HomeMy WebLinkAboutTitle VI LEP Plan
IOWA CITY TRANSIT
TITLE VI/LEP PLAN
April 2016
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 .......................................5
Title VI Complaint Procedures and Complaint Form .............................................6
Title VI Authorities ......................................................................................6
Coordinator Responsibilities .......................................................................6
General Responsibilities .............................................................................6
Filing a Complaint .......................................................................................7
Internal Complaint Process ........................................................................7
Transit Related Title VI Investigations, Complaints, and Lawsuits ........................8
Promoting Inclusive Public Participation ................................................................8
Provide Meaningful Access to LEP Persons ....................................................... 11
A. Four Factor Analysis ................................................................................. 12
Factor 1 .................................................................................................... 12
Factor 2 .................................................................................................... 19
Factor 3 ................................................................................................... 20
Factor 4 .................................................................................................... 20
B. Developing a Language Assistance Plan ................................................. 21
Results of Four Factor Analysis ................................................................ 21
Language Assistance Services by Language ........................................... 21
Notice to LEP Persons .............................................................................22
Monitor, Evaluate Update Language Access Plan .................................... 23
Employee Training .................................................................................... 23
Safe Harbor Provision .............................................................................. 24
Minority Representation on Planning and Advisory Bodies………………………..24
Assistance to Subrecipients………………………………………………………… 24
Monitoring Subrecipients………………………………………………………………24
Determination of Site or Location of Facilities……………………………………….25
ATTACHMENTS
Attachment A: Certifications and Assurances – FFY2013
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 FY2016 Certifications and Assurances for Iowa
City Transit were pinned into TrAMS on March 15, 2016. (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, 2016 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 March 22, 2016 (resolution is attached). Iowa City Transit operates a fixed
route service with 30 buses at peak time (10 of those buses are paratransit buses operated by
Johnson County SEATS) and serves a population of 67,862. 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 Iowa Council of Governments (Regional Planning Office), has produced and adopted a
Title VI Program. This document took effect in March of 2014. Iowa City Transit will require
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Johnson County SEATS to submit its updated Title VI Program 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 July 1, 2013. 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. The
committee meets on a quarterly basis.
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NOTIFICATION OF BENIFICIARIES OF PROTECTION UNDER TITLE VI
IOWA CITY TRANSIT
TITILE 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 and the Iowa City Civil Rights Coordinator will
be responsible for initiating and monitoring Title VI activities, and all other responsibilities as
required.
______________________________ _________________
Chris O’Brien, Transportation Services Director Date
Stefanie Bowers, Civil Rights Coordinator Date
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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 and the Iowa City Civil Rights Coordinator are
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,
utilization of Minority/Women/Disadvantaged Business Enterprises (DBE) contractors, public
improvement, and material acquisition. 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
IDOT 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.
IDOT will be notified of any complaint filed at the City of Iowa City involving Title VI
issues, as to any resolution.
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FILING A COMPLAINT
Eligibility
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 company 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.
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5. Any comments or recommendations from legal counsel will be reviewed by the Title VI
Coordinator.
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 IDOT’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,” available online at
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 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 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 Public Participation Plan 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 is Used
Iowa City Transit will use its Public Participation Plan when considering fare changes,
modifications to routes and schedules, and other transit planning projects. Including:
Any fare increase 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
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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.
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. 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 Public Participation Plan was adopted in October of 2010. 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 is 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 two surveys regarding transit service as part of the Long
Range Transportation Planning process for MPOJC. The surveys will be used in the
MPOJC’s 2045 Long Range Transportation Plan.
Iowa City Transit is a member of the Paratransit Advisory Committee. The Committee
membership includes public transit providers and riders of the paratransit system
operated by Johnson County SEATS. 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, as well as the MPOJC Transportation Planning division, are members
of the Johnson County Livable Communities Committee which meets monthly. This
group includes many local human services groups, public transit managers, public
officials and residents of Johnson County.
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, as well as the MPOJC Transportation Planning division, participates in
the Community Transportation Committee that was initiated by human service agencies
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in Johnson County. This group’s focus is on providing transportation to those that
require transportation to work after hours and on days the fixed route system does not
operate. This group meets monthly.
Iowa City Transit will once again participate in the MPOJC’s Long Range Transportation
Plan open houses in Coralville, North Liberty, and Iowa City to gather public input
regarding transit issues.
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
Provide opportunities for public participation through written communications,
group discussions, and one-on-one interviews.
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:
Johnson County Livable Communities
Community Transportation Committee
Center for Worker Justice
Afro American Culture Center/University of Iowa
Asian Pacific American Center/University of Iowa
Latino Native American Center/University of Iowa
International Center/University of Iowa
Neighborhood Centers of Iowa City
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
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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 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 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 74,513 in 1990, 84,672 in 2000, 91,881 in 2005 and 103,152 in 2010.
These numbers represent an average annual population growth of 1.01%.
Iowa City’s current demographics are:
Iowa City Statistics and Demographics Number Percent
Iowa City Population 67,862 100.0
SEX AND AGE
Male 33,755 49.7
Female 34,107 50.3
Under 5 years 3,204 4.7
5 to 9 years 2,799 4.1
10 to 14 years 2,566 3.8
15 to 19 years 7,538 11.1
20 to 24 years 16,711 24.6
25 to 29 years 6,958 10.3
30 to 34 years 4,225 6.2
35 to 39 years 3,280 4.8
40 to 44 years 3,007 4.4
45 to 49 years 2,931 4.3
50 to 54 years 3,230 4.8
55 to 59 years 3,315 4.9
60 to 64 years 2,563 3.8
65 to 69 years 1,629 2.4
70 to 74 years 1,161 1.7
75 to 79 years 954 1.4
80 to 84 years 863 1.3
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85 years and over 928 1.4
Median age (years) 25.6 ( X )
16 years and over 58,801 86.6
18 years and over 57,752 85.1
Male 28,627 42.2
Female 29,125 42.9
21 years and over 47,305 69.7
62 years and over 6,962 10.3
65 years and over 5,535 8.2
Male 2,277 3.4
Female 2,393 4.7
RACE
One Race 66,163 97.5
White 56,004 82.5
Black or African American 3,912 5.8
American Indian and Alaska Native 144 0.2
Asian 4,680 6.9
Asian Indian 817 1.2
Chinese 1,866 2.7
Filipino 133 0.2
Japanese 181 0.3
Korean 803 1.2
Vietnamese 318 0.5
Other Asian 562 0.8
Native Hawaiian and Other Pacific Islander 28 0.0
Native Hawaiian 6 0.0
Guamanian or Chamorro 5 0.0
Samoan 8 0.0
Other Pacific Islander 9 0.0
Some Other Race 1,395 2.1
Two or More Races 1,699 2.5
HISPANIC OR LATINO
Hispanic or Latino (of any race) 3,627 5.3
Mexican 2,218 3.3
Puerto Rican 265 0.4
Cuban 86 0.1
Other Hispanic or Latino 1,058 1.6
Not Hispanic or Latino 64,235 94.7
White alone 54,103 79.7
RELATIONSHIP
Total population 67,862 100.0
In households 61,277 90.3
Householder 27,657 40.8
Spouse 8,980 13.2
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Child 11,519 17.0
Own child under 18 years 9,621 14.2
Other relatives 1,575 2.3
Under 18 years 314 0.5
65 years and over 174 0.3
Nonrelatives 11,546 17.0
Unmarried partner 1,965 2.9
In group quarters 6,585 9.7
Institutionalized population 296 0.4
Non-institutionalized population 6,289 9.3
HOUSEHOLDS BY TYPE
Total households 27,657 100.0
Family households (families) 11,743 42.5
With own children under 18 years 5,254 19.0
Husband-wife family 8,980 32.5
With own children under 18 years 3,721 13.5
Male householder, no wife present 779 2.8
With own children under 18 years 317 1.1
Female householder, no husband present 1,984 7.2
With own children under 18 years 1,216 4.4
Nonfamily households 15,914 57.5
Householder living alone 9,488 34.3
65 years and over 1,913 7.00
Households with individuals under 18 years 5,479 19.8
Households with individuals 65 years and over 4,020 14.5
Average household size 2.22 ( X )
Average family size 2.88 ( X )
HOUSING OCCUPANCY
Total housing units 29,270 100.0
Occupied housing units 27,657 94.5
Vacant housing units 1,613 5.5
For seasonal, recreational, or occasional use 144 0.5
Homeowner vacancy rate (percent) 2.8 ( X )
Rental vacancy rate (percent) 4.1 ( X )
HOUSING TENURE
Occupied housing units 27,657 100.0
Owner-occupied housing units 13,011 47.0
Population in owner-occupied housing units 30,854 ( X )
Average household size of owner-occupied
units
2.37 ( X )
Renter-occupied housing units 14,646 53.0
Population in renter-occupied housing units 30,423 ( X )
Average household size of renter-occupied 2.08 ( X )
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units
Source: U.S. Census Bureau, 2010 Census.
There were 4,540 international students according to the University of Iowa’s fall 2015
enrollment statistics, which represents 14.12% 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 (PRC) 2,797 165
Korea, Republic of 341 37
India 341 31
Malaysia 75 0
Taiwan 72 4
Source: The University of Iowa, Fall 2015 Profile of International Students and Scholars
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, 2010-2014 U.S. Census American Community Survey (ACS) data was evaluated.
According to ACS data, 18,045 persons in Johnson County (14.05% of the population) spoke a
language other than English at home. Of the 18,045 persons residing in Johnson County who
spoke a language other than English at home, 6,385 (4.97% 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 1,883 1.47%
Other Indo-European language 864 0.67%
Asian & Pacific Island language 2,840 2.21%
Other languages 798 0.62%
Source: 2010-2014 American Community Survey 5 Year Estimates
Task 1, Step 2C; Analyze the data collected
According to the University of Iowa’s fall 2015 Profile of International Students and Scholars,
China, the Republic of Korea, India, and Malaysia remain the top represented countries in the
international student population. Taiwan (72 students) rounds out the top five, replacing Japan
(45 students) from the fall 2001 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 four of the top five represented countries are the same for
both international students and scholars in 2008.
The University of Iowa’s Intensive English Program (IIEP) reports 315 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.
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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.
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 following charts show how the use of ELL services, largely attributed to an
influx of Spanish, Bosnian, and Vietnamese speakers, and is increasing in Iowa’s schools. In
the ICCSD the number of students receiving ELL services is 9.48% (1,253 students) for the
2015-2016 school year.
Ten Year English Language Learner (ELL)
Student trends in Iowa
Source: Iowa Department of Education, PK-12 Student Data
In Iowa, students receiving English Language Learning services have increased 52.32% in the
past decade. According to US Department of Education 2013-2014 school year data, the native
language of most Iowa ELL students is Spanish (65.08% of all Iowa ELL students). The second
most common native language in Iowa is Vietnamese (3.25%), followed by Bosnian (2.74%).
Ten Year English Language Learner Trends in the
Iowa City Community School District (ICCSD)
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Source: Iowa Department of Education, PK-12 Student Data
Iowa Public School PK-12 Limited English Proficient Students (LEP) by District and Grade
For the 2015-2016 school year, there are 13,217 students (IA Dept. of Education Certified
Enrollment) in the Iowa City Community School District. Of those, 9.48% (1,253 students)
receive English Language Learning services.
Task 1, Step 4; Community organizations that serve LEP persons
Iowa City Transit and 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
Iowa City Transit in collaboration with MPOJC has developed a working relationship with the
University of Iowa’s OISS center for language assistance services. OISS 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 19 regular routes from 5:45 a.m.-11:00 p.m. All routes
operate daily with 30-minute service during peak periods. The Seventh Avenue (during a.m. and
p.m. peak periods), Melrose Express, Westside Hospital, Eastside Express, and Westport
routes operate hourly all day long. Midday service is hourly except on the Towncrest and
Oakcrest where service is 30 minutes all day during the University academic year. The Eastside
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Loop operates when Iowa City schools are in session. Hourly evening service is provided to the
same general service area using combined routes, from 6:30 p.m.-11:00 p.m. Saturday service
operates hourly all day with service ending at 7:40 p.m. There is no fixed route service on
Sundays. Iowa City Transit also extends service to Chatham Oaks Care Facility located on the
west side of Iowa City. During peak periods Iowa City Transit operates 20 buses. Twelve buses
operate weekdays off-peak. During evening hours and on Saturdays, five buses are in service.
The Downtown Iowa City Transit Interchange is the hub of 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. There is one free-fare route, the Downtown Transit
Shuttle.
The existing fare structure is a $1.00 base fare, $32 unlimited ride 31-day pass, and $8.50 for a
ten-ride ticket strip. There is a 75¢ youth fare for K-12 aged children. Children under five may
ride free accompanied by an adult. There is also a K-12 31-day pass available for $27 and a
student semester pass for $100 for persons attending the University of Iowa or Kirkwood
Community College. There is a monthly pass for University of Iowa faculty/staff for $27 per
month. Elderly persons may ride during off peak hours and all day Saturday for 50¢. Eligible
persons with disabilities and low income elderly persons may ride free during off peak hours. A
qualifying purchase from any merchant participating in the Bus and Shop Program entitles the
purchaser to one free ride any time of day. Free transfers are available and may be used on
Coralville Transit.
All Iowa City Transit fixed route buses are lift/ramp-equipped. Demand responsive paratransit
service is provided during fixed-route service hours and on Sundays (8 a.m.-2 p.m.), 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
Local news media
Audio announcements
To better understand the frequency with which LEP riders come into contact with Iowa City
Transit services, Iowa City Transit conducted an internal survey of fixed route bus drivers to
determine what language skills already exist among Iowa City Transit employees and the
number and nature of encounters with riders where language is a barrier.
Although varying degrees of fluency were discovered 5 drivers were fluent in Spanish. Iowa
City Transit employees also indicated that encounters with customers who were unable to
communicate in English were rare.
Task 2, Step 2; Review information obtained from community organizations
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Through public input and planning sessions, Iowa City Transit 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.
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
Identified employees that speak a language other than English
Transit information translated into 5 different languages on website
Provide introductory bus ride as part of the University of Iowa’s orientation
through OISS
Assistance from OISS when needed
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Cost for these measures is under $500 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
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, 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.
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 32,150 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 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 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 the Metropolitan Planning
Organization of Johnson County 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.
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Through a joint effort, all incoming international students and scholars
have the option of taking an introductory bus ride as part of OISS’ annual
orientation. OISS staff, along with student volunteers, takes the
international students on Iowa City Transit to Wal-Mart and on Coralville
Transit to Coral Ridge Mall. The bus ride exposes the students to how
the bus system operates and OISS staff is present to answer any
questions. All incoming international students take a tour of the
University of Iowa campus using the Cambus service.
Iowa City Transit 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 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.
Iowa City Transit will develop additional language services on their transit
website. A link will be added to the transit websites that will have general
transit information translated in the most common spoken languages in
Johnson County.
c. Notice to LEP Persons:
Iowa City Transit will provide general public transit information, bus timetable and
route information, and any additional pertinent information to the University of Iowa’s
Office of International Students and Scholars (OISS). OISS will distribute the
materials to international students and scholars upon their arrival and as needed. If
an international student or faculty member has any questions, the OISS can
accommodate the student in receiving translation assistance either on-site or by
directing them to the respective language program. OISS also provides international
students and scholars a handout providing information on local destinations, the
respective bus company and bus line, as well as the days the bus operates.
Handouts will be made available that contain information on language assistance
services as well as a summary of important transit information. The handout will be
translated into the most common spoken languages in Johnson County and will be
available on all buses and at all transit offices. The handouts will also be provided to
the OISS to be distributed to the international student and scholar populations.
Transit information will also be provided in the most common spoken languages in
Johnson County on the transit websites.
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
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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
Evaluate the number of outreach efforts provided by the University of
Iowa’s Office of International Students and Scholars
Determine if any changes in the level of assistance provided by the
International Office are required
Each encounter with an LEP person will be recorded by the bus driver/office on a
special card and is reported directly to the Transportation Services Director.
Dissemination of the Title VI/LEP Plan includes a link to the Title VI/LEP Plan on the
Iowa City Transit website at:
http://www.icgov.org/default/?id=1515
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
C. Safe Harbor Provision
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As identified in the four factor analysis, Iowa City Transit identified Spanish speakers
(1,883 in population) and Asian (Pacific Island) speakers (2,840 in population) 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 website.
MINORITY REPRESTATION 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. In June 2012 the City Council passed a resolution establishing an
Ad Hoc Diversity Committee to study City transit and law enforcement operations as they relate
to minority populations. Four of the seven members appointed to the Ad Hoc Committee were
African American and one member was Native American. Two members were Caucasian.
Over the course of six months, the Ad Hoc Diversity Committee held 22 Committee meetings
and held several public information gathering sessions with local community members from
diverse backgrounds to discuss and receive feedback about transit and law enforcement
operations. Iowa City Transit continues to implement the recommendations of the Ad Hoc
Diversity Committee.
Johnson County SEATS, a paratransit subrecipient to Iowa City Transit, has a 5 member
advisory committee, including Iowa City representatives, that includes riders. 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.
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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 Maintenance/Bus Storage Facility is in the early planning stages.
This facility will be built on property currently owned by the City of Iowa City.
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Attachment A: 2013 Certifications and Assurances
27
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Attachment B: Iowa City City Council Resolution approving Title VI
RESOLUTION NO. ______________
RESOLUTION APPROVING THE IOWA CITY TRANSIT TITLE VI PROGRAM 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 City should adopt a 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:
The attached Title VI Program Plan for Iowa City Transit is approved.
Passed and approved this __23rd__ day of ________March______, 2016.
________________________________________
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:
______ ______ _______ Botchway II
______ ______ _______ Cole
______ ______ _______ Dickens
______ ______ _______ Mims
______ ______ _______ Taylor
______ ______ _______ Thomas
______ ______ _______ Throgmorton
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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 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
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 without
regard to race, color, and national origin in accordance with Title VI of the Civil Rights
Act of 1964. Any person who believes she or he has been aggrieved by unlawful
discriminatory practice under Title VI may file 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 file 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 file a complaint directly with the Federal Transit Administration
(FTA) by filing a complaint with the 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.
This notice will be available on the Iowa City Transit website, on Iowa City Transit
buses, and at the Iowa City City Hall.
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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
37
of 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 5:45 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.
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Standard: For Iowa City Transit, the missed trip standard is established at 99.0 percent.
(Industry Standard: 90-95%)
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%)
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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 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 2 – 3 blocks
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
The new 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 6’ by 10’ and be enclosed on three. Service information including route
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numbers and colors, maps and schedules that serve the stop should be displayed. (Industry
Standard: Varies)
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)
NEXT BUS 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 place 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.)