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Human Rights Department Annual Report Copyrighted February 18, 2019 City of Dubuque Consent Items # 6. ITEM TITLE: Human Rights DepartmentAnnual Report SUMMARY: City Manager transmitting the FY2019 Human Rights Department Annual Report. SUGGESTED DISPOSITION: Suggested Disposition: Receive and File ATTACHMENTS: Description Type FY19 Human Rights Department Annual Report-NNM City Manager Memo Memo Staff Memo Supporting Documentation Human Rights DepartmentAnnual Report Supporting Documentation THE CITY OF Dubuque � AIFA�erlwGh UB E '�� III► Masterpiece on the Mississippi Z°°'�w'2 7A13 2017 TO: The Honorable Mayor and City Council Members FROM: Michael C. Van Milligen, City Manager SUBJECT: FY2019 Human Rights Department Annual Report DATE: February 13, 2019 Human Rights Department Director Kelly Larson is transmitting the FY2019 Human Rights Department Annual Report. �� Mic ael C. Van Milligen �� MCVM:jh Attachment cc: Crenna Brumwell, City Attorney Teri Goodmann, Assistant City Manager Cori Burbach, Assistant City Manager Kelly Larson, Human Rights Director THE CITY OF Dubuque DUB E i'�� I � � I. Masterpiece on the Mississippi Zoo,.Zo72•Zo„ TO: Michael C. Van Milligen, City Manager FROM: Kelly Larson, Human Rights Director DATE: February 13, 2019 RE: FY2019 Human Rights Department Annual Report Attached please find the Human Rights DepartmenYs FY2019 Annual Report. We are proud of the accomplishments over the past year and we appreciate and thank you for the past and continued support. • � � • • - . � • � - • . - � ,r� �' � '�`�� a N,��''� _ �� °� E r». �' � . 5 ^, �-i '. w � 8`m� -�'�ts �':-�_, ,� �� y�ft._ ` � —�. . ,, � � �: � :.. ��„�� N ��' .,.,«v,av��. :: ��El� .- ar � 3� ... ;�;�� - -- - — —��--- �:��- tL .i,_ ._ �. ... ',..u�l...�'#�. ."r � j ! !. rY� ♦ . R. A 1 "' S � s� ° ; 2 `-�' • � rd ,. -0 d�. �i i �" � y � r� P- G.r''_+ k` .� �+�f. a� l' ^}i , � d� J � "3k r �SL� &`'�+p , � � i, .+,,s� *1 �. �'.0 t �<i e .'�+ : �i -ne r a.yv+ '�h. rl . � i i 1�_ r ,.. �nl� ,eJ� � �; � / ' : C - 1�,�r�k.i _. 1 'q: 1 f 'B � Y:.", i F � �G A/ ��' ��i � �:� e�- � >�iw�+wr. �dt �yy�i+ !`s r ��.µ Ij �� t ..:i - . r. �tl�w 4��34�"+! 5 .:n��'. � ��i :�a'!' �(a'..fa1�Y � ��V�.. s �'i a �/ . i� � t'�'f ��K eJ5y ]�p�x�'/ � }��° + �Cv +�;�'-�r`S' �ydd �75��wn t � 4 a`J f�i ..',o-°� .3 x { F�, y ''�7�Nf,�4 ,Sy � d� d� _ 1' �' >a,� I �� p��+,' r �,� " '� � �� , � k �: � '.�,1^�. �I�•l��n �' ��I�;�• �.�' �;''N�u'S��µ � ;y ^ t''1`,�i c .. 1 t�F 1��<'t x � �1 � �y } �� P � y`%� F y�{r rB� 4� �;j�R�.`,e�<�,�� 'j:1+ ai. � �t�iWwY�. � — t.\�, reo- . .�tixi .' .�'.. . � ,,. 1 " � • � � � � THE CIiY OF HumanRigh6Department D0.bu�]ue DUB E CityHallAvvice fi�ii.i 1300NGivStreet pILGMwC1Y Dubuque,Iowa 52001-0�2 �� "� M[ISIeY�iPCP On fh¢Mt95t55i�JjJt 5Q.S494190 office 563696b691 hx humavr�t�ityofdubuqueorg � ,g,��.�� Honorable Mayor and City Council: I would like to begin by expressing appreciation for your leadership in continuing to support Inclusive Dubuque and the application of an equity lens to the work of our organization. In the following pages, you will find the story of partnerships throughout the organization and community that are focused on advancing equity. As a member of the Government Alliance on Race and Equity (GARE), we engaged GARE to present at the Growing Sustainable Communities Conference and several City staff also attended the national membership meeting in Chicago in April. Following the GARE model, we have finalized equity goals, objedives, and guiding principles, have worked with six departments to complete equity plans, and worked with three additional departments to begin the planning process. Our equity teams worked with contracted and purchased services partners, as well as arts and sustainability grantees, to pilot a reporting system designed to capture the ways in which partners are helping to advance equity through their efforts. Equity Core Team members also provided assistance in adjusting policies and practices impading gay, lesbian, bi-sexual, transgender, and questioning residents and staff. Our work was recognized with a score of 100 on the Municipal Equality Index. On the community side, Inclusive Dubuque Network partners have become engaged in a variety of ways, from completing the nine-month Best Practices in Diversity, Equity and Inclusion workshop to implementing pradices back in their organizations and participating in sector groups. Our staff continued to provide consultation and co-facilitation with members of the Dubuque Community School Distnct, Clarke University, and Washington Neighborhood community engagement leaders. We also remained actively involved with the Pacific Islander Health Project, the Immigration Think Tank, Crossing Borders, the Loras College Civic Adion Plan team, and the My Brother's Keeper Network. We said goodbye to AmeriCorps VISTA member Joie Brooks as she completed her term and are grateful for the work she did with the My Brother's Keeper Network. As always, thank you for your support of the work we do in our department and with our partners in the community. Respecffully submitted, `�y�Qf C/�a2�e�r� Kelly Larson Human Rights Diredor HUMAN RIGHTS DEPARTMENT FY18 ANNUAL PERFORMANCE REPORT Administrative Staff �� ' -- ^ � �t "� � , i.� �, i\ V' Lef[[o ngh[:Kelly Larson,Direc[or;Taj Suleyman,Equiry Oubeach Coordinator,andCard Spinwo,Intake5pecialist FY2018 Human Riqhts Commissioners Anthony Allen, Chairperson Jay Schiesl, Vice Chair Gerald Hammel Indigo Channing MiquelJackson Kathrin Parks Adrienne Breitfelder Nicole Borovic Ashley Melchert Commission Mission Statement The Human Rights Commission shall work to eliminate discrimination and promote the quality of life for every resident in the city of Dubuque. -1 - HUMAN RIGHTS DEPARTMENT Department Goal: partnering to advance equity in opportunities to be engaged in the community, to access City and community services, and to meet basic needs. In all we do, we treat compliance with current civil rights laws as the bare minimum required, not the end goal. � � , �� , �� , i .. - - � �� ' ,__, � SUCCESS IS ABOUT PLANNING, PARTNERSHIPS AND PEOPLE LEADING TO OUTCOMES PEOPLE PLANNING We engage traditionally We facilifate and marginalized communities to consulf on Department strengthen relationships, � and partner efforts to expand participation, and develop and implement advance equity in City services. equity plans. � � � I i' U S � _ In I � We edcrcate individuals � � and f�cl/itate and du b u q u e ��5cdt on cross-sector efforts to collectively ��, _ o_,. tm��-�s _,,,,,�.<, advance equity. -2- HUMAN RIGHTS DEPARTMENT Overview We partner with other City Departments to advance equity understanding and actions amongst our employees, through our service delivery and community engagement efforts, and with our contracted services partners. • Facilitated Equity Teams to: o Finalize equity goals, objectives, and guiding principles for the institution o Work with six departments to complete initial departmental equity plans and conducted self-assessments with three additional departments to begin their plans o Pilot a reporting tool with partners who, collectively, are receiving 2.7 million in FY19 contracted and purchased services funding o Improve score on the Municipal Equality Index o Engage Government Alliance on Race & Equity to present at the Growing Sustainable Communities Conference • Facilitated connections between the Transportation Department and the Pacific Island Health Project to obtain a grant to provide transportation to doctor appointments. .-. - .-.� ' ' \ I / � _ _ \. -�' - �' _ / � �. We support departments in their efforts to recruit and retain a high quality, diverse workforce, to deliver City services in ways that advance equity, and to engage the community in decision making so that services are responsive to community needs. represents a department that has developed an equity plan, represents a department working on a plan, and blue represents departments that are beginning a self-assessment. -3 - HUMAN RIGHTS DEPARTMENT • Facilitate self-assessments with three additional departments • Facilitate plan development with three departments • Consult on final plans for three departments • Consult on progress on plans with threedepartments • Hire and orient Strategic Workforce Equity Coordinator and Community Engagement Coordinator • Customize ICC and equity skill development to employee jobresponsibilities Organizational Development —Activity Statement Partnerwith other City Departments to advance equity amongst our employees, through our service delivery and community engagement efforts, and with our contracted services partners Goal: Financially Responsible, High Performance Organization Outcome#1: Provide City services responsive to the public and easy access to City information and services for all Service: Facilitate Equity Teams and consult on department equity plans We facilitate six cross-departmental teams and consult with departments on equity plans around the following goals: aP<�„��,r��a a,e��o�r�� Goal 1: Advancing equity through workforce recruitment and retention F,��„a„�^,e,m Eq u�ty ��mm��'" Goal 2: Advancing equiry through grant, „a'° contract, and purchased services Core Goal 3: Advancing equity through service delivery and community engagement Tea m Goal 4 Advancing equity through collective impact partnerships c�m ��m ca:n-o�vreai�� e�zaReme�x �� The first three of these goals involve working at the individual and institutional levels within City government and with partners, while the final goal involves external partnerships across sectors to begin to address systemic issues. a- HUMAN RIGHTS DEPARTMENT Effec[iveness of Facili[a[ion and Consulta[ion Across DepaAments Served Strongly l�qree Ayree N2Nrdl �Isagree Shangly Olsegrae o m zo ao ao so ao Percent of Departmen[s � Helpetl my depanment more eRectively engege iM1e publlc In equitabla antl IncWsiva ways Helped my depatlmen� unders[anC how lo use an equiry tool to a ,aiy�o A�,n �mmo�� n.o9�flms �,�n n�H�e��_s � Helpad my depatlment make program ealua[menta daslgned to iinprove equHable acwss and usa of our pmgrams ■ Hclpetl my tlopotlmen� Impmve equity ontl Inoluslan In our woMfarco s - HUMAN RIGHTS DEPARTMENT Program: Educate staffon developing intercultural skills and applying equitytools This year, 37 staff attended 10.5 hours of InterculNral Foundations Workshops offered by the InterculNral Facilitators, bringing the total number of staffwho have completed a minimum of 10.5 hours ofworkshops to 856. ICC Staff Evaluations - 4 point scale 3.5 3.0 2.5 2.0 1.5 1.0 0.5 0.0 Helped understand factors influencing equity ■ Helped understand 'mtercWtural and equlty basics � Helped find ways to identify and address inequities in my instiNtions ■ Take away new appmach for future use "O��r� (bin91 will do dillcren(lyis (o exaioinc yrouy rniar�eirons mora dosaly." votia�nt in icc rovmnouons v�w.mPo "One thing I will da diHemntlyis [a think and look at situations /rom diHerent perspectives." ParticlpantlnlCCFountlationswoMs5op 6 - HUMAN RIGHTS DEPARTMENT In addition, we respond to department requests for consultation on specifc projects. This year, we facilitated a workshop for summer staff with Leisure Services and provided staff professional development for the Multicultural Family Center. We also conducted training for 205 Ciry staff members designed to identify "right sized problems" that departments can impact in orderto contnbute towards implementation of the Fair Housing Action Plan. Fair Housing Evaluations - 7 point scale � `o � m m `m ¢' 0 1 2 3 4 5 6 7 Pmvided understanding of housing equity ■ I will use the information received ■ Presenters were engaging ■ Satisfied with quality of training "The most help/ul part o/today's session was tying tbe equitypiece in(o my day-fo-day work." Porticipanl in Fai�NwsingWoikshop 'The mosf help/u/part o/today's session was that you have to Ihinkhvork Ihraugh issues with multiple perspectives." Pa�.,cuar,.p Falr Nousu.v'NmhchoP � _ HUMAN RIGHTS DEPARTMENT Service: FaciliG[eequi[ableservicedeliveryandmmmuniryengagemen[wiN gwemmen[ One key way Ne public participa[es in govemance isNrough serving on boardsand mmmissions Na[are advisory [o [he Ciry Council. This year, we faciliL[ed Ne Qry GerKs effoR; ro es[ablish a demographic[rendline for board and mmmission participa[ion. Wealsofacili[a[ed mnnec0onswiN Ne AR; Coordinarorro engage Marshall Island mmmuniry membersin Arton Ne River. We facili[a[ed [he Human Righ6 Commission in cartying ou[[heir mle by pmviding onen[afion for new mmmissioners, �faciliG[ing developmen[of goals and s[ra[egies, pmviding informafion rela[ed m Neirgoals, and pmviding [echnical assis[ance wiN respec[ro Neirgoals, even6, and responses ro mmmuniry inciden6. This year, Ne Commission adwca[ed for a s[mng school dis[nc[focus on equiry, responded strongly m ha[e inciden6, and urged [ha[equiry mnsiderafions remain central [o Council goals. Human RlgM1ts Commlssion Self-Azsessmen[ - 5 point scale ..rv. .� imn.nc. eo..mmemmme � m.sa�ao.�.m�..ort�.€�.eo++ - co.aoniow _nomea_� ��i rvecmmc � � wwry.na.emmnnow..mmvnp � � MTyvai^ onm] x�m 1 3 5 6 fln9�as.-y o'i`vG�y Loun:Jg�.abeidcn^eil��<✓�cm." 4u.nrnP�➢��^�Ibcqn_i 9 kc�No wmNecbo c.�tlo'�0^�arc_'�ef. a ymNNosemosa/k:ietlMon tle!T Nn ��cue. 4mns��R:pMs'mqiilb-wnu g _ HUMAN RIGHTS DEPARTMENT Goal: Robust Local Economy Ou[come#1: Embrece diverse popula[ions [ha[ support a diverse mul[icul[ural workforce wi[h equi[able opportuni[ies Service: Facilitate development of equitable City workforce policies and practices This year we: • consulted on hiring practices and participated in interview processeswith several departments, including Police, Leisure Services, the Water & Resource Recovery Center, and the City Manager's Offce; • consulted with depadments working to develop a shared understanding amongst staff on the importance of equity and inclusion in their day to day work by diswssing equity as part of regular staffmeetings; • consulted with Public Works on developing an apprenticeship program focusedon expanding the diversity of the feld; and • facilitated efforts to improve the City of Dubuque's ranking on The Municipal Equality Index (MEI). Specifc successes included providing transinclusive health benefts for staff, offering domestic padner benefts to samesex partnere, including protections based on gender identity in City contrad provisions, and establishing offcial LGBTQ liaisonstothe CityManager. City of Dubuque MEI Ranking 2016 82 j 2017 94 2018 �00 75 f30 65 90 55 �00 �05 Ciry o( Dubuquc Swrc The MEl ls a anking ol mvnimpalltles acrosslhe comtrybasetl on (he IncNsivenees ol(helrlaws.polldee, antl ee/oi leeblan,gay.bisexual, hansgentler, antl queer(LGBT� iesitlenls. I(Is Isevetl annualtyby(he Human(Lghte Campaign In partnershlp wllh Ihe Eqvallty Fetleallon Inetltule. 9 - HUMAN RIGHTS DEPARTMENT Overview Community Development involves partnering with various groups and organizations within our community to address inequities in economic opportunity, health, housing, education, transportation, and safety. • Collaborated with the Inclusive Dubuque Network to design and facilitate Best Practices in Diversity, Equity and Inclusion • Collaborated with the My Brother's Keeper Network to advance equitable participation in the Dubuque Community School District summeracademy • Supported the NAACP and Legal Aid in the second employment barriers clinic • Facilitated and consulted on data analysis with the Coaches Partnership Empowerment Network (PEN) to improve equity in service delivery by identifying pattems of common barriers and collaborating to addressthem • Consulted with Greater Dubuque Development Corporation on equity resourcesfor businesses • Collaborated with the Pacific Islander Health Project, the Immigration Think Tank, Crossing Borders • Consulted with Washington Neighborhood community engagement leaders on effedive engagement practices • Consulted with Clarke University on their equity initiatives and provided co- facilitation with their trainers. • Joined the DCSD equity committee and consulted on equity initiatives, including co-facilitating with trainers at Roosevelt Middle School. �� , � , � � _ . . . �� , � � � � 10_ HUMAN RIGHTS DEPARTMENT We network with organizations and communities to strengthen intercultural relations in Dubuque and to develop partnerships to identify and address barriers to equitable access and participation in government and in the community. represents a community/organization we kept informed about our work; purple represents a community/organization we provided consultation to on equity plans; blue represents individuals/groups we collaborated with on equity efforts; and represents a community/organization we empowered to carry out a program with a City department. • Facilitate Best Practices workshops and consult on Business Cohort and Network Impact Council • Collaborate with Loras Civic Action Team on developing a Cultural Snapshop of the Latinx communities and the LGBTQ communities in Dubuque • Consult with partners to identify equity and inclusion projects and goals Community Development — Activity Statement Engage residents and organizations as partners in advancing equity in economic opportunity, housing, education, heath, transportation, and safety. Goal: Partnering for a Better Dubuque Outcome #1: Engage contracted and purchased service partners in advancing Council goals and community betterment. Service: Facilitate Cash Out Equity Team, and consult with grant and contract partners to advance equity within individual programs/institutions, as well as across institutions through collective impact partnerships. ADVANCING EQUITYINEDUCATION Campaign for Grade Level Reading" . 547 first and second grade students qualify for summer reading and support and 221 attended a summer program through the Dubuque Community School District, Dubuque Dream Center or St. Mark Youth Enrichment . Two neighborhood moms co-led parent engagement sessions with staff from the Community Foundation of Greater Dubuque to encourage summer reading. Twenty-three families attended 95°k of the sessions, developing relationships, learning about the importance of grade level reading, and creating summer reading charts for use at home. - 11 - HUMAN RIGHTS DEPARTMENT Re-Engage Dubuque — 2017-18 School Year" • 157 pf 185 students were re-engaged to work towards their High School Diploma or High School Equivalency Diploma (HSED) . 29 re-engaged students graduated high school and 11 obtained their HSED . 86 students continue to actively work towards graduation and 31 continue to work towards their HSED 'Data disaggregated by race and gender is not available due to having fewer than 10 students in these discreet categories. ` - _ �, __ � �' �j i _ � � �� '�' ��? �� , _ � :,� � r � e '� �. .I �>" ., � - ' _ ' . � /. ADVANCING EQUITYINEMPLOYMENT Opportunity Dubuque - FY18 • 96°k of those who have completed an Opportunity Dubuque certificate program since 2012 are employed or continuing their education • Of those employed or continuing their education for whom we have race or ethnicity information, 32°k are racial and ethnic minorities. Workforce Innovation & Opportunity Act Programs • 78.8°k entered employment by second quarter after exit with median earnings of $6669 during the quarter • 74.8°k were retained by fourth quarter • Persons served: 2,301 male; 1 ,511 female; 2,893 white; 536 African-American; 132 Hispanic; 32 Asian; 395 with disabilities; 246 veterans. ADVANCING EQUITYINHEALTH Dubuque Pacific IslanderHealth Project: • increased enrollment of Pacific Islanders in prevention programs and treatment; • increased primary care relationships; • decreased ER visits by 38°k; • decreased missed appointments by 60°k. Double Up Food Bucks: • token distribution up 47°k, allowing individuals receiving food benefits to access fresh, healthy food at the Farmer's Market - 12 - HUMAN RIGHTS DEPARTMENT DuRide: • provide more than 12,000 rides for seniors for medical appointments, nursing home visits, social excursions, shopping, and church services ADVANCING EQUITYINARTS AND CULTURE Arts Grants: . co-facilitate the grant orientation workshop for grant applicants on equity and inclusion expectations Program: Equity and Intercultural Workshops for partners This year we offered a 32-hour workshop entitled Developing an Equity Framework via Intercultural Methods. Twenty-nine people participated in the workshop, including participants from departments creating equity plans and organizations who receive City funding. Participants indicated they will do the following differently as a result of the workshop: • Use the 7-S while working through a SMART goal • Be slower to assume and quicker to ask questions • Speak up and be a voice for change • Remember that everyone has a story Total participants in all workshops since 2009: 567. We also offer follow-up consultation to graduates from our workshops. -- � -, .� � T ' T. �� - ' � � '� _ � ,,. _ � ��_ _ , � q� �i� ..w}� 'i e� . titl _ _ � •� . •a _ �_ L � � ✓ J -- ` �� ,�,� � ��. '� _ -_�R �—� �� -- ;� . � w��:� �� ,� 'k� ��y��;, .� �� '- �`� � � � . �.,�� ,� , =�,1 , ; �` _ .1 , � �a=� �:,� e � f� �.. _ R�j _ ;�':, - 13 - HUMAN RIGHTS DEPARTMENT Developing an Equity Framework Post Survey Results Strongly Agree � � Agree Disagree Strongly Disagree 0 20 40 60 80 100 Percent of Respondents Improved my understanding of individual factors influencing equity ■ Improved my understanding of institutional factors influencing equity Improved my understanding of systemic factors influencing equity Helped me understand the influence of implicit bias on perception � Helped me practice ways to identify and begin to address inequities in my institution ■ Taking away new approaches I will use in the future - 14- HUMAN RIGHTS DEPARTMENT Implementation Efforts by Workshop Graduates � Strongly Agree � Ag ree Neutral Disagree Strongly Disagree 0 10 20 30 40 50 60 70 Percent of Respondents My organization has made program improvements designed to improve equitable access and use of our programs � My organization solicits feedback from communities most affected by inequities My organization tracks the number of staff hired and retained who reflect communities most affected by inequities � My organization uses an equity tool to analyze and improve programs or practices - 15 - HUMAN RIGHTS DEPARTMENT Outcome #2: Have non-profit institutions, private businesses, and educational institutions contributing toward implementation of the Imagine Dubuque plan. Service: Facilitate My Brother's Keeper, a network of non-profit organizations and volunteers who are working to support youth of color and low income youth of various ages to improve school achievement, graduate from high school, and proceed to college and/or a career. '"f^:=�� " -=3 , "�=,�e ''-• ;_ , . � �.�� +n,'' _ �F �� :�;� ' " �1►'.s�, � � � r , �, —��,. } � -�. �'1�/� ��Y r � � � ,� �t� � � � � V � ��t' �.� /� ��. � � ��. � � . r• (}� �.. �.. , �n$ _ �T1�. ��. � � � `� �� ;'l. ��•-- � ,� � ''� ' � � � � ,�w `�r , , 6 . ' ' J f� c� ,.... �►6 � r� . , ,_.. � T'� ,.�.1 '�� _ _ ��0�� _ � � r =+ � - - � ��/� ,. (l� � �._� -� � � � � �. i �� - `r � I` `� � j;� �, - _ _ , , � � �.. � r J— /�• J"i �� / \/�..� 1, ��,� �� • ,I _� -� —T-- . •�� C 7� n n A�.r��, d . �� .:. a � ,Q �'� � . -. � ,� �� .'��- _ -� �- ��„�� Over the past year: • 160 students participated in summer programming and 88% maintained or increased literacy skills • Mentors and tutors donated time valued at over $5,000 • 377 students completed out-of-school-time academic programs with network partners during the school year and 191 maintained or increased literacy skills - 16- HUMAN RIGHTS DEPARTMENT Service: Information and referral: This year, 209 people contacted us with specific questions about discrimination complaints or questions about meeting basic needs. The most frequent areas where people were seeking assistance related to employment and housing needs, and more than half of the contacts did not involve allegations or concerns of discrimination. Inquiry Disposition s.o�io 27.0% ' 39.0% 28.0% Education/Counseling ■ Referral to Another Agency Declined to File ■ Filed Complaint 2018 Inquiries - Brokendown by Area 50 40 38 N � 3Q 27 3 � C u� Z� 18 14 10 3 0 , Employment Housing PublicAccomodation Education Other 12 contacts resulted in the filing of formal discrimination complaints for investigation by the Legal Department. During FY18, the Legal Department closed 11 cases. - 1�- HUMAN RIGHTS DEPARTMENT 2018 Inquiries - Brokendown by Basis 47% 60 50 40 17% 13% 0 30 6% 12/0 �o� 6% 2% 1% 2% 10 0 Other Disability Race Age Sex Gender National Sexual Religion Identity Origin Orientation Retaliation Disposition of Closed Cases 9.o°io is.o�io 55.0% 18.0% Administrative Closure � No Probable Cause Referred to lowa Civil Rights Commission ■ Successful Mediation - 18 - - 19 -