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Intermodal Title VI



Title VI Program

This plan is updated every two years (in the odd numbered year) in alignment with the Oregon state biennial cycle. The current program covers years 2025 through 2027.

For alternate formats or a printed version of this program, please contact us at ODOT.TitleVI@odot.oregon.gov, toll free at 855-540-6655, or using Oregon Relay Service at 7-1-1.

See the Languages tool in the upper right corner of this page supporting automated translation into Spanish (Español), Chinese (中人), Vietnamese (Tiếng Việt), Russian (Русский), and more.

​​Introduction:
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​​​​The ODOT Intermodal Title VI Program is in place to ensure compliance with Title VI of the ​Civil Rights Act of 1964 and provides specific information that outlines processes and procedures for ensuring equitable practices at ODOT. The ODOT Intermodal Title VI Plan describes the roles, responsibilities, and procedures for compliance with federal directives and related regulations. This plan document includes information about the organization, program monitoring, compliance review of subrecipients of federal funds, the investigation and disposition of discrimination complaints, and other nondiscrimination activities and assurances.
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​​​​Oregon Department of Transportation (ODOT):
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​ODOT was established to bring together programs that meet the objectives of contributing to the growth and economy of the state by providing for the movement of persons and goods rapidly, safely and economically.  ODOT develops and administers Oregon’s system of highways and their infrastructure; public transportation services; rail passenger and freight systems; bicycle and pedestrian paths and routes; ports and marine transportation; pipelines; transportation safety programs; driver and vehicle licensing and registration; and the enforcement of statutes, policies and procedures relating to commercial motor carriers.
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ODOT’s commitment to nondiscrimination and implementation of Title VI of the Civil Rights Act of 1964 spans across the organization and is an example of the agency’s approach to living our Values and implementing our Mission.

MISSION: We provide a safe and reliable multimodal transportation system that connects people and helps Oregon's communities and economy thrive.
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OUR VALUES: These principles inform decision-making and guide our behavior in working with each other, our partners and the communities we serve:
  • Integrity: We are accountable and transparent with public funds and hold ourselves to the highest ethical standards.
  • Safety: We share ownership and responsibility for ensuring safety in all that we do.
  • Equity: We embrace diversity and foster a culture of inclusion.
  • Excellence: We use our skills and expertise to continuously strive to be more efficient, effective and innovative.
  • Unity: We work together as one ODOT to provide better solutions and ensure alignment in our work.​​​​
​Our Strategies:​​

  • Provide outstanding customer service.
  • Use innovative program design and technologies to solve transportation problems.
  • Improve the return on investment of our transportation funds.
  • Attract, retain and develop an outstanding ODOT workforce.
  • Engage the public, other state agencies, local governments, business, and community leaders in solving transportation problems and planning for the future.
  • Increase intermodal linkages to improve access for people and goods.
  • Communicate, educate and inform the public about transportation issues.
The Oregon Department of Transportation is dedicated to a well‐qualified, diverse workforce representative of the public it serves. Diversity is an ODOT strategic business value taking advantage of diverse, creative thinking, collaborati​on, and problem solving toward common State and Federal transportation goals.

The Office of Engagement and Civil Rights (OECR) is committed to providing fair and equitable access to ODOT economic opportunities, programs and services. The Office of Engagement and Civil Rights represents all modes of transportation including public transit and passenger rail. In 2014 ODOT established the Intermodal Civil Rights Program to represent modes of public transportation, active transportation, and passenger rail programs that increase opportunities for workforce and small business stakeholders as well as ensure nondiscrimination compliance in the projects and services it supports.

The Office of Engagement and Civil Rights is responsible for creating policy and leading efforts focused on:
  • Helping hiring managers and HR recruit, retain and train employees to understand, represent and look like the communities we serve.
  • Expanding our efforts to provide contracting opportunities for disadvantaged business owners.
  • Increasing our awareness to better align our transportation decisions with community desires, especially in historically marginalized communities.
ODOT is committed to ensuring access and meaningful participation by integrating diversity, social equity and inclusion into all of the agency’s activities. The following strategies guide agency policy, decisions, and actions.​​​

​ ​​Equity:

Prioritize diversity, equity, and inclusion by identifying and addressing systemic barriers to ensure all Oregonians benefit from transportation services and investments.
  • Culture, Workforce, Operation, and Policy: Build a diverse workforce, supported by equitable operations and policies, and establish an informed culture that delivers authentic inclusivity.
  • Economic Opportunity: Promote economic opportunity for Oregonians through transportation investments, including working with businesses owned by Black, Indigenous, People of Color (BIPOC), women, and others who have been historically and/or are currently marginalized.
  • Engagement: Utilize the viewpoints of those who reside in the communities ODOT serves and who are likely to be affected by the decisions ODOT makes.
  • Climate Equity: Invest in the protection of marginalized communities from environmental hazards.

​ ​ODOT Public Transportation Division:
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The Public Transportation Division (PTD) supports the state's goals for citizens to have transportation choices to live independently and participate in the economy. PTD provides grants, policy leadership, training, and technical assistance to communities and local transportation providers. By increasing coordination between transit providers, investing in new technology, and facilitating fare-affordability, PTD contributes to a smarter, more equitable transportation system.

Strategic investment in public transportation is one method for advancing equity.  PTD incorporates equity considerations into the fund programs it manages.  For example, when making funding decisions for state and federal fund programs alike, PTD evaluates the extent to which proposed projects might benefit low-income individuals and other historically marginalized communities.  In 2018 the Oregon Transportation Commission adopted the Oregon Public Transportation Plan (OPTP)​. The OPTP provides overarching guidance for PTD, with equity specifically address in goal 4. The full OPTP is available on the web and by request.

​​ODOT is a recipient of federal financial assistance. As a condition of receiving these funds, the Department is required to comply with various nondiscrimination laws and regulations including Title VI of the Civil Rights Act of 1964. Title VI provides that: “[n]o person in the United States shall, on the ground of race, color, or national origin, be exc​luded from participation in, be denied the benefits of, or be subjected to discrimination any activity receiving Federal assistance.” 42 U.S.C. § 2000d.

Subsequently, federal authorities extended these protections to include sex, age, and disability. Entities, whether public or private, that receive federal assistance from any federal agency, must take concrete steps to ensure nondiscrimination in their programs and activities.​

​​​ ODOT's Title VI Nondiscrimination Statement reads:

It is the Oregon State Department of Transportation’s policy to assure that no person shall, on the grounds of race, color, national origin, age, sex, or disability as provided by Title VI of the Civil Rights Act of 1964 and related authorities, be excluded from participation in, be denied the benefit of, or be otherwise discriminated against under any of the programs or activities it administers.

​This statement is used in documents and on our website. In addition, ODOT developed a nondiscrimination poster that is posted in facilities open to the public, listed on ODOT websites, and translated into Spanish, Chinese, Russian, and Vietnamese. ODOT’s Nondiscrimination Posters are included in Appendix A-1.

​Federal Transit Administration's Role:

The FTA Office of Civil Rights conducts periodic discre​tionary compliance reviews of recipients and subrecipients of FTA funding, including transit providers, State Departments of Transportation, and Metropolitan Planning Organizations to determine their compliance with FTA Circular 4702.1B, “Title VI Requirements and Guidelines for Federal Transit Administration Recipients.” 

Compliance reviews also provide technical assistance and make recommendations regarding corrective actions, as deemed necessary and appropriate. Compliance reviews assess the recipient or subrecipient’s efforts to meet the requirements under the “General Reporting” and “Program‐Specific Reporting” sections of the Title VI Circular and any additional information that is necessary to make a determination that the grantee is in compliance with Title VI.

These reviews are conducted separately from the triennial, state management, or planning certification reviews. These reviews are conducted either as a desk audit or during an on‐site visit. They may cover all or a portion of the recipient’s or subrecipient’s compliance with the Title VI requirements. Such reviews are conducted at the discretion of FTA, and their scope is defined on a case‐by‐case basis. The selection of recipients or subrecipients for compliance reviews is primarily based on the following factors:
  • ​Lawsuits, complaints, or investigations conducted by organizations other than FTA alleging that the recipient or subrecipient is deficient or non‐compliant with Title VI;
  • Problems brought to the attention of FTA by other federal, state, or local civil rights agencies;
  • Incomplete Title VI program submissions that were previously submitted to FTA by a recipient;
  • Title VI findings or recommendations on prior triennial, state management, or planning certification reviews that have not been sufficiently resolved or implemented, or repeat findings in any FTA review concerning Title VI; and
  • The length of time since the last compliance review.
After reviewing the recipient or subrecipient’s efforts to meet the general requirements and guidelines reporting sections of the circular, FTA will issue findings in a draft report of no deficiencies, findings of deficiencies, or advisory comments. The recipient or subrecipient will have the opportunity to review and respond to the draft report. After FTA has received and reviewed the agency’s response, it will publish a final report that will be provided to the recipient or subrecipient and will also be subject to requests from the public under the Freedom of Information Act (FOIA).

If findings of deficiencies remain in the final report, the recipient or sub ‐recipient will be required to take corrective action and report on its progress to FTA on a basis deemed appropriate. Once FTA determines that the recipient or subrecipient has satisfactorily responded to the review’s findings, it will inform the agency that the review process has ended and release it from further progress reporting in response to the review. Compliance reviews may be followed up with additional reviews as necessary.

In a situation where the recipient or subrecipient fails to take appropriate corrective action in response to the findings of deficiency in the report, FTA may initiate enforcement proceedings that could result in the suspension, termination, refusal to grant or continued federal financial assistance to a recipient or subrecipient or a referral to the Department of Justice with a recommendation that appropriate proceedings be brought to enforce Title VI of the Civil Rights Act of 1964.

Oregon Department of Transportation’s Role:

ODOT is required to ensure that subrecipients are in compliance with Title VI requirements and demonstrate that subrecipients were selected for funding in a nondiscriminatory manner. The ODOT Office of Equity Engagement and Civil Rights ensures compliance with a variety of civil rights laws and executive orders that prohibit discrimination in programs and activities receiving direct or indirect federal financial assistance from the FTA or any other federal sources.

ODOT maintains and provides data and other relevant information as required, including all pertinent data obtained from subrecipients relating to Title VI or related statutes. Onsite compliance reviews are conducted of subrecipients on an intermittent basis by the Public Transportation Division (PTD). These reviews include compliance with Title VI with review of the following areas:
  • Inspection of all materials pertaining to implementation of Title VI and verification that all services are being implemented consistent with the updated Title VI program;
  • Review any and all Title VI complaints and their outcomes. Make comments and advise subrecipient of any needed follow‐up action;
  • Inquire about any problems involving service delivery to the minority, low‐ income, and LEP communities and their possible solution; and
  • Review other information necessary for compliance with the Title VI program requirements consistent with FTA Circular 4702.1B, dated October 1, 2012.
  • Upon conclusion of review, ODOT will issue a compliance report. This report will contain the subrecipient’s state of compliance, including recommendations and corrective actions regarding the Title VI program. Failure to submit requested information might delay consideration of any pending grant or grant application.
In addition to the periodic compliance reviews, ODOT will:
  • Provide direction and technical assistance to ODOT subrecipients, cities, counties, metropolitan planning organizations (MPO), and contractors to ensure compliance with Title VI;
  • Ensure that Title VI requirements are included in program area directives to prevent perceived or real discrimination;
  • Attend ODOT public hearings and monitor for adequate participation of communities affected by ODOT activities;
  • Investigate and resolve filed Title VI complaints;
  • Develop and update ODOT’s Intermodal Title VI Program to reflect organizational policy or implementation changes;
  • Develop and periodically deliver trainings on civil rights topics, including Title VI, Environmental Justice, Disadvantaged Business Enterprise, and ADA.

The purpose of the Intermodal Title VI Program is to enable the ODOT Public Transportation Division and its subrecipients to comply with the guidance and instructions included in the Federal Transit Administration Circular 4702.1B that are necessary to carry out the requirements contained in the Title VI regulations issued by the Department of Justice (DOJ) (28 CFR Part 42, Subpart F) and the U.S. Department of Transportation (DOT) (49 CFR Part 21), and to administer programs, policies, and activities in a manner that is consistent with the DOT Order on Environmental Justice (Order 5610.2) and the DOT Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP) Persons (70 FR 7408​7, December 14, 2005).

The Title VI Program identifies key components of a nondiscriminatory approach to programs and services funded by FTA. Here information can be found on filing complaints, ensuring equity in fare and schedule changes, links to other Federal agencies and groups related to this issue, and links to the various regulations affecting the Title VI requirements.

Note that 49 CFR 21.9(b) requires that recipients record and retain certain information and submit information to FTA as necessary or required. ODOT fulfills this requirement by submitting a Title VI Program to FTA once every three years.

The ODOT Office of Engagement and Civil Rights works with the Public Transportation Division to provide training and technical assistance, reviews, and concurrence subrecipient Title VI Programs. Working with the subrecipients to resolve issues and inconsistencies is an ongoing process and is not limited to Title VI compliance. Subrecipients of FTA funding through ODOT submit Title VI Programs to ODOT for review on a three-year staggered schedule. ODOT reviews and provides feedback on the Title VI Programs and provides concurrence when the plans are approved. The ODOT Office of Engagement and Civil Rights has direct unfettered access to the ODOT Director. An organization chart is included in Appendix A-5.​
  • Ensure the level and quality of transportation services are provided equitably and without regard to race, color, or national origin;
  • Ensure full and fair participation of all affected populations in transportation decision making;
  • Prevent the denial, reduction, or delay in benefits related to programs and activities that benefit minority populations or low‐income populations; and ensure that persons with Limited English Proficiency (LEP) have meaningful access to programs and activities that are administered by recipient and subrecipients; and
  • Ensure that recipients and subrecipients are providing services in a non‐discriminatory fashion and are informing the public of their rights.​

All applicants f​or federal financial assistance shall follow procedures to comply with Title VI regulations. ODOT complies with these requirements and describes the key elements in this Title VI Program, which was prepared in accordance with FTA Circular, 4702.1B and other FTA Guidance. This Title VI plan describes the roles, responsibilities, and procedures for assuring compliance with the Title VI of the Civil Rights Act of 1964 and related regulations and directives.

Title VI Assurances

​​​In accordance with 49 CFR Section 21.7(a), every application for financial assistance from FTA must be accompanied by an assurance that the applicant will carry out the program in compliance with DOT’s Title VI regulations. ODOT Public Transportation Division is designated as the administrative agent for the FTA programs, including, but not limited to:
  • Statewide Planning (§5304)
  • Increased Mobility for Seniors and Individuals with Disabilities (§5310),
  • Small Cities and Rural Areas (§5311),
  • Intercity Bus (§5311(f)), and
  • Bus and Bus Facilities (§5339)
The Public Transportation Division also awards and provides technical support and guidance for transit-related state funds.
This requirement is fulfilled when ODOT’s Public Transportation Division submits its annual certifications and assurances to the FTA as part of its annual Certification and Assurance through the Transit Award Management System (TrAMS). In addition, ODOT annually adopts an assurance statement in compliance with USDOT ORDER 1050.2A. A copy of the 2020 assurance statement is signed by the ODOT Director appears in Appendix A-2.​

Prepare and Submit a Title VI Program

​​​​​​​​​Title 49 CFR section 21.9(b) requires recipients to “keep such records and submit to the Secretary timely, complete, and accurate compliance reports at such times, and in such form and containing such information, as the Secretary may determine to be necessary to enable him to ascertain whether the recipient has complied or is complying with this [rule].”
The Federal Transportation Administration (FTA) requires that all direct and primary recipients document their compliance with DOT’s Title VI regulations by submitting a Title VI Program to their FTA regional civil rights officer once every three years or as otherwise directed by FTA.
ODOT complied and will continue to comply with all requirements of Title 49 CFR, §21.9 (b). ODOT will provide FTA with updates or additional information as necessary. All subrecipients approved to receive FTA-funded grants through ODOT are required to submit a Title VI Program and subsequent updates to the Office of Engagement and Civil Rights.  Subrecipients are reviewed on a three-year basis.​

Notify Beneficiaries of Protection under Title VI​

Title 49 CFR Section 21.9(d) requires recipients to provide information to the public regarding the recipient’s obligations under DOT’s Title VI regulations and apprise members of the public of the protections against discrimination afforded to by Title VI. At a minimum, recipients shall disseminate this information to the public by posting a Title VI notice on the agency’s website and in public areas of the agency’s offices.

The approach ODOT takes to provide notice to beneficiaries consists of the following primary methods:
  • Posting of ODOT’s policy statement to the public website,
  • Disseminating notices through ODOT’s subrecipients for posting and further distribution to community groups and individuals who are known as the subrecipients or included on a subrecipient mailing list,
  • Through structured outreach initiatives that ODOT, through the Office of Engagement and Civil Rights, Public Transportation Division, or other relevant departments conduct to provide notice of projects, grant opportunities and other information, and
  • Ensuring that subrecipients of funds administered by ODOT also notify the public that is served by each transit provider.
ODOT and subrecipients of federal transportation funds will disseminate and provide information to the public regarding their Title VI obligations and apprise the public of the protections against discrimination afforded to them by Title VI. This information dissemination will be accomplished through measures that can include but shall not be limited to: posting the information on the agency’s website and in public areas of the agency’s offices. The Title VI information will further be posted in all facilities of the subrecipients’ establishments, office space, and facilities including vehicles.

Title VI Complaint Procedures and Complaint Form

In order to comply with the reporting requirements established in 49 CFR Section 21.9(b), all recipients shall develop procedures for investigating and tracking Title VI complaints filed against them and make their procedures for filing a complaint available to members of the public. Recipients must also develop a Title VI complaint form, and the form and procedure for filing a complaint shall be available on the recipient’s website.​

FTA requires direct and primary recipients to report information regarding their complaint procedures in their Title VI Programs in order for FTA to determine compliance with DOT’s Title VI regulations. ODOT is a primary recipient of FTA funding and in order to reduce administrative burden ODOT’s subrecipients may adopt ODOT’s Title VI complaint investigation, tracking procedures and complaint form or create their own.

The discrimination complaint form and process are posted on ODOT’s website and available in paper copy upon request. Examples of the Discrimination Complaint Form and Compliant Process Overview are also attached in Appendix A-3.​

ODOT Discrimination Complaint Process Overview

The Oregon Department of Transportation's (ODOT) discrimination complaint procedures are intended to provide aggrieved persons an avenue to raise complaints of discrimination regarding ODOT programs, facilities and services as required by Title VI and related statutes.

The purpose of this discrimination complaint process overview is to describe the right of individuals to file a formal complaint, the authority of the ODOT Office of Engagement and Civil Rights to investigate allegations of discrimination, and the processes for complaint investigations and referrals.

Any person who feels that he or she has been subjected to discrimination on the basis of race, color, or national origin, has the right to file a complaint with the Department’s Office of Engagement and Civil Rights. The Office of Engagement and Civil Rights must review all complaints filed under Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination in Employment Act of 1967, Civil Rights Restoration Act of 1987, the Americans with Disabilities Act of 1990, and applicable Department policies. 

Discrimination complaints must be filed within 180 days of the alleged discriminatory event or practice. Complaints can be submitted by using the online form, mail, email, or over the phone if assistance is needed:

ODOT Office of Engagement and Civil Rights
800 Airport Rd SE 
Salem, Oregon 97301
Toll-free Phone Line: 855-540-6655
Email: ODOT.TitleVI@odot.oregon.gov

The Office of Engagement and Civil Rights staff will also respond to inquiries regarding ODOT’s nondiscrimination policies and programs and will assist any person seeking information about when to file a formal complaint, alternative resolution programs, and requests for language access for individuals with limited English proficiency and accommodations for persons with disabilities.

Complainants should know:
  • All formal complaints must include the complainant's name, address and phone number and a detailed description of the specific issues and circumstances of the incident of the alleged discrimination. If you have difficulty accessing the form, an OECR employee can assist you via phone or email.
  • ODOT will confirm to the complainant that the complaint has been received within 10 working days from receipt and will communicate with the complainant during the process, including providing updates on the timeline of fact finding and decisions. Every effort will be made to obtain rapid resolution of complaints at the lowest possible level.
  • If the complaint is filed but it is determined that ODOT does not have jurisdiction over the issue, we will record the information and refer the complaint to the entity of jurisdiction. ODOT will serve as a connector between the complainant and the appropriate entity.
  • Once a complaint is accepted, OECR will investigate the merits of the complaint. This investigation should conclude within 60 days. ODOT maintains a complaint log and each record contains the responses given and the steps taken to resolve the issue.
  • This complaint process does not deny or limit the right of a complainant to file a formal complaint with an outside enforcement agency (BOLI, EEOC, U.S. Dept. of Transportation, FHWA, FTA, or U. S. Dept. of Justice) or to seek private counsel for complaints alleging discrimination. 
  • All complainants have the right to appeal the investigation and findings.  The Office of Engagement and Civil Rights will reconsider completed investigations if appealed within 10 working days of the initial decision communicated in writing to the complainant and only when new facts are revealed.  Complainants may appeal to a higher authority such as the Oregon Department of Justice, Federal Highway Administration, or the Federal Transit Administration.
  • Retaliation by ODOT staff, any other government organization or sub-recipient involved in a complaint is strictly prohibited. Any allegations of retaliation will be promptly and fully investigated.​
Record and Report Transit Related Title VI Investigations, Complaints, or Lawsuits

Over the course of the reporting period since ODOT’s previous submission of a Title VI Program to the FTA, ODOT has received no Title VI investigations, complaints, or lawsuits filed with ODOT or that names the ODOT for alleged discrimination.

ODOT maintains a log of all complaints received whether by phone, email or letter. The log includes the date of any investigation, lawsuit, or complaint that was filed, a summary of the allegation(s); the status of the investigation, lawsuit or complaint; actions taken by the subrecipient in response to the investigation, lawsuit, or complaint, and a summary of all civil rights compliance review activities conducted over the past three years.​

Public Participation

The content and considerations of Title VI and the USDOT LEP Guidance shall be integrated into each subrecipient’s established public participation plan or process. Subrecipients may determine how, when, and how often specific public participation activities should take place, and which specific measures are most appropriate. 

ODOT includes public involvement components in all phases of transportation decision-making. ODOT invites the public and stakeholder groups to participate in long-range planning, in making decisions about where to invest transportation dollars. 

In an effort to more fully integrate into community outreach activities the opinions of minority, low‐income and LEP populations, ODOT’s public participation program will include:
  • Abide by all applicable state and federal laws and rules in implementing public involvement processes for the development and update of planning activities and the processes of selecting and awarding grants.
  • Follow the requirements of the Oregon Public Meetings Law for all advisory committees and other public meetings, including requirements such as holding meetings at convenient and accessible locations and times.
  • Maintain and utilize as appropriate a broad based statewide list of stakeholders.
  • During public involvement processes, seek out and consider the needs of those populations traditionally underserved by existing transportation systems, such as low‐ income and minority populations, who may face challenges accessing employment and other services.
  • Employ visualization techniques such as maps, photographs, display boards, scenario building programs and other devices to the maximum extent practicable.
  • Provide reasonable public access to technical and policy information used in the development and update of statewide transportation plans.​
Meaningful Access to LEP Individuals and Communities

Consistent with Title VI of the Civil Rights Act of 1964 and DOT’s implementing regulations, recipients shall take reasonable steps to ensure meaningful access to benefits, services, information, and other important portions of their programs and activities for individuals who are Limited‐English proficient (LEP).

According to U.S. DOT guidance, Limited English Proficient (LEP) persons are defined as “individuals who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English.”

ODOT serves a broad population of persons and communities. Providing practical access to information for all who use ODOT’s programs and services is a priority for the agency. ODOT supports the goals of the DOT LEP Guidance and is committed to taking reasonable steps to provide meaningful access for LEP individuals who use ODOT’s services, facilities, and programs, and who attend ODOT’s meetings and events.

To ensure that ODOT complies with the requirements of Title VI and the DOT LEP implementing guidance, ODOT developed a Language Access Plan that incorporates the necessary elements that the federal guidance identifies for providing language assistance to LEP persons. The LEP Plan is available on the web and in Appendix A-4.

Representation on Transit‐Related Advisory Bodies

Recipients that have transit‐related, non‐elected planning boards, advisory councils or committees, or similar committees, the membership of which is selected by the recipient, must provide a table depicting the racial breakdown of the membership of those committees, and a description of efforts made to encourage the participation of minorities on such committees. 

In 2000, the Oregon Transportation Commission established the Public Transportation Advisory Committee (PTAC). The purpose of PTAC is to provide advice to the OTC and PTD to assist in developing transit policies and programs, and to serve as a forum for forward thinking, strategic view of public transportation for the state of Oregon. PTAC focuses on current public transportation issues and provides direction on the future of public transportation.

To address current issues, PTAC concentrates on state needs and provides recommendations to the OTC and the Public Transportation Division (PTD) as well as other ODOT work groups and divisions. The Committee focuses on policy and funding areas that impact transit riders, providers and other stakeholders. To keep Oregon at the forefront of public transportation innovation, PTAC works with OTC and PTD staff to guide the implementation of the Oregon Public Transportation Plan (OPTP). 

The committee is made up of approximately 24 representatives of public transportation stakeholders, including: general public providers in urban areas over 200,000 population, urban areas between 50,000 and 200,000, and small communities under 50,000 population; Indian tribal governments; representatives of the Association of Oregon Counties; League of Oregon Cities; Transportation Options; Oregon Department of Human Services; Individuals representing Senior and People with Disabilities, Veterans, Private Transportation NEMT Transportation, Passenger Rail, Public Schools, Equity/Civil Rights, Low income, Non-English Speaking, and Multimodal Bike Share/Micro mobility and Liaisons from Advisory Committees representing Oregon Bicycle, Safe Routes to School, and Rail representation.

The demographic makeup of the PTAC, based on a voluntary self‐identity questionnaire can be found in Appendix A-5.

Assistance to Subrecipients

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ODOT complies with and ensures that all reporting requirements and assistance to the subrecipients is consistent with FTA guidance and Oregon policy.

ODOT Office of Engagement and Civil Rights works with the Public Transportation Division to provide technical assistance, review and support of subrecipients for civil rights compliance activities. Since resources are generally limited for subrecipient transit providers, ODOT provides resources to use in order to develop a Title VI plan, develop an LEP plan and identify the LEP and low‐income populations within their jurisdiction.

OECR staff also works with the subrecipients to provide ongoing technical assistance and training on all aspects of Civil Rights compliance and monitoring in an effort to improve consistency throughout the state and to integrate the work of civil rights across all modes and funding sources.

Monitoring Subrecipients

In accordance with 49 CFR 21.9(b), and to ensure that subrecipients are complying with DOT Title VI regulations, primary recipients must monitor their subrecipients for compliance with the regulations. Importantly, if a subrecipient is not in compliance with Title VI requirements, then the primary recipient is also not in compliance.

The Office of Engagement and Civil Rights, in collaboration with the Public Transportation Division, conducts compliance reviews of all subrecipients of FTA funding through ODOT. ODOT staff will have ongoing review and documentation of subrecipient Title VI plans and other reports to determine if agencies are in compliance with Title VI. ODOT also developed a Title VI Review process for internal use, which is reviewed and maintained on an annual basis.

Subrecipient Compliance Site Reviews

The purpose of the on‐site review is to assess how the agency’s management is complying with Federal and state laws, rules, requirements, and regulations. The overall goal of the program is to improve the agency’s compliance with applicable regulations while strengthening managements’ abilities in these areas.

The Public Transportation Division’s Compliance Monitoring Program Field Guide is designed to assess how transit agencies in Oregon meet the varied compliance requirements imposed by the Federal Transit Administration and Oregon DOT. ODOT contracts with a private company to conduct compliance reviews of all subrecipients; reports are then issued indicating areas of concern and/or lack of compliance.

Location of Facilities

Title 49 CFR Section 21.9(b) (3) states, “In determining the site or location of facilities, a recipient or applicant may not make selections with the purpose or effect of excluding persons from, denying them the benefits of, or subjecting them to discrimination under any program to which this regulation applies, on the grounds of race, color, or national origin; or with the purpose or effect of defeating or substantially impairing the accomplishment of the objectives of the Act or this part.”

ODOT shall comply with all requirements of determining any site or location of facilities in accordance with the requirements of Title VI and the guidance of the FTA circular. For the purpose of this requirement, “facilities” does not include bus shelters, as these are transit amenities and are covered in Chapter IV of the Circular, nor does it include transit stations, power substations, etc., as those are evaluated during project development and the NEPA process.

ODOT has not constructed a facility with FTA funds, if ODOT constructs a facility in the future a Title VI equity analysis will occur.

ODOT requires all subrecipients to complete a Title VI equity analysis during the planning stage regarding project location selection to ensure the location is selected without regard to race, color, or national origin. When necessary, needed, and required, ODOT and/or subrecipients will engage in outreach to persons potentially impacted by the placement of new facilities. The Title VI equity analysis will compare the equity impacts of various alternatives, and the analysis will occur before the selection of preferred sites.

If ODOT determines that any project location will possibly result in a disparate impact on the basis of race, color, or national origin, the project will only be located in that particular location if legitimate justification can be assessed for such location; and where there is no alternative location that would have a less disparate impact on the basis of race, color, and national origin. ODOT will also demonstrate through conclusive analysis and consideration that the analysis of the alternative would have less of a disparate impact on the basis of race, color, or national origin, and will ensure implementation of the least discriminatory alternative.

Additional Information Available Upon Request

FTA may request, at its discretion, information other than that required by the Circular in order for FTA to investigate complaints of discrimination or to resolve concerns about possible noncompliance with DOT’s Title VI regulations.

ODOT shall comply with any and all requests from the FTA for any additional information required to resolve concerns about possible noncompliance with the DOT’s Title VI regulations.

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