HomeMy WebLinkAboutTitle VI LEP Plan
IOWA CITY TRANSIT
TITLE VI/LEP PLAN
April 2025 – April 2028
City of Iowa City
410 E Washington Street
Iowa City, IA 52240
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Table of Contents
Introduction ...........................................................................................................3
Title VI Assurances ...............................................................................................3
Prepare and Submit a Title VI Program .................................................................3
Notification of Beneficiaries of Protection Under Title VI .......................................4
Title VI Complaint Procedures and Complaint Form .............................................5
Title VI Authorities ......................................................................................5
Coordinator Responsibilities .......................................................................5
General Responsibilities .............................................................................5
Filing a Complaint .......................................................................................5
Internal Complaint Process ........................................................................5
Transit Related Title VI Investigations, Complaints, and Lawsuits ........................7
Promoting Inclusive Public Participation ................................................................7
Provide Meaningful Access to LEP Persons .........................................................7
A. Four Factor Analysis ...................................................................................9
Factor 1 ......................................................................................................9
Factor 2 .................................................................................................... 15
Factor 3 ................................................................................................... 16
Factor 4 .................................................................................................... 17
B. Developing a Language Assistance Plan ................................................. 18
Results of Four Factor Analysis ................................................................ 18
Language Assistance Services by Language ........................................... 18
Notice to LEP Persons .............................................................................18
Monitor, Evaluate Update Language Access Plan .................................... 19
Employee Training .................................................................................... 19
Safe Harbor Provision .............................................................................. 20
Diversity Planning and Advisory Bodies…………………………….…...………….21
Assistance to Sub-recipients................................................................................21
Monitoring Sub-recipients……………………………………………………………..21
Determination of Site or Location of Facilities………………………………………21
ATTACHMENTS
• Attachment A: Certifications and Assurances
• Attachment B: Iowa City City Council Resolution Approving Title VI
• Attachment C: Iowa City Transit Title VI Complaint Form
• Attachment D: Title VI Contract Language for Transit Projects
• Attachment E: Notice of Title VI Provisions
• Attachment F: Title VI Notification
• Attachment G: Service Standards and Policies
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INTRODUCTION
The purpose of this document is to ensure that transit services operated in the City of Iowa City
are 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 transit 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
That corrective and remedial action will be taken if necessary to prevent discriminatory treatment
based on race, color, or national origin.
TITLE VI ASSURANCES
In accordance with 49 CFR Section 21.7(a), every application for financial assistance from FTA
must be accompanied by an assurance that the applicant will carry out the program in compliance
with DOT’s Title VI regulations. The FY2024 Certifications and Assurances for Iowa City Transit
were pinned into TrAMS on April 3, 2024. (Attachment A)
PREPARE AND SUBMIT A TITLE VI PROGRAM
In accordance with 49 CFR Section 21.9(b), all direct and primary recipients document their
compliance with DOT’s Title VI regulations by submitting a Title VI Program to their FTA regional
civil rights officer once every three years or as otherwise directed by FTA. Iowa City Transit’s
current Title VI Program expires on May 31, 2025 and will submit an updated Title VI every three
years after this date.
The Iowa City City Council, Iowa City Transit’s governing body, approved Iowa City Transit’s Title
VI Program on April 1st, 2025. Iowa City Transit operates a fixed route service with 21 buses at
peak time and contracts paratransit service with Johnson County SEATS using 13 light-duty
buses, serving a population of 75,264. This document contains all the elements required of a fixed
route transit provider operating in an urbanized area of less than 200,000 in population and
operating less than fifty vehicles in peak service. Since Iowa City Transit does not qualify as a
large urbanized area (UZA) all general requirements under Chapter III are included as well as
system-wide standards and policies under Chapter IV.
Johnson County SEATS provides contracted paratransit services to Iowa City Transit. Since Iowa
City Transit uses their 5310 funding in the paratransit services contract, Johnson County SEATS
is considered a sub recipient. Johnson County SEATS, with assistance from the East Central
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Iowa Council of Governments (Regional Planning Office), has produced and adopted a Title VI
Program. Iowa City Transit will require Johnson County SEATS to submit its Title VI Program at
least six months prior to Iowa City Transit’s Title VI expiration date, every three years. The new
5-year paratransit service contract between Iowa City Transit and Johnson County SEATS took
effect on August 1, 2023. Currently, Johnson County SEATS has no outstanding lawsuits or
complaints. Johnson County SEATS does have an advisory committee that includes a
representative from Iowa City Transit and the Iowa City City Council. The committee meets on a
quarterly basis.
NOTIFICATION OF BENIFICIARIES OF PROTECTION UNDER TITLE VI
IOWA CITY TRANSIT
TITLE VI POLICY STATEMENT
The City of Iowa City assures that no person shall, on the grounds of race, color, or national origin,
as provided by Title VI of the Civil Rights Act of 1964, and the Civil Rights Restoration Act of 1987
(P.L. 100.259), be excluded from or participation in, be denied benefits of, or be otherwise
subjected to discrimination under any program or activity. The City of Iowa City further assures
every effort will be made to ensure nondiscrimination in all of its committees, programs, and
activities, regardless of the funding source.
Iowa City Transit will include Title VI language in all written agreements and bid notices and will
monitor compliance.
The Iowa City Transportation Services Director will be responsible for initiating and monitoring
Title VI activities, and all other responsibilities as required. The Iowa City Civil Rights Coordinator
will be responsible for investigating complaints only.
_______________________________________________ _________________
Darian Nagle-Gamm, Director of Transportation Services Date
_______________________________________________ __________________
Stefanie Bowers, Human Rights Coordinator Date
March 27, 2025
March 27th, 2025
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TITLE VI COMPLAINT PROCEDURES AND COMPLAINT FORM
TITLE VI AUTHORITIES
Title VI of 1964 Civil Rights Act provides that no person in the United States shall, on the grounds
of race, color, nations origin, or sex be excluded from participation in, be denied benefits of, or be
otherwise subjected to discrimination under any program or activity receiving federal assistance
(23 CFR 200.9 and 49 CFR 21).
The Civil Rights Restoration Act of 1987 broadened the scope of Title VI coverage by expanding
the definition of terms “programs or activities” to include all programs and activities of Federal Aid
recipients, sub-recipients, and contractors, whether such programs and activities are federally
assisted or not (Public Law 100-259 {S.557} March 22, 1988).
COORDINATOR RESPONSIBILITES
The Iowa City Transportation Services Director is responsible for ensuring the implementation
and the day-to-day administration of the Iowa City Transit Title VI Plan. The Civil Rights
Coordinator will be responsible for investigating complaints only. The Iowa City Transportation
Services Director will be responsible for implementing, monitoring, and ensuring the City’s
compliance with the Title VI regulations.
GENERAL RESPONSIBILITIES
A. Public Dissemination
The City of Iowa City will disseminate Title VI Program information to Iowa City Transit employees,
sub-recipients, and contractors, as well as the general public. Public dissemination will 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 qualified City employees. All
complaints are confidential and may be made available to those assisting in an investigation.
C. Reporting
The Iowa City Transportation Services Director will be responsible for any reporting required by
Iowa DOT and/or FTA.
D. Remedial Action
The City of Iowa City 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 involving Title VI
issues, as to any resolution.
FILING A COMPLAINT
Eligibility
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If any individual, group of 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 the City of Iowa City. Every effort
will be made to resolve complaints informally at the agency, recipient, and/or contactor level.
Time Limitation on Filing Complaints
Title VI complaints may be filed with:
• City of Iowa City/Iowa City Transit
• Iowa Department of Transportation
• Federal Transit Administration
• U.S. Department of Transportation
In all situations, Iowa City Transit employees must contact the Iowa City Transportation Services
Director and/or the 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.
Complaints must be in writing, and must be signed by the complainant and/or the complainant’s
representative. The complainant must set forth as fully as possible the facts and circumstances
surrounding the claimed discrimination.
A Title VI complaint form is available at the Iowa City City Clerk’s office, the Iowa City
Transportation Services office, or the Iowa City Civil Rights Coordinator’s office during normal
business hours.
INTERNAL COMPLAINT PROCESSING
1. The Iowa City Civil Rights Coordinator acting as Title VI Coordinator, along with the City
Manager, 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.
2. The Iowa City Civil Rights Coordinator will then investigate the complaint. Additionally, a
copy of the complaint will be forwarded to the 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 City
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 investigators 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.
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6. Once the City of Iowa City is notified of Iowa Department of Transportation Office of
Employee Services/Civil Rights investigative report findings, the City 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 report.
8. If the complainant is not satisfied with the results of the investigation of the alleged
discriminatory practice(s), s/he shall be advised of their right to appeal Iowa DOT’s Office
of Employee Services/Civil Rights decision. Appeals must be filed within 180 days after
the City of Iowa City’s final resolution. Unless new facts not previously considered came
to light, reconsideration of the City’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”.
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 transit service provided by Iowa City Transit.
Iowa City Transit has not been asked to take part in any local, state, or federal civil rights
compliance reviews in the past three years. Iowa City Transit has not undertaken any federally
funded construction projects in the past three years.
PROMOTING INCLUSIVE PUBLIC PARTICIPATION
Public participation procedures are established to allow and encourage participation in Iowa City
Transit’s service area and include low income and minority individuals and those with limited
English proficiency. Iowa City Transit’s Public Participation Plan (PPP) has been prepared to
ensure that no one is precluded from participating in Iowa City Transit’s service planning and
development process. Iowa City Transit’s PPP includes a description of when the public
participation plan is used, regional partnerships/capital programming, meeting locations,
addressing comments, and the identification of stakeholders.
When the Public Participation Plan (PPP) is Used
Iowa City Transit will use its PPP when considering fare changes, modifications to routes and
schedules, and other transit planning projects. Including:
• Any fare increases for the cost of a general public fare, and subsequent
adjustments to youth and reduced fares
• A new route is established
• Elimination of an existing route
• A major service reduction involving 25% or more of the route miles of the system
Iowa City Transit will post service change notices on appropriate buses thirty days in advance of
the change date for minor schedule and service changes.
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Regional Partnerships/Capital Programming
For its capital programming, including major facility and bus procurement, Iowa City Transit uses
the Metropolitan Planning Organization of Johnson County’s (MPOJC) adopted Public
Participation Plan (PPP). The plan targets interest groups representing unique users of the
transportation system as well as groups involved in the growth and development of the
metropolitan area. The MPOJC PPP was adopted in July of 2022. This plan clearly indicates that
the MPO’s public participation process satisfies Iowa City Transit’s public participation
requirements for its Program of Projects and the notices for the regional Transportation
Improvement Program (TIP).
• Iowa City Transit also participates in the Passenger Transportation Plan (PTP) process
with other transportation services, both public and private, in the Iowa City Urbanized
Area. The PTP is a short-range plan that analyzes all aspects of transit operations and is
required by the Iowa Department of Transportation. The PTP Update is required every 5
years with and is reviewed annually by the MPOJC Urbanized Area Policy Board. Public
participation regarding the PTP has been ongoing since 2007 with focus groups and
interviews with transportation stakeholders, surveys, review of local plans, participation in
regional transportation planning sessions, and the gathering of background information.
Iowa City Transit will be represented on the MPOJC’s PTP steering committee which is
made up of local human services organizations and public transit providers.
• Iowa City Transit participated in the MPOJC’s Long-Range Transportation Plan open
houses in Coralville, North Liberty, and Iowa City to gather public input regarding transit
issues and participated in two surveys regarding transit service. The surveys were used
in the MPOJC’s 2050 Long-Range Transportation Plan.
• Iowa City Transit is a member of the Johnson County SEATS Paratransit Advisory
Committee. The Committee membership includes public transit providers and riders of the
paratransit system operated by Johnson County SEATS. Various community stakeholders
attend these meetings The Committee meets on a quarterly basis to discuss paratransit
needs.
• Quarterly transit manager meetings (or as needed), including Iowa City Transit, Coralville
Transit, University of Iowa Cambus, and Johnson County SEATS.
• Iowa City Transit is a voting member of the MPOJC Transportation Technical Advisory
Committee (TTAC). The TTAC comments and makes recommendations to MPOJC’s
Urbanized Area Policy Board.
• Iowa City Transit will also hold public hearings as needed regarding any change to the
transit routes or fares.
Meeting locations
When determining locations and schedules for public meetings, Iowa City Transit will:
• Schedule meetings at times and locations that are convenient and accessible for
minority and LEP communities
• Coordinate with community organizations and the MPO to implement public
engagement strategies that reach out to members of affected minority and/or LEP
communities
• Consider media outlets that serve LEP populations
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• Provide opportunities for public participation through written communications,
group discussions, and one-on-one interviews.
• Provide rides home from public participation meetings when transit is not in service
or is infrequent
Addressing Comments
All comments received through the public participation plan are given careful, thoughtful
consideration. Because there are a number of different ways riders or members of the community
can comment on proposed service or fare changes, all comments will be assembled into a single
document for presentation to the Iowa City City Council.
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, Iowa City Transit
will assemble a listing of stakeholders with whom we may regularly communicate by email or
direct mail. Iowa City Transit has assembled a list of stakeholders; including:
Community Transportation Committee
Center for Worker Justice
International Center/University of Iowa
Neighborhood Centers of Johnson County
PROVIDE MEANINGFUL ACCESS TO LEP PERSONS
Iowa City Transit, with assistance from the MPOJC, has conducted the following 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 uses the Four Factor
Analysis identified in the LEP Guidance.
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
Iowa City Transit serves a diverse community. The University of Iowa brings people from all over
the world to the Iowa City urbanized area which includes not only Iowa City but the communities
of University Heights, Coralville, North Liberty, and Tiffin. Iowa City Transit has a service contract
with the City of University Heights and operates in and around the University of Iowa campus.
Most non-English 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 2,000-3,000 persons on an annual basis as well as approximately 400
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 84,672 in 2000, 91,881 in 2005, 103,152 in
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2010,107,912 in 2014, 118,506 in 2019, and 125,395 in 2023. These numbers represent
an average annual population growth of 1.7%.
Iowa City’s current demographics:
Iowa City Statistics and Demographics Number Percent
Iowa City Population 75,264 100.0
SEX AND AGE
Male 36,738 48.8
Female 38,526 51.2
Under 5 years 3,141 4.2
5 to 9 years 2,998 4.0
10 to 14 years 2,691 3.6
15 to 19 years 8,791 11.7
20 to 24 years 18,288 24.3
25 to 34 years 10,921 14.5
35 to 44 years 7,301 9.7
45 to 54 years 6,214 8.3
55 to 59 years 2,709 3.6
60 to 64 years 3,071 4.1
65 to 74 years 5,346 7.1
75 to 84 years 2,543 3.4
85 years and over 1,250 1.7
Median age (years) 26.3 (X)
18 years and over 64,758 86.0
21 years and over 53,293 70.8
62 years and over 10,784 14.3
65 years and over 9,139 12.1
18 years and over 64,758 86.0
Male 31,578 48.8
Female 33,180 51.2
65 years and over 9,139 12.1
Male 4,054 44.4
Female 5,085 55.6
RACE
One Race 70,183 93.2
White 56,551 75.1
Black or African American 6,342 8.4
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American Indian and Alaska Native 186 0.2
Asian 5,156 6.9
Asian Indian 994 1.3
Chinese 1,797 2.4
Filipino 101 0.1
Japanese 123 0.2
Korean 627 0.8
Vietnamese 821 1.1
Other Asian 693 0.9
Native Hawaiian and Other Pacific Islander 14 0.0
Some Other Race 1,934 2.6
Two or More Races 5,081 6.8
HISPANIC OR LATINO
Hispanic or Latino (of any race) 6,088 8.1
Mexican 3,071 4.1
Puerto Rican 796 1.1
Cuban 232 0.3
Other Hispanic or Latino 1,989 2.6
Not Hispanic or Latino 69,176 91.9
White alone 54,459 72.4
HOUSEHOLDS BY TYPE
Total Households 30,780 ( X )
Family Households 12,434 100.0
Married-couple family 9,912 79.9
Male householder, no spouse present 691 5.6
Female householder, no spouse present 1,831 14.7
Nonfamily households 18,346 59.6
65 years and over 3,229 10.5
Households with individuals under 18 years 5,202 16.9
HOUSING OCCUPANCY
Total housing units 33,844 ( X )
Occupied housing units 30,588 90.4
Vacant housing units 3,256 9.6
Homeowner vacancy rate (percent) 0.0 ( X )
Rental vacancy rate (percent) 9.8 ( X )
HOUSING TENURE
Occupied housing units 30,588 ( X )
Owner-occupied housing units 13,288 43.4
Average household size of owner- 2.52 ( X )
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occupied units
Renter-occupied housing units 17,300 56.6
Average household size of renter-
occupied units
1.99 ( X )
Source: U.S. Census Bureau, 2023 American
Community Survey 5-year Estimates
There were 2,084 international students according to the University of Iowa’s fall 2024 enrollment
statistics, which represents 6.5% 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: 5 Largest National Representatives
National Representation Student Population Scholar Population
China 484 134
India 387 115
South Korea 139 38
Nigeri 111 5
Iran 75 9
Source: The University of Iowa, International Programs Annual Report 20024
Task 1, Step 2A; Identify the geographic boundaries of the area that your agency serves
The Iowa City Transit service area is defined by the city limits of Iowa City and University Heights,
and the University of Iowa campus. (Transit Service Area Map of Iowa City Urbanized Area)
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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, 2023 U.S. Census American Community Survey (ACS) data was evaluated. According
to ACS data, 22,686 persons in Johnson County (15.5% of the population) spoke a language
other than English at home. Of the 22,686 persons residing in Johnson County who spoke a
language other than English at home, 7,714 (5.3% 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 1,734 1.2%
Other Indo-European language 1,903 1.3%
Asian & Pacific Island language 2,067 1.4%
Other languages 2,010 1.4%
Source: American Community Survey, 2023 ACS 5 Year Estimates
Task 1, Step 2C; Analyze the data collected
According to The University of Iowa’s Fall 2024: A Profile of Students Enrolled, China, India, South
Korea, Nigeria, and Iran remain the top represented countries in the international student
population. The number of students from Iran (75 students) increased from the fall of 2017 (63
students), but fell to fifth place behind Nigeria (111 students) in 2025. Malaysia (57 students from
the fall 2017) is no longer one of the top 5 countries in the 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 2024.
The University of Iowa offers skills courses, such as oral, writing, and listening, to students who
do not speak English as their first language. These students are placed in specific courses based
on ESL (English as a Second Language) testing results. The University does not offer intensive
English courses.
Iowa City Transit assessed the frequency with which staff and drivers have, or could have, contact
with LEP persons. This includes documenting phone inquiries and surveying vehicle operators.
To date, the transit agencies have had very little to no contact with LEP persons.
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.
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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 predominantly serve Spanish, Arabic, French, and Swahili
speakers, similar to many of Iowa’s schools. For the 2023-2024 school year, there are 14,378
students (IA Dept. of Education Certified Enrollment) in the ICCSD. Of those, 15.3% (2,200
students) receive English Language Learning services. This is up from the 12.6% (1,836 students)
receiving ELL services in the 2019-2020 school year.
Task 1, Step 4; Community organizations that serve LEP persons
Iowa City Transit and MPOJC have current associations with local social service organizations,
the Iowa City Community School District, Kirkwood Community College, and the University of
Iowa and their International Student and Scholar Services (ISSS) center. All 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 ISSS center Kirkwood Community
College and local social service organizations that support immigrant and refugee populations.
Task 1, Step 4B; Contact relevant community organizations
Iowa City Transit in collaboration with MPOJC has developed a working relationship with the
University of Iowa’s ISSS center for language assistance services. ISSS has agreed to assist the
local transit agencies in Johnson County by distributing transit program information to
international students and scholars.
Task 1, Step 4C; Obtain information
Working through the MPO, Iowa City Transit will continue to reach out to LEP persons and
organizations in order to gather relevant information and provide transit information.
Factor 2: Frequency with which LEP individuals come into contact with transit programs,
activities, and services.
Task 2, Step 1; Review the relevant programs, activities, and services you provide
Iowa City Transit provides service on 13 regular routes from 5:50 a.m. – 10:45 p.m. All routes
operate daily with 15-minute service on the Downtown Shuttle, 20-minute service on the Court
Street, Lower Muscatine, and Towncrest routes, and 30-minute service on the South Iowa City,
Oakcrest, and West Iowa City routes on weekdays during peak periods and over the midday off-
peak period. Each of the Peninsula, North Dodge, Rochester, Highway 1, and South Gilbert routes
operate with 30-minute service during peak periods and 60-minute service during the midday off-
peak period. The Eastside Loop operates when Iowa City schools are in session. Evening service
is from 6:30 p.m. – 10:15 p.m. with the South Iowa City, Peninsula, North Dodge, West Iowa City,
Rochester, Highway 1, and South Gilbert routes operating on an hourly schedule. The Court
Street, Lower Muscatine, and Towncrest routes operate with a 40-minute service and the
Oakcrest remains on 30-minute service during the evenings. Saturday service operates all day
following the weekday evening schedules for each route with service ending at 7:40 p.m., except
for the Eastside Loop and Downtown Shuttle, which do not operate evenings and weekends.
There is no fixed route service on Sundays. During peak periods Iowa City Transit operates 21
buses at maximum service. Sixteen buses operate weekdays off-peak. During evening hours and
on Saturdays, 9 buses are in service. The Downtown Iowa City Transit Interchange is the hub of
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Iowa City Transit’s operations. All regular routes arrive and depart at the interchange except for
the Eastside Loop, allowing for coordinated transfers between buses.
Iowa City Transit began piloting fare-free service on all routes on August 1, 2023. While it was
initially scheduled as a 2-year pilot program, Iowa City Transit plans to continue operating as a
fare-free system for the foreseeable future. In August 2025, during a regularly scheduled meeting,
the Iowa City City Council expressed their support to continue to provide fare free service and
approved staff’s recommendation to remove fare boxes from all Iowa City Transit revenue
vehicles.
All Iowa City Transit fixed route buses are lift/ramp-equipped. Demand responsive paratransit
service is provided during fixed-route service hours operated by Johnson County SEATS.
There are many places where Iowa City transit riders and members of the LEP population can
come into contact with Iowa City Transit services. An important part of the development of Iowa
City Transit’s language assistance program is the assessment of major points of contact,
including:
• The use of bus service
• Communication with customer service staff
• Bus pass sales
• Printed outreach materials
• Web-based outreach materials
• Public meetings
• Transit app
• Local news media
• Audio announcements
Amongst Transportation Services staff, four drivers and one maintenance team member speak
Spanish, four drivers speak fluent French, two drivers speak fluent Swahili, one driver speaks
fluent Hindi, Urdu, and Punjabi, one driver speaks fluent Kifuliru, Cimbema, and Lingala in addition
to French and Swahili.
Iowa City Transit employees indicate that encounters with customers who were unable to
communicate in English are very rare.
Table 1: Transportation Services Languages Spoken
Language Driver Support Staff
Spanish 4 1
French 4
Swahili 2
Punjabi 1
Hindi 1
Urdu 1
Bamana 1
Italian 1
Lingala 1
Japanese 1
Ewe 1
Cibema 1
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Kifuliru 1
Task 2, Step 2; Review information obtained from community organizations
Through public input and planning sessions, Iowa City Transit has discovered that most
community organizations want more transit or transportation service related to jobs, education,
day care, and health care and have identified very few LEP issues.
Task 2, Step 3; Consult directly with LEP persons
LEP persons were consulted through the local planning process.
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
Using public transportation is important to LEP persons as indicated from discussions with local
groups and the University of Iowa. Iowa City Transit’s most critical services include:
• Fixed route services
• Paratransit services
• Coordination with other public transit agencies in the urbanized area
If limited English is a barrier to using these services then the consequences for the individual are
serious, including limited access to obtain health care, education, or employment. Critical
information from Iowa City Transit which can affect access includes:
• Route and schedule information
• Fare and payment information
• System rules
• Information about how to ride
• Public service announcements
• Safety and security
• Complaint forms
• Communication related to transit planning
• Information regarding paratransit services
An example of Iowa City Transit’s interior bus signage is included in Attachment F.
Task 3, Step 2; Review input from community organizations and LEP persons
Iowa City Transit 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
Iowa City Transit provides the following language assistance measures to date:
• Multilingual 24-hour telephone service
• Language Line available on website
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• Identified employees that speak a language other than English
• Transit information on website can be translated into 95 different
languages using built-in Google Translator tool
• Transit app available in English, French, Spanish, Italian, German,
Portuguese and Dutch
Cost for these measures is under $1500 annually.
Task 4, Step 2; Determine what, if any additional services are needed to provide meaningful
access
Iowa City Transit will focus on the following service improvements:
• Translation of critical printed information including bus schedules,
Paratransit application, Riders Guide, and Reasonable Modification
Request form
• Translate Iowa City Transit service map into Chinese, French, Arabic, and
Spanish.
Task 4, Step 3; Analyze your budget
Like most public agencies, Iowa City Transit’s budget is constrained by several factors and staff
resources are also limited. Devoting more resources to printing, webpage design, signage, and
additional administrative costs are included in future transit budgets.
Task 4, Step 4; Consider cost effective practices for providing language services
Iowa City Transit 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.
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B. Developing a Language Assistance Plan
a. Results of Four Factor Analysis:
The City of Iowa City is part of the Iowa City Urbanized Area that includes a large
university with over 32,000 students. Because of the University, many international
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 approached
the University of Iowa’s International Student and Scholar Services to assist in
identifying the top Asian/Pacific Island languages within the University system that
may require language assistance. Chinese was identified as the top Asian/Pacific
Island language. As a result, Iowa City Transit will continue to translate critical
documents in Chinese and Spanish and make them available in hardcopy or Iowa City
Transit’s website. Bus schedules have been available in Spanish, French, English,
Arabic, and Chinese since 2021.
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 has identified 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 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.
• In 2022, the Iowa City Transit website was updated to allow for quick and
easy translation of general transit information into approximately 95
different languages using Google Translate.
• Translation of critical printed information including Paratransit application,
Title VI Notice, Title VI Complaint Process and Form, Riders Guide, and
Reasonable Modification Request form into Spanish and Chinese.
c. Notice to LEP Persons:
Iowa City Transit will provide general public transit information, trip planning
instructions using the Transit app and Google transit, and translated route and
schedule information via the Iowa City Transit website.
Handouts will be made available that contain information on language assistance
services as well as a summary of important transit information and instructions for
downloading the information from the website in another language.
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The City of Iowa City also utilizes the Language Line Services for translation of
languages that are not English. Language Line Services are free to the user and
interprets from English into more than 170 languages and are accessible 24 hours a
day, 7 days a week. Those seeking language assistance can visit the transit office and
work with a customer service representative using language identification cards to
inform us as to which language they speak. The individual needing language
assistance can point at a language on the identification card which includes a message
stating, “Point to your language”. An interpreter will be called. The interpreter is
provided at no cost to you.
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
• Determine if any changes in the level of assistance available on our website
or through our
Each encounter with an LEP person will be recorded by the bus driver/office is reported
directly to the Transportation Services Director.
The Title VI/LEP Plan includes a link to the Title VI/LEP Plan on the Iowa City Transit
website at:
https://www.iowa-
city.org/WebLink/browse.aspx?id=1472428&dbid=0&repo=CityofIowaCity
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
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• How to handle a potential Title VI/LEP complaint
C. Safe Harbor Provision
As identified in the four-factor analysis, Iowa City Transit identified Spanish speakers
(1,756 households) and Asian and Pacific Island speakers (1,735 households) as
requiring language/written materials assistance. The Asian language speakers were also
identified in the analysis of the University population. Information regarding translation
services for these populations is included on the Iowa City Transit.
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DIVERSITY ON PLANNING AND ADVISORY BODIES
Iowa City Transit is part of the City of Iowa City which has an elected City Council to oversee Iowa
City Transit activities. The Mayor and one City Councilor are Black while the remaining Councilors
are Caucasian. There are a total of 3 women and 4 men on the Iowa City City Council.
Johnson County SEATS, a paratransit subrecipient to Iowa City Transit, has a 7-member advisory
committee including Iowa City representatives. All current members of this advisory committee
are Caucasian. This committee meets quarterly.
ASSISTANCE TO SUBRECIPIENTS
Johnson County SEATS, a paratransit subrecipient to Iowa City Transit, by contract requires
SEATS to comply with their Title VI Program and to report any Title VI complaints. As primary
recipient, Iowa City Transit will provide the following information to Johnson County SEATS:
• Sample notices to the public informing beneficiaries of their rights under DOT’s
Title VI regulations, procedures on how to file a complaint, and the recipient’s Title
VI complaint form.
• Sample procedures for tracking and investigating Title VI complaints filed with a
subrecipient, and when the primary recipient expects the subrecipient to notify the
primary recipient of complaints received by the subrecipient.
• Demographic information on the race and English proficiency of residents served
by the subrecipient. This information will assist the subrecipient in assessing the
level of service it provides to the community and in assessing the need for
language assistance.
• Other information will be provided at quarterly meetings with the transit systems in
the Iowa City urbanized area.
MONITORING SUBRECIPIENTS
In order for Iowa City Transit to ensure compliance with Title VI requirements by a subrecipient,
Iowa City Transit shall undertake 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.
• At the request of FTA, 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.
• Iowa City Transit will meet annually with Johnson County SEATS to ensure
compliance.
DETERMINATION OF SITE OR LOCATION OF FACILITIES
The future Iowa City Transit Operations and Maintenance Facility is in the design stage after a
2023 Low/No Emissions Award for a new facility and four replacement electric buses. We
expect to commence revenue operations in the new facility by 2029. This facility will be built on
property currently owned by the City of Iowa City.
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Attachment A: 2024 Certifications and Assurances
**FY2025 Certifications and Assurances not yet available at the time of writing this
document
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Attachment B: Iowa City City Council Resolution Approving Title VI
Prepared by: Darian Nagle-Gamm, Director of Transportation, 1200 S. Riverside Drive, Iowa City, IA 52245
319-356-5156
RESOLUTION NO. ______________ Resolution Approving the Iowa City Transit Title VI and Limited English Proficiency Plan
WHEREAS, Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or
national origin by agencies such as Iowa City Transit in any programs and activities that receive
federal funds; and
WHEREAS, the Federal Transit Administration (FTA) requires adoption, and renewal every three
years of a transit-specific Title VI Program and Limited English Proficiency Plan for Transit
operations receiving federal funding; and
WHEREAS, the City should rescind the Title VI Program Plan for Iowa City Transit adopted in 2019,
and adopt the attached, revised plan to ensure compliance with Title VI and similar federal laws
prohibiting discrimination in the use of federal funds.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF IOWA CITY,
IOWA, THAT:
1. The attached Title VI and Limited English Proficiency Program Plan for Iowa City Transit is
approved.
Passed and approved this 1st day of April, 2025.
________________________________________
MAYOR
Approved by
ATTEST: ___________________________ ________________________
CITY CLERK City Attorney's Office
It was moved by __________________ and seconded by ________________ the Resolution be
adopted, and upon roll call there were:
AYES: NAYS: ABSENT:
______ ______ _______ Alter
______ ______ _______ Bergus
______ ______ _______ Harmsen
______ ______ _______ Moe
______ ______ _______ Salih
______ ______ _______ Teague
______ ______ _______ Weilein
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Attachment C: Iowa City Transit Title VI Complaint Form
IOWA CITY TRANSIT
TITLE VI COMPLAINT FORM
This form may be used to file a complaint with 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 statement
that provides the same information may be provided to submit 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
ALLEGED DISCRIMINATION:
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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: 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.
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Attachment D: Title VI Contract Language for Transit Projects
TITLE VI CONTRACT LANGUAGE
During the performance of this contract, the contractor, for itself, its assignees, and
successor 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 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 is Appendix B of the
Regulations.
3. Solicitation for Subcontracts, including Procurement of Materials and Equipment
In all solicitations whether 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 Regulation relative to nondiscrimination on the grounds of race,
color, sex, or national origin.
4. Information and Reports
The contractor 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 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 contractors 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.
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5. Sanctions for Noncompliance
In the event of the contractor’s noncompliance with the nondiscrimination
provisions of this contract, the 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 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.
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Attachment E: Notice of Title VI Provisions
CITY OF IOWA CITY
NOTICE
OF TITLE VI PROVISIONS
The City of Iowa City (Iowa City Transit) operates its programs and services in compliance
with the FTA Circular 4702.1B and Title VI of Civil Rights Act of 1964, which states, no
person in the United States shall, on the grounds of race, color, and 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.
Any person who believes she or he has been aggrieved by unlawful discriminatory
practice under Title VI may submit a complaint with Iowa City Transit. 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.
If you feel you are being denied participation and/or benefits in this program, or otherwise
being discriminated against because of your race, color, or national origin, or would like
more information on Iowa City Transit’s civil rights program and the procedures to submit
a complaint you may contact:
City of Iowa City
Civil Rights Office
410 East Washington Street
Iowa City, Iowa 52240
319-356-5022
http://www.icgov.org/default/?id=1515
Iowa Department of Transportation
Office of Employee Services – Civil Rights
800 Lincoln Way, Ames, Iowa 50010
Iowa DOT: 800-262-0003
Civil Rights Commission: 800-457-4416
A complainant may submit a complaint directly with the Federal Transit Administration
(FTA) Office of Civil Rights, Attention: Title VI Program Coordinator, East Building, 5th
Floor-TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.
YOU SHOULD CONTACT THE ABOVE INDIVIDUALS AS SOON AS POSSIBLE BUT
NO LATER THAN 180 DAYS AFTER THE ALLEGED DISCRIMINATION OCCURRED,
OR IF THERE HAS BEEN CONTINUING COURSE OF CONDUCT, NO LATER THAN
180 DAYS AFTER THE ALLEGED DISCRIMINATION WAS DISCONTINUED.
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This notice will be available on the Iowa City Transit website, on Iowa City Transit
buses, and at the Iowa City City Hall.
Esta notificación estará disponible en el sitio web Iowa City Transit, en Iowa City
autobuses de tránsito, y en las instalaciones de Tránsito Iowa City.
此通知将可在在科勒尔维尔交通网站，科勒尔维尔公交车，并在的科勒尔维尔交通设施。
If information is needed in another language, contact 319-356-5022.
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Attachment F: Title VI Notification
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Attachment G: Service Standards and Policies
Iowa City Transit
SERVICE STANDARDS AND POLICIES
SYSTEMWIDE SERVICE STANDARDS
To prevent discriminatory service design or operation, the FTA circular requires transit agencies
to adopt system wide service standards and system wide service policies (policies are discussed
later in this section). System wide service standards are required for the following criteria:
Vehicle Load
Vehicle Headway
On-time performance
Service Availability
VEHICLE LOAD
To ensure Iowa City Transit customers can gain access to public transit services while balancing
customer comfort, loading standards must be established and schedules devised that reflect
customer volumes. This standard is measured as the ratio of customers on board to the seated
bus capacity expressed as a percent. Values of 100 percent or less indicate all riders are provided
a seated ride while values above 100 percent indicate standees. The following loading standard
indicates the degree of crowding (i.e., standees) that is acceptable based on bus type and
manufacturer’s recommendation for safe, maximum loading capacity. These standards reflect
standees in the center portion of the bus only, not in the stairwells. For ridership consistently
above these standards below, Iowa City Transit will place a second bus on the trip.
Standard: Acceptable load factors should never consistently exceed the following: (Industry
Standard: 125-150% in urban areas, 175% in university systems)
Bus Type Vehicle Load Standard
Seated Capacity Total Customers Percentage
Standard 40’ Bus 38-45 67-79 175%
Iowa City Transit experiences heavy demand on a daily basis as a result of providing service on a
university campus. It operates a uniform fleet of 40’ buses. This has resulted in the addition of
“helper buses” to address capacity concerns.
VEHICLE HEADWAY
Vehicle headway (the time interval between two vehicles traveling in the same direction on the
same route) standards at Iowa City Transit relate to frequency of service. This standard is one of
the commonly applied measures of transit adequacy, particularly from the customer's point of
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view. Consequently, it can be one service characteristic that is the course of customer
dissatisfaction. In general, frequencies or "headways" (i.e., the time from one bus to the next at
the same location) are established to provide enough vehicles operating past bus stops on a route
to accommodate the customer volume and to stay within the recommended loading standards,
which were discussed previously. If customer loads are light enough that more time is needed
between vehicles to meet loading standards, then headways should be set on clock-face
headways operating at 30 and 60-minute intervals.
Standard: For periods in which service is operated, the standard minimum headways by
type/time of service are as follows. (Industry Standard: Varies)
Weekday
Service Type/Time Base Night Saturday Sunday
Weekday 30-minute 60-minute --- ---
Evening --- 60-minute --- ---
Saturday --- --- 60-minute ---
The definition of the above service types/times is as follows:
Weekday. Routes operated generally from 5:45 a.m. to 6:30 p.m., Monday-Friday.
Weekday Night. Routes operated generally from 6:30 p.m. to 11:00 p.m., Monday-Friday.
Saturday. Routes operated generally from 6:45 a.m. to 7:40 p.m.
Sunday. Iowa City Transit does not operate fixed route service on Sunday.
As with all standards, this headway matrix should be considered a guide, not an absolute
measure.
ON-TIME PERFORMANCE
Published timetables must provide the transit customer with a reasonable guarantee that the
scheduled service will operate, and will, additionally, operate on time. The dependability of Iowa
City Transit is important to people who typically plan trips around the availability of bus service.
Moreover, customers associate a time penalty with unreliable bus service that reduces the
attractiveness of public transportation. There are several ways to measure Iowa City Transit’s
dependability. The first is whether service operates at all. Measures of actual versus scheduled
service (missed trips) are expressed as the percentage of scheduled trips that are actually made.
Iowa City Transit should have sufficient spare buses and bus drivers to assure that the standard
is met.
Standard: For Iowa City Transit, the missed trip standard is established at 99.0 percent. (Industry
Standard: 90-95%)
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On-time performance is also examined in terms of schedule adherence, which means the
difference between scheduled time and the time the bus actually passes a particular location.
The schedule adherence standard consists of two parts: 1) the definition of on time, and 2) the
proportion of buses that operate within the on-time range. For purposes of establishing Iowa
City Transit’s on-time performance, "on-time" is established at zero minutes early to 7 minutes
late. This allows the bus reasonable latitude for encountering general delays due to traffic,
weather or other on-route delays, without unduly inconveniencing customers. Scheduled buses
should never be early, for this would cause customers to miss the bus entirely and subject many
riders to an even longer wait for the next scheduled bus. However, Iowa City Transit operates a
significant number of “helper buses” to address capacity issues. “Helper Buses” provide the
additional capacity needed to carry the number of people waiting for the scheduled bus. These
buses are not considered when calculating the system wide on-time performance of the buses
as they are used to assist the scheduled bus.
Standard: The standard for Iowa City Transit’s schedule adherence is established at 75% of
scheduled trips system wide. Therefore, 15 out of every 20 scheduled bus trips should be
considered "on-time" according to the standard. (Industry Standard: 73-75%)
SERVICE AVAILABILITY
A transit system inevitably receives many requests for service from citizens who are not within
walking distance of a route, or who desire buses operating in their neighborhoods connecting
with different destinations. Since transit resources are limited, it is unlikely that everyone will be
accommodated to a satisfactory degree. Therefore, it is necessary to determine how to allocate
the available resources to provide the best possible service. In developing measures for Iowa
City Transit service, this standard has been divided into three separate components that reflect
travel concentrations, trip purpose, and the need for bus service. The three components are:
Production End representing the trip end that produces travel
Attraction End that attracts travel
Bus Stop Spacing
Production End. Determination of which residential neighborhoods should be candidates for
service is a function of reasonable walking distance. Numerous studies have indicated that the
maximum distance an average person can reside from a bus route and still be considered to
“have service” is approximately one-quarter mile, which is roughly equivalent to a five-minute
walk.
Standard: The standard will be 85% of the population within ¼ mile walking distance between
home and an Iowa City Transit bus stop or attraction. (Industry Standard: ¼ mile, 85-90%)
This route coverage guide is just that-a guide. It is not an exact measurement. In some areas, the
street pattern is not uniform or major generators are further apart than the guide indicates. Iowa
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City Transit’s service may not and should not conform to the guide in all areas due to other factors
such as population density and operational hours compared to destination.
Attraction End. Major traffic generators in the Iowa City community create a transit opportunity.
Standard: Iowa City Transit will apply the following standards when considering service
modifications.
• Hospitals/Nursing Homes. These usually do not attract a large number of trips.
These facilities do, however, often serve those who depend on transit. Therefore,
institutions of 100 or more beds may be considered candidates for Iowa City Transit
service. (Industry Standard: None Found)
• Colleges/Schools. Students in a university community often comprise a major segment of
the transportation dependent population. For this reason, colleges and post-secondary
schools have been included in the availability standard. Those institutions with an
enrollment of at least 1,000 students warrant consideration for service. (Industry
Standard: None Found)
• Shopping Centers. Shopping trips constitute a major reason for transit travel. Shopping
centers with more than 100,000 square feet of leased retail space are large enough to
warrant consideration for Iowa City Transit service. Mixed-use retail, housing and office
complexes can also be included within this category. (Industry Standard: None Found)
• Social Service/Government Centers. Public Agencies, government centers and
community facilities attract significant traffic volume. While the nature and size of these
facilities varies greatly, it can be generally stated that those serving at least 100 clients
daily warrant consideration for public transit service. (Industry Standard: None Found)
Bus Stop Spacing
While route alignments are the primary determinants of transit availability, a second influence
on the proximity of transit is the bus stop spacing along these routes. Obviously, stops at every
intersection provide the shortest walking distance to the bus, but may not be warranted based
on other considerations. Therefore, a bus stop spacing standard must consider service area
density and land characteristics served. Using these criteria, Iowa City Transit has developed two
categories, Campus and Non-Campus, and established standards for each.
Standard: The general bus stop spacing standard for Iowa City Transit is summarized below:
(Industry Standard: Varies, most far-sided)
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Bus Stop Spacing Standard
Location Stop Spacing
Campus Every other building
Non-Campus Every ¼ mile
It should be noted that in some instances, the bus stop spacing standard should be discarded in
favor of simply considering the location of customer concentration. This is especially true for
stops that serve major activity centers or high-density residential locations.
The exact placement of a bus stop in the area of a signalized intersection is also a matter of
concern. Generally, far-sided bus stops will be the Iowa City Transit standard unless determined,
on a case-by-case basis, that other factors, such as business ingress/egress or congestion issues,
dictate otherwise.
SYSTEMWIDE SERVICE POLICIES
The FTA circular requires system wide service policies for distribution of transit amenities, vehicle
assignment and for transit security. Policies differ from standards in that policies are not
necessarily based on a quantitative threshold and are actions or procedures as opposed to
standards that are rules or principles.
DISTRIBUTION OF TRANSIT AMENITIES
Title VI circular requires that Iowa City Transit maintain service standards for the distribution of
various transit amenities, including bus shelters, benches, route map/timetable, and trash
receptacles owned by Iowa City Transit. There are several amenities that are placed at bus stops
by private entities. These are not governed by these standards. The Iowa City Transit standard
for each of these amenities is described below.
Bus Shelters. A major concern of transit riders, especially regarding inclement weather, is the
amount of time spent on the street exposed to the elements. The abundance of cold and windy
conditions is of particular concern in Iowa. The placement of shelters and the development of a
priority location program are based upon the following:
• Number of boarding and/or transferring customers at a specific stop,
• Amount of shelter from the elements or lighting at or near the stop, and
• ADA considerations
• Safety concerns
• Customer comments received
Policy: Shelters should be provided at stops which serve 150 or more boarding daily and/or
transferring customers or which serve concentrations of elderly or disabled residents. Shelters
should be at least 5’ by 8’ and be enclosed on three sides. Service information including route
numbers and colors, maps and schedules that serve the stop should be displayed. (Industry
Standard: Varies)
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Benches. Benches represent a medium level of amenity to provide greater comfort for Iowa City
Transit customers.
Policy: Benches may be installed independently at bus stops that do not have shelters. For
these benches, they should be placed facing the street, a minimum of 6 to 8 feet from the bus
stop sign and anchored in place. (Industry Standard: None Found)
Digital Signage
Iowa City Transit provides real-time vehicle tracking technology to assist customers in
conveniently using the transit service. One of the techniques used to convey this information is
through digital signs at the bus stop.
Policy: Iowa City Transit will increase digital signs at major transfer locations throughout its
system.
Route Map/Timetable. Iowa City Transit’s printed route map/schedule provides information for
the general public at the bus stop where they will be boarding the bus.
Policy: Iowa City Transit’s route map/timetables are provided in all shelters. They are also
provided at major transfer points throughout the system. (Industry Standard: Shelters and
Transfer Points)
Trash Receptacles. Trash receptacles are located only at bus stops with a larger number of
boardings, usually in conjunction with a bus shelter.
Policy: Iowa City Transit provides trash barrels at shelters. (Industry Standard: None Found)
These standards are guidelines only in placement of amenities throughout Iowa City Transit’s
system. Not all bus stop locations are able to physically accommodate the amenities.
VEHICLE ASSIGNMENT
Vehicle assignment refers to the process by which vehicles are placed into service on
routes throughout the system. The following policy has been established.
Policy: Iowa City Transit has a uniform fleet consisting of 40’ heavy-duty buses. Buses are rotated
and randomly assigned to a route. (Industry Standard: Random with Exceptions for Route
Geometrics and Lower Demand)
TRANSIT SECURITY
Transit systems are required to develop security policies that will protect employees and the
public against any intentional act or threat of violence or personal harm, either from criminal
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activities or terrorist acts. In response to this requirement, Iowa City Transit provides the
following security policy:
Policy: Iowa City Transit buses are equipped with two-way radios to communicate security
concerns and security cameras as a method to after-the-fact review situations that may occur on
the bus. All Iowa City Transit bus shelters will have nearby lighting to ensure customers security
while waiting or exiting a bus. Additionally, all Iowa City Transit buses display signage educating
customers on what to look for and do if they find a suspicious package. Also, all new bus drivers
are provided with transit security training consisting of: warning signs, what to look for and
procedures to follow in security situations. Finally, Iowa City Transit works with the Iowa City
Police Department to simulate emergency situations on an Iowa City Transit bus. (Industry
Standard: Larger systems have protocols for various emergency scenarios; smaller systems have
language similar to the above.)