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Since April 2000, the Department has aggressively developed
and implemented the Title VI Program through an interdisciplinary approach.
Civil Rights and program specialists have worked closely together to
accomplish the following:
1. Designation of a Title VI Coordinator and staffing.
2. Formation of an Interdisciplinary Team.
3. Approval of the Civil Rights Title VI Program Plan
by FHWA.
4. Compliance Review Pilot Project and Survey.
5. Compliance Review Process for Headquarters Programs
and district offices.
6. Civil Rights Title VI Program Resource Directory.
7. Title VI Program Publications.
8. Annual Accomplishment and Upcoming Goals Report
to FHWA.
9. Title VI Complaint Procedures and Form.
The document that follows provides guidance to Title
VI Program customers to Assist in meeting compliance with nondiscrimination
law. The guidelines focus on process and delivery of activities, products
and services, to whom and when, whether the outcome is a benefit or
burden to the eligible population, what was done to mitigate any disparate
or disproportionate impacts and whether the actions were documented.
Implementation of the Title VI Program and interaction
with Department Headquarters and district personnel, Federal Highway
Administration (FHWA), Federal Transit Administration (FTA) representatives
and Metropolitan Planning Organizations (MPO) have led to the following
immediate recommendations:
1. Implementation of a comprehensive data collection
mechanism and methodologies for analysis to determine disparate or
disproportionate impacts.
2. Initiation of context sensitive mitigation measures
that reduce the unavoidable
adverse impacts to minority or low-income populations.
3. Implementation of a comprehensive Public Involvement
Plan.
4. Completion of demographic analysis; statewide and
by district; by race, language, gender, age, disability and income.
5. Documentation and record retention of actions taken
by decision makers.
6. Implementation of procedure for pre-grant and post-grant
reviews of applicants
for compliance with Title VI requirements.
7. Adherence to Assurances included in the Nondiscrimination
Agreement between
the Department and FHWA and the Director’s Policy
statement.
8. Initiate Headquarters’ and district’s self monitoring
and corrective action.
9. Implementation of mechanisms that provide access
to Department programs,
activities and services for Limited English Proficient
persons.
10. Implementation of a continuous comprehensive training
program.
In conclusion, the Department decision makers have been
supportive and proactively implementing Title VI and related statutes
and policy requirements. The recommendations stated above are a requirement
of meeting and maintaining compliance with Title VI and related statues.
Time, commitment and resources are needed to fully implement the requirements.
The FHWA and FTA support the Department’s approach of implementing
the Title VI Program.
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