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RESOLUTION 20-05


A RESOLUTION OF THE NORTHWESTERN INDIANA REGIONAL PLANNING COMMISSION AUTHORIZING AND ADOPTING THE TITLE VI PROGRAM OF THE U.S. DEPARTMENT OF TRANSPORTATION UNDER PROVISION OF FTA CIRCULAR 4702.1b


WHEREAS, Federal Transit Administration statutes, requirements, policies, and regulations, including those related to Title VI of the Civil Rights Act of 1964, as amended, and other U.S. Department of Transportation requirements and implementing regulations; and


WHEREAS, in accordance with Title VI non-discrimination laws in regard to providing appropriate access to services and activities provided by federal agencies and recipients of federal assistance, the Limited English Proficiency requirement will accommodate persons with Limited English Proficiency; and


NOW, THEREFORE, BE IT RESOLVED by the Northwestern Indiana Regional Planning Commission:


The Commission approves and submits to the Federal Transit Administration and/or

U.S. Department of Transportation pertaining to Title VI of the Civil Rights Act of 1964, on behalf of the Northwestern Indiana Regional Planning Commission.


Duly adopted by the Northwestern Indiana Regional Planning Commission on this nineteenth day of March, 2020.

6100 Southport Road

Portage, Indiana 46368

(219) 763-6060

www.nirpc.org


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ATTEST:

Michael Griffin Chair



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Justin Kiel Secretary

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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

e-mail: 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 3

  1. REQUIREMENT TO PROVIDE AN ANNUAL TITLE VI CERTIFICATION AND ASSURANCES 3

  2. REQUIREMENT TO DEVELOP TITLE VI COMPLAINT PROCEDURES 3

  3. REQUIREMENT TO RECORD TITLE VI INVESTIGATIONS, COMPLAINTS, & LAWSUITS 3

  4. REQUIREMENT TO PROVIDE MEANINGFUL ACCESS TO LIMITED ENGLISH PROFICIENCY (LEP) PERSONS 3

  5. REQUIREMENT TO NOTIFY BENEFICIARIES OF PROTECTION UNDER TITLE VI 3

  6. SUMMARY OF PUBLIC OUTREACH AND INVOLVEMENT ACTIVITIES 4

  7. MINORITY REPRESENTATION ON PLANNING & ADVISORY BOARDS 11

  8. MONITORING SUBRECIPIENTS 12

  9. REQUIREMENT TO CONDUCT EQUITY ANALYSIS 13

PART II. MPO REQUIREMENTS 15

  1. DEMOGRAPHIC PROFILE 15

  2. ENVIRONMENTAL JUSTICE BENEFITS AND BURDENS ANALYSIS 15

  3. DESCRIPTION OF PROCEDURES WITHIN PLANNING PROCESS 15

  4. DEMOGRAPHIC MAPS SHOWING IMPACTS OF STATE AND FEDERAL FUNDS 17

  5. ANALYSIS OF TRANSPORTATION SYSTEM INVESTMENTS 18

  6. DESCRIPTION OF THE PROCEDURES THE MPO USES TO PASS THROUGH FTA FINANCIAL ASSISTANCE TO SUBRECIPIENTS IN A NON-DISCRIMINATORY MANNER 19

  7. 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 19

    PART III. NIRPC RECERTIFICATION ATTACHMENTS 21

    ATTACHMENT #1: NIRPC’S TITLE VI COMPLAINT PROCEDURES 22

    ATTACHMENT #2: LIMITED ENGLISH PROFICIENCY STRATEGY 29

    ATTACHMENT #3: 2010 LIMITED ENGLISH PROFICIENCY DEMOGRAPHIC PROFILE 38

    ATTACHMENT #4: MINORITY & LOW INCOME POPULATION DISTRIBUTION MAPS 47

    ATTACHMENT #5: MINORITY & LOW INCOME POPULATION DISTRIBUTION CHART 49

    PART IV. TRANSIT OPERATOR SUBMISSIONS 57

    NORTHERN INDIANA COMMUTER TRANSPORTATION DISTRICT (NICTD) 58

    CITY OF EAST CHICAGO, IN (EAST CHICAGO TRANSIT) 59

    NORTH TOWNSHIP, LAKE COUNTY, IN (NORTH TWP DIAL-A-RIDE) 92

    SOUTH LAKE COUNTY COMMUNITY SERVICES, INC. (SOUTHLAKE TRANSIT) 105

    OPPORTUNITY ENTERPRISES, INC. (OE EXPRESS) 122

    PORTER COUNTY AGING & COMMUNITY SERVICES, INC 141

    CITY OF VALPARAISO, IN (V-LINE/ CHICAGO DASH) 160

    CITY OF LA PORTE, IN (TRANSPORTE) 192


    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 2011 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)763-6060 (extension 141) 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:


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 organizes 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 scientific 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 includes 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

The table below depicts membership of NIRPC Committees broken down by race based on 2010 Census for the NIRPC Region of Lake, Porter and LaPorte Counties.


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 Americ an alone

Americ an 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

100.00%

-

-

-

-

-

-

-

NIRPC Executive Board

100.00%

-

-

-

-

-

-

-

Finance and Personal Committee

100.00%

-

-

-

-

-

-

-

Legislative Committee

No Responses

-

-

-

-

-

-

-

Local Government Assistance Committee

100.00%

-

-

-

-

-

-

-

Outreach Committee

No Responses

-

-

-

-

-

-

-

Transportation Resources and Oversight Committee

85.72%

14.28%

-

-

-

-

-

-

Technical Planning Committee

87.50%

12.50%

-

-

-

-

-

-

Environmental Management Policy Committee

88.24%

5.88%

-

5.88%

-

-

-

-

Ped, Pedal, and Paddle Committee

95.00%

-

-

-

-

-

-

5.00%

Land Use Committee

66.68%

16.66%

-

-

-

-

-

16.66%

Transit Operators Round Table

75.00%

25.00%

-

-

-

-

-

-

Surface Transportation Committee

80.00%

20.00%

-

-

-

-

-

-

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 America n alone

America n Indian and Alaska Native alone

Asian alone

Native Hawaiia n

and Other Pacific Islander alone

Some Other Race alone

Two or More Races

Hispani c or Latino

2010 Population

65.60%

18.40%

0.20%

1.10

%

0.00%

0.10

%

1.30

%

13.30%

NIRPC Commission

100.00

%

-

-

-

-

-

-

-

NIRPC Executive Board

100.00

%

-

-

-

-

-

-

-

Finance and Personal Committee

100.00

%

-

-

-

-

-

-

-

Legislative Committee

100.00

%

-

-

-

-

-

-

-

Local Government Assistance Committee

100.00

%

-

-

-

-

-

-

-

Outreach Committee

-

-

-

-

-

-

-

100.00

%

Transportation Resources and Oversight Committee

87.50%

12.50%

-

-

-

-

-

-

Technical Planning Committee

88.89%

11.11%

-

-

-

-

-

-

Environmental Management Policy Committee

88.24%

5.88%

-

5.88

%

-

-

-

-

Ped, Pedal, and Paddle Committee

93.75%

-

-

-

-

-

-

6.25%

Land Use Committee

66.68%

16.66%

-

-

-

-

-

16.66%

Transit Operators Round Table

80.00%

20.00%

-

-

-

-

-

-

Surface Transportation Committee

66.67%

33.33%

-

-

-

-

-

-



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

100.00%

-

-

-

-

-

-

-

NIRPC Executive Board

100.00%

-

-

-

-

-

-

-

Finance and Personal Committee

100.00%

-

-

-

-

-

-

-

Legislative Committee

100.00%

-

-

-

-

-

-

-

Local Government Assistance Committee

100.00%

-

-

-

-

-

-

-

Outreach Committee

83.40%

-

-

-

-

-

-

16.60%

Transportation Research and Oversight Committee

91.67%

8.33%

-

-

-

-

-

-

Technical Planning Committee

83.40%

16.60%

-

-

-

-

-

-

Environmental Management Policy Committee

89.48%

5.26%

-

5.26%

-

-

-

-

Ped, Pedal, and Paddle Committee

93.75%

-

-

-

-

-

-

6.25%

Land Use Committee

75.00%

12.50%

-

-

-

-

-

12.50%

Transit Operators Round Table

66.67%

33.33%

-

-

-

-

-

-

Surface Transportation Committee

80.00%

20.00%

-

-

-

-

-

-

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.


        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

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

      image

      Figure 5: Demand Response Transit Operators in Northwest Indiana


      image

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



      Population Within Service Area

      Federal Funds Awarded

      Funding by Minority Status within Service Area

      Transit Operator

      Total Population

      Non- Minor ity

      Min ority

      Percen t Minorit y

      201

      7

      2018

      2019

      Total

      Total Populati on Per Capita

      Non- Minority Funding Totals

      Minority Funding Totals

      East Chicago Transit


      95,6

      99


      29,045


      66,

      654

      69.65

      %

      $ 68

      6,5

      24

      $ 743,

      766

      $ 347,

      507

      $ 1,7

      77,

      797

      $ 18.58

      $ 539,56

      7.96

      $ 1,238,229

      .04

      North Township DAR


      157,

      356


      70,464


      86,

      892

      55.22

      %

      $ 58

      8,5

      78

      $ 484,

      784

      $ 192,

      812

      $ 1,2

      66,

      174

      $ 8.05

      $ 566,99

      2.58

      $ 699,181.4

      2

      SLCCS


      253,

      922


      186,673


      67,

      249

      26.48

      %

      $ 34

      3,9

      99

      $ 392,

      000

      $ 356,

      584

      $ 1,0

      92,

      583

      $ 4.30

      $ 803,22

      2.04

      $ 289,360.9

      6

      OE


      248,

      483


      187,711


      60,

      772

      24.46

      %

      $ 10

      8,3

      74

      $ 111,

      551

      $ 105,

      972

      $ 325

      ,89

      7

      $ 1.31

      $ 246,19

      1.70

      $ 79,705.30

      PCACS


      167,

      391


      140,547


      26,

      844

      16.04

      %

      $ 19

      6,1

      06

      $ 212,

      849

      $ 150,

      637

      $ 559

      ,59

      2

      $ 3.34

      $ 469,85

      1.88

      $ 89,740.12

      Valparaiso Transit


      50,7

      00


      44,523


      6,1

      77

      12.18

      %

      $ 49

      3,7

      57

      $ 518,

      778

      $ 550,

      169

      $ 1,5

      62,

      704

      $ 30.82

      $ 1,372,3

      13.02

      $ 190,390.9

      8

      TransPorte


      8,04

      8


      6,415


      1,6

      33

      20.29

      %

      $ 22

      2,1

      36

      $ 236,

      527

      $ 254,

      838

      $ 713

      ,50

      1

      $ 88.66

      $ 568,72

      6.26

      $ 144,774.7

      4

      All NIRPC

      Subrecipients:


      981,

      599


      665,378


      316

      ,22

      1

      32.21

      %

      $ 2,6

      39,

      47

      4

      $ 2,70

      0,25

      5

      $ 1,95

      8,51

      9

      $ 7,2

      98,

      248

      $ 7.44

      $ 4,566,8

      65.44

      $ 2,731,382

      .56

      NICTD


      766,

      924


      495,349


      271

      ,57

      5

      35.41

      %

      $ 34,

      82

      0,8

      39

      $ 37,6

      45,1

      21

      $ 40,6

      43,3

      21


      $11 3,1

      09,

      280

      $ 147.48

      $ 73,056,

      220.51

      $ 40,053,05

      9.73

      GPTC


      223,

      844


      65,260


      158

      ,58

      4

      70.85

      %

      $ 4,0

      02,

      48

      5

      $ 4,33

      1,80

      8

      $ 4,30

      2,54

      3

      $ 12,

      636

      ,83

      6

      $ 56.45

      $ 3,684,1

      72.54

      $ 8,952,663

      .46

      Michigan City Transit / Transit Triangle


      36,0

      81


      22,611


      13,

      470

      37.33

      %

      $ 1,2

      32,

      30

      4

      $ 1,50

      3,88

      8

      $ 1,51

      3,06

      5

      $ 4,2

      49,

      257

      $ 117.77

      $ 2,662,8

      95.98

      $ 1,586,361

      .02

      Non-NIRPC

      Direct Recipients:


      1,02

      6,84

      9


      583,220


      443

      ,62

      9

      43.20

      %

      $ 40,

      05

      5,6

      28

      $ 43,4

      80,8

      17

      $ 46,4

      58,9

      29


      $12 9,9

      95,

      373

      $ 126.60

      $ 79,403,

      289.03

      $ 50,592,08

      4.21

      All Transit Operators:


      2,00

      8,44

      8


      1,248,59

      8


      759

      ,85

      0

      37.83

      %


      42,

      69

      5,1

      02


      46,1

      81,0

      72


      48,4

      17,4

      48


      137

      ,29

      3,6

      21

      $ 68.36


      83,970,

      154


      53,323,46

      7



      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.

      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

      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.


      image

      image

      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 Transportation Policy 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 operates an air quality public education program funded with FHWA Congestion Mitigation/Air Quality Program funds. There is 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 may be used for document translation. 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.


A staff person who is fluent in Spanish has been assigned to handle all telephone calls and respond to e-mail messages that are placed or sent by a person speaking Spanish.


Se habla español “Spanish is spoken” is placed on public documents and NIRPC’s website.


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 48 hours before a transportation outreach event, a staff person fluent in Spanish will be assigned to attend the outreach event and translate comments made in Spanish. If a staff person is not available a translator will be hired.


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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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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)


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 town, Indiana

614

23

3.7%

Burns Harbor town, Indiana

1452

210

14.5%

Cedar Lake town, Indiana

12024

1024

8.5%

Chesterton town, Indiana

14052

1725

12.3%

Crown Point city, Indiana

28952

5144

17.8%

Dune Acres town, Indiana

173

4

2.3%

Dyer town, Indiana

16077

3271

20.3%

East Chicago city, Indiana

28728

26857

93.5%

Gary city, Indiana

77416

68289

88.2%

Griffith town, Indiana

16468

5432

33.0%

Hammond city, Indiana

77827

47260

60.7%

Hebron town, Indiana

3968

667

16.8%

Highland town, Indiana

22938

5332

23.2%

Hobart city, Indiana

28573

6358

22.3%

Kingsbury town, Indiana

205

15

7.3%

Kingsford Heights town, Indiana

1370

217

15.8%

Kouts town, Indiana

1950

77

3.9%

La Crosse town, Indiana

552

13

2.4%

Lake Station city, Indiana

12157

4799

39.5%

La Porte city, Indiana

21825

3805

17.4%

Long Beach town, Indiana

1126

42

3.7%

Lowell town, Indiana

9502

785

8.3%

Merrillville town, Indiana

35183

22523

64.0%

Michiana Shores town, Indiana

262

2

0.8%

Michigan City, Indiana

31352

12579

40.1%

Munster town, Indiana

23005

5425

23.6%

New Chicago town, Indiana

1803

770

42.7%

Ogden Dunes town, Indiana

1195

80

6.7%

Portage city, Indiana

36849

11359

30.8%

Porter town, Indiana

4855

696

14.3%

Pottawattamie Park town, Indiana

262

12

4.6%

St. John town, Indiana

16391

2089

12.7%

Schererville town, Indiana

28778

6513

22.6%

Schneider town, Indiana

249

7

2.8%

Town of Pines town, Indiana

731

91

12.4%

Trail Creek town, Indiana

2000

354

17.7%

Valparaiso city, Indiana

32501

4412

13.6%

Wanatah town, Indiana

1234

138

11.2%

Westville town, Indiana

6659

2169

32.6%

Whiting city, Indiana

4858

2018

41.5%

Winfield town, Indiana

5395

1555

28.8%

Municipal

446324

215451

48.3%

Municipal

66847

19346

28.9%

Municipal

98340

19344

19.7%

Unincorporated

42370

6979

16.5%

Unincorporated

43992

2955

6.7%

Unincorporated

69051

7500

10.9%


Municipality

Total (for whom poverty status is determined)

Below poverty level

Percent below poverty level

Beverly Shores town, Indiana

614

23

3.7%

Burns Harbor town, Indiana

1445

125

8.7%

Cedar Lake town, Indiana

12008

1183

9.9%

Chesterton town, Indiana

13875

1121

8.1%

Crown Point city, Indiana

27536

2142

7.8%

Dune Acres town, Indiana

173

5

2.9%

Dyer town, Indiana

15741

563

3.6%

East Chicago city, Indiana

28580

9876

34.6%

Gary city, Indiana

76469

27344

35.8%

Griffith town, Indiana

16445

1466

8.9%

Hammond city, Indiana

76723

17021

22.2%

Hebron town, Indiana

3968

688

17.3%

Highland town, Indiana

22841

1749

7.7%

Hobart city, Indiana

28290

3129

11.1%

Kingsbury town, Indiana

205

4

2.0%

Kingsford Heights town, Indiana

1349

343

25.4%

Kouts town, Indiana

1947

108

5.5%

La Crosse town, Indiana

549

80

14.6%

Lake Station city, Indiana

12130

3079

25.4%

La Porte city, Indiana

21035

4716

22.4%

Long Beach town, Indiana

1126

28

2.5%

Lowell town, Indiana

9394

851

9.1%

Merrillville town, Indiana

34693

3789

10.9%

Michiana Shores town, Indiana

262

23

8.8%

Michigan City, Indiana

28337

7219

25.5%

Munster town, Indiana

22592

1079

4.8%

New Chicago town, Indiana

1801

499

27.7%

Ogden Dunes town, Indiana

1195

44

3.7%

Portage city, Indiana

36469

6266

17.2%

Porter town, Indiana

4855

411

8.5%

Pottawattamie Park town, Indiana

262

15

5.7%

St. John town, Indiana

16382

522

3.2%

Schererville town, Indiana

28542

1280

4.5%

Schneider town, Indiana

249

55

22.1%

Town of Pines town, Indiana

729

141

19.3%

Trail Creek town, Indiana

1989

159

8.0%

Valparaiso city, Indiana

29294

3976

13.6%

Wanatah town, Indiana

1234

114

9.2%

Westville town, Indiana

2012

520

25.8%

Whiting city, Indiana

4852

789

16.3%

Winfield town, Indiana

5227

114

2.2%