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The environmental process, although complex and fluid, is an integral part of the project development process. It is the Department’s policy to evaluate the environmental benefits and consequences of its activities and implement practices that minimize environmental impacts; a systematic interdisciplinary approach is used to identify and evaluate environmental issues and problems. The resulting documentation can take many forms depending upon the laws and regulations under consideration and the complexity of the impacts.

Potential Title VI Issues
The environmental study of project alternatives and impacts must include the consideration of mitigation measures for unavoidable impacts. Mitigation measures and other agreements that are made as part of the decision making process must be documented and implemented. Environmental commitments, such as noise barriers, joint-use facilities, replacement housing, protection of cultural resources and others should be monitored to assure that these mitigation measures are included in the design plans and the construction of the project. The environmental process should consider, as applicable, whether:
1. Public information was adequately solicited and seriously considered.
2. Social, economic and environmental (SEE) impacts were adequately identified and documented.
3. The potential for disproportionate or discriminatory impacts has been adequately addressed.
4. Beneficial impacts, such as increased access to facilities/services and upgrading of affected communities, have been identified.
5. The following disparate or disproportionate impacts have been identified:
· Diminished access to facilities/services;
· Disruption of community cohesion;
· Disruption of people, businesses and farms;
· Changes in tax base and property values;
· Traffic Noise;
· Relocation of residences and businesses;
· Diminished quality of the water, air or natural environment used by residents.
6. The potential for the discovery and protection of cultural resources has been adequately identified and addressed with Tribal Governments and other Native American communities and individuals.

Recommended Good Practices and Mitigation Measures
1. Restoration of circulation and pedestrian patterns for disrupted communities.
2. Provisions of relocation assistance and advisory services, replacement housing and payments for moving displaced families and businesses.
3. Provisions for maximum retention of existing trees and shrubs included in grading plans for ramp areas and along right of way.
4. Provision for last resort housing.
5. Provision of traffic control.
6. Improvements in traffic signalization and street lighting.
7. Establishment of priorities for employment, training and contracting opportunities for residents of the affected community.
8. Provision of noise barriers and buffer zones.
9. Provision of landscaping.
10. Functional replacement of publicly-owned facilities displaced by the project.
11. Coordination with community development agencies to implement jointly funded initiatives.
12. Develop a public involvement program during the concept scoping planning stage and continue during the project development process. Utilize public involvement techniques to identify issues of potential discrimination as early as possible in the project development processes to meet the needs of a particular community (e.g., minority, disabled, elderly).
13. Use newsletters, speakers bureaus and media to provide a consistent flow of information on project development status.
14. Provide opportunity for public hearing after release of the Draft Environmental Impact Statement (DEIS) or Environmental Assessment.
15. Focus outreach on appropriate (target) community to ensure involvement.
16. Use informal contact, which is more effective than a formal atmosphere for a public hearing.
17. Experiment with informal open forum public hearing formats; allowing one-on-one comments to a recorder.
18. Develop mitigation and enhancement strategies based on public involvement and agency coordination.
19. The project team should become aware of other actions that have occurred in the impacted area and how these actions were perceived by members of the community.
20. The project team should study avoidance, minimization, mitigation and enhancement strategies when working with the affected community on the specifics as a definite proposal begins to take shape.
21. Community impact assessments should include compilation and analysis of demographic data including breakdowns by characteristics protected under Title VI and related statutes; race, color, national origin, sex, disability and age. Also, consider the impacts to minority and/or low-income populations.
22. Tribal Governments and Native Americans are properly consulted for the identification and protection of cultural resources, and the proper mitigation is in place.
23. Tribal Governments are consulted to ensure mitigation of environmental issues that might impact their communities.

Possible Compliance Review Questions
A. General
1. What office or section has the lead responsibility for Title VI matters?
2. What is the process followed whenever a new directive is issued?
3. Is your Program Area Administrator (PAA) involved in policy development?
4. When awarding a contract, grant, loan or permit, what mechanism is used to ensure that the contractor or applicant does not have any unresolved Title VI violations?
5. What is the role of the PAA and/or key personnel in the environmental stage?
Please describe for each area below:
· Public Involvement and citizen advisory committees,
· Scheduling time and location of public meetings and hearings,
· Identification of impacts,
· Identification of mitigation measures,
· Environmental assessments,
· Analysis,
· Consideration of alternative with respect to corridors and locations.
6. Who is responsible for identifying Title VI issues in the environmental documents of proposed projects?
7. Are there any Tribal Governments in the project area; if there are, have they been consulted regarding projects?
8. What measures have you taken to identify cultural resources? If cultural resources have been identified, or a Reservation or Rancheria is to be impacted, was the proper Native American community, individual or Tribal Government notified to ensure proper mitigation measures?
B. Management Staff Composition
1. Provide a staffing composition listing by position, race and gender. Include an organizational chart.
2. Policy and Advisory Committees – Provide a staffing composition listing of committees and their respective members by position, race and gender.
3. Provide a listing of persons who are designated to provide alternative language assistance and identify what languages they translate.
C. Complaint Procedure
1. Provide a copy of the procedure your program uses to handle a Title VI complaint.
How are your customers made aware of this process?
2. How many Title VI related complaints have you received in the past two years?
What was the outcome of those complaints?
3. How are Title VI complaint procedures disseminated to program personnel?
D. Training
1. Has staff received formal or informal training regarding Title VI of the Civil Rights Act of 1964 and/or Environmental Justice Executive Orders? Please describe.
2. Do you have a schedule for Title VI and related statues training this year? If yes, please provide the schedule and who will attend?

E. Data Collection & Monitoring
1. Do you conduct self monitoring within the Division of Environmental Analysis?
If yes, what programs and how? If not, why not?
2. What process does the program use to self monitor data collection and contract/grant language requirements?
3. What data (race, color, national origin, language considerations, sex, disability and age) do you maintain that reflects the extent to which members of minority groups are beneficiaries of your program?
4. What records and/or reports are maintained which specifically reflect compliance with Title VI?
5. Who is responsible for developing, maintaining and reporting this data?
6. How is this data used?

Strategies and Goals
1. Provide a copy of your Strategic Plan and Performance Measure Objective for the current fiscal year.
2. What strategies and efforts have you developed for ensuring, demonstrating and substantiating compliance with Title VI?
3. How do you use the demographic profiles that include identification of the locations of socioeconomic groups, including low-income and minority populations as covered by the Executive Order on Environmental Justice and Title VI provisions?
Describe how you developed the profile.
4. Does your process seek to identify the needs of low-income and minority populations?
Describe how.
5. Does your process seek to make use of demographic information to examine the distributions across these groups of the benefits and burdens of the transportation investments included in the plan and TIP?
6. What methods are used to identify imbalances?
7. How does the program follow-up to ensure mitigative measures identified for projects significantly impacting minorities are carried through?

Social, Economic, Environmental (SEE)
1. Is an in depth analysis of the SEE effects and impacts identified, described and considered? Describe this process.
2. Does your program follow up on any identified SEE impacts? Please explain.
3. Explain how your program monitors SEE impacts.

Service Equity
1. Describe, in summary, the programs administered by the Environmental Program.
2. Does your environmental process have an analytical process in place for assessing the benefits and burdens of a transportation system project on different socioeconomic groups?
3. Does it have a data collection process to support the analysis effort? Describe and provide an example.
4. Does this analytical process seek to assess the benefit and impact distributions of the project?
5. How does your process respond to the analysis produced?

Public Involvement
1. Provide a copy of your public involvement process policy. What is the public comment period before the process or revision is adopted?
2. Is information about environmental issues and processes provided timely to citizens, public agencies, transportation agency employees, private sector transportation providers and others affected by transportation plans, programs and projects?
Describe how.
3. Does the public have access to technical and policy information used to develop environmental documents where Federal-aid highway and transit programs are considered? Describe how.
4. Is advance public notice given for public review and comment on key decisions, including approval and amendments? Describe how.
5. Are the needs of low-income and minority households taken into account?
Describe how.
6. Does the public outreach effort use media such as print, television, radio, etc. targeted to low-income or minority populations?
7. Has your program made funds available to local organizations that represent low-income and minority populations to enable their participation in the environmental process?
8. What is your process for advertising a Public Notice that your program is an equal opportunity program and/or that Federal law prohibits discrimination?
9. Are Tribal Governments and related public agencies on public or tribal land involved in the environmental process? Describe how Tribal Governments are involved in the environmental process, and what considerations are given to Indian reservation roads.
10. Give an example of what changes have occurred as a result of input by public involvement, specifically low-income and minority populations?
11. Is the public involvement process reviewed periodically to determine the effectiveness of full and open access to all? Describe how.
12. Describe the types of assurances utilized to assure that no one has been excluded from participation in or denied benefit of or otherwise subjected to discrimination on the basis of race, color, sex, national origin or physical handicap for any program receiving federal financial assistance.
13. Describe actions taken to comply with the Americans with Disabilities Act.
14. How does the PAA assist program area personnel in obtaining public involvement?
15. Has the PAA or key program personnel attended public meetings and/or hearings held for projects with potential Title VI impacts? If yes, list the meetings/hearings, whom attended and the outcome(s).
16. What role did the PAA and/or key program personnel play to facilitate participation of historically under represented groups and accessibility to the location of the meetings or hearings?
17. Does the PAA review procedures and efforts made by the programs and MPOs to obtain public involvement, particularly minority citizen participation? If so, please provide examples.

1. What statistics are kept on public hearing participation by race and gender?
Visual identification?
2. Are minority group concerns addressed in a timely manner? Describe how.
3. Are public meeting announcements made available in languages other than English, according to the affected minority population? Describe how, and provide an example.
4. Are accessible locations (geographically and structurally), appropriate times and translation services planned for and provided during public hearings?
1. Who in the program monitors the contractor’s adherence with the Title VI requirements?
2. How does your program promote the participation of Disadvantaged Business Enterprises (DBE) contracts?
3. Are DBE goals set and do you meet these goals?
4. Provide the number, dollar values and types of contracts and funding sources used during the last two fiscal years. Identify if there were any DBEs on the contracts.

Self Monitoring
1. What office or section has the lead responsibility for Title VI matters?
2. How does the program follow-up to ensure mitigative measures identified for projects significantly impacting minorities are carried through?
3. What is the role of the PAA, District Title VI Liaison and/or key personnel in the environmental stage? Be prepared to describe that role in the following areas:
· Public involvement and citizen advisory committees
· Scheduling time and location of public meetings and hearings
· Identification of impacts
· Identification of mitigation measures
· Environmental assessments
· Analysis
· Consideration of alternatives with respect to corridors and locations.

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