Title VI Implementation Plan Limited English Proficiency Language Assistance Plan - January 1, 2021 - December 31, 2021
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Title VI Implementation Plan
Limited English Proficiency
Language Assistance Plan
January 1, 2021 - December 31, 2021
Federal Highway Federal Transit
Administation Administation
Title VI Implementation Plan and
Limited English Proficiency
Language Assistance Plan
for the Evansville-Henderson Urbanized Area
Adopted: January 11, 2018
Updated: February 14, 2019
Updated: June 13, 2019
Updated: January 15, 2020
Updated: April 14, 2020
Updated: June 11, 2020
Updated: March 18, 2021
Updated: April 19, 2021
Evansville Metropolitan Planning Organization
1 NW Martin Luther King, Jr. Blvd.
Room 316 - Civic Center Complex
Evansville, IN 47708
Phone: 812.436.7833
www.evansvillempo.com
This project was partially funded by grants from the U.S. Department of Transportation, Federal Highway
and Federal Transit Administrations.
Page intentionally left blank.
ACKNOWLEDGEMENTS
EVANSVILLE MPO POLICY COMMITTEE MEMBERS
Mr. Jack Corn, Jr. Chairperson, Evansville City Council Appointment
Mr. Rusty Fowler Vice-Chairperson, Indiana Department of Transportation
Mr. Lloyd Winnecke Mayor, City of Evansville
Mr. William “Buzzy” Newman Henderson City Manager, City of Henderson Appointment
Mr. Ron Beane Councilmember, Evansville City Council
Mr. Ben Shoulders Commissioner, Vanderburgh County Commission
Ms. Jill Hahn Councilmember, Vanderburgh County Council
Mr. Dan Saylor Commissioner, Warrick County Commission
Mr. William Hubiak County Engineer, Henderson County Appointment
Mr. John Stoll County Engineer, Vanderburgh County Commission Appointment
Mr. Todd M. Robertson Transportation and Services Director, City of Evansville Mayoral Appointment
Ms. Christy Powell Town Manager, Town of Newburgh Appointment
Ms. Deneatra Henderson Chief District Engineer, Kentucky Transportation Cabinet
Mr. Joe McGuinness Indiana Department of Transportation (NV)
Mr. Jermaine Hannon Indiana Federal Highway Administration (NV)
Ms. Kari Carmany-George Indiana Federal Highway Administration (NV)
Mr. Shawn Seals Indiana Department of Environmental Management (NV)
Ms. Marisol Simon Federal Transit Administration Region V (NV)
Ms. Cecilia Godfrey Federal Transit Administration Region V (NV)
Mr. Todd Jeter Kentucky Federal Highway Administration (NV)
Ms. Bernadette Dupont Kentucky Federal Highway Administration (NV)
Mr. Jim Gray Kentucky Transportation Cabinet (NV)
Mr. Mikael Pelfrey Kentucky Transportation Cabinet (NV)
Ms. Melissa Duff Kentucky Division of Air Quality (NV)
(NV) = Non-voting
ACKNOWLEDGEMENTS EVANSVILLE MPO TECHNICAL COMMITTEE MEMBERS Mr. Greg Wathen Chairperson, Economic Development Coalition of Southwest Indiana Mr. John Stoll Vice-Chairperson, Vanderburgh County Engineer The following organizations are represented on the Technical Committee: American Medical Response Indiana Department of Transportation (Indianapolis) Carver Community Organization Indiana Department of Transportation (Vincennes) CSX Transportation Indiana Southern Railroad Easter Seals Rehabilitation Center Kentucky Transportation Cabinet (Frankfort) Economic Development Coalition of Southwest Indiana Kentucky Transportation Cabinet (Madisonville) EnviroKinetics, Inc. Lochmueller Group Evansville ARC Metropolitan Evansville Transit System Evansville Bicycle Club Port of Indiana-Mount Vernon Evansville Board of Public Safety Posey County Chamber Evansville Chamber of Commerce Qk4 Inc. Evansville City Engineer River City Taxi Evansville Department of Metropolitan Development St. Vincent’s Trauma Hospital Evansville Department of Transportation and Services Shrewsberry & Associates, LLC Evansville Department of Urban Forestry SIRS Inc. Evansville Environmental Protection Agency University of Evansville Evansville Parks and Recreation Department Vanderburgh County Emergency Management Agency Evansville Police Department Vanderburgh County Engineer Evansville Regional Airport Warrick County Economic Development Evansville-Vanderburgh Area Plan Commission Warrick County Plan Commission Evansville Water and Sewer Department Warrick County School Corporation Federal Highway Administration (Indiana) Westside Improvement Association Federal Highway Administration (Kentucky) Federal Transit Administration (Region V) Green River Area Development District Henderson Area Rapid Transit Henderson City Engineer Assistant Henderson City Manager Henderson County Engineer Henderson County Riverport Henderson-Henderson County Chamber of Commerce Henderson-Henderson County Plan Commission Henderson Judge Executive Indiana Department of Environmental Management (Indianapolis)
ACKNOWLEDGEMENTS
CITIZEN’S ADVISORY COMMITTEE (MTP 2045)
Ms. Shari Sherman Warrick County Chamber of Commerce
Mr. Tony Iriti Kyndle (Henderson Chamber of Commerce)
Ms. Donna Crooks Kyndle (Henderson Chamber of Commerce)
Mr. Larry Taylor Success Warrick County
Mr. Justin Groenert Southwest Indiana Chamber of Commerce
Mr. Wil Marquez Diverse Business Alliance
Mr. Josh Armstrong Downtown Alliance Director
Ms. Ellen Horan GAGE (Growth Alliance for Greater Evansville)
Ms. Abby Dixon Henderson County Tourist Commission
Mr. Jim Heck WorkOne Southwest
Mr. Greg Wathen Economic Development Coalition of Southwest Indiana
Ms. Helen Zimmerman Historic Newburgh, Inc
Mr. Shawn Hayden Eastland Mall
Mr. Nate Hahn Evansville Regional Airport
Mr. Phil Wilzbacher Ports of Indiana
Mr. John DiDomizio Beam, Longest and Neff
Mr. Mike O’Daniel D-Patrick Automotive
Mr. John Petkovsek David Matthews Associates
Mr. Jonathan Weinzapfel Ivy Tech Community College
Mr. Ben Payne Henderson County Schools
Mr. Rick Cameron Evansville-Vanderburgh School Corporation
Ms. Kris Williams Henderson Community College
Ms. Donna Teague University of Evansville
Mr. Jim Wilsbacher CAJE (Congregations Acting for Justice and Empowerment)
Ms. Angie Higgins Easterseals Rehabilitation Center
Mr. Andy Imlay Evansville Advisory Board on Disability Services
Ms. Vanessa Rodriguez HOLA Evansville
Mr. Silas Matchem Promise Zone
Ms. Diane Clements-Boyd Evansville Human Relations Commission
Mr. Ted Miller Citizen
Mr. Nibby Priest Henderson Bikeway Advisory Committee
Ms. Lorie Van Hook Evansville Trails Coalition
Mr. Steve Roelle Warrick Trails
Ms. Mary Raley St. Vincent Evansville
Mr. Jim Renne Deaconess Hospital
Ms. Andrea Hays Welborn Baptist Foundation
Mr. Noah Robinson Vanderburgh County Sheriff’s Department
Mr. Brent Jackson United Neighborhoods of Evansville
Mr. Leonard Collins Goosetown Neighborhood Association
Ms. DeAnna Outlaw Westside Improvement Association
Mr. Randy Garratt Culver Neighborhood Association
Ms. Janelle Lemon INDOT
ACKNOWLEDGEMENTS EVANSVILLE MPO STAFF Mr. Seyed Shokouhzadeh Executive Director Ms. Pamela Drach Deputy Director Ms. Erin Schriefer Senior Transportation Planner Mr. Matt Schriefer, AICP Transportation Planner Mr. Amir Varshochi Transportation Planner Ms. Laura Lamb Chief Transportation Engineer Mr. Xinbo Mi Transportation Engineer Ms. Kari Akin Finance Officer Mr. Lorenzo Marsh Transportation Technician
TABLE OF CONTENTS
TITLE VI IMPLEMENTATION PLAN.................................................................................................... 1
Introduction................................................................................................................................................................ 1
Evansville Metropolitan Planning Organization Title VI Policy Statement.............................................................. 2
Organización de Planificación Metropolitana de Evansville Declaración de política del Título VI........................ 3
Notification to the Public of Rights under Title VI.................................................................................................... 4
La notificación al público de derechos en virtud del Título VI................................................................................. 5
Evansville MPO Title VI Complaint Procedures........................................................................................................ 6
Overview................................................................................................................................................................ 6
Persons Eligible to File a Complaint.................................................................................................................... 6
Filing a Complaint................................................................................................................................................. 6
Receipt of Complaints.......................................................................................................................................... 6
Processing Complaints......................................................................................................................................... 7
Acceptance and/or Dismissal of Complaints...................................................................................................... 7
Withdrawal of a Complaint................................................................................................................................... 8
Appeal Process...................................................................................................................................................... 8
Final Agency Reports............................................................................................................................................ 9
Record of Title VI Complaints, Investigations and Lawsuits.................................................................................... 9
Program Review Procedures..................................................................................................................................... 9
Review of Plans, Policies and Directives.................................................................................................................. 9
Compliance/Noncompliance Review...................................................................................................................... 10
Special Emphasis Program Areas........................................................................................................................... 10
Title VI Organization and Staffing............................................................................................................................ 10
Staff Training............................................................................................................................................................ 11
Sub-Recipient Review.............................................................................................................................................. 12
Public Participation.................................................................................................................................................. 12
Inclusive and Meaningful Public Participation.................................................................................................. 12
Title VI Public Involvement Survey..................................................................................................................... 12
Evansville MPO Policy and Technical Committees............................................................................................ 13
Data Collection, Reporting and Analysis................................................................................................................ 13
Regional Demographic Profile................................................................................................................................. 14
Total Population.................................................................................................................................................. 14
Age and Gender.................................................................................................................................................. 15
Race and Ethnicity.............................................................................................................................................. 15
Individuals with a Disability................................................................................................................................ 15
Household Income.............................................................................................................................................. 16
Poverty................................................................................................................................................................. 16
Language............................................................................................................................................................. 17
Potentially Disadvantaged Areas....................................................................................................................... 17
Environmental Justice.............................................................................................................................................. 25
Impact of Planned Projects on Disadvantaged Populations................................................................................. 25TABLE OF CONTENTS
LIMITED ENGLISH PROFICIENCY LANGUAGE ASSISTANCE PLAN................................................... 27
Introduction.............................................................................................................................................................. 27
Limited English Proficiency Defined........................................................................................................................ 28
Safe Harbor Provision.............................................................................................................................................. 29
Four Factor Analysis................................................................................................................................................. 29
Factor 1................................................................................................................................................................ 29
Factor 2................................................................................................................................................................ 29
Factor 3................................................................................................................................................................ 30
Factor 4................................................................................................................................................................ 30
Identifying LEP Individuals Who Need Language Assistance............................................................................... 30
Language Assistance Measures............................................................................................................................. 31
Staff Training............................................................................................................................................................ 31
Outreach and Providing Notice to LEP Persons..................................................................................................... 31
Monitoring and Updating the Language Assistance Plan..................................................................................... 31
Submission of Questions, Comments or Requests............................................................................................... 32
FIGURES
Figure 1: 2015 Regional Population....................................................................................................................... 14
Figure 2: 2015 Age and Gender............................................................................................................................. 15
Figure 3: 2015 Race and Ethnicity......................................................................................................................... 15
Figure 4: 2010 and 2015 Individuals with Disabilities......................................................................................... 15
Figure 5: 2015 Median Household Income........................................................................................................... 16
Figure 6: 2015 Language Spoken.......................................................................................................................... 17
Figure 7: Potentially Disadvantaged Areas............................................................................................................. 18
Figure 8: Individuals Below Poverty........................................................................................................................ 19
Figure 9: Individuals Age 65 and Older.................................................................................................................. 19
Figure 10: Minority (non-Hispanic) Population....................................................................................................... 20
Figure 11: Hispanic Population............................................................................................................................... 20
Figure 12: Individuals with Limited English Proficiency (speak English “less than very well”)........................... 21
Figure 13: Individuals with a Disability................................................................................................................... 21
Figure 14: Households with No Vehicles................................................................................................................ 22
Figure 15: Targeted Outreach Areas with MTP 2040 Projects.............................................................................. 23
Figure 16: Targeted Outreach Areas with 2018-2021 TIP Projects...................................................................... 24
TABLES
Table 1: 2015 Poverty Thresholds.......................................................................................................................... 16
Table 2: Language Spoken at Home....................................................................................................................... 28
Table 3: Frequency of Contact with LEP Individuals.............................................................................................. 29
APPENDICES
Appendix A: Location of Title VI/LEP Plan for Viewing.......................................................................................... A-1
Appendix B: Title VI Public Notice, Complaint Procedures and Complaint Form................................................ B-1
Appendix C: Title VI Public Involvement Survey..................................................................................................... C-1
Appendix D: U.S. DOT Standard Title VI/Non-Discrimination Assurances...........................................................D-1
Appendix E: MPO Policy and Technical Committee Members.............................................................................. E-1
Appendix F: Title VI Complaints, Investigations and Lawsuits Log...................................................................... F-1
Appendix G: Title VI Annual Goals and Accomplishments Reports......................................................................G-1TITLE VI IMPLEMENTATION PLAN
INTRODUCTION
The Evansville Metropolitan Planning Organization (MPO), the designated MPO for the Evansville Urbanized Area,
has developed this Title VI Implementation Plan pursuant to Title VI of the Civil Rights Act of 1964, which states:
“No person in the United States shall, on the ground of race, color, or national origin, be excluded from
participation in, be denied the benefits of, or be subjected to discrimination under any program or activity
receiving Federal financial assistance.”
Furthermore, this Title VI Implementation Plan follows the Department of Transportation regulations within Title
49, Code of Federal Regulations (CFR), Department of Transportation (DOT), Subtitle A, Office of the Secretary,
Part 21, Nondiscrimination in Federally- Assisted Programs of the Department of Transportation-Effectuation of
Title VI of the Civil Rights Act of 1964. The purpose of 49 CFR Part 21 is stated as:
“…to effectuate the provisions of Title VI of the Civil Rights Act of 1964 to the end that 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 receiving Federal financial
assistance from the Department of Transportation.”
By adoption of this Title VI Implementation Plan, the MPO’s Policy Board ensures that all programs, policies and
activities of the MPO comply with Title VI regulations.
Any person or persons who believe they have been aggrieved by an unlawful discriminatory practice under Title
VI has a right to file a formal complaint with the MPO. The entire Title VI complaint procedure can be found in
Appendix A of this Plan. Any such complaint must be in writing and filed with the MPO’s Title VI Coordinator within
one hundred eighty (180) days following the date of the alleged discriminatory occurrence.
1Title VI Implementation Plan 2 EVANSVILLE MPO
Title VI Implementation Plan EVANSVILLE MPO 3
Title VI Implementation Plan 4 EVANSVILLE MPO
Title VI Implementation Plan EVANSVILLE MPO 5
Title VI Implementation Plan
EVANSVILLE MPO TITLE VI COMPLAINT
• Sufficient information regarding the facts that led
PROCEDURES the complainant to believe that discrimination has
occurred;
Overview • Date(s) of the alleged discriminatory act(s); and
The following complaint procedures describe • Signature of the complainant or the complainant’s
the process for filing a Title VI complaint and the representative.
investigation process. They apply to the Evansville
MPO and its subrecipients. The procedures The Complaint Form or written complaint may be:
have been developed to ensure due process for • Hand delivered:
complainants. The process does not preclude the The Evansville MPO office, located in the Civic
Evansville MPO from attempting to informally or Center Complex at 1 NW Martin Luther King,
independently resolved complaints. Jr. Blvd, Room 316, Evansville, Indiana 47708
• Mailed:
Persons Eligible to File a Complaint Evansville Metropolitan Planning Organization
Attn: Matt Schriefer, Title VI Coordinator
Any person or persons who believe, either individually 1 NW Martin Luther King, Jr. Blvd
or as a member of any specific class of persons, they Civic Center Complex, Room 316 Evansville,
have been subjected to discrimination or retaliation Indiana 47708
prohibited by any of the Civil Rights authorities, on • E-mailed:
the basis of race, color, national origin, sex, age,
mschriefer@evansvillempo.com
sexual orientation, income, LEP status or disability
may file a written complaint with the Evansville MPO. • Faxed:
A Title VI Complaint Form is available on the MPO (812) 436-7834
website at: http://www.evansvillempo.com/TitleVI.
html. The affected individual or a representative may If any person requires reasonable accommodations
file the complaint. to file the complaint, contact Title VI Coordinator Matt
Schriefer at any of the above addresses or by phone
at (812) 436-7833.
Filing a Complaint
Complaints should be filed within 180-calendar days Receipt of Complaints
from the date of the alleged discriminatory act.
The Evansville MPO Executive Director and/or Title
The Title VI Complaint Form is available on the MPO VI Coordinator will provide the complainant or their
website at: http://www.evansvillempo.com/TitleVI. representative with a written acknowledgement
html. The form includes detailed questions to assist by mail within 10 working days that the MPO has
in filing the complaint. A complaint may also be filed received the complaint. The acknowledgement will
in writing without the Complaint Form if the following include an estimated timeframe for completing the
are included: investigation.
• A signed and dated (by the complainant or the
complainant’s representative) written explanation The complaint will be reviewed by the Title VI
of what has happened; Coordinator and Legal Counsel. It will then be
forwarded to the MPO Executive Director and MPO
• The complainant’s contact information; Policy Committee. The MPO will then notify the
• Identification of the respondent, i.e. agency/ Federal Highway Administration (FHWA) and/or
organization alleged to have discriminated; Federal Transit Administration (FTA) that a complaint
has been received.
6 EVANSVILLE MPOTitle VI Implementation Plan
The MPO Title VI Coordinator shall conduct MPO for investigation. Complaints filed with KYTC
a full investigation, when warranted, and against a sub-recipient shall be processed by the
furnish a preliminary written report, including MPO in accordance with FHWA and/or FTA approved
recommendations for resolution to the MPO procedures. Complaints filed with a sub-recipient
Executive Director and MPO Policy Committee for shall be forwarded to the MPO within three days of
final determination. The MPO Executive Director shall receipt.
notify the complainant of the final decision within
10 working days of completion of the investigation Complaints filed with a subrecipient shall be
and a copy of the decision will be forwarded to FHWA forwarded to the Evansville MPO Title VI Coordinator.
and/or FTA. The MPO Executive Director shall further In special cases warranting intervention to ensure
notify the complainant of his or her right to appeal justice, the FHWA and/or FTA may assume
the decision to the FHWA and/or FTA if the decision jurisdiction and either complete or obtain services
is not acceptable. Appeals should be made in writing to review or investigate the matter. Materials
and forwarded to: already obtained by the MPO may be relied upon or
supplemented or the matter may be reinvestigated.
Federal Highway Administration
Office of Civil Rights A copy of the complaint, together with a copy of the
Attn: Title VI Program Coordinator MPO report of the investigation, shall be forwarded to
8th Floor E81-105 the FHWA and/or FTA within 60 days of the date the
1200 New Jersey Ave., SE complaint was received by the MPO. An extension of
Washington, DC 20590 an additional 60 days may be granted by the FHWA
and/or FTA for justifiable reasons.
Federal Transit Administration
Office of Civil Rights Acceptance and/or Dismissal of Complaints
Attn: Title VI Program Coordinator
East Building, 5th Floor-TCR When the Evansville MPO receives an inquiry,
1200 New Jersey Ave., SE comment or complaint, which alleges or implies
Washington, DC 20590 discrimination as addressed by Title VI of the Civil
Rights Act of 1964, a copy is forwarded immediately
Records pertaining to complaints, inquiries and to the MPO Title VI Coordinator, MPO Executive
investigations will be maintained by the Evansville Director and the FHWA or FTA Division Administrator.
MPO Title VI Coordinator. The MPO Title VI Coordinator is responsible for
logging in the document and maintaining the
The public may also submit discrimination complaints required statistical data.
directly to the Federal Highway Administration (FHWA)
or Federal Transit Administration (FTA). The complaint The MPO Executive Director and FHWA or FTA
should be mailed to the Office of Civil Rights at either Division Administrator or their designee in the Civil
the FHWA or FTA at the mailing addresses listed Rights office will discuss the matter to determine if
above. it constitutes a Title VI complaint. If it is determined
that the issues do not meet a Title VI complaint, the
Processing Complaints MPO Executive Director will submit the appropriate
response the FHWA or FTA Division Office.
Complaints filed with the Evansville MPO in which
the MPO is named as the respondent, shall be If it is determined that the issues constitute a Title
forwarded to FHWA and/or FTA. Complaints received VI complaint, the MPO Executive Director or the Title
by the FHWA and/or FTA filed against federal aid VI Coordinator will determine responsibility and the
subrecipients or contractors will be sent to the need for additional information. The MPO, FHWA or
EVANSVILLE MPO 7Title VI Implementation Plan
FTA Division Administrator, or designee may request Withdrawal of a Complaint
additional information and/or clarification. The MPO
shall maintain a log of complaints filed with and The complainant may withdraw his or her complaint
investigated by the MPO. at any time after filing and prior to the issuance of a
determination or resolution by the Evansville MPO.
Evansville MPO Executive Director and/or Title VI The complainant must submit a written withdrawal to
Coordinator will respond in writing, acknowledging the following:
receipt of complaint within 10 days from date of
receipt. After reviewing the complaint, the MPO Evansville Metropolitan Planning Organization
Executive Director may recommend dismissal of a Attn: Matt Schriefer, Title VI Coordinator
complaint for any of the following reasons: 1 NW Martin Luther King, Jr. Blvd
• The complaint was filed in an untimely manner. Civic Center Complex, Room 316
• The complaint does not allege a basis covered by Evansville, Indiana 47708
the statutes for which the MPO is responsible.
• The complaint does not allege any harm with Appeal Process
regard to covered programs or statutes.
If a complaint cannot be resolved by the MPO to the
• The complainant requests the withdrawal of the satisfaction of the complainant, the complainant may
complaint. appeal, in writing, to the following:
• The complainant fails to respond to repeated
requests for additional information needed to Federal Highway Administration
process the complaint. Office of Civil Rights
• The complainant cannot be located after Attn: Title VI Program Coordinator
reasonable attempts. 8th Floor E81-105
1200 New Jersey Ave., SE
• The complainant fails to accept a reasonable
Washington, DC 20590
resolution. Reasonableness to be determined by
the FHWA and/or FTA Civil Rights Office.
Federal Transit Administration
• The complainant has filed a legal action in Federal Office of Civil Rights
District Court with the same basis and issue(s) Attn: Title VI Program Coordinator
involved in the complaint. East Building, 5th Floor-TCR
• The same complaint’s allegations have been filed 1200 New Jersey Ave., SE
with another federal, state, or local agency. Washington, DC 20590
Acceptance of a complaint will be determined by the Discrimination complaints may be filed with the
following: FHWA and/or FTA before, during or after the
complaint has been filed with the MPO.
• Timely filing of the complaint.
• If the allegations involve a covered basis such as This procedure does not deprive the complainant his
race, color, sex, age, national origin, disability, or or her right to file a complaint:
retaliation. • The U.S. Department of Transportation: www.dot.
• If the allegations involve a program or activity of a gov
federal aid recipient, subrecipient, or contractor. • The U.S. Department of Justice: www.usdoj.gov
• Federal Highway Administration: www.fhwa.dot.gov
8 EVANSVILLE MPOTitle VI Implementation Plan
Final Agency Reports impact of proposed plans, programs and projects;
• Ensuring all contract documents contain the
The Headquarters Civil Rights Office of the FHWA appropriate Title VI provisions;
or FTA via the FHWA or FTA Division Office will issue
• Consulting with the Title VI Coordinator or
all Final Agency Decisions and dismissals. The
Executive Director when complaints are received
MPO will forward, through the FHWA or FTA Division
or issues arise during a public hearing/meeting;
Office, the investigative report, investigative file and
a recommended decision to the Chief Investigations • Ensuring that all people are treated equitably
and Adjudications. regardless of race, color or national origin;
• Monitoring Title VI accomplishments, notifying
The MPO takes the position that a Title VI finding the Title VI Coordinator of problem areas and
of violation or no violation is a federal decision that summarizing activities for inclusion in the Title VI
cannot be delegated. Although an MPO recipient can Plan Update;
conduct a Title VI investigation of its subrecipients • Developing and updating internal policies and
or contractors and make a recommendation to the procedures to ensure Title VI compliance during all
federal decision making authority, the MPO must phases of projects and activities;
submit its proposed dispositions to FHWA and/
or FTA for a Final Agency Decision. The Civil Rights • Ensuring that all business pertaining to the
Offices of these agencies may request that further selection, negotiation, and administration
investigation be undertaken if the record of evidence of consultant contracts and agreements is
is incomplete. accomplished without discrimination based on
race, color or national origin;
• Ensuring that efforts are made to include minority
RECORD OF TITLE VI COMPLAINTS, and women owned businesses in consideration for
INVESTIGATIONS AND LAWSUITS contracts;
• Ensuring that internal and external publications
There have not been any complaints, investigations and all other relevant communications
or lawsuits alleging discrimination on the basis disseminated to the public include the Title VI
of race, color, or national origin filed against the policy reference;
Evansville MPO within the past five years.
• Providing reasonable accommodations,
The Evansville MPO Title VI Complaints, Investigations information in the appropriate language or
and Lawsuits Log can be found in Appendix F. If a interpreters as needed for individuals with
Title VI complaint is made against the MPO, it will be disabilities and LEP persons.
logged and kept on record at the MPO office. This
Title VI/LEP Plan would also be amdeded to update
the Complaints, Investigations and Lawsuits Log REVIEW OF PLANS, POLICIES AND
found in Appendix F.
DIRECTIVES
PROGRAM REVIEW PROCEDURES As the Metropolitan Planning Organization for the
Evansville-Henderson Urbanized Area, the Evansville
The Evansville MPO and its staff are responsible for MPO facilitates transportation policy development,
the following under Title VI: planning and programming for the region. This
• Collecting and analyzing data on minority and low includes development of the long range Metropolitan
income populations to determine the potential Transportation Plan and short term Transportation
Improvement Program, among other specific highway,
EVANSVILLE MPO 9Title VI Implementation Plan
street, transit, bicycle, and pedestrian plans. The the annual discussion, the Title VI Coordinator may
majority of the MPO’s plans include a demographic review and discuss potential issues with staff at
profile and most document the potential impacts any time. If it is determined there may be a real or
of projects on disadvantaged populations. If a potential issue, the Title VI Coordinator will work with
concern were to arise, based on a public complaint the appropriate staff to alleviate the issue.
or observation by a staff member, appropriate steps
would be taken to review the plan or program and In the event of a formal complaint from the public
mitigate the concern. or other organization, the Title VI Coordinator will
notify the MPO Executive Director and work with
All plans, policies and guidance manuals developed the appropriate staff to alleviate the issue. The
by the MPO are updated as needed. Some are Coordinator and MPO Executive Director will issue a
updated annually, others are updated when changes formal response to the complainant. The complaint
in State and Federal regulations and guidance will also be filed in the Title VI Complaint Log in the
require an update. When updates occur, the plans, appendices of the Title VI Implementation Plan.
policies and guidance manuals are reviewed to
determine Title VI implications and modified as
necessary. These include:
SPECIAL EMPHASIS PROGRAM AREAS
Certification reviews in 2017 and 2021 conducted
Administrative
by FHWA and FTA have not revealed any deficiencies
• MPO By-Laws in the MPO’s Title VI Program, but have mentioned
• Employee Handbook continuing advanced outreach methods. KYTC’s
• Unified Planning Work Program review of the MPO’s Title VI Plan over the last few
years has revealed some additions needed to the
Planning
plan document.
• Metropolitan Transportation Plan
• Transportation Improvement Program The MPO will continue to train staff on the
• Public Participation Plan importance of Title VI compliance and continue
to increase their efforts to ensure outreach to
• Access Management Manual
Environmental Justice population areas. The MPO will
Multi-Modal also continue to ensure the Title VI Plan is current
• Coordinated Public Transit – Human Services and accurate based on current regulations.
Transportation Plan
• Section 5310 Program Management Plan Title VI Special Emphasis Areas:
• Completing the Street: A Complete Street Toolkit • Public Outreach and Participation
• MPO Complete Streets Policy • Staff Training
• Environmental Analysis (red flag investigations)
COMPLIANCE/NONCOMPLIANCE • Inclusion of Title VI in all MPO Planning documents
REVIEW
TITLE VI ORGANIZATION AND STAFFING
On an annual basis, a presentation by the MPO’s Title
VI Coordinator is offered to MPO staff to review Title The Evansville MPO includes the Executive
VI and ADA regulations and recent changes. After the Director, Deputy Director, and a staff of multiple
presentation, the staff reviews and discusses any Transportation Planners and Transportation
issues that may have arisen over the past year or any Engineers. Being a staff of less than 10 people, all
foreseeable issues over the next year. In addition to employees work closely on almost every project.
10 EVANSVILLE MPOTitle VI Implementation Plan
For this reason, Civil Rights responsibilities are held including LEP planning. This training is available in-
by all staff members by ensuring that each plan person in Indianapolis or virtually. The MPO may also
and program considers the potential impacts to all attend other training hosted by the Federal Highway
individuals in the region. Administration (FHWA), the Kentucky Transportation
Cabinet (KYTC) or online resources if available.
The Title VI/ADA Coordinator role is held by Matt
Schriefer, Transportation Planner. The Title VI/ADA The MPO Title VI and ADA Coordinator also trains
Coordinator is the main point of contact for all Civil the rest of the MPO staff annually in the office and/
Rights issues from the public. The Coordinator also or virtually. The training covers an overview of the
provides Title VI, LEP and ADA training to employees Federal regulations and requirements, a summary
annually, assists all staff members regarding Civil of the MPO’s Title VI responsibilities, a review of the
Rights, and is responsible for developing Title VI, LEP Public Notice and Complaint Procedures, and the
and ADA plans, reports and surveys. process to follow in case of a complaint.
The MPO trains new employees as they start their
STAFF TRAINING new positions. The MPO Title VI and ADA Coordinator
first provides the new hire with a copy of the Title
At least one MPO staff member, typically the Title
VI Implementation Plan for review. This is followed
VI and ADA Coordinator, attends Title VI and ADA
with the same training that is completed for all staff
training annually. The Indiana Department of
members annually, with more detail provided for the
Transportation (INDOT) provides Title VI and ADA
process and procedures for handling complaints.
training every year, covering all aspects of Title VI,
Executive Director
Deputy Director
Title VI/ADA Transportation Transportation
Coordinator Planners* Engineers
Civil Rights
*a Transportation Planner serves as the Title VI/ADA Coordinator and is the primary point of contact for all
Civil Rights issues.
EVANSVILLE MPO 11Title VI Implementation Plan
SUB-RECIPIENT REVIEW of outreach may be used to ensure participation by
residents. Maps of the TOAs and a description of
At a minimum, the MPO will review the Title VI and the process for identifying them can be found in the
LEP planning efforts of subrecipients when the local Regional Demographic Profile.
public agency (LPA) requests transportation funding.
If the LPA has an inadequate Title VI/LEP process The MPO Technical Committee, Policy Committee,
or document, the MPO will provide resources to the and working groups include a variety of local
LPA to help them make necessary updates. The MPO organizations. These organizations represent
will also forward training opportunities to the LPAs neighborhood residents, low-income individuals,
as appropriate. On occasion, the MPO will review individuals with a disability, minority groups, and
the Title VI/LEP process for all LPAs through website advocacy groups. Appendix E includes a list of
review, direct contact and/or surveys. the Policy Committee members and organizations
represented on the Technical Committee.
PUBLIC PARTICIPATION The general public also has an opportunity to
participate and provide input at the monthly MPO
Inclusive and Meaningful Public Participation Policy Committee meetings. The Policy Committee
meetings can also be viewed live online on the
The MPO strives to ensure all individuals within the City of Evansville website. Minutes of the Technical
Metropolitan Planning Area have an opportunity to and Policy Committees are available in audio and
be informed and involved in transportation planning text format on the MPO website. The public has
decisions. The MPO’s Public Participation Plan details the opportunity to comment on any transportation
the specific steps taken to ensure public outreach related items every month under the public
and involvement in MPO plans and projects. The plan comments section of the Policy Committee agenda.
can be found on the MPO website.
Public comment and questions regarding regional
The Public Participation Plan identifies two methods transportation projects is always welcome by visiting
for public outreach: general outreach and targeted the MPO office, calling or emailing staff, or providing
outreach. General outreach methods include comments through the website.
providing information on the MPO website and
Facebook page, public notices in local newspapers, Title VI Public Involvement Survey
notices on city/county websites and bulletin boards,
notices at bus terminals and on buses, and other At all of the MPO’s public involvement meetings and
methods as appropriate. open houses, a Title VI Public Involvement Survey is
made available to attendees. Attendees are made
Targeted outreach methods depend on the specific aware that the survey is voluntary, but useful to
plan or project. The Public Participation Plan has ensure that the MPO’s outreach efforts are reaching
identified Targeted Outreach Areas (TOA) based on all possible residents. The survey responses will help
U.S. Census data. The TOAs identify concentrations the MPO determine if an appropriate mix of people,
of traditionally underserved or disadvantaged based on age, race/ethnicity, income, and disability,
populations. This includes individuals below poverty, are attending the public involvement events.
seniors, minorities, Hispanic populations, individuals Appendix C includes the survey made available at
with Limited English Proficiency, individuals with a meetings.
disability, and households with no vehicles. Plans
developed by the MPO that require multiple public
meetings will have at least one meeting within a TOA.
If a project directly impacts a TOA, additional forms
12 EVANSVILLE MPOTitle VI Implementation Plan
Evansville MPO Policy and Technical
Committees • Persons to include in the decision making
process;
The Evansville MPO Technical Committee • Percent of benefits allocated to persons below
consists of 53 organizations representing one of the poverty line versus persons above the poverty
six categories: City/County/State Government, line;
Regional Government/Organizations, Public/Private • Distribution of benefits (dollars, facilities,
Transportation, Non-Profits/Social Services, Medical/ systems, projects) to groups and communities;
Education, and Private Business. Each organization
receives Technical Committee meeting agendas, • Projected population increases versus planned
memos, and minutes. Attendance at the Technical facilities and types of facilities;
Committee meetings fluctuates from month to • Language needs assessment;
month. Appendix E lists each of the organizations • Transportation needs of all persons within
represented on the MPO Technical Committee. boundaries of plans or projects;
• Strategies to address impacts;
The Evansville MPO Policy Committee is a non-
elected, 13 member board that meets monthly. • The manner in which services are or will be
The Policy Committee has governing authority provided and the related data necessary for
over the MPO. The Committee is appointed by determining whether any persons are or will be
the governmental agencies within the Evansville denied such services on the basis of prohibited
MPO Planning Area. Appendix E lists each of the discrimination;
appointments to the Policy Board. • The location of existing or proposed facilities
connected with the program and related
DATA COLLECTION, REPORTING AND information for determining whether the location
has or will have the effect of unnecessarily
ANALYSIS denying access to any persons on the basis of
prohibited discrimination;
Statistical data on race, color, national origin, sex,
• The present or proposed membership, by race,
age, disability, LEP, poverty status, and availability
color, national origin, sex, disability and age, in
of vehicles of participants in and beneficiaries of
any planning or advisory body which is an integral
MPO plans and programs will be gathered, analyzed,
part of the program;
and maintained by the MPO to determine the
transportation investment benefits and burdens • Strategies to disseminate information.
to these populations. Each plan and program will
include an analysis of potential impacts, both The MPO has developed an analysis tool to use
negative and positive. Data gathering procedures when determining the potential impacts of projects
will be reviewed regularly to ensure sufficiency of the on disadvantaged populations. Further review
data in meeting the requirements of Title VI program of potential impacts is conducted in Potentially
administration. Analysis of the data collected may Disadvantaged Areas (also called Targeted
include: Outreach Areas or Environmental Justice Areas in
other MPO documents). The areas are prioritized
• The race, color, national origin, sex, age, disability, based on the percentage of the population that
LEP, poverty status, and availability of vehicles of is considered underserved or disadvantaged.
the population eligible to be served; The MPO includes the following seven population
categories to determine areas of underserved
• Socioeconomic Assessment to evaluate project’s
or disadvantaged populations: individuals below
potential impacts to the human environment;
EVANSVILLE MPO 13Title VI Implementation Plan
poverty; individuals age 65 and older; minority The Decennial Census provides more accurate
population; Hispanic population; individuals with information than the ACS data, but is available for
Limited English Proficiency (LEP; speaks English fewer demographic topics than the ACS data. The
“less than very well”); individuals with a disability; 2010 Decennial Census was used for population
and households with no vehicles. See the Potentially specific data, including total population, age and
Disadvantage Areas section for more information. gender, and race and ethnicity. The 2000 Decennial
Census was also used for total population.
REGIONAL DEMOGRAPHIC PROFILE
Total Population
Demographic data on race, color, national origin,
sex, age, disability, income and language spoken The 2015 ACS shows the three county population
is gathered, analyzed, and updated periodically for Vanderburgh, Warrick, and Henderson counties
by the MPO to determine the transportation to be 288,696. The Urbanized Area includes a
investment impacts on the region’s population. large portion of this population, at 231,115. (Note:
The demographic data is mapped to determine the A portion of the Evansville Urbanized Area reaches
locations of concentrated areas of disadvantage into a small area in Posey County.) Vanderburgh
populations. New projects planned by the MPO and/ County makes up more than half of the regions total
or its subrecipients are also mapped and compared population. The Region and Urbanized Area have
to the areas of potentially disadvantaged populations seen slow, but steady growth between 2000 and
to determine if a potential impact may occur. The 2015.
following demographic information helps form the
basis for the potentially disadvantage areas mapping.
The following sections provide an overview of the
demographics for the Evansville, IN-KY Urbanized
Area, Vanderburgh County, Warrick County, and Figure 1: 2015 Regional Population
Henderson County. The Evansville Urbanized Area
(sometimes referred to as the Evansville-Henderson
Urbanized Area) includes the connected urban-
suburban region covering the City of Evansville, the
City of Henderson, the Town of Newburgh, the Town
of Chandler, and the developed areas just beyond
and between these communities.
The U.S. Census website was used to gather the
demographic data. The American Community Survey
(ACS) was used for 2015 and some 2010 data. The
ACS data is released annually as either a 1-year
estimate, 3-year estimate, or 5-year estimate. The
5-year estimates were used for this document as they
provide a more accurate estimate. The most current
ACS data is for the year 2015.
In some cases, the Decennial Census was used
as the data source. The Decennial Census is
released every 10 years, with the last being 2010.
14 EVANSVILLE MPOTitle VI Implementation Plan
Age and Gender Figure 2: 2015 Age and Gender
The 2015 ACS shows that there is a higher
percentage of females in the Urbanized Area than
males at 52% compared to 48%. Much of this
difference is in the 65 and over category. The data
also shows that the region is getting older. The
percentage of the total population under 25 slightly
decreased by almost 1% between 2010 and 2015,
while the percentage of the total population 65 and
over increased by nearly 1% over the same time
period.
Race and Ethnicity
The Evansville-Henderson Urbanized Area is more
diverse than the region as a whole and surrounding Figure 3: 2015 Race and Ethnicity
counties. Vanderburgh County has the highest
non-white population of the three counties in total
number and as a percentage of the total county
population. All three counties have had an increase
in non-white population between 2010 and 2015.
Individuals with a Disability
Nearly 15% of the Urbanized Area’s population had
some type of disability at the time of the 2015 ACS.
This includes 5.5% of children under 18, 13% of
adults age 18-64, and 38% of seniors age 65 and
over. Every age category had an increase in the total
number of individuals with a disability.
Figure 4: 2010 and 2015 Individuals with Disabilities
EVANSVILLE MPO 15Title VI Implementation Plan
Household Income Figure 5: 2015 Median Household Income
The 2015 median household income for the
Urbanized Area was $43,301. This is lower than both
the Kentucky median household income of $43,740
and the Indiana median of $49,255. The U.S. Census
sets income thresholds to determine poverty levels.
In 2015, a household was considered in poverty if the
total income was less than $12,082 for a one-person
household, $15,391 for a two-person household, and
$24,257 for a four-person household. In 2015, 27%
of households in the Urbanized Area made less than
$25,000. More details about poverty are in the next
section.
Poverty
Households with extremely low incomes are Individuals in poverty is defined as all of the people
considered to be in poverty. Sixteen percent of all that live within a household in poverty. The more
households in the Urbanized Area are in poverty. people living in a household, the higher the poverty
Henderson County has the highest household poverty threshold. A family of four must have an annual
rate of the three counties at 18%. The household income greater than $24,257 to be considered above
poverty rate in Warrick County is 8%. Poverty is poverty, while a family of six must have an annual
determined based on national income thresholds income greater than $32,542 to be considered
that are developed by the U.S. Census. Table 1 shows above poverty.
the thresholds for 2015.
Table 1: 2015 Poverty Thresholds
Size of Family Unit Weighted Related children under 18 years
Average 0 1 2 3 4 5 6 7 8+
1 person $12,082
Under 65 $12,331 $12,331
65 and over $11,367 $11,367
2 people $15,391
HHer under 65 $15,952 $15,871 $16,337
HHer 65 and over $14,342 $14,326 $16,275
3 people $18,871 $18,540 $19,078 $19,096
4 people $24,257 $24,447 $24,847 $24,036 $24,120
5 people $28,741 $29,482 $29,911 $28,995 $28,286 $27,853
6 people $32,542 $33,909 $34,044 $33,342 $32,670 $31,670 $31,078
7 people $36,998 $39,017 $39,260 $38,421 $37,835 $36,745 $35,473 $34,077
8 people $41,029 $43,637 $44,023 $43,230 $42,536 $41,551 $40,300 $38,999 $38,668
9+ people $49,177 $52,493 $52,747 $52,046 $51,457 $50,490 $49,159 $47,956 $47,658 $45,822
Source: U.S Census Bureau
Note: HHer = Householder
16 EVANSVILLE MPOTitle VI Implementation Plan
Language Figure 6: 2015 Language Spoken
In the Evansville Urbanized Area, there are nearly
9,000 individuals that speak a language other than
English. The majority of them, almost 6,000 people,
speak English “very well”. Just over 3,000 people
speak English “less than very well”. Of those that
speak a language other than English, 45% speak
Spanish, 26% other Indo-European languages, 25%
speech Asian/Pacific Island languages, and 4%
speak other languages.
Potentially Disadvantaged Areas
Within the Evansville MPO Public Participation Plan,
Targeted Outreach Areas (TOAs) were identified All of these demographic characteristics were added
based on Census Tracts with concentrations of to a database of all 71 Census Tracts within the
underserved and disadvantage populations. These three counties. For each Census Tract, the total
TOAs may receive additional public outreach beyond number of categories that exceeded the Potentially
the general public notices, depending on the type of Disadvantaged Threshold was identified. These
project being completed by the MPO. Census Tracts were then labeled as one of three
Potentially Disadvantaged Area Tiers depending
The TOAs were developed based on data from on the number of categories that exceeded the
the 2010-2014 American Community Survey. The Potentially Disadvantaged Threshold. Below are the
following data was gathered for all 71 Census Tracts Potentially Disadvantaged Area Tiers based on the
in Henderson, Vanderburgh, and Warrick counties: number of categories that exceeded the threshold.
• individuals below poverty;
• Tier 1: Exceeds 6-7 Potentially Disadvantaged
• individuals age 65 and older;
Thresholds
• minority (non-Hispanic) population;
• Tier 2: Exceeds 4-5 Potentially Disadvantaged
• Hispanic population; Thresholds
• individuals with limited English proficiency (speak • Tier 3: Exceeds 2-3 Potentially Disadvantaged
English “less than very well”); Thresholds
• individuals with a disability; and
• households with no vehicles. The Potentially Disadvantaged Areas are shown in
Figure 7. Figures 8 through 14 show the individual
For each one of these key demographic maps for each disadvantaged population category.
characteristics, a regional average combining all
three counties was found using the ACS data.
This average is considered to be the Potentially
Disadvantaged Threshold. If the percentage for a
particular Census Tract exceeds this Threshold in
more than one of these demographic categories, it is
considered to be a Potentially Disadvantaged Area or
Targeted Outreach Area.
EVANSVILLE MPO 17You can also read
