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Analysis of Evidence .. - : . <br /> Complainants allege that State&County.officials"deliberately".•undercount residents due to <br /> policy by State and County officials-in favor.of large land owners',/developers Complainants <br /> allegethat`State and County officials knowingly zone residential land as farm land,based upon <br /> or:Ha aii <br /> orted-: the State w , <br /> . erroneous;pro}�c#ed°population=figures;Which cannot Vie:supp by; <br /> County officials : <br /> • Complainants provided•data which shows that the HDOT&Hawaii County are excluding:low <br /> income and Native Hawaiians from consideration:in,its H ;RTP based upon land use policies. <br /> Investigation.disclosed that Respondent:officials use outside consultants to prepare population <br /> ' . projections,in formulating their general plan Respondent officials were unable-to,provide <br /> . .: .documentation regarding how.:the consultants arrive at their projected population data for:any of <br /> its jurisdictions Investigation disclosed that Respondents take the word of the consultants <br /> without verification,,..: ' <br /> Investigation further disclosed that Respondents are riot collecting data in accordance with the • <br /> requirements of23:CFR,Part 200.9 (b) (4)and Executive Order.12898,:Sectiorn 3-3. <br /> . Investigation also disclosed:through.an interview with the Title-..VI-Specialist for:HD OT that the <br /> • Title VT Specialist.only spends 5%of his:time..iii the Title VI`area. - <br /> The position description,for the Title ecia <br /> VI Splist which is.dated May.8J 1.910, addresses only <br /> equal employment.opporturiity�(EEO)duties. There is nothing- r1.the,position description that - <br /> covers Title VI . <br /> The Title VI Specialist:stated;that he doe not conduct program reviews for compliance_with.Title • <br /> • VI nor does he exercise'oversight for Title VI compliance with:subrecipients. <br /> Record evidence shows thati-the latest Title VI Plan submitted by HDOT to die Division••Office - . <br /> does',not complywith 49'CPR2 i;of 23 CFR 200. . <br /> Conclusion: <br /> . Based upon the information reviewed durin• g the investigation,the record shows that the <br /> Respondents Hawaii.Department of Transportation and Hawaii Countyare not in compliance <br /> with':the requirements of Title VI:of the:Civil.Rights Act of 1969•asine <br /> onitld by the procedures <br /> _ and requirements at 23 CFR 200 and 49 CFR 21 The evidence further shows that the <br /> requirements of JEitecutive Order-12898,Section.3-3 are;not being followed. <br /> • - of6 <br /> Page 4 . . <br /> • EXHIBIT A <br />