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other services 23 CFR 200; 49 CFR 21; UMTA Cir. 4702.1
local assistance 90
23 CFR 200; 49 CFR 21
The Division of Local Assistance is responsible for the funding and management of
the State’s local agency projects and programs that utilize Federal-aid funds. Title VI
assurances are required for all of the Federal-aid projects this office oversees.
Extensive efforts to implement Title VI have been undertaken using the Local Assistance
Procedures Manual (LAPM), the Local Assistance Program Guidelines and the District
Liaison Area Engineer’s (DLAE) staff to ensure Federal requirements are being met.

Potential Title VI Issues
Local agency projects have the potential for being discriminatory should the local agencies
not comply with Title VI, and the local agency not include the Title VI requirements in
their contract provisions. These two areas are addressed in the procedures by the local
agency signing an agreement with the Department that they will comply with all Federal
and State laws including civil rights and Title VI. Other areas of concern could be:
1. Whether data collection/analysis is adequate.
2. Whether social, economic and environmental effects and impacts have been identified
and described.
3. Contract language should include Title VI requirements.
4. When awarding a contract, determine whether the contractor has any unresolved
Title VI violations.

Recommended Good Practices and Mitigation Measures
1. Incorporate Title VI requirements into policies and procedures.
2. Encourage and seek participation from those most directly impacted.
3. Conduct an adequate number of meetings and hearings.
4. Demonstrate consideration of community input via newsletters, letters, leaflets or
whatever medium will potentially reach the target group/audience.
5. Develop and implement forms, surveys and other data collection methods.
6. During solicitation of contracts, ensure equal participation including minority and
women-owned firms.
7. When local agencies give presentations at community workshops, put graphics, slides,
etc. in applicable languages and provide diagrams that show the relationship between
their input and the final product. Attempt to include types of diagrams that describe
processes and community interactions in ways that translated words cannot.
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8. In cooperation with other transportation entities, provide technical assistance.
9. Treat everyone fairly.

Compliance Reviews

Compliance Reviews - Selection Methodology
The Division of Local Assistance will not randomly select local agencies for compliance
reviews. Rather, the selection will be based on neutral criteria or evidence of a violation.
A credible complaint can serve as specific evidence suggesting a violation that could
trigger a compliance review.
Criteria for identifying local agencies for a compliance review may include the following:
1. Issues targeted in the agency’s strategic plan;
2. Issues frequently identified as problems faced by program beneficiaries;
3. Geographical areas the agency wishes to target, because of the many known
problems beneficiaries are experiencing, or because the agency has not had
a “presence” there for some time;
4. Issues raised in a complaint or identified using a complaint investigation that
could not be covered within the scope of the complaint investigation;
5. Problems identified to the Department by community organizations or advocacy
groups that cite actual incidents to support their concerns;
6. Problems identified to the Department by its grant recipients;
7. Problems identified to the Department by other State, Federal or local civil
rights agencies;
8. The population served by the local agency.
The Local Assistance Program will develop a compliance review instrument in coordination
with the Title VI Program. A Title VI representative will participate in all Local Assistance
Program Title VI compliance reviews.
An adequate and representative sample of local agencies reviewed is necessary
to indicate whether local agencies are in compliance with Title VI.

Annual Report
Annually, the Title VI Program submits to the FHWA an accomplishment report detailing
its accomplishments and each Emphasis Program’s accomplishments for the past year
and goals for the upcoming year. The reporting period is October 1 through September 30
which is the Federal Fiscal Year. The Local Assistance Program will be responsible for
developing selection methodology to identify the number selection of local agencies
that will be required to submit annual reports. A representative sample is sufficient
and should be alternated annually.

Methods of Administration
The Division of Local Assistance is required to integrate the Title VI Assurances described
in the model Nondiscrimination Agreement between the Local Assistance Program and
the Named Recipient into the Local Assistance Program Master Agreement or as a
separate agreement as a condition of receiving Federal funds. A copy of the model
Nondiscrimination Agreement is located in the Assurances/Agreements appendix section.
Planning and Project Development Process
Refer to the “Requirements for All Programs” and “Emphasis Programs” requirements
for guidance. Because Division of Local Assistance is an external program, the focus
will be placed on oversight, monitor and review. Approach the discussions requirements
from an oversight perspective with the exception of the “Contract/Grants/Permits/Loans
Assurances” and “Complaint Handling” sections, which may directly apply.

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