Northeast Missouri Regional Planning Commission

(NEMO RPC)

Title VI Program

Date filed with MoDOT Transit Section:

___January 24th 2018___

DATE

Title VI Plan

Table of Contents

  1. Introduction / Title VI Assurancespage 2
  2. Agency Informationpage 3
  3. Notice to the Publicpage 6
  4. Procedure for Filing a Title VI Complaintpage 7
  5. Title VI Complaints, Investigations, Lawsuitspage 9

and Evidence of Agency Staff Title VI Training

  1. Public Participation Planpage 10
  2. Language Assistance Planpage 13
  3. Advisory Bodiespage 16
  4. Subrecipient Assistancepage 17
  5. Subrecipient Monitoringpage 17
  6. Equity Analysis of Facilitiespage 17

Attachments

Attachment 1 – Title VI Complaint Form

Attachment 2 – Title VI Self Survey Form

Attachment 3 – Demographic Information

A. Title VI Assurances

NEMO RPC agrees to comply with all provisions prohibiting discrimination on the basis of race, color, or national origin of Title VI of the Civil Rights Act of 1964, as amended, 42 U.S.C. 200d et seq., and with U.S. DOT regulations, “Nondiscrimination in Federally-Assisted Programs of the Department of Transportation – Effectuation of Title VI of the Civil Rights Act,” 49 CFR part 21.

NEMO RPC assures that no person shall, as provided by Federal and State civil rights laws, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity. NEMO RPC further ensures every effort will be made to ensure non-discrimination in all programs and activities, whether those programs and activities are federally funded or not.

NEMO RPC meets the objectives of the FTA Master Agreement which governs all entities applying for FTA funding, including NEMO RPC and its third-party contractors by promoting actions that:

  1. Ensure that the level and quality of transportation service is provided without regard to race, color, or national origin.
  1. Identify and address, as appropriate, disproportionally high and adverse effects of programs and activities on minority populations and low-income populations.
  1. Promote the full and fair participation of all affected Title VI populations in transportation decision making.
  1. Prevent the denial, reduction, or delay in benefits related to programs and activities that benefit minority populations or low-income populations.
  1. Ensure meaningful access to programs and activities by persons with Limited English Proficiency (LEP).

B. Agency Information

  1. Mission of Northeast Missouri Regional Planning Commission:

Northeast Missouri Regional Planning Commission's purpose is to bring progress in a number of ways to the six counties in northeast Missouri; Adair, Schuyler, Knox, Scotland, Clark and Lewis County. Northeast Missouri Regional Planning Commission does this through grant administration, transportation planning, economic development, solid waste management, hazard mitigation, and rental assistance. Northeast Missouri Regional Planning Commission communicates with all of our members to identify the needs and concerns of each community. Northeast Missouri Regional Planning Commission then implements plans to achieve these goals and create the progress each community desires.

  1. History

The Northeast Missouri Regional Planning Commission (NEMORPC) is one of nineteen regional planning commissions in the State of Missouri, which are authorized by the State of Missouri Regional Planning and Community Development Act of 1966, Revised Missouri Statutes Chapter 251. The Regional Planning and Community Development Act of 1966 permitted the establishment of regional planning commissions to formally organize and band together by counties to promote the spirit of cooperatively working together to solve problems and plan the future development of regions and the State of Missouri.

The Northeast Missouri Regional Planning Commission (NEMORPC) was designated such by the State of Missouri by Governor Warren E. Hearnes on the 19thday of March in 1969. On this date, the Northeast Missouri Regional Planning Commission was created; with the boundaries of the commission’s authority to coincide with the boundaries of the counties of Adair, Clark, Knox, Schuyler, and Scotland. The original region served the five counties and 27 incorporated cities for a total of 32 member governments in Northeast Missouri. During the year of 1992, Lewis County, Missouri petitioned the State of Missouri and the NEMORPC membership to join the region. In late 1992, The State of Missouri assigned the County of Lewis to the boundaries of the Northeast Missouri Regional Planning Commission/ Rural Development Corporation and Economic Development District. We now serve Adair, Clark, Knox, Lewis, Schuyler, and Scotland counties and the 33 incorporated cities for a total of 39 member governments in Northeast Missouri.

On December 22, 1975, the Northeast Missouri RPC entered into a cooperative agreement with the Counties of Adair, Clark, Knox, Schuyler and Scotland to formulate the Public Housing Agency (PHA) for the member counties. The Northeast Missouri Regional Planning Commission was designated the administrative agency for the newly formed Public Housing Agency (PHA) and Scotland County was designated as the designated official signatory lead county to act on behalf of the member counties.

On August 16, 1978, the Northeast Missouri Regional Planning Commission incorporated the Northeast Rural Development Corporation (NEMORDC) to expand the mission and objectives for the region in Northeast Missouri. The Corporation was established with the same by-laws as the Regional Planning Commission and the Commission and Corporation would be one and the same.On October 2, 1978, the region of Northeast Missouri was designated by the United States Department of Commerce, Economic Development Administration as the Northeast Missouri Economic Development District. This was authorized under Title V of the Public Works and Economic Development Act of 1985 to designate multi-county districts for the purpose of fostering and promoting their economic growth.In February 2013, we moved to our new location at 121 S. Cecil Street, Memphis, MO.

  1. Regional Profile

NEMO RPC covers six counties and approximately 2,800 square miles in the Northeast corner of Missouri. The region is bordered on the East by the Mississippi River and extends west to Schuyler and Adair Counties. The Mississippi River has an important influence on the economic development in the region as it lends accessibility and provides transportation for commerce in the region. Moving west from the river the region is relatively flat and open. The area would be considered by most to be extremely rural however Kirksville would be considered the population center. There are many small communities that hold on to their small town, and historical nature. The majority of land area in the region would be considered open space used in a variety of agricultural and outdoor activities. There are many public parks, public recreation areas, and opportunities for outdoor activity dispersed throughout the region.

The climate of the area is moderate with four distinct seasons, none of which is extreme. There is ample rainfall and growing season, which accounts for plentiful vegetation.

  1. Population served (in relation to regional population)

The NEMO Region is made up of six counties (Schuyler, Adair, Scotland, Knox, Lewis and Clark) and 33 cities with a total population of 56,362 people according to the 2010 Census.

  1. Service area (include map, with any routes utilized)
  1. Governing body make-up (include terms of office)

An Executive Board of Directors that is appointed from the general membership governs the Commission/Corporation. The Executive Board is comprised of one county elected official or their designee and one city elected official or their designee from each of the six counties. The NEMO Executive board comprises 13 total members. There is a two year term limit for officers while there is no term limit for general board members.

C. Notice to the Public

Notifying the Public of Rights under Title VI

Northeast Missouri Regional Planning Commission (NEMO RPC)posts Title VI notices on our agency’s website, in public areas of our agency, in our board room, and on our buses and/or paratransit vehicles.

NEMO RPC operates its programs and services without regard to race, color, or national origin, in accordance with Title VI of the Civil Rights Act of 1964.

If you believe you have been discriminated against on the basis of race, color, or national origin by NEMO RPC, you may file a Title VI complaint by completing, signing, and submitting the agency’s Title VI Complaint Form.

How to file a Title VI complaint with NEMO RPC:

  1. Contact Derek Weber- Executive Director:

Telephone- (660)465-7281

Email-

121 S. Cecil St

Memphis, MO 63555

Website: nemorpc.org

  1. In addition to the complaint process at NEMO RPC, complaints may be filed directly with the Federal Transit Administration, Office of Civil Rights, Region 7, 901 Locust St, Suite 404, Kansas City, MO 64106; Phone: (816)329-3920 Fax: (816)329-3921.
  1. Complaints must be filed within 180 days following the date of the alleged discriminatory occurrence and should contain as much detailed information about the alleged discrimination as possible.
  1. The form must be signed and dated, and include your contact information.

If information is needed in another language, contact (660)465-7281.

D. Procedure for Filing aTitle VI Complaint

Filing a Title VI Complaint

The complaint procedures apply to the beneficiaries of NEMO RPC’s programs, activities, and services.

RIGHT TO FILE A COMPLAINT: Any person who believes they have been discriminated against on the basis of race, color, or national origin by NEMO RPC may file a Title VI com-plaint by completing and submitting the agency’s Title VI Complaint Form. Title VI complaints must be received in writing within 180 days of the alleged discriminatory complaint.

HOW TO FILE A COMPLAINT: Information on how to file a Title VIcomplaint is posted on our agency’s website, and in public areas of our agency.

You may download the NEMO RPC Title VI Complaint Form at [web address], or request a copy by writing to [agency’s full address.] Information on how to file a Title VI complaint may also be obtained by calling NEMO RPCat (660)465-7281.

You may file a signed, dated complaint no more than 180 days from the date of the alleged incident. The complaint should include:

- Your name, address and telephone number.

- Specific, detailed information (how, why and when) about the alleged act of discrimination.

- Any other relevant information, including the names of any persons, if known, the agency should contact for clarity of the allegations.

Please submit your complaint form to [agency contact and full address].

COMPLAINT ACCEPTANCE: NEMO RPC will process complaints that are complete.

Once a completed Title VI Complaint Form is received,NEMO RPC will review it to determine if NEMO RPC has jurisdiction. The complainant will receive an acknowledgement letter informing them whether or not the complaint will be investigated by NEMO RPC.

INVESTIGATIONS: NEMO RPC will generally complete an investigation within 90 days from receipt of a completed complaint form. If more information is needed to resolve the case, NEMO RPCmay contact the complainant. Unless a longer period is specified by NEMO RPC, the complainant will have ten (10) days from the date of the letter to send requested information to the NEMO RPC investigator assigned to the case.

If the requested information is not received within that timeframe the case will be closed. Also, a case can be administratively closed if the complainant no longer wishes to pursue the case.

LETTERS OF CLOSURE OR FINDING: After the Title VI investigator reviews the complaint, the Title VI investigator will issue one of two letters to the complainant: a closure letter or letter of finding (LOF).

- A closure letter summarizes the allegations and states that there was not a Title VI violation and that the case will be closed.

- A Letter of Finding (LOF) summarizes the allegations and provides an explanation of the corrective action taken.

If the complainant disagrees with NEMO RPC’s determination, the complainant may request reconsideration by submitting the request in writing to the Title VI investigator within seven (7) days after the date of the letter of closure or letter of finding, stating with specificity the basis for the reconsideration. NEMO RPC will notify the complainant of the decision either to accept or reject the request for reconsideration within ten (10) days. In cases where reconsideration is granted, NEMO RPC will issue a determination letter to the complainant upon completion of the reconsideration review.

A person may also file a complaint directly with the Federal Transit Administration, at the FTA Office of Civil Rights, 1200 New Jersey Avenue SE, Washington, DC 20590.

If information is needed in another language, contact Derek Weber, Executive Director at 121 S. Cecil St. Memphis, MO 63555,or at (660)465-7281.

E. Monitoring Title VI Complaints, Investigations, Lawsuits

and Documenting Evidence of Agency Staff Title VI Training

Documenting Title VI Complaints/Investigations

All Title VI complaints will be entered and tracked in NEMO RPC’s complaint log. Active investigations will be monitored for timely response on the part of all parties. The agency’s Title VI Coordinator shall maintain the log.

Agency Title VI Complaint Log

Date complaint filed / Complainant / Basis of complaint R-C-NO / Summary of allegation / Pending status of complaint / Actions taken / Closure Letter (CL) / Letter of Finding (LOF) / Date of CL or LOF

Documenting Evidence of Agency Staff Title VI Training

NEMO RPC’s staff are given Title VI training, and agency can answer affirmatively to all the following questions:

  1. Are new employees made aware of Title VI responsibilities pertaining to their specific duties?
  2. Do new employees receive this information via employee orientation?
  3. Is Title VI information provided to all employees and program applicants?
  4. Is Title VI information prominently displayed in the agency and on any program materials distributed, as necessary?

F. Public Engagement Plan

Goal

The goal of the Public Engagement Plan is to have significant and ongoing public involvement, by all identified audiences, in the public participation process for major agency outreach efforts.

Objectives

  • To understand the service area demographics and determine what non-English languages and other cultural barriers exist to public participation.
  • To provide general notification of meetings and forums for public input, in a manner that is understandable to all populations in the area.
  • To hold public meetings in locations that are accessible to all area stakeholders, including but not limited to minority and low income members of the community.
  • To provide methods for two-way communication and information and input from populations which are less likely to attend meetings.
  • To convey the information in various formats to reach all key stakeholder groups.

Identification of Stakeholders

Stakeholders are those who are either directly or indirectly affected by an outreach effort, system or service plan or recommendations of that plan. Stakeholders include but are not limited to the following:

  • Board of Directors – the governing board of the agency. The role of the Board is to establish policy and legislative direction for the agency. The Board defines the agency’s mission, establishes goals, and approves then budget to accomplish the goals.
  • Advisory Bodies – non-elected advisory bodies review current and proposed activities of the agency, and are encouraged to be active in the agency’s public engagement process. Advisory bodies provide insight and feedback to the agency.
  • Agency Transit riders and clients
  • Minority and low income populations, including limited English proficient persons
  • Local jurisdictions and other government stakeholders
  • Private businesses and organizations
  • Employers
  • Partner agencies

Elements of the Public Engagement Plan

It is necessary to establish a public participation plan that includes an outreach plan to engage minority and limited English proficient (LEP) populations.

Elements of the Public Engagement Plan include:

  1. Public Notice
  2. Official notification of intent to provide opportunity for members of the general public to participate in public engagement plan development, including participation in open Board/council meetings, and advisory committees.
  1. Public Engagement Process/Outreach Efforts:
  2. Public meetings
  3. Open houses
  4. Rider forums
  5. Rider outreach
  6. Public hearings
  7. Focus groups
  8. Surveys
  9. Services for the Disabled (Notices of opportunities for public involvement include contact information for people needing these or other special accommodations.)

Events such as public meetings and/or open houses are held at schools, churches, libraries and other non-profit locations easily accessible to public transit and compliant with the Americans with Disabilities Act.

  1. Public Comment
  2. Formal public comment periods are used to solicit comments on major public involvement efforts around an agency service or system change.
  3. Comments are accepted through various means:
  4. Dedicated email address.
  5. Website.
  6. Regular mail.
  7. Forms using survey tool for compilation.
  8. Videotaping.
  9. Phone calls to Customer Service Center [phone]
  1. Response to Public Input

All public comments are provided to the Board of Directors prior to decision making. A publicly available summary report is compiled, including all individual comments.

Title VI Outreach Best Practices

NEMO RPC ensures all outreach strategies, communications and public involvement efforts comply with Title VI. NEMO RPC’s Public Engagement Plan proactively initiates the public involvement process and makes concerted efforts to involve members of all social, economic, and ethnic groups in the public involvement process. Aligned with the above referenced communication tactics, NEMO RPC provides the following:

  1. Public notices published in non-English publications (if available).
  2. Title VI non-discrimination notice on agency’s website.
  3. Agency communication materials in languages other than English (subject to Safe Harbor parameters).
  4. Services for Limited English Proficient persons. Upon advance notice, translators may be provided.

2017 – 2022 Title VI Program Public Engagement Process

NEMO RPC will conduct a Public Engagement Process for the 2017-2022 Title VI Program. This process includes Community Meetings to seek input, provide education, and highlight key components of the Title VI Plan. Materials have been created to explain Title VI policies as well as provide education on how they relate to minority populations.