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HomeMy Public PortalAbout005-2022 - Approving and Updating the City's Policy Under Tittle VI of the Civil Rights Act of 1964 s t CITY OF RICHMOND,INDIANA BOARD OF PUBLIC WORKS AND SAFETY RESOLUTION NO. 5-2022 A RESOLUTION APPROVING AND UPDATING THE CITY OF RICHMOND'S POLICY IN CONNECTION WITH PUBLIC NOTICE OF RIGHTS UNDER TITLE VI OF THE CIVIL RIGHTS ACT OF 1964 WHEREAS, In accordance with the federal Americans with Disabilities Act(ADA) as well as Indiana Department of Transportation (INDOT) requirements, the City of Richmond utilizes certain policies and procedures in connection with Public Notice of Rights under Title VI of the Civil Rights Act of 1964, in order to continue to remain in compliance with the ADA and in order to continue to receive federal funding; and WHEREAS, Said policies and procedures are required to be updated by the City from time to time and said Public Notice Policy hereto as Exhibit A; and WHEREAS, It is in the best interest of the City of Richmond that the Board of Public Works and Safety approve the updated policies and procedures set forth in Exhibit A in order that the City of Richmond may continue to remain in compliance with the ADA and INDOT requirements. NOW THEREFORE, BE IT RESOLVED by the Board of Public Works and Safety of the City of Richmond, Indiana, that said Board hereby affirms, approves, and adopts the updated Implementation Plan and Policy in connection with Title VI of the Civil Rights Act of 1964, attach:d as Exhibit A. NOW THEREFORE, BE IT ALSO RESOLVED by the Board of Public Works a d Safety of the City of Richmond, Indiana, that Imani Murphy, Director of the Department of Human R•sources, be authorized to sign any documentation in connection with the Title VI Policy on behalf of the I:oard. Passed and adopted this '1` day of,&`1 , 2022, by the Boa d of Public Works and Safety of the City of Richmond,Indiana. BOARD OF PUBLIC WORKS •ND SAFETY 4.4 Vicki Robinson,President TC(IQ E i y Pal er Member Approved: Matt Evans,Member '�:: . Sno ` • ROSEVIEW TRANSIT PUBLIC TRANSPORTATION TITLE VI POLICY CITYOF RICHMOND RICHMOND, INDIANA JANUARY 2022 • [XHIBIT k PAGE I OFF t Table of Contents } I. Introduction 1 Rose View's Commitment to Civil Rights 1 II.General Requirements 2 Notice to the Public • 2 Discrimination Complaint Procedures 2 The Procedure 2 Active Lawsuits,Complaints or Inquiries Alleging Discrimination 3 III. Rose View's Public Participation Plan 4 Key Principles 4 Limited English Proficient(LEP)Goals of the Public Participation Plan 4 Objectives of the Public Participation Plan 5 IV: Rose View's Public Participation Process 6 Outreach Efforts-Alerting Riders and Encouraging Engagement. 6 Selection of Meeting Locations 7 Rose View Mediums 7 Addressing Comments 8 The Incorporation of Public Comments into Decisions 8 Identification of Stakeholders 8 Our Community Partners 8 Stakeholder List 8 V.Decision Making Bodies 8 Non-Elected Committees and Councils 8 Service Review Committee 9 Passenger Advisory Committee (PAC) 9 VI.Service Standards and Policies 10 Vehicle Load 1 0 Vehicle Headway (Frequency) 11 On-Time Performance 11 Service Availability-Access to the Bus 11 Vehicle Assignment Policy 11 1EXHIBIT A , PAGE 2 OF33�! Transit Amenity Policy 12 Monitoring Service Standards 12 VII, Summary of Changes 13 Service Change Evaluations Since[date of last plan] 13 Program Specific Requirements 13 Title VI Monitoring 13 Subrecipient Compliance 13 Equity Analysis for Facility 13 Demographic Service Profile 13 VIII. Grants,Reviews and Certifications 13 Pending Applications for Financial Assistance 13 Civil Rights Compliance Reviews in the Past 3 Years 13 • • Recent Annual Certifications and Assurances 13 Contact 14 IX.Language Assistance Plan 15 Improving Access for People with Limited English Proficiency (LEP) 15 Factor 1 15 Service Area Overview 15 The Locations of the LEP Community 16 Factor 2 16 Factor 3 18 Factor 4 19 Outcomes 20 New tools and alerting riders of language assistance 20 Oversight 20 Monitoring,Evaluating and Updating the Language Assistance Plan and Public 20 Participation Process 20 EXHIBIT A PAGE 3 c*33_. ! S I. INTRODUCTION • ROSE VIEW TRANSIT'S COMMITMENT TO CIVIL RIGHTS This update of Rose View Transit's Title VI Program has been prepared to ensure that the level and quality of Rose View's fixed route/demand response services are provided in a nondiscriminatory manner and that the opportunity for full and fair participation is offered to Rose View's riders and other community members, Additionally, through this program,Rose View has examined the need for services and materials for persons for whom English is not their primary language and who have a limited ability to read,write,speak,or understand English. While it is a matter of principle that Rose View is committed to ensuring that no person is excluded from participation in,or denied the benefits of,or subjected to discrimination in the receipt of any of Rose View's services on the basis of race,color,or national origin.The contents of this program have been prepared in accordance with Section 601 of Title VI of the Civil Rights Act of 1964 and Executive Order 13116(Improving Access to Services for Persons with Limited English Proficiency)and other statutes and authorities that prohibit discrimination in any Federally assisted program or service. Under the Civil Rights Act of 1964,and as a recipient of federal funding under the programs of the Federal.Transit Administration(FTA)of the U.S.Department of Transportation(US DOT),Rose View has an obligation to ensure that: + The benefits of its bus services are shared equitably throughout the service area; + The level and quality of bus services are sufficient to provide equal access to all riders in its service area; + No one is precluded from participating in Rose View's service planning and development process; + Decisions regarding service changes or facility locations are made without regard to race, color, or national origin and that development and urban renewal benefitting a community as a whole not be unjustifiably purchased through the disproportionate allocation of its adverse environmental and health burdens on the community's minority population;and + A program is in place for correcting any discrimination,whether intentional or unintentional. 1 I EXHIBIT PAGE LOF 33 l } i II. GENERAL REQUIREMENTS Notice to the Public To make Rose View riders aware of its commitment to Title VI compliance, and their right to file a civil rights complaint,Rose View has presented the following information,in both English and Spanish,on it's website, and in route maps. Your Civil Rights Rose View TY•ansitoper•ates it's programs and services without regard to race,color,or national origin,in accordance with Title VI of the Civil Rights Act and other statutes and authorities that prohibit discrimination in Federally assisted programs and activities.Any person who believes they have been aggrieved by any zrnlart f rl discriminatory practice under Title IV may file a complaint with Rose View Transit at www.richmondindiana.gov.For more information on Rose View's civil rights program and the procedures to file a complaint,please contact Imani Murphy,the Human Resources Director for the City of Richmond,email imurphy@richniondindiana.gov or visit our administrative office at 401 south"Q"St.from 8:00 am-9:00 pm.A complaint may also befiled directly with the ETA, Office ofCivil Rights, 1200New Jersey Avenue SE, Washington DC 20590. For more information about Rose ViewTransit's programs and services, visit www.richmondindiana.ciov.If iriforniation is needed in another language,please contact the Human Resources Office at 765-983-7435. Discrimination Complaint Procedures Rose View has established a process for riders to file a complaint under Title VI.Any person who believes that she or he has been discriminated against on the basis of race,color, or national origin by Rose View may file a Title IV complaint by completing and submitting the agency's Title VI Complaint available at our administrative offices or on our website wivw.richmondindiana.eov. • Rose View will notify INDOT of all formal complaints within five business days of receiving the complaint. The Procedure If you believe that you have received discriminatory treatment by Rose View Transit on the basis of race,color,or national origin you have the right to file a complaint with the Transit Management. • Methods of filing a complaint: Complete the Complaint Form,and send it to: Imani Murphy, 2 4cvi-) tIT Ilk PAGE ,rj OF 351 Human Resource Director,City of Richmond 50 North Sth Street Richmond,IN 47374 Verbal complaints are accepted and transcribed by office personnel. To make a verbal complaint, call 765-983-7227 and ask for the manager. Rose View investigates complaints received no more than 180 days after the alleged incident. Rose View will process complaints that are complete. Once the complaint is received,Rose View will review it and the complainant will receive an acknowledgement letter informing them whether the complaint will be investigated by Rose View. Rose View has up to thirty days to investigate the complaint. If more information is needed to resolve the case,Rose View may contact the complainant.The complainant has thirty days from the date of the letter to send requested information to the investigator assigned to the case. If Rose View's investigator is not contacted by the complainant or does not receive the additional Information within thirty days,Rose View can administratively close the case.A case can be administratively closed also if the complainant no longer wishes'to pursue their case. After the investigator reviews the complaint,one of two letters will be issued to the complainant:a closure letter or a 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 LOF summarizes the allegations and the interviews regarding the alleged incident,and explains whether any disciplinary action,additional training of the staff member, or other action will occur. If the complainant wishes to appeal the decision,she/he has ten days after the date of the letter or the . LOF to do so. A person may also file a complaint directly with the Federal Transit Administration at: Federal Transit Administration Office of Civil Rights 1200 New Jersey Avenue SE Washington,DC 20590 Active Lawsuits. Complaints or Inquiries Alleging Discrimination Rose View maintains a list of active investigations conducted by FTA and entities other than FTA, including lawsuits and complaints naming Rose View that allege discrimination on the basis of race, color,or national origin. This list includes the date that the transit-related Title VI investigation, lawsuit or complaint was filed;a summary of the allegation(s); the status of the investigation, lawsuit or complaint,and actions taken by Rose View in response, or final findings related to the investigation,lawsuit, or complaint. 3 A- PAGE (y OE33 Discrimination Complaint Form Title VI and ADA �er_ G- ..��.� a ti-.!+,?ij.- .4�._ _ x;-.:P� `:S�t ?y tL�r ,� � �� �'t'-' e a t ;; . 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If not, please supply the name and relationship of the person for whom you are complaining, Please explain why you have filed for a third party: Please confirm that you have obtained the permission of the 0 Yes j ❑ No • aggrieved party if you are filing on_behalf of a third party. • i{'''7.^• :::��i "ii R',-GYr nt w.-.y..y�' L 54 rF �•�. sir "+*.,}�. e:4�:•�:7 � *`I.7��'b-'f".J!<1!'t � _:_��y �u: �1i?hC �t`.� r-���°-. . -.�1. 3ai �• �40.-+•^Y+>'ta--:- µ•+,.4�'� �... .'�,i� GART . ek asS�.is '.V a...ii: Z�-`°'3' i a L? ` �' ! y ija'<<nara ' �i ,<:. I believe the discrimination I experienced was based on (check all that apply): ❑ Race 0 Color ❑ National Origin 0 Disability Date of Alleged Discrimination (Month, Day, Year): Explain as clearly as possible what happened and why you believe you were discriminated against. Describe all persons who were involved. Include the name and contact information of the person(s)who discriminated against you (if known) as well as names and contact Information of any witnesses, If more space is needed, please use the back of this form. Yt at y ga� � Y : "� e � 7 540 4� /53i : §: -0:6�i N St ` � ,. 0 . .Have you previously filed a Discrimination Complaint with this ❑ Yes ❑ No agency? If yes, please provide any reference information regarding your previous complaint. _.lam PAGE OF53 I � f -;cf,.-�;�;.y. .,�•'6'✓xe:yr. r.'�`t�-+roe "'�5 7;' rt�::�d� :y;:•ceu'}>}<n•"s::? �::a' "�.',�'_.,�- i,. • Q Yn1 !s(r yy�R ,�'� a�#� r � .�, �l .s (`,�''•��s'�, �?'-if",�'-�:��.i;�s�.-;,•.y,...,.�.,,_,•z:ti?:'. wfs5,Q.41,01.1G1 3..1512 Suti �3 `� 4�E'.."' r� n Eav�: �I+f ,:s'.., €,. s bn]•�-'. .�,, 1: !,,•• t- I. #. ..S 41,{{cl�ctrys! s ,� ���Y` �s E�: ;�1 � S y,�?•"a^r 't..v�1• t.:f.r{a �.,:`�� ��4 �S" nl' ..£4�1�+.4}.,:.n.S�r��.�'1..�a�f�Yvhr55�C'At;..S:k."rlr;xsk�� .$t'�i�tn� hcr;G;Frt�41}ti:;)9�:1a'x �!f. txt%.� }=, Have you filed this complaint with any other Federal,State, or local agency, or with any Federal , or State court? ❑Yes O No If yes,check aIIthat apply; ❑ Federal Agency: ❑ Federal Court: ❑ State Agency: ❑State Court: ❑ Local Agency: Please provide information about a contact person at the agency/court where the complaint was filed. Name: Title: Agency: Address: Telephone: rC<r:T�;;,p•-"•f': - �r.a� .`4�Dt•:'a�sl•'�yJk4•`�'- s i. a � t �q {�US����^.J-.cfT�`'L.".Lh t,7.ai;i crN'1 er�''L��?'•;,.i'i:+ �'ac s.-'r) s:, '}f2 t� .� � � r; U sN���� 5�,:1' 1...�'•� �.....�•'yti', i�" t`r`-' �Ki • �1 t !. v �� r .`. . t e * '�,G.,: sr-. <.0a7 a t7tM`j'. �% Se��I.onr..tl,,�F•�r<t `�. .= r �, gq4�yy,.'��{{I * x'f{c�jr,�(F`•.�)� +�. .f��Y:_ttk� �,i��f�. �-�`:�� .Y,x�'N�'�:��t TaM.s�'A t��/Z-• iLIYFS Jt'I.43L� .:1 v�+ .ct'.l, t,..y'...3�6�':t.Y„R:':`.. `viv l� Name of agency complaint is against: Name of person complaint is against: Title: Location: . I Telephone Number(If available): You may attach any written materials or other information that you think Is relevant to your complaint. Your signature and date are required below: Signature Date Please submit this form In person at the address below, or mall this form to: • ROSEVIEW TRANSIT-CITY OF RICHMOND IMANI MURPHY,DIRECTOR OF HUMAN RESOURCES 50 NORTH 5TH ST,RICHMOND,IN 47374 765-983-7435 IMURPHY@RICHMONDINDIANA.GOV A copy of this form can be found online at RICHMONDINDIANA.GOV • • i iEXHIBI KTAGE OF33 I As of the writing of this program, there are zero complaints pending which allege discrimination on the grounds of race, color,or national origin, or any other form of discrimination. Active Lawsuits, Complaints or Inquiries Alleging Discrimination Type (Investigation, Lawsuit, Action(s) Complaint) Date Summary of Complaint Status Taken III.ROSE VIEW'S PUBLIC PARTICIPATION PLAN Key Principles, Rose View's Public Participation Plan(PPP)has been prepared to ensure that no one is precluded from participating in Rose View's service planning and development process. It ensures that: • Potentially affected community members will have an appropriate opportunity to participate in decisions about a proposed activity that will affect their environment and/or health; • The public's contribution can and will influence Rose View's decision making; • The concerns of all participants involved will be considered in the decision-making process; and, • Rose View will seek out and facilitate the involvement of those potentially affected. Through an open public process,Rose View has developed a public participation plan to encourage and guide public involvement efforts and enhance access to Rose View's transportation decision- making process by minority and Limited English Proficient(LEP)populations.The public participation plan describes the overall goals, guiding principles and outreach methods that Rose View uses to reach its riders. LEP refers to persons for whom English is nottheir primary language and who have a limited ability to read,write,speak,or understand English.It includes people who reported to the U.S.Census that they speak English less than very well,not well,or not at all. Limited English Proficient(LEP) Goals of the J'ublic Participation Plan The overarching goals of Rose View's PPP include: 4 EXHIBIT irk PAGE' OP 3 • Clarity in Potential for Influence-The process clearly identifies and communicates where and how participants can have influence and direct impact on decision making. • Consistent Commitment- Rose View communicates regularly, develops trust with riders and our community and builds community capacity to provide public input. • Diversity -Participants represent a range of socioeconomic, ethnic and cultural perspectives, with representative participants including residents from low-income neighborhoods, ethnic communities and residents with Limited English Proficiency • Accessibility - Every reasonable effort is made to ensure that opportunities to participate are physically, geographically,temporally, linguistically, and culturally accessible. • Relevance-Issues are framed in such a way that the significance and potential effect is understood by participants. • Participant Satisfaction-People who take the time to participate feel it is worth the effort to join the discussion and provide feedback. • Partnerships-Rose View develops and maintains partnerships with communities through the methods described in its public participation plan. • Quality Input and Participation -That comments received by Rose View are useful, relevant and constructive, contributing to better plans, projects,strategies and decisions. Objectives of the Public Participation Plan Rose View's Public Participation Plan is based on the following principles: • Flexibility-The engagement process will accommodate participation in a variety of ways and be adjusted as needed. • Inclusiveness-Rose View will proactively reach outto and engage low income,minority and LEP populations from the Rose View's service area. • Respect-All feedback will be given careful and respectful consideration. • Proactive and Timeliness -Participation methods will allow for early involvement and be ongoing. • Clear,Focused and Understandable -Participation methods will have a clear purpose and use for the input, and will be described in language that is easy to understand. • Honest and Transparent-Information provided will be accurate,trustworthy and complete. • Responsiveness-Rose View will respond and incorporate appropriate public comments into transportation decisions. • Accessibility-Meetings will be held in locations which are fully accessible and welcoming to all area residents,including,but not limited to,low-income and minority members of the public and in locations relevant to the topics being presented and discussed. Rose View will use its public participation plan when considering all fare changes, major modifications to routes and schedules, and other transit planning projects when: • A fare increase/decrease or significant change in the method of fare payment is being considered; 5 EXHIBIT f1 PAGE 10_0 33 • Advance reservation policy is reduced or increased; • Area for deviating to pick up passengers is changed; • A new route is established; • An existing route is proposed for elimination; • Considering the total discontinuance of service on any line or group of lines on any given day when service is currently offered; • Any system-wide change in service hours that exceeds(plus or minus) 10%of current total service hours; • Routing on any given route or group of routes that affects more than 25%of the riders using the affected route(s); or • Schedules are changed on any given route or group of routes that reduces the total number of one-way bus trips by more than 25%of the current number of bus trips. • For minor schedule and service changes not rising to the level of those above,Rose View will post service change notices on appropriate buses and stops sixty days in advance of the change date. IV. ROSE VIEW'S PUBLIC PARTICIPATION PROCESS • Outreach Efforts-Alerting Riders and Encouraging Engagement Rose View's PPP includes many new mediums extending beyond the traditional approach which relied on legal notices and intermittent media coverage. While Rose View maintains these elements to its outreach program along with traditional seat-drop flyers, Rose View has availed itself of the communication methods more widely used by members of our community and riders. While there may be minor variation in the outreach process from time-to-time,the outline below • provides the general steps for engaging riders in the decision-making process using a fare or service change as an example. 1. A service/fare change proposal is developed internally or as a result of public comment; 2. An internal review by the appropriate committees is conducted.Rose View's Service Review Committee will review all service change proposals. 3. Proposals are reviewed by Rose View's Passenger Advisory Committee (PAC); 4. A Title VI review of the proposal is conducted; • • 5. If required,authorization from the Rose View's Board of Public Works&Safety is sought to proceed to a public comment period; 6. Public outreach venues,dates and times are determined with consideration of the proposed changes and their impact on specific locations/populations within the Rose View service • area; 7. Bilingual English and Spanish • 8. public outreach materials and a program are developed; • 9. Outreach In advance of public information sessions is released(using tool-box of mediums listed below: 1. An Email is transmitted to Rose View's community partners; 6 • 'EXHIBIT ►3- PAGE 't( OF 33( . 2. Local radio station advertisement. The public comment period ends; 3. The TAC committee is presented details of the outcome of the public participation process along with staff recommendations]; 4. The final service/fare change date is set; 5. Outreach is conducted in advance of any service or fare change; 6. Bilingual system timetable and website updated in advance of the proposed change. Selection of Meeting Locations When determining locations and schedules for public meetings,Rose View will: • Schedule meetings at times and Iocations that are convenient and accessible for minority and LEP communities; • Coordinate with community organizations, educational institutions,and other organizations to implement public engagement strategies that reach out specifically to members of affected minority and/or LEP communities; • Ensure that transportation is available to and from the meeting if requested; • Provide opportunities for public participation through means other than written communication,such as one-on-one interviews or use of audio or video recording devices to capture oral comments. Rose View Mediums • Print-Newspapers and other periodicals • Outdoor-Advertising on buses-exterior • Website-Rose View has assembled a comprehensive website. • Web-Based Feedback-(Report It. Shout It Suggest It How Are We Doing. and Toll Us Your Story). • Social Media-Rose View has used Facebook since 2018 to help engage community • Radio-Promos • Seat Drops, On-board Flyers-Rose View regularly uses flyers to provide riders with details of service changes and schedules of public meetings and hearings. • Direct Mail to Community Partners • Public Information Sessions • Public Hearings • Legal Notices 7 1EXHIBIT iI- EVADE lZ OF 37] Addressing Comments 77?B Incorporation of Public Commanta into Parisians 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 mail,email,social media,public meetings. All comments are assembled into a single document for presentation to the Board of Public Works& Safety for consideration. Identification of Stakeholders Our Community Partners Stakeholders are those who are either directly or indirectly affected by a plan,or the recommendations of the plan.Those who maybe adversely affected,or who may be denied benefits ofa plan's recommendation(s),are ofparticular interest in the identification ofspecificstakeholders. Stakeholders can come from a number of groups including general citizens/residents,minority and low-income persons,public agencies,and private organizations and businesses.While stakeholders may vary based on the plan or program being considered,Rose View has assembled a listing of stakeholders with whom we regularly communicate through email and direct mail.A complete list of Rose View's community stakeholders can be obtained by contacting management. Stakahnidar List Any community organization or person can be added to the Rose View stakeholder list and receive regular communications regarding service changes by contacting the Rose View administrative office at 765-983-7227. V.DECISION MAKING BODIES Pion-Elented Committees and Councils At Rose View, decisions regarding policy,service changes,fares,capital programming and facility locations are made by the Board of Public Works&Safety.The Board of Public Works &Safety is composed of three members representing the City of Richmond. Rose View's Passenger Advisory Committee(PAC)who hold ongoing meetings to help to guide decisions regarding routes,schedules, and other topics important to the community and our riders.Meetings of the Board of Public Works &Safety and the Passenger Advisory Committee are always open to the public,held in the Common Council Chambers, in the City Bldg., 50 north 5th Street. 8 A passenger Advisory Committee(PAC) • This committee is open to the public and comprised of passengers representing various bus routes. • At the bimonthly meetings, members discuss all aspects of Rose View's services from the • perspective of the public.This group offers an invaluable service to Rose View. Membership is voluntary and open-ended. • (i.e. members are not appointed and they may serve for as long as they desire)and it changes • from time to time.This group has been meeting for several years. Presently there are five • members. Body Caucasian African Hispanic Asian Race4 Race 5 American Board of WorIcs 2 1 0 0 0 0 Passenger Advisory 3 1 1 0 0 0 Committee Service Review Committee 9 [EXHIBIT.�PAGE 1 K OF I VI.SERVICE STANDARDS AND POLICIES Rose View has developed a set of quantifiable service standards and policies. These service standards were updated in 2001 through a public participations process, approved by the City's Board of Works and with the input of Rose View's Passenger Advisory Committee(PAC). These service standards and policies include: Vehicle Load + Headways (Frequencies) On-time Performance(Schedule Adherence) $ Service Availability Vehicle Assignment Policy $ Transit Amenity Policy Following the internal updating of these policies and standards, Rose View will advertise and hold a public information session to receive comments on the proposed standards. During the session, Rose View staff will present an overview of the components of Rose View's public participation process as well as the various policies and standards.A copy of the presentation will be available by contacting Rose View office. Vehicle Load • Vehicle load for each mode: Generally expressed as the ratio of passengers to the number of seats on a vehicle, relative to the vehicle's maximum load point. For example, on a 40-seat bus,a vehicle load of 1.3 means all seats are filled and there are approximately 12 standees. Transit providers can specify vehicle loads for peak vs. off-peak times, and for different modes of transit. Vehicle load is expressed as the ratio of passengers to the total number of seats on a vehicle. Vehicle Type Seated Standing Total Average Maximum Capacity Capacity Capacity Load Load Ford E-450 Rose View 16 8 24 .50 1.5 Ford E-350 Paratransit 8 4 12 .50 1.5 10 [EXHIBIT 1 PAGE I SOF.33 • Vehicle Headway(Frequency Vehicle headway is the amount of time between two buses traveling in the same direction on a given route.Rose View buses are scheduled with a variety of frequencies based generally on demand. Routes are schedule in 30 minute frequencies. Service/Mins Weekday Weekday Saturday Saturday Sunday Sunday Peak Off-Peak Peak Off-Peak Peak Off-Peak Rose View 30 30 30 30 N/A N/A Local Service min. min. min. min. On-Time Performance Among the most important service standard for riders is on-time performance or adherence to published schedules. • • A vehicle is considered on time if it departs a scheduled time point no more than two minutes • early and no more than 5 minutes late. • • Rose View's on-time performance objective is 90%or greater. • Service Availability-Access to the Btu, • Rose View currently provides transit service so that 60%of all residents of Richmond are within a mile and one half walk of bus service. Consideration is given to new markets as demand warrants and as resources become available. • • • Vehicle Assignment Policy With several practical considerations,Rose View assigns buses to service so that average age of the • buses serving each route does not exceed the average age of the fleet.Bus assignments take into account the operating characteristics of buses of various lengths,which are matched to the operating characteristics of the route, • • �I !EXHIBIT PPAGE I60cF33 . • Transit Amenity Policy. • Rose View's bus stops are virtually any street corner in the service area. • Stops, shelters and benches will be placed according to industry standards(TCRP Report 19) with consideration of permitting and for local and special needs.The installation of new bus amenities can be requested through the customer service office, or at public meetings. When the annual cost of repairs to any amenity(beyond the cost of normal cleaning) is greater than the cost of the structure,Rose View reserves the right to permanently remove the amenity. jVlonitoring Service Sfandardg For the on-going monitoring and measurement of service standards and policies,Rose View uses the following schedule and methods. Service Standard/Policy Sample Schedule Methodology Survey samples and/or Vehicle Load All Routes Bi-Annually sample of dispatch logs Assessed Annually as Part of Survey samples and/or Vehicle Headway Service Planning sample of dispatch logs • On-time Survey samples and/or Performance Assessed Monthly sample of dispatch logs Service Assessed Annually as Part of Survey samples and/or Accessibility Service Planning sample of dispatch logs Vehicle Assignment Survey samples and/or Policy Assessed Quarterly sample of dispatch logs 12 EXHIBIT PAGE I/ OF 33-1 VII. SUMMARY OF CHANGES Service Change Evaluations Since Since Rose View's 2008 Title VI Plan Submission there have been no changes in Rose View's fare structure. There have been no service changes. These changes,the associated outreach and Title VI determination and Rose View Board of Works Approval are available by contacting Rose View. Program Specific Requirements Title VI monitoring(from March 3, 2016 Title VI Plan) The results of the ongoing monitoring of service standards as defined in the Rose View's March 3, 2016 program can be obtained by contacting Rose View. Sltbrecinieni compliance Rose View has no subrecipients. Equity Analysis for Facility Rose View has not constructed any new buildings since 2010. Demopranhic Service Pro`J7le Because Rose View operates fewer than 50 buses in peak service, a demographic service profile was not prepared for this plan update. VIII. GRANTS,REVIEWS AND CERTIFICATIONS ,Pending,Applications for Financial.Assistance NONE Civil Rights Compliance Reviews in the Past 3 Years • Rose View has not been the subject of any such reviews since its March 3,2016 submission. • Rose View's compliance review/approval letter dated 8/15/2018 is on file at the transit office. Recent Annual Certifications and Assurances Rose View executed its most recent Certifications and Assurances to the FTA in May 15,2020, and is in the process of executing 2021 certifications and assurances. 13 rE-XHIBIT P1AJoIGEF31j.; f � Contact For additional information on the Rose View Title VI Plan,or its efforts to comply with the Civil Rights Act of 1964 or Executive Order 13166 Improving Access to Services for Persons with Limited English Proficiency,please contact: Imani Murphy,Director Human Resources City of Richmond 765-983-7435 X.LANGUAGE ASSISTANCE PLAN Improving Access for People with Limited English Proficiency fLEPI In order to ensure meaningful access to programs and activities,Rose View uses the information obtained in a Four Factor Analysis to determine the specific language services that are appropriate. This analysis helps Rose View to determine if it communicates effectively with LEP persons and informs language access planning. The Four Factor Analysis is a local assessment that considers: 1. The number or proportion of LEP persons eligible to be served or likely to be encountered byRose View; 2.The frequency with which LEP persons come into contact with Rose View services andprograms; 3. The nature and importance of Rose View's services and programs in people's lives;and 4. The resources available to Rose View for LEP outreach,as well as the costs associated with thatoutreach Fa ctorl-NumberofLEPPersonsinServiceRegion The first step in determining the appropriate components of a language Assistance Plan is understanding the proportion of LEP persons who may encounter Rose View's services,their Literacy skills in English and their native language,the location of their communities and neighborhoods,and more importantly,if any are under served as a result of a language barrier odothis,RoseView evaluated the level of English literacy and to what degree people in its service are speak a language other than English and what those languages are.Data for this review is derived from the United States Census and the American Community Survey 2010 Census Data was reviewed by Rose View's city leaders in its entirety. Service Area Overview Rose View's service area encompasses the entire City of Richmond Corp.limits and is home to a population speaking more than one different language.Of the total service area population,35,539, less than 1%of residents repor tspeaking English less than very well.The mos tpopulous groups in the category are shown below. Of the remaining populations,those reporting English"less than very well" range from 1%to 5%of the total service area population. 14 ;HIBIT PAGE lei ©E 33 .d • SpeakEnglish Population in the Language Percent of Total Population "Less:tban.very Well" Group Spanish 1% Chinese None The Locations of rhe.LEP community. • The map.in Exhibit A-illustrates the distribution of population densities by Census Tract where individuals speak English"Less than Very Rte1l;.for Richmond,- includes the LEP community_A trap Factor 2-Frequency of LEP Use There are many places where RoseView riders and members ofthe LEP population can come into contactwithRoseViewservicesincludingtheuseoffixedrouteand demand responsebuses,callsto customer service representatives,reservation agents and RoseView's outreach materials.An important part of the development of RoseView's Language Access Plan is the assessment of major points of contact,including: • The use of the bus service(on-boardsignage,announcements and driver language skills); • Communication withRoseView's customerservice staff; • Printed outreach materials; • Web-based outreach materials; • Buspass sales; • Public meetings; • Demandresponsereservationagents; • Localnewsmedia(printandradio); • Automatic,service related audio announcements on-board Rose View buses; and • Service related posters at Rose View's bus terminal. Rose View distributed a language survey to its employees.The objective of the survey was to evaluate the needs of Rose View customers who are not able to communicate in English.The first question asked, In What way(s)Do You Interact with RoseView'sriders?The chart below illustrates the results. .Arethodzf Tntaraction.. Percent-nfRpspnnsps -.- F�retnF�ee — 3%..__...... Frnait. - - - Fax ...- -- __.... _.. 15 EXHIA PA -7d P33 _ Next,the survey asked how often employees come into contact with LEP customers. The chart • below outlines the results. Frequency of Interaction Percent of Responses Often Sometimes Rarely 100% Never Next,the survey asked employees to identify how often they interact with the following languages on a typical workday. Language Percent of Interactions English only 75% Spanish 25% The survey asked, overall,how effective employees are in communicating with Limited English Proficient Rose View passengers. The results are summarized below. Effectiveness Percent of Total Responses Very Effective Moderately Effective 100% Less Effective Unable to Communicate Community Partners Rose View also canvassed its community partners to assess the extent to which they came into contact with LEP populations. Community partners were asked the following questions: • 1.Do you encounter non-English speaking/reading people who need your services? 2.If so,what are the top three languages that you encounter? 3.How do you address language barriers? 4. Do you find language to be a barrier in preventing you from providing service? • • Questionll Walmart-Richmond Kroger Grocery Store Cracker Barrel Do you encounter non- English . speaking/reading people who need your services? • If so,what are the top ,Spanish Asian,Spanish German,French, three languages that Asian Middle Eastern • 16 EXHIBIT Pc PAGE 21 OF 331 • you encounter? How do you address Phone translator Do not address them. Sign language language barriers? jing,, Servers work with the customer to figure out what they want. Do you find language HQ, No. They should be No barrier,we make to be a barrier in able to speak English. it work.We get them preventing you from their meal. providing service? Consulting Directly with the LEP Population In addition to the U.S. Census data,employee survey, and outreach to community partners,Rose View will implement a survey of its riders.. Factor 3-The Importance of Rose View's Service to People's Lives • Access to the services provided by Rose View are critical to the lives of many in the service area, Many depend on Rose View's services for access to jobs and for access to essential community services like schools, shopping and medical appointments.Riders eligible for service under the American's with Disabilities Act(ADA)require service for the same reasons. Because of the essential nature of the services and the importance of these programs in the lives of many of the region's residents,there is a need to ensure that language is not a barrier to access. If limited English proficiency is a barrier to using these services,then the consequences for the individual could limit their access to obtain health care, education or employment. Critical information from Rose View which can affect access includes: • Route and schedule information • Fare information • Information regarding making the best use of the system(How To) • Service announcements • Safety and security announcements • Complaint and comment forms • Outreach related to opportunity for public comments • Information about demand response'services under the ADA and other special programs 1'l 'EXHIBIT 1k PAGE .2.20F33 • • The following notice is posted on all Rose View vehicles. Rose View ensures that no person shall, on the grounds of race, color, or national origin be excluded from participating in or denied benefits of or be subjected to discrimination as it relates to the provision of public transportation services provided by Rose View. Any person who wants additional information on Rose View's nondiscrimination obligation or believes that he or she individually or as a member of any specific class of persons,has been subjected to discrimination on the basis of race,color, or national origin may file a complaint with the Rose View within 180 days of the date of the alleged discrimination. To file a complaint contact lmani Murphy at 765-983-7435,www.richmondindiana.gov or send a letter to 50 North 5th St.Richmond IN 47374.A complaint may also be filed directly with the FTA, Office of Civil Rights, 1200 New Jersey Avenue SE,Washington DC 20590. La companfa Rose View Transit garantiza que ninguna persona,por motivos de raza, color, o origen nacional esten excluida de la participaci6n o negado de los beneficios o ser subjeto de discriminaci6n en respecto a los servicios proveidos de la Authoridad del transporte publico. Cualquier persona que cree que el o ella a tf tulo individual o como miembro de una clase especffica de personas,ha sido subjeto de discriminaci6n por motivos de raza, color, o origen nacional puede presentar una queja a la companfa Rose View dentro de los 180 dfas siguientes a la fecha de la supuesta discriminaci6n. Para presentar una queja al Rose View, !lame al 765-983-7435, www.richmondindiana,gov, o escribe una calta y envia a 50 North 5th St., Richmond, IN 47374 Se puede presentar una queja directamente ante el FTA,Oficina de Derechos Civiles, 1200 New Jersey Avenue SE,Washington DC 20590. Factor 4-Resources and Costs for LEP Outreach Rose View has committed resources to improving access to its services and programs for LEP persons. Today,bilingual information(English/Spanish)is distributed in an extensive number of mediums including the following: The City of Richmond has a bilingual speaking person on staff to translate if needed. $ A bi-lingual English/Language(s) website A complete bilingual English/Language(s)system timetable $ A complete bilingual English/Language(s)Rider's Guide to demand response services(ADA paratransit) 1 Bilingual English/Language(s)outreach materials(seat drops and service change alerts) 4 Bilingual English/Language(s)representation at public meetings Bilingual English/Language(s)customer service representatives 4 Bilingual English/Language(s)Demand Response reservation agents/customer service representatives I Bilingual English/Language(s)on-board signage • Increased use of Bilingual English/Language(s) and Facebook posts(not yet EXHIBIT p PAGE 23 OF33 T � + 100%) To date,the costs associated with these efforts fit within the Rose View's marketing and outreach budget. Costs are predominantly associated with translation services and material production. Outcomes New tools and alertinu riders of lanuuave assistance Following the "Four Factor Analysis", Rose View concluded that, while there is currently extensive outreach and materials for the Language(s) speaking LEP population of the service area, additional services would assist other LEP populations regardless of the total population in the region. These include: 1. Adding Google Translate to the Rose View website; • 2. Adding translation services for telephone communications with customer service representatives; 3. Assigning new staff charged with improvement community engagement; and 4.• Creating a page with multiple languages for print(system timetable) and web-based posting indicating how Rose View provides language assistance. 5. Use a smart phone with translation application. The above items are in process and will be launched on March 1, 2023, Additional recommendations gleaned from the internal staff survey include: 1. Offering employees conversational or transit specific language training 2. Recruiting more multilingual employees. 3. A multi-language touch screen monitor where passengers can access bus route information at the terminal. 4. On-board announcements in different languages. • Rose View is considering all these items and other methods that become available. Oversight Monitoring.Evaluating and Updating the Language Assistance Plan and Public Participation Process The monitoring of the Language Assistance Plan will include: Annual reviews of regional census data for changing patterns of LEP populations; • Update the policy every three years; Ongoing collaboration with regional partners; 19. !EXHIBIT A PAGE 2u 0P33 F c f Ongoing review of Google Translate requests at Rose View's website; and 4 Post Event Assessments (PEA) Post-Event Assessments Following service changes,fare increases and planning projects,Rose View staff assesses the effectiveness of public involvement against the goals established in this plan. This assessment will ask the questions: • Did the public know there was an opportunity to participate? • Was the purpose of the participation clearly articulated to the public? • Did the public have access to appropriate resources and information to allow for meaningful participation? • Did the decision making process allow for consideration and incorporation of public input? Were there complaints about the public engagement process? 1 Were the public engagement efforts cost effective? What additional methods could have been employed to improve the process? • • Should the Public Participation Process or Language Assistance Plan be amended? Training Employees Rose View conducts annual and new employee training on how to use LEP translation services that are available to the public and how to inform passengers of services and documents available for LEP populations.Rose View also conducts training for office staff on how to use translation applications. Employee awareness training for the ability to basically communicate with the LEP and low-literacy population. • Translation of Vital Documents Rose View has translated many vital documents into Spanish and is in the process of translating others.The list of documents that are or will be translated is provided below: Civil Rights Complaint Form-Translated into 2015 ADA Eligibility Applications-Translated in 2015 • • ADA Service Overview Booklet-Translated into Spanish in 2015 Maps and schedules,rider information,ADA service information,news and event announcements are all translated into Spanish on Rose View's website:richmondindiana.gov • } 1 [)(HIBIT PAGE 2.SOF , • ,, . Exhibit A .,/ . . . -. ... .. f. i,., • . i . g-.• . i ., '. :lot '..2.•• 1 • •' 4* r 0\ i • Tumer•Rd • •-"' 7. i •• P L A!4 ' 1 ." "tifil :,.. '• 11,4,.' „ 4;*1 ..., •:.' ands Fork•Rti r - .-c tur0 ,..,.. Y: I ..... . . • Srtlyar Rd • , ,.,• I 1 %S...,,•1:„. ,' !..i 1 IE.1)1. ' - N. •s!.,_...,,-.1,4L.s.),„4 t: '•-•. :. 1 W,rap.1-75'1"1 • 1'''--g•-• ""• • ta LI • , 1,V,20\7k % :. .. ejeliiilt TIBCI4 Wm l'41 1••. • . roni Hi,a ,r6 1 .6,516(+1`0.7) ar Jail * i 5 Percentage of Residents keurt ,COO- 0,3) *,, . ."" :. .• , 'i 000(kJ- ...., .- ' Ps::.;r:VV.*Rd • Who Speak English Less than"Very Well" .... ;,!;GrOtiki , •.. - • s ,..• :.? '. •• -, . • , 1-...• Vt • • . 1.4';;L..1?• -1.?-:'-;:troi- k • ,.•• .. I:1 City Limits --a,::','Ijc,, 6- 14177''1:7L. "., ...• • .''.*:N.,ifli........1-,t,,,,,,..ets.Ed:,i:,:,,,,,,,,t4 ' 7. '... . .. . .. 4'7 "..•:*..‘r.::'-1.tie&51,1T-Frg•ftlikV t!..;••, --4--1,,,___ .,-ror..`P••:-!-?. - - =.2 „.,..,.,,Tie:..,----e. 4'._- 6 ,,,, •.i•m, -----,---,7-... ':;1••,•37:,,,,,-;',.''• ?. 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