Loading...
HomeMy WebLinkAboutTitle VI 20191 FTA TITLE VI PROGRAM THE CIVIL RIGHTS ACT OF 1964 Compliance Plan January 2019 Metropolitan Planning Organization of Johnson County 410 East Washington Street Iowa City, Iowa 52240 2 Recipient Profile Recipient: _Metropolitan Planning Organization of Johnson County Administrative Head: _Kent Ralston_______Executive Director_______________ Name Title Recipient Title VI Coordinator: Brad Neumann____Assistant Transportation Planner_ Name Title Address: 410 East Washington Street City/State: Iowa City, Iowa Zip Code/County: 52240/Johnson Phone: 319-356-5253 Fax: 319-356-5217 Email: kent-Ralston@iowa-city.org Website: MPOJC.org Has the recipient signed and submitted its Title VI Assurances? Yes _X_ No ____ Has the recipient submitted its Title VI Program Plan? Yes _X_ No ____ Purpose of Title VI Program The purpose of this document is to ensure that the Metropolitan Planning Organization of Johnson County (MPOJC) is in compliance with the FTA Circular 4702.1B and Title VI of the Civil Rights Act of 1964, which states: “No person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity that receives Federal financial assistance.” With specific regard to planning services, this document ensures that: 1. FTA assisted benefits and related services are made available and are equitably distributed without regard to race, color, or national origin; 2. That the level and quality of FTA assisted transit services are sufficient to provide equal access and mobility for any person without regard to race, color, or national origin; 3. That opportunities to participate in the transit planning and decision-making processes are provided to persons without regard to race, color, or national origin; 4. That decisions on the location of transit services and facilities are made without regard to race, color, or national origin; and 3 That corrective and remedial action will be taken if necessary to prevent discriminatory treatment based on race, color, or national origin. Strategies MPOJC’s planning process ensures compliance with Title VI through the many transportation related plans it develops and posts on the MPOJC website. The planning process includes the scoring of projects, use of demographics in project location, Limited English Proficiency Plan, and requires adherence to a complete streets policy for all funded projects. 4 5 6 COORDINATOR RESPONSIBILITES The MPOJC Executive Director and the Civil Rights Coordinator are responsible for ensuring the implementation and the day to day administration of the MPOJC Title VI Plan. The Executive Director is also responsible for implementing, monitoring, and ensuring the MPO's compliance with the Title VI regulations. GENERAL RESPONSIBILITIES A. Public Dissemination The MPOJC will disseminate Title VI Program information to MPO employees, sub-recipients, and contractors, as well as the general public. Public dissemination may include posting of public statements, inclusion of Title VI language in contracts, and announcements of hearings, and meetings in minority newspapers when determined necessary and funding is available. B. Prevention of Discrimination Procedures will be implemented to detect and eliminate discrimination when found to exist, including, but not limited to, issues of accessibility of training to all MPOJC employees, utilization of Minority/Women/Disadvantaged Business Enterprises (DBE) contractors, public involvement and material acquisition. C. Remedial Action The MPOJC will actively pursue the prevention of any Title VI deficiencies or violations and will take the necessary steps to ensure compliance through a program review with the program administrative requirements. If irregularities occur in the administration of the programs operation, procedures will be promptly implemented to resolve Title VI issues and reduce to writing remedial action agreed to be necessary, all within a period not to exceed 90 days. Iowa DOT will be notified of any complaint filed at the City of Iowa City, regarding MPOJC involving Title VI issues, and any resolution. FILING A COMPLAINT Applicability The complaint procedures apply to the beneficiaries of the MPOJC programs, activities, including but not limited to: the public, contractors, sub-contractors, consultants, employees and other sub-recipients of federal and state funds. Eligibility If any individual, group or individuals, or entity believes that they or any other program beneficiaries have been subjected to discrimination prohibited by Title VI nondiscrimination provision as a recipient of benefits and/or services, or on the grounds of race, color, national origin, or sex, they may exercise the right to file a complaint with MPOJC (as part of the City of Iowa City). Every effort will be made to resolve complaints informally at the agency, recipient and/or contractor level. 7 Time Limitation on Filing Complaints Title VI complaints may be filed with: • City of Iowa City/MPOJC • Iowa Department of Transportation • Federal Highway Administration • U.S. Department of Transportation In all situations, MPOJC employees must contact the Executive Director and/or the City of Iowa City Civil Rights Coordinator immediately upon receipt of Title VI or related statutes complaints. Complaints must be filed not later than 180 days after: • The date of the alleged act of discrimination; or • The date the person became aware of the alleged discrimination; or • Where there has been a continuing course of discriminatory conduct, the date on which the conduct was discontinued. Complaints must be in writing, and must be signed by the complainant and/or the complainant's representative. The complaint must set forth as fully as possible the facts and circumstances surrounding the claimed discrimination. A Title VI complaint form (Attachment B) is available at the MPOJC office and the Iowa City Civil Rights Coordinator's office during normal business hours. INTERNAL COMPLAINT PROCESSING 1. The Iowa City Civil Rights Coordinator, acting as the Title VI Coordinator, along with the MPOJC Executive Director, will review the complaint upon receipt to ensure that all information is provided, the complaint meets the 180-day filing deadline and falls within the jurisdiction of the City and follow the procedures as outlined in Title Two of the Iowa City City Code. 2. The Civil Rights Coordinator will then investigate the complaint. If the complaint is against the Civil Rights Coordinator or the MPOJC Executive Director, then the Chair of the MPOJC Urbanized Area Board and/or the MPOJC Urbanized Area Policy Board or its designee will investigate the complaint. Additionally, a copy of the complaint will be forwarded to the Iowa City City Attorney. 3. If the complaint warrants a full investigation, the complainant will be notified in writing by certified mail. This notice will name the investigator and/or investigating agency. The MPOJC will also notify the Iowa Department of Transportation Office of Employee Services/Civil Rights. 4. The party alleged to have acted in a discriminatory manner will also be notified by certified mail as to the complaint. This letter will also include the investigator's name and will request that this party be available for an interview. 5. Any comments or recommendations from legal counsel will be reviewed by the Title VI Coordinator. 8 6. Once the Iowa Department of Transportation Office of Employee Services/Civil Rights is notified of MPOJC/City of Iowa City finding concerning the complaint, the MPOJC will adopt a final resolution. 7. All parties will be properly notified of the outcome of the Iowa Department of Transportation Office of Employee Services/Civil Rights Opportunity report. 8. If the complainant is not satisfied with the results of the investigation of the alleged discriminatory practices, she/he shall be advised of their right to appeal the MPOJC/City of Iowa City's decision. Appeals must be filed within 180 days after the MPOJC final resolution. Unless new facts not previously considered come to light, reconsideration of the MPOJC’s determination will not be available. The foregoing complaint resolution procedure will be implemented in accordance with the Department of Justice guidance manual entitled "Investigation Procedures Manual for the Investigation and Resolution of Complaints Alleging Violations of Title VI and Other Nondiscrimination Statutes," available on line at: http://www.usdoj.gov/crt/cor/Pubs/manuals/complain.html. TRANSIT RELATED TITLE VI INVESTIGATIONS, COMPLAINTS, AND LAWSUITS There are no active lawsuits or complaints alleging discrimination on the basis of race, color, or national origin with respect to services provided by MPOJC. MPOJC has not been asked to take part in any local, state, or federal civil rights compliance reviews in the past three years. MPOJC has not undertaken any federally funded construction projects in the past three years. Identification of Stakeholders Stakeholders are those who are either directly or indirectly affected by a plan, or the recommendations of that plan. Those who may be adversely affected, or may be denied benefits of a plan’s recommendations, are of particular interest in the identification of specific stakeholders. While stakeholders may vary based on the plan or program being considered, MPOJC will assemble a listing of stakeholders with whom we may regularly communicate by email or direct mail. Meeting locations When determining locations and schedules for public meetings, MPOJC will: • Schedule meetings at times and locations that are convenient and accessible for minority and LEP communities • Coordinate with community organizations to implement public engagement strategies that reach out to members of affected minority and/or LEP communities • Consider media outlets that serve LEP populations • Provide opportunities for public participation through written communications, group discussions, and one-on-one interviews PROVIDE MEANINGFUL ACCESS TO LEP PERSONS MPOJC uses Iowa City Transit’s Four Factor LEP analysis to meet requirements under Title VI of the Civil Rights Act of 1964. This Act seeks to improve access to services for persons with Limited English Proficiency (LEP). The following analysis uses the Four Factor Analysis identified in the LEP Guidance. 9 A. Four Factor Analysis Factor 1: Assessing the number and proportion of LEP persons served or encountered in the eligible service population Task 1, Step 1; Examine prior experiences with LEP individuals MPOJC serves a diverse community. The University of Iowa brings people from all over the world to the Iowa City urbanized area which includes the communities of Iowa City, University Heights, Coralville, North Liberty, and Tiffin. Most foreign-speaking residents residing in Iowa City are affiliated with the University of Iowa, either as an international student or visiting scholar. The University has, on average, an international student population of 4,000 persons on an annual basis as well as approximately 450 visiting scholars. Task 1, Step 2; Become familiar with data from the U.S. Census The Iowa City Urbanized Area includes the municipalities of Coralville, Iowa City, North Liberty, Tiffin, and University Heights. According to the U.S. Census Bureau, the population for the urbanized area was 74,513 in 1990, 84,672 in 2000, 91,881 in 2005, 103,152 in 2010 and 125,538 in 2014. Iowa City Urbanized Area’s current demographics: Iowa City Urbanized Area Statistics and Demographics Number Percent Iowa City Urbanized Area Population 118,506 100.0 SEX AND AGE Male 58,815 49.6 Female 59,691 50.4 Under 5 years 7,350 6.2 5 to 9 years 6,950 5.9 10 to 14 years 5,737 4.8 15 to 19 years 10,888 9.2 20 to 24 years 21,082 17.8 25 to 29 years 11,302 9.5 30 to 34 years 9,505 8.0 35 to 39 years 8,089 6.8 40 to 44 years 5,745 4.8 45 to 49 years 5,738 4.8 50 to 54 years 5,082 4.3 55 to 59 years 5,524 4.7 60 to 64 years 4,757 4.0 65 to 69 years 3,874 3.3 70 to 74 years 2,582 2.2 75 to 79 years 1,414 1.2 80 to 84 years 1,227 1.0 85 years and over 1,660 1.4 Median age (years) 28.2 ( X ) 16 years and over 97,476 82.3 10 18 years and over 95,422 80.5 Male 47,181 49.4 Female 48,241 50.6 21 years and over 82,908 70.0 62 years and over 13,578 11.5 65 years and over 10,757 9.1 Male 4,688 43.6 Female 6,069 56.4 RACE One Race 115,329 97.3 White 95,020 80.2 Black or African American 8,985 7.6 American Indian and Alaska Native 206 .2 Asian 8,676 7.3 Asian Indian 1,631 1.4 Chinese 3,730 3.1 Filipino 452 .4 Japanese 268 .2 Korean 1,220 1.0 Vietnamese 391 .3 Other Asian 984 .8 Native Hawaiian and Other Pacific Islander 161 .1 Some Other Race 2,281 1.9 Two or More Races 3,177 2.7 HISPANIC OR LATINO Hispanic or Latino (of any race) 7,199 6.1 Mexican 4,385 3.7 Puerto Rican 498 .4 Cuban 134 .1 Other Hispanic or Latino 2,182 1.8 Not Hispanic or Latino 111,307 93.9 White alone 90,671 76.5 RELATIONSHIP Total population 118,506 100.0 In households 110,360 93.1 In family households 72,708 61.4 Householder 23,603 100.0 Male 12,518 53.0 Female 11,085 47.0 Spouse 18,543 X Child 25,034 X In group quarters 8146 X HOUSEHOLDS BY TYPE Total households 47,343 Total families 23,603 100 With own children under 18 years 11,608 49.2 11 Husband-wife family 18,464 78.2 With own children under 18 years 8,523 46.2 Male householder, no wife present 1,570 6.7 With own children under 18 years 950 60.5 Female householder, no husband present 3,569 15.1 With own children under 18 years 2,135 59.8 Nonfamily households 23,470 49.6 65 years and over 3,403 14.5 Households with individuals under 18 years 12,214 25.8 Households with individuals 65 years and over 3,456 7.3 Average household size 2.33 Average family size 2.99 HOUSING OCCUPANCY Total housing units 50,425 Occupied housing units 47,343 93.9 Vacant housing units 3,082 6.1 Homeowner vacancy rate (percent) 1.3 Rental vacancy rate (percent) 3.3 HOUSING TENURE Occupied housing units 47,343 100 Owner-occupied housing units 25,436 53.7 Average household size of owner-occupied units 2.46 Renter-occupied housing units 21,907 46.3 Average household size of renter-occupied units 2.14 Source: U.S. Census Bureau, ACS 2017 5-year Estimates There were 4,011 international students according to the University of Iowa’s fall 2017 enrollment statistics, which represents 12.4% of the University of Iowa student enrollment. The largest national representations of international students and scholars at the University of Iowa are from Asia, as shown below: UI International Students and Scholars by World Region National Representation Undergraduate Student Population Scholar Population China (PRC) 2,381 162 India 363 49 South Korea 303 20 Malaysia 73 1 Iran 58 1 Source: The University of Iowa, Fall 2017 Profile of International Students and Scholars 12 Task 1, Step 2A; Identify the geographic boundaries of the area that your agency serves The Iowa City urbanized area includes the communities of Iowa City, University Heights, Coralville, North Liberty, and Tiffin. Task 1, Step 2B; Obtain Census data on LEP population in your service area In determining the number or proportion of LEP persons in Johnson County, including the City of Iowa City, 2012-2016 U.S. Census American Community Survey (ACS) data was evaluated. According to ACS data, 18,099 persons in Johnson County (13.6% of the population) spoke a language other than English at home. Of the 18,099 persons residing in Johnson County who spoke a language other than English at home, 7,420 (5.6% of the population) reported speaking English less than “very well”, or in other words, would be considered to have limited English proficiency. The table below shows the language subgroups as follows: Persons in Johnson County Who Reported Speaking English Less Than “Very Well” Language Spoken Number of Persons Percent of Total Population Spanish 2,149 1.6% Other Indo-European language 971 0.7% Asian & Pacific Island language 3,300 2.5% Other languages 1000 0.8% Source: 2012-2016 American Community Survey, 2016 ACS 5 Year Estimates Task 1, Step 2C; Analyze the data collected According to the University of Iowa’s fall 2017 Profile of International Students and Scholars, China, India, South Korea, and Malaysia remain the top represented countries in the international student population. Iran (58 students) rounds out the top five, replacing Taiwan (79 students) from the fall 2011 largest international student enrollment representations. While the same data is not available for the international scholar population, it can be assumed that past national representation trends found among the student population can be applied to the international scholar population, as three of the top five represented countries are the same for both international students and scholars in 2017. The University of Iowa’s Intensive English Program (IIEP) reports 200 international students enrolled in the intensive English language classes, while other visiting students speak and understand, at minimum, some English. The International Students and Scholars Services (OISS) director stated that the student population from India generally speaks advanced-to-fluent English. Visiting scholars have no English speaking requirements and often speak little-to-no English. The scholars attend the University to conduct research with an affiliated University member who speaks the scholar’s native language. There is an additional international population of approximately 500 dependents and spouses that accompany international students and scholars. Task 1, Step 2D; Identify any concentrations of persons within service area No large concentrations of LEP persons exist in the Iowa City urbanized area. Task 1, Step 3; Consult state and local sources of data The Iowa City Community School District (ICCSD) and the Iowa Department of Education compile information regarding the number of students receiving English Language Learning (ELL) services. The ICCSD ELL services are largely attributed to an influx of Spanish, Bosnian, and 13 Vietnamese speakers, similar to many of Iowa’s schools. For the 2017-2018 school year, there are 13,850 students (IA Dept. of Education Certified Enrollment) in the ICCSD. Of thos e, 11.3% (1,563 students) receive English Language Learning services. This is up from the 3.8% (482 students) receiving ELL services in the 2012-2013 school year. Task 1, Step 4; Community organizations that serve LEP persons MPOJC have current associations with local business, the Iowa City Community School District, and the University of Iowa and their OISS center. All of these organizations provide service for persons speaking limited English. Task 1, Step 4A; Identify community organizations LEP persons are served mainly by the University of Iowa’s OISS center. Task 1, Step 4B; Contact relevant community organizations MPOJC, in collaboration with Iowa City Transit, has developed a working relationship with the University of Iowa’s OISS center for language assistance services. Task 1, Step 4C; Obtain information MPOJC will continue to reach out to LEP persons and organizations in order to gather relevant information and provide information. Factor 2: Frequency with which LEP individuals come into contact with MPOJC programs, activities, and services. Task 2, Step 1; Review the relevant programs, activities, and services you provide MPOJC provides primarily planning services to member agencies. MPOJC does not operate any transit services and has limited contact with the LEP population. MPOJC’s language assistance program includes: • Printed outreach materials • Web-based outreach materials • Public meetings • Local news media • Planning activities such as the Long Range Transportation Plan, Passenger Transportation Plan, Transportation Improvement Plan, and Work Program MPOJC has identified City of Iowa City employees that have language skills to assist with the LEP population where language is a barrier. Most employees indicated that encounters with customers who were unable to communicate in English were rare. The MPOJC website has the ability to translate up to 80 different languages and also has access to Iowa City’s Language Line program. Task 2, Step 2; Review information obtained from community organizations Through interviews and planning sessions, Iowa City Transit/MPOJC has discovered that most community organizations want more service related to jobs, education, day care, and health care and have identified very few LEP issues. Community organizations include: o The Arc of Southeast Iowa o Neighborhood Centers of Johnson County o Systems Unlimited o Chatham Oaks Care Facility 14 o Hometies Childcare o Reach for Your Potential o United Action for Youth o Big Brothers/Big Sisters o Four Oaks o Youth Homes o Goodwill Industries o Shelter House o Iowa City Community School District o Access 2 Independence o Elder Services Task 2, Step 3; Consult directly with LEP persons LEP persons were consulted through the Title VI planning process through interviews with agencies (and clients) listed above. Factor 3: Assess the nature and importance of the program, activity, or service provided by the program Task 3, Step 1; Identify your agencies most critical services MPOJC provides primarily planning services to member agencies. MPOJC does not operate any transit services. Task 3, Step 2; Review input from community organizations and LEP persons MPOJC has received very little input from the community regarding problems with language barriers. Factor 4: Assessing the resources available to the recipient and costs Task 4, Step 1; Inventory language assistance measures currently being provided, along with associated costs MPOJC provides the following language assistance measures to date: • Language assistance service on website for over 80 languages • Language Line available • Identified employees that speak a language other than English • Information translated into 3 different languages on website Task 4, Step 2; Determine what, if any additional services are needed to provide meaningful access Iowa City Transit/MPOJC will focus on the following service improvements: • Translation of critical printed information • Improve website information regarding LEP • Translation of paratransit information • Provide additional signage in buses in multiple languages • Include LEP in driver training Task 4, Step 3; Analyze your budget Like most public agencies, MPOJC budgets are constrained by several factors and staff resources are also limited. Devoting more resources to printing, webpage design, signage, and additional administrative costs may be included in future budgets. 15 Task 4, Step 4; Consider cost effective practices for providing language services MPOJC will continue to work with the community and the university to provide cost effective practices including researching and pursuing language assistance products and translation services developed and paid by local, regional, and state government agencies. B. Developing a Language Assistance Plan a. Results of Four Factor Analysis: MPOJC is part of the Iowa City Urbanized Area that includes a large university with over 30,000 students. Because of the University, many foreign students and faculty live in the Iowa City urbanized area creating the potential for language issues. As identified in the four-factor analysis, both the Hispanic/Latino and the Asian/Pacific Island populations were identified as needing language assistance since their populations were each over 5% of the total population in Iowa City. Because of the diversity of the Asian/Pacific Island population, Iowa City Transit/MPOJC approached the University of Iowa’s Office of International Students and Scholars to assist in identifying the top Asian/Pacific Island languages within the University system that may require language assistance. Chinese and Korean were identified as the top two Asian/Pacific Island languages. As a result, Iowa City Transit/MPOJC offers information in Chinese, Korean, and Spanish. b. Language Assistance Services by Language: The following measures have or will be implemented to ensure LEP persons have adequate access to transit information: • Iowa City Transit, in collaboration with Coralville Transit, Johnson County SEATS, University of Iowa Cambus, and MPOJC have developed a working relationship with the University of Iowa’s Office of International Students and Scholars (OISS) for language assistance services. OISS has agreed to assist the transit agencies in Johnson County by distributing transit program information to international students and scholars. • MPOJC will identify any employees who speak a language other than English. For those employees who are able and willing to provide translation services, their services will be called upon as needed during fixed route service hours to interpret and assist LEP individuals. • The City of Iowa City (MPOJC) has a multilingual 24-hour telephone service, the Language Line. The Language Line is a three-way call translation service that can translate numerous languages. Language Line Services provides a sheet which lists the languages available for translation assistance. The language sheet can be used by transit agency staff to determine the language spoken by an LEP individual. • MPOJC will develop additional language services on their websites. A link will be added to the websites that will have general information translated in the most common spoken languages in Johnson County. c. Notice to LEP Persons: MPOJC will provide general information to the public in the most common spoken languages in Johnson County on the transit websites. 16 d. Monitor, Evaluate and Update Language Access Plan: All language assistance programs and procedures will be evaluated on an annual basis. The following will be monitored and reviewed annually: • The number of documented LEP persons encountered • How the needs of the LEP persons were addressed • Determine whether local language assistance programs have been effective Each encounter with an LEP person will be recorded and reported directly to the MPOJC Executive Director. Dissemination of the Title VI/LEP Plan includes a link to the Title VI/LEP Plan on the MPOJC websites. Any person or agency with internet access will be able to access and download the plan from the above-referenced website. Alternatively, any person or agency may request a copy of the plan via telephone, fax, mail, or in person, and shall be provided a copy of the plan at no cost. LEP individuals may request copies of the plan in translation which will provided if feasible. e. Employee Training: Current and incoming employees will be trained on the policies and procedures of the language assistance program. Staff would have the necessary information provided to them to assist LEP individuals. The following information will be available to assure staff can adequately assist LEP persons: • Information on Title VI Policy and LEP responsibilities • Description of language assistance services offered to the public • Contact information of chosen bilingual staff who have agreed to assist in translation services • Documentation of language assistance requests • Use of the Language Line Services • How to handle a potential Title VI/LEP complaint Safe Harbor Provision As identified in the four- factor analysis, MPOJC identified Spanish speakers (2,149 in population) and Asian (Pacific Island) speakers (3,300 in population) as requiring language/written materials assistance. The Asian language speakers were also identified in the analysis of the University population. Translation of written materials for these populations are included on the MPOJC website and on posted information. MINORITY REPRESTATION ON PLANNING AND ADVISORY BODIES MPOJC Board is made up of elected officials. The Transportation Technical Advisory Committee the Regional Trails and Bicycling Committee consist mainly of municipal or county staff appointed by the elected officials. MPOJC does encourage participation by minorities in Board created ad- hoc committees through their postings. MPOJC Urbanized Area Policy Board The MPOJC Urbanized Area Policy Board includes representatives from all governmental units included in the Iowa City Urbanized Area as defined by the U.S. Census. The number of 17 representatives is roughly proportional to population, although Iowa City is limited to six members so they do not have a majority of the Board. All representatives are elected officials (the University of Iowa's representative is appointed by the president of the University). Federal transportation regulations mandate the Iowa Department of Transportation be included as a non-voting member. Current Members: Steve Berner (Chair): Mayor, City of Tiffin Tom Gill: Coralville City Council Meghann Foster: Coralville City Council Bruce Teague: Iowa City City Council Rockne Cole: Iowa City City Council Mazahir Salih: Iowa City City Council Susan Mims: Iowa City City Council Pauline Taylor: Iowa City City Council John Thomas: Iowa City City Council Mike Carberry: Johnson County Board of Supervisors Lisa Green-Douglass: Johnson County Board of Supervisors Terry Donahue (Vice Chair): Mayor, City of North Liberty Chris Hoffman: North Liberty City Council Louise From: Mayor, City of University Heights Jim Sayre: University of Iowa, Parking and Transportation Lori Roetlin: ICCSD (non-voting) Group Number Male 9 Female 7 White 14 Black or African American 2 American Indian or Alaskan Native 0 Asian 0 Native Hawaiian or other Pacific Islander 0 Other 0 MPOJC Transportation Technical Advisory Committee The Transportation Technical Advisory Committee (TTAC) advises the Urbanized Area Policy Board on policy matters. This committee is composed of transportation staff members from appointed by MPOJC member agencies. Representatives of the Iowa and U.S. Departments of Transportation are also represented on the Transportation TAC. This committee meets on an as- needed basis. Current Members: Kelly Hayworth: City Administrator, City of Coralville Vicky Robrock: Director, Parking and Transportation, City of Coralville Dan Holderness: City Engineer, City of Coralville 18 Simon Andrew: Assistant to the City Manager, City of Iowa City Darian Nagle-Gamm: Director, Transportation Services, City of Iowa City Mark Rummel: Assoc. Director, Transportation Services, City of Iowa City Ron Knoche: Director of Public Works, City of Iowa City Jason Havel: City Engineer, City of Iowa City Greg Parker: Johnson County Engineer Tom Brase: Johnson County SEATS Brian McClatchey: Manager, University of Iowa Cambus David Kieft: Business Manager, University of Iowa Sadie Greiner: Assoc. Director Planning, Design and Construction, University of Iowa Catherine Cutler: Transportation Planner, Iowa DOT District 6 Darla Hugaboom: Federal Highway Administration, Ames Bob Oppliger: Regional Trails & Bicycling Committee Dean Wheatley: City Planner, City of North Liberty Louise From: Mayor, City of University Heights Doug Boldt: City Administrator, City of Tiffin Brock Grenis: East Central Iowa Council of Governments Group Number Male 14 Female 6 White 20 Black or African American 0 American Indian or Alaskan Native 0 Asian 0 Native Hawaiian or other Pacific Islander 0 Other 0 MPOJC Regional Trails and Bicycling Committee The MPOJC Regional Trails and Bicycling Committee (RTBC) is an ad hoc subcommittee of the MPOJC Transportation Technical Advisory Committee. The RTBC includes representatives appointed by each MPOJC entity and several bicycle interest groups. The RTBC is a valuable information sharing and planning group for our cities as we work toward regional trail connections and connections with multi-county trails such as the American Discovery Trial, the Hoover Nature Trail, and the Ioway Trail. As a subcommittee of MPOJC, the RTBC is able to discuss and make recommendations on trails, bicycling and pedestrian issues as requested by MPOJC entities. Current Members: Sherri Proud: Director, Parks and Recreation, City of Coralville Juli Seydell Johnson: Director, Parks and Recreation, City of Iowa City Shelly Simpson: Director, Parks and Recreation, City of North Liberty Doug Boldt: City Administrator, City of Tiffin Louise From: Mayor, City of University Heights 19 Janelle Rettig: Johnson County Board of Supervisors Michelle Ribble: Parking and Transportation, University of Iowa Brian Loring: Bicyclists of Iowa City Anne Duggan: Think Bicycles Coalition of Johnson County Bob Oppliger: Think Bicycles of Johnson County Group Number Male 3 Female 7 White 10 Black or African American 0 American Indian or Alaskan Native 0 Asian 0 Native Hawaiian or other Pacific Islander 0 Other 0 ASSISTANCE TO SUBRECIPIENTS/MONITORING SUBRECIPIENTS MPOJC does not currently have any subrecipients. MPOJC does ensure compliance with Title VI requirements by a subrecipient by undertaking the following activities: • Document its process for ensuring that all subrecipients are complying with the general reporting requirements, as well as other requirements that apply to the subrecipient. • Collect Title VI Programs from subrecipients and review programs for compliance. • In response to a complaint of discrimination, or as otherwise deemed necessary by the primary recipient, the primary recipient shall request that subrecipients who provide transportation services verify that their level and quality of service is provided on an equitable basis. DETERMINATION OF SITE OR LOCATION OF FACILITIES MPOJC is part of the City of Iowa City and is not responsible for facility development. DEMOGRAPHICS/MAPPING As part of the MPOJC Long Range Transportation Plan process, demographic profiles have been developed. Attached are three maps that were produced identifying locations of socioeconomic groups, including low-income and minority populations as well as special needs housing. Also included in each map is the location of STBG/TAP projects from FY2015 and FY2016 as well as each bus route in the metropolitan area. Mobility needs of minority populations are considered in the MPOJC planning process in the Long Range Transportation Plan scoring criteria for STBG and TAP projects. Many of the scoring criteria take into consideration the needs of minority populations; including Economic Opportunity, 20 Environment, Quality of Life, Choice, Health, and Equity. Minority locations are also considered regarding bus routes and operating formula funding for each transit agency (see attached maps). No disparate impacts have been identified in by any participating MPOJC community in any planning documents or MPOJC’s transportation investment programs. Attached maps: • Median Household Income/Transit Routes/STBG and TAP project locations • Special-Needs Housing/Transit Routes/STBG and TAP project locations • Non-White Population Density/Transit Routes/STBG and TAP Project locations 21 Attachment A: MPOJC Title VI Resolution 22 Attachment B: MPOJC Title VI Complaint Form METROPOLITAN PLANNING ORGANIZATION of JOHNSON COUNTY TITLE VI NOTICE TO THE PUBLIC The Metropolitan Planning Organization of Johnson County (MPOJC) hereby gives public notice that it is the policy of MPOJC to assure full compliance with Title VI of the Civil Rights Act of 1964, related statutes and regulation provide that no person shall on the ground of race, color, or national origin be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. The Civil Rights Restoration Act of 1987 amended Title VI to specify that entire institutions receiving federal funds, whether schools, colleges, government entities, or private employers, must comply with Federal civil rights laws, rather than just the particular programs or activities that receive federal funds. MPOJC is concerned with the impacts of our programs, projects, and activities on low-income and minority populations (“Environmental Justice”) under the Title VI. Any person who believes that they are being denied participation in a project, denied benefits of a program, or otherwise being discriminated against because they identify with one of the listed characteristics or protected classes, please contact: Brad Neumann, Assistant Transportation Planner & Title VI Coordinator Metropolitan Planning Organization of Johnson County 319-356-5235 or brad-neumann@iowa-city.org OR, you may also contact: Iowa Department of Transportation’s Civil Rights Coordinator Office of Employee Services - Civil Rights 800-262-0003 or 515-262-1921 PLAESE CONTACT THE TITLE VI COORDINATOR ABOVE AS SOON AS POSSIBLE, BUT NO LATER THAN 180 DAYS AFTER THE ALLEGED DISCRIMINATION OCCURRED, OR IF THERE HAS BEEN A CONTINUING COURSE OF CONDUCT, NO LATER THAN 180 DAYS AFTER THE ALLEGED DISCRIMINATION WAS DISCONTINUED. For more information about Title VI, visit the Iowa DOT’s Civil Rights website at: http://www.iowadot.gov/civilrights/ or contact the MPOJC Title VI Coordinator 23 Attachment C: MPOJC Title VI Complaint Form METROPOLITAN PLANNING ORGANIZZATION of JOHNSON COUNTY TITLE VI COMPLAINT FORM This form may be used to file a complaint with the Metropolitan Planning Organization of Johnson County (as part of the City of Iowa City) based on violations of Title VI of the Civil Rights Act of 1964. You are not required to use this form, a letter that provides the same information may be submitted to file your complaint. Complaints must be submitted within 180 calendar days. Name: Date: Street Address: City: State: Zip: Telephone: (home) (work) Individual(s) discriminated against, if different that above (use additional pages if needed). Name: Date: Street Address: City: State: Zip: Telephone: (home) (work) Please explain your relationship with the individual(s) indicated above: Name of agency and department or program that discriminated: Agency or department name: Name of Individual (if known): Address: City: State: Zip: Date(s) of alleged discrimination: Date Discrimination began Last or most recent date 24 ALLEGED DISCRIMINATION: If your complaint is in regard to discrimination in the delivery of services or discrimination that involved the treatment of you by others by the agency or department indicated above, please indicate below the basin on which you believe these discriminatory actions were taken. Race Color National Origin Explain: Please explain as clearly as possible what happened. Provide the name(s) of witness(es) and others involved in the alleged discrimination. (attach additional sheets if necessary and provide a copy of written materials pertaining to your case). Signature: __________________________________ Date: __________________ Note: MPOJC (as part of the City of Iowa City) prohibits retaliation or intimidation against anyone because that individual has either taken action or participated in action to secure rights protected by policies of the City. Please inform the Iowa City Civil Rights Office if you feel you were intimidated or experienced perceived retaliation in relation to filing this complaint. 25 Attachment D: MPOJC Public Input Process Metropolitan Planning Organization of Johnson County PUBLIC PARTICIPATION PLAN Adopted by the Urbanized Area Policy Board September 20, 2017 26 IMPO ORGANIZATION I Urbanized Area Policy Board Susan Mims, Chairperson Council Member, City of Iowa City Terry Dickens Council Member, City of Iowa City Kingsley Botchway Council Member, City of Iowa City Pauline Taylor Council Member, City of Iowa City John Thomas Council Member, City of Iowa City Rockne Cole Council Member, City of Iowa City Steve Berner, Vice Chairperson Mayor, City of Tiffin Jill Dodds Council Member, City of Coralville Tom Gill Council Member, City of Coralville Mike Carberry Johnson County Board of Supervisors Janelle Rettig Johnson County Board of Supervisors Terry Donahue Mayor, City of North Liberty Vacant Council Member, City of North Liberty Louise From Mayor, City of University Heights David Ricketts Director, Parking and Transportation, University of Iowa Chris Lynch (non-voting) Board Member, Iowa City Community School District Rural Policy Board Tim Kemp, Chairperson Mayor, City of Hills Christopher Taylor, Vice Chairperson Mayor, City of Swisher Mike Carberry Johnson County Board of Supervisors Janelle Rettig Johnson County Board of Supervisors Sandra Flake Mayor, City of Lone Tree Mickey Coonfare Mayor, City of Shueyville Steve Stange Mayor, City of Solon Brodie Campbell Council Member, City of Oxford Transportation Technical Advisory Committee (TTAC) Kelly Hayworth City Administrator, City of Coralville Dan Holderness City Engineer, City of Coralville Vicky Robrock Director, Parking and Transportation, City of Coralville Mark Rummel Acting Director, Transportation Services, City of Iowa City Vacant Director, Transportation Services, City of Iowa City Ron Knoche Director, Public Works, City of Iowa City Jason Havel City Engineer, City of Iowa City Simon Andrew Assistant to the City Manager, City of Iowa City Dean Wheatley Planning Director, City of North Liberty Louise From Mayor, City of University Heights Doug Boldt City Administrator, City of Tiffin Greg Parker Johnson County Engineer Tom Brase Director, Johnson County SEATS Brian McClatchey Cambus Manager, University of Iowa David Kieft Business Manager, University of Iowa 27 Sadie Greiner Director, Design and Construction, University of Iowa Terry Dahms MPOJC Regional Trails & Bicycling Committee Cathy Cutler (ex-officio) Iowa DOT District 6 Planner, Cedar Rapids Darla Hugaboom (ex-officio) Federal Highway Administration, Ames Brock Grenis (ex-officio) East Central Iowa Council of Governments Mark Bechtel (ex-officio) Federal Transit Administration, Kansas City (TTAC is charged with making technical recommendations to the Urbanized Area Policy Board) Regional Trails and Bicycling Committee (RTBC) Sherri Proud Director, Parks and Recreation, City of Coralville Juli Seydell-Johnson Director, Parks and Recreation, City of Iowa City Shelly Simpson Director, Parks and Recreation, City of North Liberty Louise From Mayor, City of University Heights Janelle Rettig Johnson County Board of Supervisors Michelle Ribble Parking and Transportation, University of Iowa Brian Loring Bicyclists of Iowa City Anne Duggan Think Bicycles Coalition of Johnson County Terry Dahms Johnson County Trails Foundation Doug Boldt City Administrator, City of Tiffin (RTBC is charged with making recommendations to the TTAC and Urbanized Area Policy Board) MPO Transportation Planning Division Staff Kent Ralston Executive Director Darian Nagle-Gamm Senior Transportation Engineering Planner Brad Neumann Assistant Transportation Planner Emily Bothell Assistant Transportation Planner Sarah Walz Assistant Transportation Planner 28 29 INTRODUCTION I Providing opportunities for public input during planning processes ensures that future development is informed by the interests of the community. As a result, residents of MPOJC entities are routinely encouraged to participate in local planning efforts. The following MPOJC Public Participation Plan, in accordance with the Code of Federal Regulations section §450.316 “Interested parties, participation, and consultation”, documents a process for providing citizens and stakeholders with reasonable opportunities to be involved in the planning process. The core public involvement opportunities for MPOJC work products include the development and adoption of the Long-Range Transportation Plan, the Transportation Improvement Program, the Passenger Transportation Plan, the Transportation Planning Work Program, and apportionment of Surface Transportation Block Grant Program and Transportation Alternatives Program funds. Similarly, the entities of Coralville, Iowa City, North Liberty, Tiffin, University Heights, Johnson County, and the University of Iowa each follow their own public involvement processes when developing or updating local plans. However, the University of Iowa uses the MPO’s Public Participation Plan process to satisfy the public participation requirements for its annual Program of Projects for transit, and the Transportation Improvement Program (TIP) public notice of public involvement activities and time established for public review and comment on the TIP will satisfy the Transit Program of Projects requirements of the FTA Section 5307 Program. 30 I MPO PLANNING BOUNDARY I 31 MPO PUBLIC INPUT PROCESS I Outreach Strategies MPOJC gathers public comment on each key work product and forwards the comments to the Urbanized Area Policy Board and sub-committees for consideration during the decision making process. The following three methods form the foundation for public involvement during development of key MPOJC products. Public Comment Period MPOJC staff initiates a formal public comment period lasting 30 days prior to the adoption and/or amendment of the Long Range Transportation Plan, the Transportation Improvement Program (15 days minimum prior for TIP amendments), and the Passenger Transportation Plan. During public comment periods, residents are encouraged to submit written comments on the given topic. MPOJC staff then forwards these comments to the MPOJC Urbanized Area Policy Board for consideration during the decision making process. Written public input may be submitted to: Kent Ralston, Director Metropolitan Planning Organization of Johnson County 410 E. Washington St., Iowa City, IA 52245 Kent-ralston@iowa-city.org Urbanized Area Policy Board Public Meetings In addition to written input, residents are encouraged to attend and provide comments at regularly scheduled Urbanized Area Policy Board meetings where MPOJC work products are adopted or amended. Staff typically provides a brief presentation followed by a period for formal public comment. Anyone wishing to provide input is given an opportunity, and all comments become part of the public record. Public meetings of the Urbanized Area Policy Board are open to the public and are subject to the Iowa’s Open Meetings Law. MPO member entities may request a special meeting of the Urbanized Area Policy Board to consider time sensitive amendments to the adopted Transportation Improvement Program. This capability is intended to prevent costly delays in the project letting process. Public Workshops/Open Houses Public workshops are informal and open to all residents. The purpose of the workshop is to provide information to the public and to solicit public comment. An attendance record is kept and attendees are given the opportunity to sign up for the MPOJC mailing list. MPOJC staff typically provide a brief presentation, share information using displays and handouts, and interact with the public to answer questions. Public workshops are frequently used for key MPOJC work products. Accommodations for Special Populations: All meeting rooms are accessible by ADA standards. Additionally, any MPO documents can be made available in alternative formats upon request. 32 Individuals with disabilities may request special accommodations by contacting MPOJC staff at (319) 356-5230. GETTING THE WORD OUT I MPOJC uses five outlets to notify residents about upcoming public comment periods and public workshops: 1. Residents may sign-up to receive email notices of public input opportunities by visiting www.icgov.org/e-subscriptions and completing the subscription form. 2. Notices of public input opportunities are published in the Iowa City Press Citizen. 3. The MPOJC website (www.MPOJC.org) lists upcoming meeting information. 4. Posters are displayed Iowa City, Coralville, and University of Iowa Cambus buses. 5. Notices are sent to the following MPOJC Public Input Organizations: ▪ Access 2 Independence ▪ Allen Lund Company ▪ Bicyclists of Iowa City ▪ Chamber of Commerce ▪ Citizens for Sensible Development ▪ Clear Creek Amana School District ▪ Iowa City Area Assoc. of Realtors ▪ Iowa City Area Development Group ▪ Iowa City Historic Preservation Commission ▪ Iowa City/Johnson County Senior Center ▪ Iowa City Neighborhood Services Office ▪ Iowa City Sierra Club ▪ Iowa City School Board ▪ Iowa Interstate Railroad ▪ MPOJC Regional Trails and Bicycling Committee ▪ Johnson County Historic Preservation Commission ▪ Johnson Co. Historical Society ▪ Coralville Parks & Recreation Commission ▪ CRANDIC Railroad ▪ Environmental Advocates ▪ FAIR! ▪ Friends of the Iowa River Scenic Trail ▪ Friends of Historic Preservation ▪ Goodwill of the Heartland ▪ Iowa Bicycle Coalition ▪ Johnson Co. Planning and Zoning Commission ▪ Johnson Co. SEATS ▪ League of Women Voters of Johnson County ▪ North Liberty Parks & Recreation Commission ▪ North Liberty Community Center ▪ Project GREEN ▪ Soil & Water Conservation Service ▪ Systems Unlimited ▪ Tiffin Planning and Zoning Commission 33 To request being added to the MPOJC Public Input Organization list, please contact MPOJC staff at (319) 356-5230. PROCEDURAL NOTICES AND PROCESSES I Public Participation Plan The Public Participation Plan outlines the process MPOJC will follow to adequately involve the community and gather meaningful input regarding transportation decisions. A minimum public comment period of 45 days will be established prior to any Public Participation Plan adoption or revision. Notice is sent to interested parties, posted on the MPOJC website, and posted in a local newspaper 45 days in advance of any change. Long Range Transportation Plan The Long Range Transportation Plan (LRTP) provides direction and guidance for MPOJC to make efficient transportation investment decisions over a 20-year planning horizon and to address major transportation needs in the Iowa City Urbanized Area. The LRTP must be updated every five years. A minimum of two public workshops shall be held to present new or major updates to the LRTP prior to adoption. At least one of these meetings shall be held a minimum of 30 days prior to adoption of the LRTP to provide for a 30-day comment period. Notice is sent to interested parties and posted on the MPOJC website. Amendments to the LRTP require a recommendation from the Transportation Technical Advisory Committee (TTAC). A 30-day public input notice will be published in the Iowa City Press-Citizen prior to the Urbanized Area Policy Board meeting. Notice is sent to interested parties and posted on the MPOJC website. Transportation Improvement Plan The Transportation Improvement Program (TIP) is a four-year schedule of projects to improve or maintain the quality of the public transportation network. A new TIP is developed and adopted annually. Revising the Approved TIP: Revisions are defined as any changes to the TIP that occur outside of the annual updating process. There are two types of changes that occur under the umbrella of revision. The first is a major revision or “Amendment.” The second is a minor revision or “Administrative Modification.” The MPO uses the following definitions and thresholds when determining an amendment vs. an administrative modification. Amendments: An amendment is a revision to the TIP that involves a major change to a project included in the TIP, the creation of a new project, a major change in design concept, or a change in scope or project cost. The following criteria define the need for an amendment: 34 • Project Cost: Projects in which the recalculated project costs increase federal aid by more than 30% or increase total federal aid by more than $2 million from the original amount. • Schedule Changes: Projects added or deleted from the TIP. • Funding Sources: Adding an additional federal funding source. • Scope Changes: Changing the project termini, project alignment, the amount of through lanes, type of work from an overlay to reconstruction, or a change to include widening of the roadway. Procedural Requirements for an Amendment: Amendments are considered major revisions and therefore have additional procedural requirements. When the TIP is amended, MPOJC is required to conduct our adopted amendment process, including public review and comment, re- demonstration of fiscal constraint or a conformity determination (non-exempt projects in nonattainment and maintenance areas), review by the Transportation Technical Advisory Committee (TTAC), and Urbanized Area Policy Board approval. Notices announcing TIP amendments are published in the Iowa City Press-Citizen a minimum of 15 days prior to an Urbanized Area Policy Board meeting. Iowa DOT sponsored projects located within the MPO planning boundary must also use the MPO’s public participation process. Illustrative projects that are found to be regionally significant must also use the MPOJC adopted amendment process, if revised. Administrative Modifications: A minor revision to a TIP is known as an administrative modification. Administrative modifications include minor changes to project costs, minor changes to funding sources, and minor changes to project phase initiation dates. Administrative modifications are subject to re-demonstration of fiscal constraint of the TIP. The following criteria define the need for an administrative modification: • Project Costs: Projects in which the recalculated project costs do not increase federal aid by more than 30% or do not increase total federal aid by more than $2 million from the original amount. • Schedule Changes: Changes in schedules to projects included in the first four years of the TIP. • Funding Sources: Changing funding from one source to another. • Scope changes: All changes to a project’s scope will require an amendment. Procedural Requirements for an Administrative Modification: Administrative modifications have simplified procedures which allow more flexibility when processing changes. Public participation procedures are not required for administrative modifications (both local and DOT projects). Passenger Transportation Plan The MPOJC Passenger Transportation Plan (PTP) promotes joint, coordinated passenger transportation planning programs and provides needs-based justification for passenger transportation projects. The PTP involves key community organizations, including human services organizations, public and private transit providers, and local business representatives. The PTP 35 identifies transportation needs and service requests and recommends strategies or projects to overcome these needs. The PTP is updated every 5 years with annual updates provided to the Iowa DOT. Amendments to the Passenger Transportation Plan will be required when any changes are proposed to Section 5310 funding. Amendments will be presented to the Transportation Technical Advisory Committee and a recommendation will be presented to the Urbanized Area Policy Board for approval. A 30-day public input notice will be published in the Press-Citizen prior to the Urbanized Area Policy Board meeting. A notice is sent to interested parties and is posted on the MPOJC website. Transportation Planning Work Program The Transportation Planning Work Program (TPWP) is developed each year by MPOJC in a coordinated effort involving the Transportation Technical Advisory Committee, the Regional Trails and Bicycling Committee, and the Urbanized Area Policy Board. The TPWP includes special requested projects, ongoing and routinely occurring projects, projects required by the FHWA, FTA, and Iowa DOT, and carry-over projects from the previous year. Public participation is required in the preparation of the TPWP. The Transportation Technical Advisory Committee reviews and makes a recommendation to the Urbanized Area Policy Board for approval. A notice is sent to interested parties and is posted on the MPOJC website. 36 TYPE OF PUBLIC INPUT NOTICEPUBLIC INPUT OPPORTUNITIESMPO PROGRAMDESCRIPTIONREQUIREMENTSPublic Participation PlanPublic input process forUpdated as necessary(45 days)YESYESYEStransportation planningLong Range Transportation Plan20-year long range planAdopted every 5-years by MPOJC(30 days)YESYESYESYESincluding policies and projectsUrbanized Area Policy BoardAmending the LRTPChanges to projects and Adopted as necessary(30 days)YESYESYESYESfinancial constraints4-year schedule of projectsAdopted annually by MPOJC(30 days)YESYESYESYESUrbanized Area Policy BoardAwarding STBG/TAP fundingLocal process to awardAwarded by MPOJC YESYESYESfederal fundingUrbanized Area Policy BoardAmending the TIPChanges to programmedAdopted as necessary(15 days min)YESYESYESprojectsPassenger Tranportation ProgramCoordinated transitAdopted every 5-years by MPOJC(30 days)YESYESYESplanningUrbanized Area Policy BoardTransportation Planning Work ProgramAnnual Work ProgramAdopted annually by MPOJCYESYESUrbanized Area Policy BoardPublic Input/MtgOpen HouseTransportation Improvement ProgramPublic Notice/Public CommentBus Notice/PosterNotice to Interested PartiesWeb Notice 37 Attachment D: Iowa City Transit Contract Language TITLE VI CONTRACT LANGUAGE During the performance of this contract, the contractor, for itself, its assignees, and successors in interest, (hereinafter referred to as the "contractor") agrees as follows: 1. Compliance with Regulation The contractor shall comply with the regulations relative to nondiscrimination in federally assisted programs of the Department of Transportation (hereinafter referred to as DOT), Title 49, Code of Federal Regulations, part 21 (hereinafter referred to as the Regulations), as they may be amended from time to time, herein incorporated by reference and made a part of this contract. 2. Nondiscrimination The contractor, with regard to the work performed during the contract, shall not discriminate on the grounds of race, color, sex, or national origin in the selection of and retention of subcontractors, including procurement of materials and leases of equipment. The contractor shall not participate either directly or indirectly in discrimination prohibited by Section 21.5 of the Regulations, including employment practices when the contract covers a program set forth in Appendix B of the Regulations. 3. Solicitation for Subcontracts, including Procurement of Materials and Equipment In all solicitations either by competitive bidding or negotiations made by the contractor for work to be performed under a subcontract, including the procurement of material for leases of equipment, each potential subcontractor or supplier shall be notified by the contractor of the contractor's obligations under this contract and the Regulations relative to nondiscrimination on the grounds of race, color, sex, or national origin. 4. Information and Reports The contractors shall provide all information and reports required by the Regulation or directives issued pursuant thereto, and shall permit access to its books, records, accounts, other sources of information and its facilities as may be determined by the MPOJC, the City of Iowa City, Iowa Department of Transportation or appropriate Federal Agency to be pertinent to ascertain compliance with such Regulation, orders and instructions. Where any information required of a contractor is in exclusive possession of another who fails or refuses to furnish this information, the contractor shall so certify to the Iowa Department of Transportation or the appropriate Federal Agency as needed, and shall set forth what efforts it has made to obtain the information. 38 5. Sanctions for Noncompliance In the event of the contractor's noncompliance with the nondiscrimination provisions of this contract, the MPOJC/City of Iowa City shall impose such contract sanctions as the Iowa Department of Transportation may determine to be appropriate, including, but not limited to: • Withholding of payments to the contractor under contract until the contractor complies, and/or • Cancellation, termination, or suspension of the contract, in whole or in part. 6. Incorporations of Provisions The contractor shall include the provisions of paragraphs (1) through (5) in every subcontract, including procurement of materials and leases of equipment, unless exempt by Regulations or directives issued pursuant thereto. The contractor shall take such action with respect to any subcontractor or procurement as the MPOJC/City of Iowa City, Iowa Department of Transportation, or appropriate Federal Agency may direct as a means of enforcing such provisions, including sanctions for noncompliance. 39 Attachment E: Maps: Median Household Income/Transit Routes/STP and TAP project locations Special Needs Housing/Transit Routes/STP and TAP project locations Non-White Population Density/Transit Routes/STP and TAP project locations 40 41 42