………………………………………… City …………………………………….……State…………. Zip …………………… Telephone Number ……………………………………


      Title ..….… Name(s).………………………………………..….. Address

      ..………………………………………………………………………………………………… City …………………………………….……State…………. Zip …………………… Telephone Number ……………………………………

      SECTION B – NATURE OF THE COMPLAINT

      Please set out below the main points of your complaint.



      Use additional sheets if necessary.


      Use additional sheets if necessary.

      PLEASE LIST ANY DOCUMENTARY EVIDENCE ATTACHED AND MAKE SURE YOU KEEP A COPY.

      (E.g., any correspondence, list of dates when events occurred, or other documentation related to your complaint)

      image


      SECTION C - AN OUTLINE OF THE ACTION YOU HAVE TAKEN SO FAR

      Please outline the steps you have already taken to resolve your complaint informally:

      With whom was it discussed? …………………………………………………..….……….. Date ..………………………

      Position ………………………………………………………………………………………………….. Department(s) …………………………………………………...…………………………………………………

      With whom was it discussed? …………………………………………………..….……….. Date ..………………………

      Position ………………………………………………………………………………………………….. Department(s) …………………………………………………...…………………………………………………


      Describe the outcome of any action taken so far and explain why you believe that the matter has not yet been resolved.

      image


      SECTION D - DESIRED OUTCOME

      Please describe the action you would like to see taken in order to resolve the complaint to your satisfaction.

      image


      SECTION E – DECLARATION

      I believe that the above information is accurate. I confirm that details of this complaint can be passed on to the NIRPC Finance and Personnel Committee for appeal (if applicable).


      Signature: …………………………………………………………………. Name ……………………………………………………………………… Contact Information ……………………………………………………… Date: ...…………………………………………


      FOR OFFICE USE ONLY:


      Acknowledgement sent …………………………..…………………… Reply sent ………………………………………


      Complaint forwarded to department …………………………… Response received ………………………….

      What action (if any) is now needed?

      ………………………………………………………………………………………..


      ………………………………………………………………………………………..

      FOR OFFICE USE ONLY:


      Acknowledgement sent …………………………..…………………… Reply sent ………………………………………


      Complaint forwarded to department …………………………… Response received ………………………….

      What action (if any) is now needed?

      ………………………………………………………………………………………..


      ………………………………………………………………………………………..

      Attachment #2: Limited English Proficiency Strategy


      Northwestern Indiana Regional Planning Commission Lake, Porter, and LaPorte Counties, Indiana

      Northwestern Indiana Regional Planning Commission (NIRPC) receives federal financial assistance from the US Department of Transportation (US DOT). For this reason, it is subject to the US DOT’s Limited English Proficiency Guidance, issued on December 14, 2005. NIRPC has prepared a Limited English Proficiency (LEP) strategy, as well as completed the Four Factor Analysis suggested in the guidance.


      NIRPC offers services to outside entities that include: 1) Transportation Planning & Technical Assistance; 2) Public Transit Grants Management, Oversight, Procurement, and Technical Assistance; and 3) Environmental Public Education. NIRPC also passes FTA public transit funds through to seven

  6. public transit operators in Lake, Porter, and LaPorte Counties.


Pass-Through Public Transit Operators. The Public Transit Grants division, among other things, passes FTA funds through to seven (7) public transit operators in the three-county area. A separate LEP analysis was not prepared for these operators. The three operators serving identified LEP areas have long acknowledged the need for and developed second language schedules and rider guides, and other service information. These operators include East Chicago Transit, North Township Dial-a-Ride and City of La Porte Transporte.


Demographic Data. Demographic data for northwest Indiana shows a significant concentration of Limited English Proficiency (LEP) persons in ten census tracts in northern Lake County. One of these is in Gary (Indiana), which is outside of the area covered by NIRPC’s transit subrecipients but within the area of our other services (Planning and Environmental Education).


The Four Factor Analysis.


Number or proportion of LEP persons eligible to be served or likely to be served or encountered by a program, activity, or service.


Transportation Planning & Technical Assistance: Fewer than 10 persons per year.


Persons served or encountered under these programs on a regular (ongoing) basis are those regular participants in the metropolitan transportation planning process, representatives of cities, towns, and counties, and technical personnel, including engineers and federal/state transportation officials.

Persons served or encountered on a sporadic basis are members of the general public who are asked to serve on planning focus groups to comment on transportation plans and projects. These are usually one-time only encounters.


Public Transit Grants Management, Oversight, Procurement, and Technical Assistance: Fewer than 10 persons per year.


Most encounters are the representatives of local transit operators, chief elected officials, and State/FTA officials.


Environmental Services: Over 500 persons per year (estimated)


Most encounters here are with the public at outreach events, which occur at public schools, county fairs, recycling events, and other sometimes unusual locations and venues.


Frequency with which LEP persons come in contact with the program. Transportation Planning and Technical Assistance: Low Frequency

The public is involved in the transportation planning process through purposeful, intentional interactions (such as open houses, focus groups, and other venues established with the intent of obtaining thoughts, ideas, comments, and suggestions regarding a vision of the future. These events are usually held in conjunction with a long-range transportation plan development (every four years) and transportation improvement program development (every two years).


There is also a Technical Planning Committee (TPC) that meets monthly at which topics of interest, including policy recommendations are considered & recommended for approval by the NIRPC Board.


Public Transit Grants Management, Oversight, Procurement, and Technical Assistance: Low Frequency This function within NIRPC is responsible for all post-grant activities associated with FTA grants.

Environmental Services: Moderate Frequency


This division of NIRPC previously operated an air quality public education program funded with FHWA Congestion Mitigation/Air Quality Program funds. There was significant interaction with school-age children, environmental organizations, public officials, and community groups on an ongoing basis.


The nature and importance of the program, activity, or service provided by the recipient to people’s lives.


All Services: Very Low to Low

NIRPC’s services to the public are neither life-sustaining nor critical to the daily needs of people. Transportation planning, transit grant administration, transit subrecipient oversight/procurement, and environmental education are not quite as significant in comparison to the need for food, human services, medical services, transportation, and other similar, life-sustaining services.


The resources available to the recipient and costs.


The cost of developing written materials in multiple languages has not been explored. However, given the low encounter rates discussed earlier, it is likely that a large-scale production of written documents, such as transportation plans, transportation improvement programs, and air quality conformity determinations within the metropolitan planning division would be expensive. In these instances, the cost of translating these documents would likely not be cost-effective.


The environmental education program does not generate any significant planning studies and related documents. It already produces some Spanish-language materials that are intended for direct distribution to the public in northern Lake County.


Planning funds are utilized for document translations. Conclusion.

The low number of LEP persons accessing services in the past, the low frequency at which LEP persons encounter NIRPC’s services, and the insignificant value of our services to the daily lives of people all seem to indicate that only very limited measures are needed to address needs of the LEP (primarily Spanish-speaking) population. Although the needs are limited based on the four-factor analysis, NIRPC accommodates LEP persons as a part of the planning process by translating documents, and hiring translators for outreach events.


The NIRPC website can be translated into Arabic, Chinese, French, German, Greek, Hindi, Italian, Korean, Macedonian, Polish, Portuguese, Russian, Serbian, Spanish and Thai using the “Translate This Page” option available on the NIRPC website.


Regarding metropolitan planning, when NIRPC communicates with the public regarding an opportunity for anyone to participate in, comment on, or provide input to, some effort is needed to communicate with LEP persons so that their thoughts, concerns, and suggestions may be heard and understood.


Upon-request, up to 72 hours before a transportation outreach event, per the requirements of Engage NWI, NIRPC’s Public Participation Plan accommodations for LEP persons can be made. As a part of NIRPC’s LEP strategy, prior to outreach events, NIRPC has documents translated into Spanish as well as a Spanish translator available to attend outreach events to translate comments.


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    Title VI Program 2020

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    There is no need for grant administration, oversight, and procurement program-related materials to be translated.


    The number of encounters with LEP populations is higher in the environmental department than other NIRPC divisions. There is a need for bilingual environmental education materials in locations where there is a significant Spanish-speaking population. Due to this, the Environmental Division has and will continue to translate core educational materials into Spanish and distribute these materials in these areas. Materials include an asthma awareness guide, a watershed protection booklet, and a Citizens Guide to the MS4 Program.


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Title VI Program 2020

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Attachment #3: Limited English Proficiency by Census Tract – Demographic Profile


Municipality

Population 5 years and over

Speak English only or speak English "very well"

Percent speak English only or speak English "very well"

Speak English less than "very well"

Percent speak English less than "very well"

Beverly Shores

612

588

96.1%

24

3.9%

Burns Harbor

1,352

1,337

98.9%

15

1.1%

Cedar Lake

11,291

11,199

99.2%

92

0.8%

Chesterton

13,466

13,394

99.5%

72

0.5%

Crown Point

27,297

26,286

96.3%

1,011

3.7%

Dune Acres

169

169

100.0%

-

0.0%

Dyer

15,278

14,901

97.5%

377

2.5%

East Chicago

26,465

21,906

82.8%

4,559

17.2%

Gary

71,704

70,876

98.8%

828

1.2%

Griffith

15,234

14,795

97.1%

439

2.9%

Hammond

72,333

65,278

90.2%

7,055

9.8%

Hebron

3,745

3,730

99.6%

15

0.4%

Highland

21,814

21,050

96.5%

764

3.5%

Hobart

26,709

26,199

98.1%

510

1.9%

Kingsbury

193

188

97.4%

5

2.6%

Kingsford Heights

1,241

1,229

99.0%

12

1.0%

Kouts

1,796

1,768

98.4%

28

1.6%

La Crosse

530

530

100.0%

-

0.0%

Lake Station

11,431

10,828

94.7%

603

5.3%

La Porte

20,210

19,257

95.3%

953

4.7%

Long Beach

1,066

1,058

99.2%

8

0.8%

Lowell

8,770

8,632

98.4%

138

1.6%

Merrillville

33,621

32,534

96.8%

1,087

3.2%

Michiana Shores

253

253

100.0%

-

0.0%

Michigan City

29,050

28,552

98.3%

498

1.7%

Munster

21,984

20,666

94.0%

1,318

6.0%

New Chicago

1,678

1,484

88.4%

194

11.6%

Ogden Dunes

1,146

1,130

98.6%

16

1.4%

Portage

34,780

33,926

97.5%

854

2.5%

Porter

4,494

4,404

98.0%

90

2.0%

Pottawattamie Park

245

245

100.0%

-

0.0%

St. John

15,683

15,339

97.8%

344

2.2%

Schererville

27,406

25,891

94.5%

1,515

5.5%

Schneider

227

227

100.0%

-

0.0%

Town of Pines

693

679

98.0%

14

2.0%

Trail Creek

1,873

1,848

98.7%

25

1.3%

Valparaiso

30,727

29,955

97.5%

772

2.5%

Wanatah

1,143

1,139

99.7%

4

0.3%

Westville

6,472

6,452

99.7%

20

0.3%

Whiting

4,462

4,143

92.9%

319

7.1%

Winfield

5,181

5,117

98.8%

64

1.2%

Source: U.S. Census Bureau, 2013-2017 American Community Survey (Table S1601)


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Attachment #4: Minority and Low-Income Population Distribution Map


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Attachment #5: Minority and Low-Income Population Distribution Chart

Minority and Low-Income Populations by Census Tract


Municipality

Total:

Minority

Percent Minority

Beverly Shores

614

23

3.7%

Burns Harbor

1,452

210

14.5%

Cedar Lake

12,024

1,024

8.5%

Chesterton

14,052

1,725

12.3%

Crown Point

28,952

5,144

17.8%

Dune Acres

173

4

2.3%

Dyer

16,077

3,271

20.3%

East Chicago

28,728

26,857

93.5%

Gary

77,416

68,289

88.2%

Griffith

16,468

5,432

33.0%

Hammond

77,827

47,260

60.7%

Hebron

3,968

667

16.8%

Highland

22,938

5,332

23.2%

Hobart

28,573

6,358

22.3%

Kingsbury

205

15

7.3%

Kingsford Heights

1,370

217

15.8%

Kouts

1,950

77

3.9%

La Crosse

552

13

2.4%

Lake Station

12,157

4,799

39.5%

La Porte

21,825

3,805

17.4%

Long Beach

1,126

42

3.7%

Lowell

9,502

785

8.3%

Merrillville

35,183

22,523

64.0%

Michiana Shores

262

2

0.8%

Michigan City

31,352

12,579

40.1%

Munster

23,005

5,425

23.6%


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New Chicago

1,803

770

42.7%

Ogden Dunes

1,195

80

6.7%

Portage

36,849

11,359

30.8%

Porter

4,855

696

14.3%

Pottawattamie Park

262

12

4.6%

St. John

16,391

2,089

12.7%

Schererville

28,778

6,513

22.6%

Schneider

249

7

2.8%

Town of Pines

731

91

12.4%

Trail Creek

2,000

354

17.7%

Valparaiso

32,501

4,412

13.6%

Wanatah

1,234

138

11.2%

Westville

6,659

2,169

32.6%

Whiting

4,858

2,018

41.5%

Winfield

5,395

1,555

28.8%

Municipal

446,324

215,451

48.3%

Municipal

66,847

19,346

28.9%

Municipal

98,340

19,344

19.7%

Unincorporated

42,370

6,979

16.5%

Unincorporated

43,992

2,955

6.7%

Unincorporated

69,051

7,500

10.9%


Municipality

Total (for whom poverty status is determined)

Below poverty level

Percent below poverty level

Beverly Shores

614

23

3.7%

Burns Harbor

1445

125

8.7%

Cedar Lake

12008

1183

9.9%

Chesterton

13875

1121

8.1%

Crown Point

27536

2142

7.8%

Dune Acres

173

5

2.9%

Dyer

15741

563

3.6%

East Chicago

28580

9876

34.6%

Gary

76469

27344

35.8%

Griffith

16445

1466

8.9%

Hammond

76723

17021

22.2%

Hebron

3968

688

17.3%

Highland

22841

1749

7.7%

Hobart

28290

3129

11.1%

Kingsbury

205

4

2.0%

Kingsford Heights

1349

343

25.4%

Kouts

1947

108

5.5%

La Crosse

549

80

14.6%

Lake Station

12130

3079

25.4%

La Porte

21035

4716

22.4%

Long Beach

1126

28

2.5%

Lowell

9394

851

9.1%

Merrillville

34693

3789

10.9%

Michiana Shores

262

23

8.8%

Michigan City

28337

7219

25.5%

Munster

22592

1079

4.8%

New Chicago

1801

499

27.7%

Ogden Dunes

1195

44

3.7%

Portage

36469

6266

17.2%

Porter

4855

411

8.5%

Pottawattamie Park

262

15

5.7%

St. John

16382

522

3.2%

Schererville

28542

1280

4.5%

Schneider

249

55

22.1%

Town of Pines

729

141

19.3%

Trail Creek

1989

159

8.0%

Valparaiso City

29294

3976

13.6%

Wanatah

1234

114

9.2%

Westville

2012

520

25.8%

Whiting

4852

789

16.3%

Winfield

5227

114

2.2%

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Engage NWI


Northwestern Indiana Regional Planning Commission’s Public Participation Plan – Adopted August 15, 2019 by Resolution 19-24



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About Engage NWI

Engage NWI is the federally required “Public Participation Plan” that enables Northwestern Indiana Regional Planning Commission (NIRPC) staff to ensure that it is meeting all federal requirements for public participation, but more importantly, a guide that enables the public to engage with regional planning. Engage NWI promotes a meaningful exchange of ideas, identification of regional issues and solutions, as well as advancing initiatives to achieve the vision for Northwestern Indiana (NWI).


The Northwestern Indiana Regional Planning Commission (NIRPC), as the Metropolitan Planning Organization (MPO) and Council of Governments (COG) for NWI, has the responsibility to conduct economic development, environmental, and transportation planning for Lake, LaPorte and Porter Counties. Engage NWI is required of a Metropolitan Planning Organization (MPO) by the United States Department of Transportation (USDOT) to fulfill the regulations governing public participation (23 CFR 450.316).


Engage NWI is laid out in a question and answer format to assist NWI’s general public and stakeholders, and NIRPC’s regional planners to understand:

How the general public and stakeholders can most effectively connect with regional planning – Page 3

What is regional planning? Page 4-5

When/where is the public engaged in regional planning? Page 6-7

Why is public participation important to regional planning? Page 7-8

Who is and should be involved in public participation? Page 8-10

How is public participation conducted? Page 11-13

The technical requirements of public participation Page 14-16


How to follow regional planning activities and find participation opportunities:

How to follow regional planning activities and find participation opportunities:

Website: nirpc.org

Sign-up for emails and newsletters here

Follow our calendar for events and meetings

Find NIRPC’s latest plans and updates

YouTube: youtube.com/user/NIRPCPlanning

For livestreamed Commission and Committee meetings if you cannot or do not want to attend in-person

Facebook: facebook.com/nirpcmpo

Like NIRPC’s Facebook page to follow planning activities and learn about engagement opportunities.

Twitter: twitter.com/NIRPC

Follow NIRPC’s Twitter feed to hear the latest news and learn about engagement opportunities.

Instagram: instagram.com/regionMPO

Follow NIRPC’s Instagram page to see what is going on in the region and learn about NIRPC’s work.

LinkedIn: linkedin.com/company/nirpc

Connect with NIRPC’s LinkedIn page to learn about NIRPC’s work and other planning partners.

RTIP: https://rtip.nirpc.org/

The Regional Transportation Improvement Program is NIRPC’s online database of funded transportation investments throughout the region. Amendments are posted on RTIP when available for public comment.

Direct mail:

To be added to our direct mail list, please send a request for newsletters: Public Participation Planner

6100 Southport Road

Portage, IN 46368


What is regional planning?

Regional planning in NWI is conducted by NIRPC regional planners. NIRPC is charged in state law to focus on economic development, the environment, and transportation planning. NIRPC provides a regional forum to discuss issues, opportunities, problems, challenges, and concerns of member communities, the general public, and stakeholders. Regional planners work planning initiatives each year that will hopefully advance NWI towards achieving the visions laid out in the adopted long-range plan of the Commission, the NWI 2050 Plan.


It is important to note that while regional planners may provide guidance on best practices, policy, zoning, transportation investments, economic development, or the environment, they do not make or enforce local ordinances or policies, as NIRPC is not charged with this mandate, nor given authority to do so, in state or federal law. In order to affect change locally, participation efforts by the general public and stakeholders must be geared towards local, state or federal government. Regional planners often may not lobby under federal law, rather may only educate or guide elected officials.


For regional transportation planning, NIRPC must follow the federally required “3C" transportation planning process. The “3C” transportation planning process requires cooperation among all levels of government, comprehensive consideration of many planning factors, and be a continuously evaluated planning process. Planning is carried out following contemporary federal transportation planning requirements of the Fixing America’s Surface Transportation Act (FAST Act), the Americans with Disabilities (ADA) Act, Section 504 of the Rehabilitation Act, Environmental Justice Executive Order 12898, Persons with Limited English Proficiency Executive Order 13166, the Clean Air Act, Title VI of the Civil Rights Act, and their predecessor acts. Engage NWI reflects all such requirements, especially those of 23 CFR 450.316, the regulation that governs public participation.

Regional planners at NIRPC are responsible for the following:

Regional planners at NIRPC are responsible for the following:


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Economic development, environmental, and transportation planning


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Technical assistance on planning best practices, and governance


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Providing a forum for regional issues identification and problem solving


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Facilitation of the prioritization of transportation investments for NWI


Public participation and transit

Public participation and transit

Transit is an important travel option for many residents in the region, and many instances the only travel option for some residents. Transit in NWI consistently is rated by the public as a primary concern for our regional transportation system. The NWI 2050 Plan and the 2018 Coordinated Transit Plan demonstrate those issues and concerns.


The Federal Transit Administration allows a transit operator to rely on the MPO’s Public Participation Plan for the Transportation Improvement Program. For transit operators to be compliant with Federal “Program of Projects” requirements, transit operators may utilize the public participation efforts of regional planners. Projects need to be published in sufficient detail, and the users of these projects should be provided an opportunity to examine the proposed program and submit comments. Transit Operators therefore must assist NIRPC with public participation efforts, including advertising and inviting the public to engagement opportunities.


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When/where is the public engaged in regional planning?

There are three core MPO planning documents out of which all other regional planning activities are derived:

Long-Range Plan (LRP) – The LRP sets the vision for NWI and focuses on economic development, the environment, and transportation. The LRP is updated every four years and is amended from time to time. The development of the MTP takes approximately one to two years and engagement opportunities are provided throughout its development to shape the vision, goals, and priorities of the Plan.

Transportation Improvement Program (TIP) – The TIP is updated every two years and amended four times per year. The TIP includes transportation

investments for the next five years made by communities, transit operators, and the Indiana Department of Transportation. The development of the TIP involves all the towns, cities, counties, and transit operators of NWI and must be consistent with the NWI 2050 Plan. Direct engagement with municipalities and transit operators is the most effective way for the public to influence the projects each applicant submits to NIRPC for funding.

Unified Planning Work Program (UPWP) – The UPWP is updated every two years and amended in between generally once. The UPWP contains all the planning activities required by the Federal Highway and Transit Administrations in addition to planning activities identified by the NWI 2050 Plan. The planning tasks are conducted by the regional planners at NIRPC. Each UPWP task includes a public participation goal appropriate for the task: Inform, Consult, Involve, or Collaborate. See page 12 for details on goals.

Understanding the core planning activities of NIRPC will help to connect interested individuals on when and where to engage in regional planning.


Engage NWI emphasizes that for effective regional planning, engagement should occur where people are, and early in the process. Input will be solicited from the general public and stakeholders when active engagement methods are utilized (described on Page 13), close to where the general public are already gathering and while plans are in development so that input can shape the outcome which is deliberated at the Commission. Every attempt will be made to hold active engagement activities throughout the region, balanced where transit is available and for the rest of the region, through a variety of creative means while plans are in development. The Commission will determine where and when to hold its meetings and those of its advisory and business committees.


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Why is public participation critical to regional planning?

Engage NWI stresses the need for the general public and stakeholders to engage in regional planning to identify regional challenges, problems, and opportunities. Regional planners need to listen to voices of the general public and stakeholders to gain a diversity of input – especially from those traditionally underrepresented in planning processes – and hear potential solutions or to shape planning processes and achieve desired outcomes. The map on Page 9 represents the places in NWI that should be emphasized in engagement efforts. These places include higher than regionally average areas of minorities, low-income individuals, limited-English proficiency individuals, zero-car households, veterans, individuals over sixty-five years of age, and individuals with disabilities. Regional planners need input early in the process so that final plans can reflect a balance of priorities and interests heard from all over the NWI.


Engage NWI stresses the importance that additional effort be made to invite individuals that reside in such areas to participate in regional planning efforts to give voice to communities who have traditionally been under-represented.


Traditionally Underrepresented Populations

Traditionally Underrepresented Populations


Strategies to engage with emphasized places in NWI

Strategies to engage with emphasized places in NWI

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One-on-Ones – depending on the planning activity, regional planners may make face- to-face contact with community-based organizations, neighborhood leaders, faith- based organizations, elected officials, and other important stakeholders that can connect regional planners to residents and businesses that have been underrepresented in regional planning activities. Such interactions are called “Out and Abouts” in Engage NWI and are described on Page 13.

Targeted formal engagement – depending on the planning activity, regional planners may ensure that some of the formal meetings or “Pop-Up Events,” described on Page 13, are held in these emphasized places to make participation convenient, especially if community residents rely on limited public transit.


Who is and should be involved in public participation?

Engage NWI focuses upon “regional planners,” “the general public,” and “stakeholders” as three critical groups involved in public engagement. Each plays a unique and important role in the planning process. Regional planners at NIRPC seek to undertake various planning initiatives that need to be shaped by public input. The general public includes individuals and businesses that represent themselves in the planning process, while stakeholders represent “grouped” interests, needs, or desires in the outcome of a planning process. The perspectives, experience, and expertise from the general public, or stakeholders, is not only welcomed, but necessary in the planning process.


Shaped by their personal experiences, regional planners do not know and cannot see every detail of every issue in every community. Therefore, Engage NWI stresses the need for regional planners to listen to the general public and stakeholders as a duty, but also for the general public and stakeholders to share their perspectives, experiences, and expertise as regional citizens.


For Engage NWI to be effective, NIRPC, as the regional planners, will inform the general public and stakeholders of every opportunity to participate through the channels described on Page 3; however, the general public and stakeholders have the freedom to take advantage of the opportunity to play their part and actively engage in shaping their region.



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General public

The general public is made up of individuals who choose to participate in the planning process. Their perspectives and experiences help shape the priorities of planning initiatives.


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Regional planners

Regional planners include NIRPC staff, Commissioners, and NIRPC Committee members.

Regional planners are in the “middle” since they should listen and hear the general public and stakeholders, but are also entrusted to find a balance between the priorities heard from all who participated, while also meeting any required planning objectives.


Stakeholders

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Stakeholders represent many individuals as a group for one or many shared interests. Stakeholders play a vital role since they often speak for many individuals at once. Stakeholders may include advocacy organizations, community-based organizations, partners, and federal, state, and municipal governments.

About the regional planners - NIRPC

About the regional planners - NIRPC


Regional planning and coordination came to Northwestern Indiana in 1965 when enabling legislation was passed by the Indiana General Assembly and signed into law by the Governor. The first state law called for a transportation planning commission, which was inspired by the 1962 Federal Highway Act. The state law has since been amended to create what is known today as the Northwestern Indiana Regional Planning Commission, a three- county council of governments. In 2007, NIRPC’s Executive Board membership expanded, and weighted voting added.


NIRPC’s governing body is the Commission composed of 53 county, municipal, and some township elected officials and a Gubernatorial appointment. The Commission membership is established in state statute and is required to meet in full at least four times per year and at a minimum statutorily responsible for the hiring of the Executive Director, adopting bylaws, electing officers, and annual budget appropriations. A smaller Executive Board is annually elected by and from the full Commission membership and takes on the routine business of NIRPC. The Commission has established several committees to make advice and assist in conducting its business along with lower topical committees focused on specific interests.

Please check NIRPC.org for updates on the committee structure and membership.


All Commission and committee business related to transportation planning and investment decision-making must adhere to Engage NWI. Planning for economic development and the environment may adhere to Engage NWI or the specific requirements of grants funding those activities in question. Noticing for Commission and Committee meetings will follow Indiana Open Door Law.

Commission

Full Commission

Meets four times per year or

Executive Board

Meets approximately six times per year

Advisory / Business

Technical Planning

Local Government Assistance

Legislative

Finance and Personnel

Topical

Environmental Management and Policy

Ped, Pedal, and Paddle

Land Use

Surface Transportation

Transit Operators

Transportation Resources Oversight

Committees

Committees

Committees

Committees

Last revised February 2018 / Any future changes to committee structure made by the Commission will be reflected in Engage NWI as a technical amendment.

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How is public participation conducted?


Engage NWI lays out on Page 12 the engagement goals, the promise made by Engage NWI associated with that goal, engagement methods associated with each goal, and the when the goal will be chosen for each planning task. Then all the technical requirements of Engage NWI are laid out (Page 14-16). Input from the general public and stakeholders early in the process is critical to shaping the final outcomes of each plan. With a diversity of perspectives in a region as large as NWI, it will be up to regional planners to find a balance between competing priorities and interests for the region. Before plan adoption by the Commission, the plan will be put out for a formal comment period, if required.


Techniques to invite participation

Techniques to invite participation

Engage NWI outlines methods to ensure regional planning is conducting with participation always at mind from the beginning of planning processes. Each planning task undertaken will identify a participation goal appropriate for that task (Page 12) and then planners will employ the methods that goal requires. It is expected that most tasks will be on the more participatory end of the spectrum.


However, no matter which type of participation goal that is required, participation will be possible in formats that are inclusive. All meeting locations will be compliant with the ADA and requests for reasonable accommodations taken upon request within 72 hours of a formal meeting to ensure participation those who may need alternate formats of materials – including language translation, foreign, American Sign Language, or braille.

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Adapted from the International Association of Public Participation (IAP2) Public Participation Spectrum


Does the task


Active participation methods

require? Inform Consult Involve Collaborate

Engage NWI goal: Provide public with

objective information and assist their understanding of regional challenges, options, opportunities, or solutions.


Obtain feedback on regional planning tasks, analyses, or prior to policy making.


Work directly with public and stakeholders throughout planning process to ensure concerns and ideas are consistently understood and considered.


Partner with the public and stakeholders in every aspect of the planning process from project scoping through adoption of plans or policies.


Engage NWI

promise

Keep general public and stakeholders informed.

Keep public informed, listen and acknowledge concerns and ideas, and provide public with report on how input shaped outcomes.

Work with public and stakeholders to ensure goals and ideas are directly reflected in planning work as much as possible and report on how input shaped outcomes.

Work with public and stakeholders to inform planning work from start at project scoping to understand issues, generate solutions, and incorporate feedback to shape outcomes.



Involvement methods / tools may include:


Website, social media, newsletters, multi-language publications, press releases, mailings, live streaming, white papers, or fact sheets.


Activities listed in “Inform” plus surveys, comment forms, webinars, or formal meetings


Activities listed in “Consult” plus focus groups, targeted outreach to meet people where they are such as “Out and Abouts,” or “Pop-up Events”


Activities listed in “Involve” plus task forces, charrettes, keypad polling, and working groups


When goal will be selected:

The “Inform” level of participation will be used for technical documents, but the methods will be used frequently to communicate regularly with the public

The “Consult” level of participation will be used less frequently, but the methods will be used when needed

The “Involve” method will be used frequently and the methods as well

The “Collaborate” method will be used frequently with major planning processes

Examples of active engagement

Examples of active engagement

Some types of active and in-person engagement will be conducted by employing the following:

“Out and Abouts” – regional planners meeting face-to-face to invite interest in planning activities, events or to solicit direct feedback

“Pop-up Events” – regional planners sharing information / asking for feedback at other organization’s events

Formal meetings – advertised open houses or public hearings – timely notice per Engage NWI for all public meetings listed in the table to the right will be two weeks prior to the meeting.

Task force / working groups – invited and targeted participation of subject matter experts at the discretion of the NIRPC Executive Director



Effectiveness of methods and evaluation

Effectiveness of methods and evaluation

From time to time the strategies and methods contained within Engage NWI will be reviewed for their effectiveness. The principal measure for effectiveness of Engage NWI will be:

The frequency in which planning activities are conducted with the “Involve” or “Collaborate” goal of active participation methods described on Page 12 – should be at least 50% of activities; and

How aggressively regional planners have made attempts to invite participation from the general public and stakeholders throughout the planning process. Opportunities include advertising, ”Out and Abouts,” ”Pop-Up Events,” social media or newsletter content, etc.

A summary of public participation efforts by regional planners will be published in the “Performance Report” recommended in the NWI 2050 Plan.

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Technical aspects of public participation:


Public comment periods and public meeting requirements Core planning documents

Minimum comment period by law

Engage NWI

comment length policy

Engage NWI

formal meeting policy

Long-range plan (new adoption)

Not specified in federal law

30 days

Required

Long-range plan

Policy/Project amendment

21 days

Not required

Long-range plan

Modification / Technical amendment

None

Not required

Transportation Improvement Program (TIP) (new adoption)

30 days

Required

TIP amendment

21 days

Not required

TIP modification / technical amendment

None

Not required

Air Quality Conformity

30 days

Required

Unified Planning Work Program (new or amendment)

None

Not required

Coordinated Public Transit Human Services Transportation Plan

(new or amendment)

21 days

Not required

Public Participation Plan

(new or amendment)

45 days

45 days

Not required

Other planning and policy documents

Regional and sub-regional modal, corridor, development, or environment plans/policies

Not specified in federal law

21 days

Not required

Technical documents required to fulfill federal requirements

None

Not required

Amendment and modification procedures

Amendment and modification procedures

Amendment:

1) any phase of any project is added or construction phase or transit project deleted;

2) any addition of funds over $100,000;

3) change to an air quality non-exempt project;

4) project scope change that alters original intent of project;

5) change to policy or programming rules.

Interagency Consultation Group review on all TIP amendments and a redetermination of fiscal constraint is required. Twenty-one-day comment period required.

Must be approved by Commission or Executive Board. Public comment opportunity is available at the meeting.


Modification:

1) project moving year to year (but not out of the TIP, which is an amendment);

2) project fund source change;

3) project is split into multiple construction segments;

4) addition of funds under $100,000 (TIP and UPWP); or

5) typographical changes.

Modifications are made by NIRPC staff at the request of project sponsor subject to regulation and funding availability.

A redetermination of fiscal constraint is required.


Technical Amendment:

Changes to technical information that does impact policy or programmed projects, ie: performance targets, data updates, asset information.

Must be approved by Commission or Executive Board. Public comment opportunity is available at the meeting.


Emergency Amendment:

NIRPC Executive Director authorizes a TIP amendment without public process or Commission if:

1) public well-being or safety is at risk; or

2) lapse or loss of federal funds is at risk.

A redetermination of fiscal constraint is required.


Path to address public comments

Path to address public comments

Comments received during a comment period will be reported to the Commission via a “Public Comment Report.” The Report will be made available on the NIRPC website and included with draft plans before adoption The Report will constitute the formal response to comments and will contain the following: 1) the original comment, as received; 2) a recommendation by staff on how the final plan may address the substance of the comment; and 3) a notation on whether or not the recommendation is a major or minor revision.


Any such recommendation to revise a draft plan that proposes: 1) Policy revisions; 2) Adds a project not previously subjected to public review; or 3) deletes a project subjected to public review, will be considered a major revision and will trigger an additional public comment period. All other recommendations will be regarded as minor revisions representing comments that are more general. Advisory Committee(s) or the Commission will consider recommendations at their discretion.


Public Comment Period (per Engage NWI policy)



Recommended major revisions?

Recommended minor revisions?


Recommended major revisions?

Recommended minor revisions?


The commission may accept or modify major revisions and start new full comment period

The Commission may reject major revisions and adopt the plan

The Commission may accept, reject, or modify minor revisions and adopt the plan

The commission may accept or modify major revisions and start new full comment period

The Commission may reject major revisions and adopt the plan

The Commission may accept, reject, or modify minor revisions and adopt the plan



Second Public Comment Period

(per Engage NWI policy)


Second Public Comment Period

(per Engage NWI policy)


The Commission may accept, reject, or modify major revisions and adopt the plan. Public engagement ends.

The Commission may accept, reject, or modify major revisions and adopt the plan. Public engagement ends.


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NIRPC’s Role in the Region



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To provide a common voice for Northwest


To serve as NWI’s Metropolitan Planning Organization and act as the designated recipient for certain transportation funding


To generate meaningful dialogue

commu

Indiana in its

and cooperation on


th fed

nications with e state and the

issues of common concern

eral government


To create opportunities for partnership between the public and private

sectors


To provide a forum in which elected officials and other decision- makers can develop and implement solutions to regional problems

To contribute to the development of a common vision pertaining to Northwest Indiana’s future


For more information:

Visit: www.nirpc.org


Contact:

Public Participation Planner at comments@nirpc.org or 219-763-6060


Request alternative formats of plans or meeting materials: nirpc@nirpc.org or 219-763-6060


Table of Contents

East Chicago Transit 1-34

North Township Dial A Ride 35-50

Opportunity Enterprises 51-66

Porter County Aging & Community Services 67-85

South Lake County Community Services 86-157

Transporte 158-166

  1. Line 167-206


    þÿ

    Hispanic - 13,925 (46.4%)

    Black alone - 13,016 (43.4%)

    White alone - 2,694 (9.0%)

Exhibit II

Complaint Appeal Process


How to File a Complaint to East Chicago Transit (ECT)

A person with a complaint may submit the complaint to ECT using the following procedures.


  1. A complaint may be submitted in writing and must include the person’s name and contact information, the date of the incidence, and the identity of the person or department or service that caused the complaint. Complaint. Complaints may be sent via mail, email, fax or hand delivered.


  2. A complaint may be taken verbally and must include the person’s name and contact information, date of the incidence, and the identity of the person, department or service that caused the complaint.


  3. Persons with a complaint may request a neutral third party (East Chicago Law Department ) to hear a verbal complaint or assist with a written complaint. The selection of the neutral third party shall be made cooperatively between ECT and the person filing the complaint.


  4. All complaints shall be addressed to the ECT.


    ECT Complaint Procedure


    1. The person filing a complaint will be informed that the complaint be filed directly with ECT. ECT shall be responsible for follow up and monitoring the complaint.


    2. If the complaint is valid and supported by facts, ECT will order corrective action be taken.


    3. The person who filed the complaint will be consulted as to the adequacy of the proposed remedy. If acceptable, the matter is concluded.


    4. If the proposed remedy is not acceptable, the person who filed the complaint may appeal with East Chicago Law Department, 4525 Indianapolis Blvd., East Chicago, IN 46312, 219-391-8291 for purposes of stating their complaint and identifying an appropriate remedy.


    5. East Chicago Law Department will provide further assistance.


    6. If acceptable, the matter is concluded. If not, the person is again advised of the appropriate steps to file the complaint by East Chicago Law Department.


ALTERNATE FORMAT AVAILABLE UPON REQUEST


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NORTHERN LAKE COUNTY HAMMOND AND EAST CHICAGO INSET


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Literature Distribution List

Flyers, Brochures, and Complaint Forms Locations:


City of East Chicago, Public Transit Title VI Complaint Form


East Chicago Transit es responsable para la operación y implementación de los programas públicos de transporte, que son financiados en parte con asistencia financiera Federal otorgada por el Departamento de transporte de los Estados Unidos y la Administración Federal de tránsito, sin discriminación contra cualquier persona por razón de raza, color u origen nacional.


Sección I

Nombre:


Dirección:


Números de teléfono:


Casa/celular: Trabajo:


Dirección de correo electrónico:


Requisitos de formato accesible:

Letra grande

Cinta de audio

Dispositivo de telecomunicaciones para sordos


Otro


Sección II


Esta queja esta presentada en su propio nombre? Si No


Si usted respondió “si” a esta pregunta vaya a la sección III.


Si usted respondió “no” a esta pregunta por favor proporcione el nombre y la relación de la persona para quien usted se esta quejando.


Nombre:


Relación:


Por favor explique por que usted ha presentado por una tercera persona.


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Confirme que haya obtenido el permiso de la parte agraviada.

Si No


Sección III


Usted ha presentado un titulo VI ante la cuidad anteriormente? Si No


Se ha presentado esta queja con cualquiera de las siguientes agencias? Administración Federal de Transito Si No Departamento de Transporte Si No Departamento de Justicia Si No

Comisión de oportunidad de igualdad en el empleo Si No Otro


Si la respuesta es si, por favor proporcione una copia del formulario de denuncia que presento con cualquiera de las agencias mencionadas.


Ha presentado una demanda con respecto a esta queja? Si No


Sección IV


Esta queja es contra East Chicago Transit? Si No


Ha estado en contacto con un empleado de la ciudad con respecto a esta queja? Si No

Si usted respondió “si” a esta pregunta por favor proporcione el nombre, titulo (si los sabe) y número telefónico de la persona que ha estado en contacto.


Nombre:


Titulo:


Numero de teléfono:


En pagina(s) separada por favor describa su queja. Usted debe incluir detalles específicos, tales como nombre(s), fecha(s), hora(s), número(s) de ruta, información de testigos y cualquier otra información que nos ayude en nuestra investigación de su(s) denuncias. Proporcione cualquier otra documentación que sea pertinente a esta queja.

Sección V


Firma:


Fecha:


[NOTA: la ciudad no puede aceptar este formulario de queja sin firma.]


Por favor, envié por correo el formulario completado a:


City of East Chicago

Public Transportation Department 5400 Cline Ave.

East Chicago, IN 46312

City of East Chicago, Public Transit Title VI Complaint Form


East Chicago Transit is responsible for operating Public Transportation Programs and implementing transit related projects, which are funded in part with Federal financial assistance awarded by the

U.S. Department of Transportation and the Federal Transit Administration (FTA), without discriminating against any person in the United States on the basis of race, color, or national origin.


Section I


Name:


Address:


Telephone Numbers:


Home/Cell Work


    1. ail Address:


      Accessible Format Requirements:


      Large Print

      Audio Tape

      TDD

      Other


      Section II


      Are you filing this complaint on your own behalf? Yes No


      If you answered “yes” to this question go to Section III.


      If you answered “no” to this question please provide the name and relationship of the person for whom you are complaining.


      Name:


      Relationship:


      Please explain why you have filed for a third party.


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      Please confirm you have obtained the permission of the aggrieved party. Yes No


      Section III

      Have you previously filed a Title VI complaint with East Chicago Transit? Yes No


      Have you filed this complaint with any of the following agencies? Federal Transit Administration Yes No Department of Transportation Yes No Department of Justice Yes No

      Equal Employment Opportunity Commission Yes No

      Other


      If yes, please provide a copy of the complaint form you filed with any of the above agencies. Have you filed a lawsuit regarding this complaint? Yes No

      Section IV

      Is this complaint against the East Chicago Transit? Yes No


      Have you been in contact with an East Chicago Transit employee regarding this complaint? Yes No


      If you answered “yes” to this question please provide the name, title (if known), and telephone number of the person you have been in contact with.


      Name:


      Title:


      Telephone Number:


      On separate page(s) please describe your complaint. You should include specific details such as name(s), date(s), time(s), route number(s), witness information, and any other information which would assist us in our investigation of your allegations. Please also provide any other documentation which is relevant to this complaint.

      Section V


      Signature:


      Date:


      [NOTE: East Chicago Transit cannot accept this complaint form without a signature.]


      Please mail your completed form to:


      City of East Chicago

      Public Transportation Department 5400 Cline Ave.

      East Chicago, IN 46312



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      2020 Title VI Questionnaire


      (REFERENCES: FTA Circular 4702.1B)


      1. GENERAL REPORTING REQUIREMENTS:


        1. MOST RECENTLY FILED ANNUAL TITLE VI CERTIFICATIONS AND ASSURANCES

          6100 Southport Road

          Portage, Indiana 46368

          (219) 763-6060

          www.nirpc.org


          Execution Date of your most recent Certification and Assurances filed with NIRPC (This would be sometime in 2019 for FFY 2020).

          The most recent Certifications and Assurances filled with NIPRC were signed March 27th, 2019.


        2. COPY OF PROCEDURES FOR FILING A TITLE VI COMPLAINT and a summary for investigating and tracking Title VI complaints.


          ECT offers a complaint form on every transit vehicle and on our website: http://www.eastchicago.com/page10/page90/page92/index.html You can share your comments, suggestions, and complaints by filling out this form. You can also call our office and a complaint form will be mailed to you. If assistance in filling out a complaint form is required, please contact the office and one of our staff will assist you. Comments, complaints or suggestions may be submitted by mail, on our web site, or by phone.


          All service complaints are subject to ECT Complaint Policy. All complaints are investigated and receive responses. We can only resolve problems if we are informed, so please do not hesitate to contact us.


          A service complaint is defined as a dispute or dissatisfaction with service. Any passenger or citizen with a complaint has within 10 business days to submit the complaint. Preferably complaints should be in writing with a signature, address and phone number so that we can contact the complainant for additional information and to provide a response. It is possible to submit complaints anonymously but this will limit the ability of ECT to investigate the matter and no response can be provided. Please mail, email, fax or deliver this form to: East Chicago Transit, Attn. Transit Director; 5400 Cline Ave; East

          Chicago, IN 46312. Phone-in complaints shall be documented by our management staff and given to the ECT Director. The ECT Director or designee shall review the complaint and within 30 business days of its receipt and notify the complainant if contact information is provided.


          If the proposed remedy is not acceptable, the person who filed the complaint may appeal with East Chicago Law Department,

          4525 Indianapolis Blvd., East Chicago, IN 46312, 219-391-8291 for purposes of stating their complaint and identifying an appropriate remedy.


          East Chicago Law Department will provide further assistance.


          If acceptable, the matter is concluded. If not, the person is again advised of the appropriate steps to file the complaint by East Chicago Law Department.


        3. LIST OF ALL ACTIVE TITLE VI INVESTIGATIONS, LAWSUITS OR COMPLAINTS naming your organization which allege discrimination on the basis of race, color, or national origin with respect to transit service or other transit benefits. Include: date lawsuit or complaint was filed, summary of the allegation, status of investigation, lawsuit or complaint, and actions taken in response (including whether or not the parties involved have entered into a consent decree).


          (The lawsuit/complain/investigation information here should be transit service- related and/or transit benefit-related. If your organization has any contractors that provide some or all of your transportation service, provide investigation/lawsuit/complaint information for those entities also.)


          ECT has no pending lawsuits or complaints.


          1. COPY OF PLAN OR POLICY FOR PROVIDING LANGUAGE ASSISTANCE FOR PERSONS WITH LIMITED ENGLISH PROFICIENCY.


            Describe how information and programs are accessed for those individuals who are Limited English Proficient (LEP). Include the actions taken to ensure the benefits, resources and services are provided to them. If a plan does not exist, provide a policy or description on how this is performed.


            Plan may be based on the DOT LEP Guidance or an alternative framework.


            Individuals who are Limited English Proficient (LEP) are still able to access our system based on the fact that our literature, information is available in Spanish.

            When people call for information, our office also has Spanish-speaking individuals to interpret.


            ECT also utilizes Spanish-speaking staff in communicating route information to passengers when they call the office, and when attending community meetings. Transit schedules are printed in both English and Spanish due to the fact that a large percentage of East Chicago Transit’s ridership is of Hispanic origin (based on 2010 census). A Title VI statement of rights and complaint handling procedures is posted at the central garage for all employees to see and is available at East Chicago Transit’s main office (pg 9 of ECT’s Title VI)


          2. COPY AND DESCRIPTION OF NOTIFICATION TO THE PUBLIC OF PROTECTION UNDER TITLE VI.


          Describe how the agency provides information regarding Title VI obligations (programs operated without regard to race, color, and national origin) to the public. List and describe the media tools used to post and distribute this information. (Media tools can include but not limited to websites, bus postings, brochures, complaint forms.)


          ECT uses local newspapers, social media and website, various community organizations, and ECT fleet to disseminate information to the citizens of the City of East Chicago. (pg. 9 of ECT Title VI).


          ECT also has a distribution list which shows the locations where any and all information to be posted are located.


          (see attached “Literature Distribution List”)


      2. PROGRAM SPECIFIC REQUIREMENTS FOR GRANTEES IN URBANIZED ZONE AREAS OF 200,000 OR MORE:


        1. COLLECTION OF DEMOGRAPHIC DATA.


          FTA Requirement: Submit maps and charts demonstrating the collection and analysis of racial and ethnic data showing the extent to which members of minority groups are beneficiaries of programs receiving Federal financial assistance.


          Requirement Summary: Submit the following; demographic and service profile maps and charts, survey information on customer demographic and travel patterns, and/or a locally developed alternative.

          (see Exhibits I)


        2. MODIFIED SYSTEMWIDE SERVICE STANDARDS AND POLICIES.


          FTA Requirement: Submit a copy of systemwide service standards and policies. Describe the impact of the service standard or policy changes on the minority community, if any. Changes resulting in an adverse impact upon the minority community must be identified, including the actions the agency has taken or will take to eliminate, minimize or mitigate the adverse impact. If there have been no changes in service standards and policies within this timeframe, please respond accordingly.


          Requirement Summary: Submit a complete copy of your systemwide service standards and policies including standards for on-time performance and transit security.


          Briefly describe the impact of each change on minority communities in your service area. If any change resulted in adverse impacts on minority communities, describe actions taken (or to be taken) to eliminate, minimize, or mitigate these adverse impacts.


          ECT will use the following 5 transit service indicators to monitor Title VI compliance:

          1. Vehicle Load - is a ratio of the number of seats on a vehicle to the number of passengers. The load factor is and indicator of the extent of probable overcrowding or the need for additional vehicles.

          2. Vehicle Assignment - refers to the process by which transit vehicles are assigned to routes throughout ECT service area.

          3. Vehicle Headway - is a measurement of the time interval between 2 vehicles traveling in the same direction on the same route. The frequency of service is a general indicator of the level of service provided along a route and a factor in the calculation of the amount of travel time expended by a passenger to reach his/her destination.

          4. Distribution of Transit Amenities - refers to items of comfort and convenience available to the general riding public such as signage and shelters

          5. Transit Access - is a measure of the distance a person must travel to gain access to ECT. Transit access is a general measure of the distribution routes within ECT service area.


            In compliance with FTA Title VI guidelines, the Director of ECT will be responsible to review the local service standards established above (transit service indicators), for compliance.


            Procedures and guidelines to monitor compliance with Title VI and identify possible areas of noncompliance are in place. ECT will review transit