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FFY 2020

WISCONSIN DEPARTMENT OF TRANSPORTATION

TITLE VI/NONDISCRIMINATION

GOALS AND ACCOMPLISHMENTS REPORT

Office of Business Opportunity & Equity Compliance November 1, 2020

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TABLE OF CONTENTS

I. WisDOT Statement of Nondiscrimination……………………………………………………………………….3

II. Title VI Office Staffing and Organization…………………………………………………………………………4

III. Title VI Managing Committee…………………………………………………………………………………………5

IV. Program Area Reviews…………………….…………………………………………………………………………….7

V. Subrecipient Reviews……………………………………………………………………………………………………10

VI. Training…………………………………………………………………………………………………………………………13

VII. Complaints……………………………………………………………………………………………………………………14

VIII. Native American Initiatives…………………………………………………………………………………………..15

IX. Corrective Action Plans…………………………………………………………………………………………………16

X. Appendices…………………………………………………………………………………………………………………..17

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I. WISDOT STATEMENT OF NONDISCRIMINATION

A. WisDOT Title VI Commitment

The Wisconsin Department of Transportation (WisDOT) is committed to providing compliance with Title

VI of the Civil Rights Act of 1964 (49 CFR 21) so that, no person in the United States shall, on the grounds

of race, color or national origin be excluded from participation in, be denied the benefits of, or be

otherwise subjected to discrimination under any program or activity for which WisDOT receives federal

financial assistance from the U.S. Department of Transportation, including the Federal Highway

Administration.

B. WisDOT Title VI Policy

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and national

origin in all federally-assisted programs. The Federal-aid Highway Act of 1973 (23 USC 324) added sex as

a protected status in all Federal Highway Administration activities. The scope of Title VI was clarified by

the Civil Rights Restoration Act of 1987 (PL 100-259), effective March 22, 1988, which added Section

606, expanding the definition of the terms "programs or activities" to include all of the operations of an

educational institution, government entity, or private employer that receives federal funds if any one

operation receives federal funds.

The Wisconsin Department of Transportation (WisDOT) is a state governmental entity. It is the policy of

WisDOT to ensure compliance with Title VI of the Civil Rights Act of 1964 and all related statutes or

regulations in all programs and activities. WisDOT will take all steps to ensure that no person or groups

of persons shall, on the grounds of race, color or national origin be excluded from participation in, be

denied the benefits of, or be otherwise subjected to discrimination under any program, service, or

activity administered by WisDOT, its subrecipients, and contractors.

All administrators, bureau directors, section chiefs, supervisors, and other WisDOT employees are

hereby delegated the responsibility to implement the WisDOT Title VI Policy and Title VI Implementation

Plan in their work areas, to include the responsibility to develop and implement procedures and

guidelines which would adequately help execute and monitor their programs.

WisDOT recognizes the need for continuous Title VI Training for WisDOT personnel in order to promote

and achieve successful implementation of the WisDOT Title VI Policy and Title VI Implementation Plan.

The WisDOT Title VI Coordinators are granted the authority to monitor, promote, and direct the

implementation of the WisDOT Title VI Program, Policy and Implementation Plan.

Any individual who believes that he or she has been discriminated against, in violation of Title VI or

related statutes, under any WisDOT program or activity should contact the Senior Title VI/ADA

Coordinator at (608) 266-8129 or http://wisconsindot.gov/Pages/doing-bus/civil-rights/titlevi-

ada/default.aspx.

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II. TITLE VI OFFICE STAFFING AND ORGANIZATION

A. OBOEC Director

Lea Collins-Worachek is the Director of the Office of Business Opportunity and Equity Compliance

(OBOEC) and oversees the Title VI Office. The OBOEC director is also the chair of the Title VI Managing

Committee.

B. Senior Title VI/ADA Coordinator

Taqwanya Smith is the Senior Title VI/ADA Coordinator and is responsible for ensuring that WisDOT is

effectively monitoring internal program areas, processing complaints, conducting training, and staffing

the ADA Working Group.

C. Title VI Subrecipient Coordinator

The Title VI Subrecipient Coordinator position is vacant. The Title VI Subrecipient Coordinator is

responsible for monitoring subrecipients, staffing the Title VI Managing Committee, and implementing

the language access plan.

D. Title VI Staff General Duties

Title VI staff meet regularly with the director of the OBOEC to administer the Title VI Program. Issues

covered in these meetings are the Title VI Implementation Plan, Title VI Goals and Accomplishments

Report, Title VI Online Training Module, complaint processing, FHWA Subrecipient Title VI Assurances

and Implementation Plan Agreement, and staffing the Title VI Managing Committee. The Director of

OBOEC shares these issues with the DTSD Deputy Administrator for Bureaus and brings them to the

WisDOT Board of Directors, as necessary.

Annually, the Title VI Office is responsible for developing and submitting the Title VI Implementation

Plan and Assurances, and Title VI Goals and Accomplishments Report to the FHWA Wisconsin-Division

Office.

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III. TITLE VI MANAGING COMMITTEE

A. Purpose

The purpose of the Title VI Managing Committee is to provide an interdisciplinary approach to fulfilling

Title VI/Nondiscrimination requirements for the overall agency. The Managing Committee is currently

made up of the following members:

B. Membership

Voting Members

Lea Collins-Worachek, Chair Office of Business Opportunity & Equity Compliance

Carolyn Amegashie Division of Transportation System Development

Joel Batha Federal Highway Administration

Dan Graff Office of General Counsel

Major Adrian Logan Division of State Patrol

Becky Soderholm Division of Transportation Investment Management

Marcia Traska Division of Motor Vehicles

Charles Wade Division of Transportation Investment Management

Vacant Division of Budget and Strategic Initiatives

Vacant Division of Business Management

Committee Staff

Taqwanya Smith Senior Title VI/ADA Coordinator

Vacant Title VI Subrecipient Coordinator

C. FFY 2020 Accomplishments

• Developed a chart listing Title VI responsibilities for each division except the Division of

Business Management and the Division of Budget and Strategic Initiatives which currently

do not have representatives on the committee.

• Distributed the FHWA handout “What types of discrimination are prohibited by Title VI?”

• Gave an overview of FHWA handout “Title VI - Sample Data Sources Assessment.”

• Distributed the FHWA handout “State Title VI Implementation Plans: A collection of

commendable procedures and practices.”

• Distributed the FHWA Federal-aid Essentials for Local Public Agencies online training.

https://www.fhwa.dot.gov/federal-aidessentials/catmod.cfm?id=71

• Distributed a handout showing “U.S. DOT Civil Rights Agencies” included in the U.S. DOT

External Civil Rights Program – FAA, FHWA, FMCSA, FRA, FTA, NHTSA, Maritime

Administration, Pipeline and Hazardous Materials Safety Administration, and St. Lawrence

Seaway Development Corporation.

• Distributed a handout “The WisDOT Title VI Implementation Strategy” showing a draft

committee structure.

• One-pagers from the Division of Motor Vehicles on the automated knowledge testing

system and the Transit Title VI Program (see attachments).

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D. FFY 2021 Goals

• Add representatives from the Division of Business Management and the Division of Budget

and Strategic Initiatives to the committee.

• Complete the chart listing Title VI responsibilities for each division with the two remaining

divisions.

• Restructure the committee into two committees: 1) Managing Committee – representatives

from each division and 2) Data Collection Committee - representatives from FHWA program

areas to assist in (quarterly) data collection and reporting for the Goals & Accomplishments

Report. The Data Collection Committee would develop procedures for collection of

statistical data and accomplishments. FHWA requirements are listed in 49 CFR 21 –

Appendix C subparagraph (a)(2) and 23 CFR 200 – 200.9(b). The two committees will clearly

delineate FHWA reporting and U.S. DOT Title VI requirements for the overall agency.

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IV. PROGRAM AREA REVIEWS

This section describes FFY 2020 accomplishments and FFY 2021 goals related to internal monitoring

including the data collection and analysis component of WisDOT’s Title VI/Nondiscrimination Program.

A. Federal Program Area Reviews conducted

Program Area WisDOT Office

Construction DTSD Regions - Project Development Section

Contract Administration Audit and Contract Administration Section

Design DTSD Regions - Project Development Section

Environment Environment Process & Documentation Section and Environmental Services Section

Local Programs Local Programs and Finance Section

Maintenance Freight Management and Roadside Facilities Section

Planning Planning Section

Research Performance, Policy, and Research Section

Right-of-Way Acquisition & Services Section and Appraisal/Relocation/Property Management Section

Safety Traffic Engineering and Safety Section

B. Federal Program Area Title VI Liaisons

Program Area Liaisons

Construction Project Development Section Supervisors and Chiefs

Contract Administration Randy Knoche

Design Project Development Section Supervisors and Chiefs

Environment Jay Waldschmidt

Local Programs Merrill Mechler-Hickson

Maintenance Dan Mulder

Planning Jennifer Murray

Research Jacquelyn Irving

Right-of-Way Greg Gasper and Norman Pawelcyzk

Safety Bill McNary

C. Data Collection/Analysis/Reporting

For FFY 2020, the Title VI Office conducted program area reviews through online surveys and desk

audits. The online surveys collected data in the following areas:

• Use of FHWA funds in contracting and funding locals/subrecipients

• Conducting public involvement meetings

• Title VI complaints received

• Provision of bilingual support or translation services

• Completion of Title VI Training

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Copies of public involvement meeting agendas and complaints were also requested and received for

analysis.

D. FFY 2020 Accomplishments

1. Use of FHWA Funds in contracting and funding locals/subrecipients

Ninety-four percent (94%) of respondents use FHWA funds in contracting. Thirty-five percent (35%) of

respondents use FHWA funds in funding locals/subrecipients.

The Audit and Contract Administration Section in the Bureau of Financial Management ensures that

Appendix A (Nondiscrimination Provisions) and Appendix E (Pertinent Nondiscrimination Authorities) of

U.S. DOT Standard Title VI/Nondiscrimination Assurances, Order No. 1050.2A, are programmed to

automatically build into the standard provisions for design engineering contracts and general provisions

for construction engineering contracts.

These “boilerplates” for design engineering contracts and construction engineering contracts reflect

language meeting all of the appropriate state and federal laws and regulations. The boilerplates are not

to be altered, and the newest version must always be used. Boilerplate language not pertaining for a

particular contract or additional necessary language are deleted/added through special provisions.

Boilerplates are incorporated by reference into the contract cover/signature pages. Boilerplates and

signature pages are located on the WisDOT website at https://wisconsindot.gov/Pages/doing-bus/eng-

consultants/cnslt-rsrces/contracts/con-docs.aspx . By signing and entering into a contract with WisDOT,

the prime contractor indicates its understanding of the contract requirements. The Audit and Contract

Administration Section reviews all contracts ensuring that the boilerplates are included in each contract.

2. Conducting public involvement meetings

Program Areas conducted a total of 53 public involvement meetings. The five regional offices (Project

Development Section) conducted 44 public involvement meetings. The Local Programs and Finance

Section in the Bureau of Transit, Local Roads, Railroads, and Harbors conducted 9 public involvement

meetings.

Sign-in sheets are used at public involvement meetings for recording names and addresses of attendees.

Meeting locations are tracked on sign-in sheets. All meetings are held in publicly accessible buildings

such as schools, churches, and local government offices (e.g. city hall). Regional offices do some type of

public involvement for all projects depending upon the scope of the project. See Chapter 6 “Public

Involvement” of the Facilities Development Manual (https://wisconsindot.gov/rdwy/fdm/fd-06-

00toc.pdf ). There is a Public Involvement Plan for every project detailing how to engage the public,

demographics of the population in the area, good faith efforts, and analysis tools such as the EJSCREEN.

Statistical data is tracked for all environmental documents including Programmatic Categorical

Exclusions, Categorical Exclusions, Environmental Reports, Environmental Assessments, and

Environmental Impact Statements. Factor Sheets and Guidance can be used for every environmental

document if needed (https://wisconsindot.gov/Pages/doing-bus/eng-consultants/cnslt-

rsrces/environment/formsandtools.aspx . Regional staff upload the data to a sharepoint site for the

Environmental Process and Documentation Section in the Bureau of Technical Services

(https://wigov.sharepoint.com/sites/dot-dtsd/bts/epd/edts/SitePages/Home.aspx ).

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3. Title VI Complaints

Program Areas did not receive any Title VI complaints in FFY 2020.

4. Provision of bilingual support or translation services

Program Areas provided 3 bilingual support or translation services in FFY 2020.

5. Completion of Title VI Training

Thirty-eight (38) employees completed Title VI or Nondiscrimination training in FFY2020.

E. FFY 2021 Goals

• Begin using the FHWA Title VI - Sample Data Sources Assessment for reviews.

• Ask Title VI liaisons to identify data collection personnel, data contact, and internal

system/resource for each data point in their program area of the assessment.

• Public involvement meeting notices include language offering translation services or translated

documents upon request.

• Public involvement meeting notices include language that accommodations such as sign

language interpreters and alternate formats are available upon request.

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V. SUBRECIPIENT REVIEWS

This section describes FFY 2020 accomplishments and FFY 2021 goals related to subrecipient

(Metropolitan Planning Organizations and Regional Planning Commissions) monitoring including the

data collection and analysis component of WisDOT’s Title VI/Nondiscrimination Program.

A. Subrecipient Reviews conducted and Title VI Liaisons

Subrecipient Title VI Liaisons

1. Bay-Lake RPC (Sheboygan MPO) Jeffrey Agee-Aguayo

2. Brown County Planning Commission (Green Bay MPO) Cole Runge

3. Capital Area RPC Steve Steinhoff

4. Chippewa-Eau Claire MPO Eric Anderson

5. East Central Wisconsin RPC (Appleton & Oshkosh MPOs) Melissa Kraemer Badtke

6. Fond du Lac MPO Melissa Kraemer Badtke

7. Janesville MPO Alexander Brown

8. La Crosse Area Planning Committee (La Crosse MPO) Peter Fletcher

9. Greater Madison MPO William Schaefer

10. Marathon County Metropolitan Planning Commission (Wausau MPO)

Dave Mack

11. Mississippi River RPC Bob Gollnik

12. North Central Wisconsin RPC Darryl Landeau

13. Northwest RPC Sheldon Johnson

14. Southeastern Wisconsin RPC Elizabeth Larsen

15. Southwestern Wisconsin RPC Troy Maggied

16. State Line Area Transportation Study (Beloit MPO) T.J. Nee

17. West Central Wisconsin RPC Eric Anderson

B. Data Collection/Analysis/Reporting

For FFY 2020, the Title VI Office conducted subrecipient reviews through online surveys and desk audits.

The online surveys collected data in the following areas:

• Title VI complaint policy and/or form and its posting

• Engaging minority and low-income populations concerning project initiatives

• Engaging limited English proficiency populations regarding projects in their communities

• Ensuring that programs, services, and activities are accessible to persons with disabilities

A signed copy of the FFY 2021 FHWA Subrecipient Title VI Assurances and Implementation Plan

Agreement by the Executive Director was also requested and received.

C. FFY 2020 Accomplishments

1. Do you have a complaint policy and/or form whereby anyone who feels he or she has been discriminated against based upon race, color, national origin, age, sex or disability may file? Where is it posted?

• 80% of respondents have a complaint policy/form and it is posted on their websites.

• 50% of respondents have the complaint policy/form posted on their websites and posted in their office, lobby, reception area or bulletin board.

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Respondents also have the complaint policy/form in the agency’s “Title VI and Non-

Discrimination Program/Limited English Proficiency Plan,” complaint policy/form in English,

Spanish, and Hmong, and the complaint policy/form posted on the agency’s website with links

to Spanish, Hmong, and Traditional Chinese translations.

2. When engaging minority and low-income populations concerning project initiatives, how do you notify them of meetings and other activities?

• 58% of respondents use contact/email lists.

• 42% of respondents use their agency website and community organizations.

• 33% of respondents use public/legal notices.

• 25% of respondents use Public Participation Plans, social media, and minority-focused news outlets

• 17% of respondents use public involvement meetings, representatives on advisory committees, and Facebook.

Respondents also use open “open house style” meetings, “bringing the meeting” to libraries and community events, focus groups, newsletters, local print and broadcast media, flyers on transit buses, flyers at transit stations, flyers at businesses – i.e. grocers, meetings in places convenient to EJ population groups, making translators available if requested, staff volunteer with community organizations, public transit agencies, telephone, and a Title VI Plan.

3. What methods do you use to engage limited English proficiency populations regarding projects that affect them or their communities?

• 42% of respondents use a Title VI/Limited English Proficiency or Language Access Plan.

• 17% of respondents have Title VI vital documents translated into Spanish.

• 17% of respondents use meeting notices include language translated into Spanish and

Hmong offering translation services or materials in an alternate format, if requested.

• 17% of respondents use their agency website, contact/email lists, and community

organizations.

• 17% of respondents have regions or areas that fall below the safe harbor threshold.

• One respondent has not had projects that would appear to impact LEP persons based on

demographic analysis.

Respondents also use surveys, focus groups, “bring meetings” to existing events and locations,

social media, public transit agencies, “I Speak” Language Identification Card, commission staff

that are fluent in Spanish, notices in multiple languages, Title VI vital documents translated into

Spanish, Hmong, and Traditional Chinese, meeting notices include language translated into

Spanish, Hmong, and Traditional Chinese offering translation services or materials in alternate

formats if requested at least 72 hours before the meeting, provide information on how to

participate in Spanish, provide information in Spanish and Hmong in print, video, and website

content for public participation purposes, survey outreach for specific initiatives is translated

into Spanish, access to Spanish-speaking if translation or interpreter services are needed, Public

Participation Plan, and Title VI Plan.

4. How do you ensure that your programs, services, and activities are accessible to persons with disabilities?

• 58% of respondents use accessible meeting locations.

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• 50% of respondents use accessible meeting locations along transit/paratransit routes, and/or bicycle and pedestrian facilities.

• 50% of respondents provide accommodations, such as sign language interpreters and alternate formats upon request.

• 25% of respondents allow participants to participate remotely.

Respondents also partner with organizations that serve people with disabilities and have websites that comply with ADA standards.

5. A signed copy of the FFY 2021 FHWA Subrecipient Title VI Assurances and Implementation

Plan Agreement by the Executive Director was also requested and received.

Eighty-seven (87%) of respondents signed and returned the FFY 2021 FHWA Subrecipient Title VI

Assurances and Implementation Plan Agreement.

D. FFY 2021 Goals

• 100% of Metropolitan Planning Organizations and Regional Planning Commissions participation

in the subrecipient review.

• 100% of Metropolitan Planning Organizations and Regional Planning Commissions sign and

return the FHWA Subrecipient Title VI Assurances and Implementation Plan Agreement.

• Public meeting notices include language offering translation services or translated documents

upon request.

• Public meetings are held in accessible meeting locations.

• Public meeting notices include language that accommodations such as sign language

interpreters and alternate formats are available upon request.

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VI. TRAINING

A. Title VI Staff

Title VI staff completed the following trainings in FFY 2020.

• EDC-5 VPI Virtual Peer Exchange on Iowa DOT’s PIMA Tool – July 21, 2020

• FHWA Title VI Civil Rights Connect Walkthrough – September 11, 2020

B. Title VI Liaisons

Title VI Managing Committee members received the following training to be completed in FFY 2020.

• FHWA Federal-aid Essentials for Local Public Agencies – July 13, 2020

C. Other Employees

WisDOT staff completed the following Title VI training in FFY 2020.

• “Title VI: Knowing your role” - 149 employees

▪ Staff - 146

▪ Supervisory staff - 3

This introductory online module explains the parameters of Title VI and the employee role in ensuring

nondiscrimination in WisDOT programs and activities. All WisDOT employees including staff,

supervisors, and managers complete the module as part of the New Employee Orientation Program.

A second module “Title VI and Nondiscrimination,” is in development. This module provides an in-depth

understanding of Title VI and related nondiscrimination laws, facts and figures, and case studies.

Expected publication is June 2021.

D. Subrecipients

Each year, subrecipient training needs will be assessed and delivered through various methods. Some

training needs will be self-reported by subrecipients through the Annual Title VI Subrecipient Survey and

additional needs will be assessed through WisDOT's subrecipient review procedures. Training may be

provided to subrecipients on an individual or group basis, depending on need. Subrecipients may also

be provided with the option to attend training offered through WisDOT. A list of possible training

delivery methods includes the following:

• Presentation by Title VI Office staff:

▪ At semi-annual MPO Directors’ meetings.

▪ At the annual fall WisDOT Planning Conference.

▪ Conferences or meetings held by other WisDOT program areas.

▪ Conferences or meetings held by MPOs or RPCs.

▪ Project meetings held by WisDOT at various project locations.

• Online Training Modules for WisDOT and subrecipient personnel.

• Resource referrals that bring Title VI, ADA, LEP, and EJ trainings to the attention of

subrecipients.

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Vll. TITLE VI COMPLAINTS

A. Complaints

The Title VI Office received 8 complaints in FFY 2020. The bases for complaints are shown below. Some

complaints contained more than one basis.

• Disability – 4

• Race - 3

• National Origin – 3

• Color – 2

• Sex - 2

B. Technical Assistance

The Title VI Office received 19 requests for technical assistance in FFY 2020. The bases for requests are

shown below.

• Disability – 15

• Title VI – 2

• Race – 1

• Age - 1

C. Status of complaints

The status of the complaints received in FFY 2020 is listed below. Two of the open complaints are being

investigated by the National Highway Traffic Safety Administration Office of Civil Rights. Three of the

open complaints are ADA complaints and are being investigated by WisDOT.

• Closed – 3

• Open – 5

The complaints log is available any time for inspection.

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VIII. NATIVE AMERICAN INITIATIVES

A. Overview

The Office of Tribal Affairs works with Wisconsin’s eleven federally recognized tribes to provide training,

funding opportunities, and resources on transportation and transportation-related issues. The Office of

Tribal Affairs includes two statewide tribal liaisons and five regional tribal liaisons that serve as primary

points of contact for program, policy, and project-related issues and needs to support enhanced

communication and coordination with Tribal Government partners.

B. Annual Tribal Transportation Conference

The annual WisDOT Tribal Transportation Conference was held in Green Bay, Wisconsin on October 29

and 30, 2019. This event brought together over 200 people with a focus on transportation safety,

cultural and environmental resources, business and economic development opportunities, and

construction project updates.

C. National Summer Transportation Institute

For the last 19 years, WisDOT has worked in partnership with the College of the Menominee Nation and

the Lac Courte Oreilles Ojibwa Community College to offer the National Summer Transportation

Institute (NSTI). NSTI is a summer youth enrichment program designed to introduce middle and high

school students, from disadvantaged or at-risk populations, to careers in the transportation industry

with an emphasis on science, technology, engineering and math. FHWA places special emphasis on

offering this program in partnership with Historically Black Colleges and Universities, Hispanic-Serving

Institutions and Tribal Colleges. Wisconsin is only one of two states in the country that offer this

program with tribal colleges within the state.

In 2019, WisDOT received $90,000 in grant funding from FHWA to provide the NSTI program to both

tribal colleges. Those funds were evenly distributed to both colleges at $45,000 each, with WisDOT

supplementing those funds with an additional $30,000 for a total of $75,000 per project. The

accomplishments of the 2019 programs include the delivery of classroom and hands-on activities,

presentations by transportation professionals, and field trips that focused on all modes of transportation

including land, air, and water; and the production of public service announcements conceptualized,

written, directed and edited by student participants, which focused on driver safety and awareness.

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IX. CORRECTIVE ACTION PLANS

A. Program Area Reviews

• Work with selected program areas in collecting and analyzing data to identify and address

any trends/patterns of discrimination in their respective bureaus.

• Explore training opportunities for WisDOT program areas to ensure compliance with Title VI,

specifically in collecting Title VI data and analyzing the data to identify and address any

trends/patterns of discrimination.

• Ensure operating or informational manuals include the required Title VI information and

procedures to implement these requirements.

B. Reviews Conducted

Action Step Timeline Participants Results

Review preceding FFY results

Q1 (Oct 1 – Dec 31) Title VI Office

Review preceding FFY reported data and analysis

Q1 (Oct 1 – Dec 31) Title VI Office

Prepare a plan for these reviews on an ongoing basis

Q2 (Jan 1 – Mar 31) Title VI Office

Provide feedback to improve program area Title VI efforts, reporting, and compliance

Q2 (Jan 1 – Mar 31) Title VI Office & Title VI Liaisons

C. Upcoming Reviews

Action Step Timeline Participants Results

Identify documents that should be reviewed for compliance

Q3 (Apr 1 – Jun 30) Title VI Office

Develop a plan, strategy and process for document reviews

Q3 (Apr 1 – Jun 30) Title VI Office

Conduct document reviews

Q3 (Apr 1 – Jun 30) Title VI Office & Title VI Liaisons

Schedule review with program area

Q4 (Jul 1 – Sep 30) Title VI Office & Title VI Liaisons

Conduct reviews

Q4 (Jul 1 – Sep 30) Title VI Office & Title VI Liaisons

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APPENDICES

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Appendix A: Title VI Managing Committee – WisDOT Transit Title VI Program

DTIM - Transit and Planning Bureaus

(FTA) Civil Rights Compliance Requirements (Date: 7/9/2020)

The WisDOT-Transit Section and Planning Sections adhere to Federal Transit Administration (FTA) civil rights compliance requirements as recipients of federal transit funds per FTA Circular 4702 (as amended) and FTA Circular 4710.1 (as amended) and 49 CFR Part 26, and additional related nondiscrimination authorities. This document outlines efforts taken by the Transit and Planning sections and the WisDOT Title VI Office to meet the FTA requirements. While the Planning Section also complies with Federal Highway Administration requirements, this document does not address FHWA-specific civil rights compliance. A detailed discussion of how the Transit and Planning Sections meets federal civil rights requirements is explained in the following documents and website materials:

✓ 3-Year Transit Title VI Report – Documents the Transit Section’s transit-focused Title VI program report submitted for approval by FTA every (3) three years. A copy is available upon request.

✓ State Management Plan (SMP) - Outlines the Transit Section’s policies and procedures for ensuring compliance of FTA’s Civil Rights requirements.

✓ Transit Title VI-ADA Webpage – Provides resource materials to subrecipients for completing Title VI-ADA plans.

✓ Transit DBE Webpage – Notifies the public of Transit’s (3) three-year DBE goal on its DBE and discusses its oversight and

✓ Compliance Site Review (CSR) Program Webpage – Provides subrecipients with information on the Transit Section’s comprehensive onsite review process, with Civil Rights as an emphasis area.

The table below shows which work area takes the lead on the required civil rights compliance elements.

A discussion of how the Transit and Planning section complies with these requirements are presented in

the Transit’s 3 Year Title VI Report, State Management Plan, and transit webpages.

Lead Work Area

Civil Rights Requirements Transit Section

Planning Section

Dept. Title VI Office

Post Notice of Nondiscrimination to the Public

X

Develop and utilize Complaint Form

X

X

Develop and implement Complaint Procedure

X

X

Maintain Complaint Log to address, resolve and close complaints and review for patterns of discrimination

X

Submit a 3-Year Title VI Report to FTA which addresses the compliance areas in this list.

X

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Lead Work Area

Civil Rights Requirements Transit Section

Planning Section

Dept. Title VI Office

Sign annual Certifications and Assurances to FTA

X

Require and collect Certifications and Assurances at the time of Subrecipient grant application and grant award

X

Implement Competitive Grant Selection Process

X

Provide oversight for Civil Rights compliance of approximately 140 transit Subrecipients, and MPO and RPC monitoring

X Oversight of MPO/RPCs

only

Review and approve Subrecipient and MPO and RPC Title VI-ADA Plans1

X X

Review and approve Subrecipient ADA Plans, as applicable.

X

Conduct on-site visits of 140 subrecipients on a (5) five-year schedule

through its Compliance Site Review (CSR) Program2

X

Ensure Subrecipients receiving transit funds for construction projects conduct an Environmental Justice analysis and meet NEPA requirements.

X

Provide Education and Outreach on Transit Grant Programs and Civil Rights Requirements to Subrecipients, MPOs, RPCs, and the public

X

Statewide Planning Process – Ensure WisDOT meets FTA and FHWA requirements in its Statewide Transportation Improvement Program (STIP)

and Transportation Improvement Programs (TIP)3.

X X

Planning Section takes

the lead

Submit a Disadvantage Business Enterprise (DBE)4 Program every 3 years to FTA, including a 3-year goal, setting contract specific goals, as applicable and submitting semi-annual reports to FTA.

X

X

For More Information Contact:

Becky Soderholm, Federal Compliance Manager WisDOT-DTIM- Bureau of Transit, Local Roads, Railroads and Harbors 608.266.1650 | becky.soderholm@dot.wi.gov

1 Transit Title VI and ADA - https://wisconsindot.gov/Pages/doing-bus/local-gov/astnce-pgms/transit/compliance/title6.aspx

2 Compliance Site Review (CSR) Program - https://wisconsindot.gov/Pages/doing-bus/local-gov/astnce-pgms/transit/compliance/csr.aspx

3 Statewide Transportation Improvement Program (STIP) - https://wisconsindot.gov/Pages/doing-bus/local-gov/astnce-

pgms/highway/stip.aspx

4 Disadvantaged Business Enterprises (DBE) - https://wisconsindot.gov/Pages/doing-bus/local-gov/astnce-pgms/transit/compliance/dbe.aspx

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Appendix B: Title VI Managing Committee – DMV Automated Knowledge Test System

WI DMV Automated Knowledge Test System Replacement Project Summary

Automated Knowledge Test System (AKTS) was implemented in DMV just over 20 years ago using touch

screen computers and an application to randomize tests. With the latest Request for Proposal (RFP) in

2019, and current project to be implemented fully on September 28, 2020, significant enhancements

have been added to the testing system to assist with accessibility.

Test question improvements • Test questions for the Class D, Sales Person and Driver Training School tests were evaluated.

Those questions where there was a high rate of failure were rewritten for clarification.

• Images for all test questions were updated and made relevant to the test question. If the test

question could be answered without an image, no image is to be displayed as to not distract the

applicant.

• Serbo-Croat was no longer a recognized language. All tests available in that language were

translated to Croatian and Serbian.

• All CDL tests (excluding the Wisconsin School Bus test) have been updated to the current 2017

version of tests from the American Association for Motor Vehicle Administrators (AAMVA). In

addition, questions were translated for currently supported languages (English, Croatian, Polish,

Russian, Serbian, Spanish)

• The Spanish Motorcycle test was available in text only. Audio had been added.

• Several Spanish tests had an improper use of a verb. All questions with that verb were updated.

• When evaluating the use of translators and number of tests translated, Burmese was identified

as having a significantly higher number of translated tests than any other language. As a result,

Burmese has been added for Class D, signs and all CDL tests (excluding Hazardous Materials and

the School Bus tests).

• American Sign Language (ASL) is also being added for Class D, signs and all CDL tests (excluding

Hazardous Materials and the School Bus tests).

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Appendix C: Public Involvement Meeting Handout Sample Excerpts

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