The Title VI coordinator is responsible for implementing, monitoring and ensuring the department's compliance with Title VI regulations. Responsibilities include:

• Consultation with and informing the director of nondiscrimination program activities.
• Disposition of Title VI complaints received by the department, with assistance from program area officials.
• Collection of statistical data (race, color, sex and national origin) of participants in, and beneficiaries of state highway programs (i.e., persons relocated as a result of property acquisition, impacted citizens and affected communities).
• Review of environmental impact statements for Title VI and environmental justice compliance.
• Conducting Title VI reviews of cities, counties, consultant contractors, suppliers, universities, colleges, planning agencies and other recipients of federal-aid highway funds.
• Review of state program directives in coordination with Title VI liaisons for special emphasis program areas; and, where applicable, inclusion of Title VI language and related requirements.
• Conducting training programs on Title VI and related statutes for state program officers, civil rights officials and federal-aid subrecipients.
• Preparation of the annual Title VI report presenting accomplishments of the past year and goals for the upcoming year.
• Development of Title VI information for dissemination to the public, where languages other than English are required.
• Conducting post-grant approval reviews of state programs and applicants for compliance with Title VI requirements (i.e., highway location, design and relocation; and persons seeking contracts with the state).
• Identification, investigation and elimination of discrimination when found to exist.
• Establishment of procedures for promptly resolving deficiency status and development of a written remedial action plan, as necessary, within a period not to exceed 90 days.
• Provision of technical assistance to subrecipients in the development of their Title VI plan and assurances.

The Title VI specialist is responsible for coordinating and providing technical assistance for all Title VI and Title II programs, and preparing required reports. Duties include:

• Coordination of Title VI Program development and implementation with affected program areas.
• Provision of technical assistance and advice on Title VI matters to Title VI liaisons and program area officials.
• Conducting internal Title VI reviews of the department’s offices’ program activities, when necessary, to cover aspects not covered through the routine monitoring.
• Participation, with program area staff, in reviews of section program activities that include Title IV issues.
• Conducting Title VI reviews of consultants, universities, metropolitan planning organization, regional planning organizations and other subrecipients to ensure Title VI compliance.
• Review of Iowa DOT program manuals, contracts and policy documents to determine whether Title VI is appropriately covered.
• Promptly investigating and resolving Title VI complaints of discrimination. Investigations shall be completed and reports of findings submitted to FHWA within 60 days from the date the complaint was received.
• Working with program areas to correct identified Title VI problems, including discriminatory practices or policies.
• Conducting Title VI training for Title VI liaisons, Iowa DOT staff and federal-aid subrecipients.
• Assisting in the preparation of annual reports of Title VI activities and accomplishments.
• Assisting in updating the Title VI plan as necessary to reflect organizational, policy or implementation changes.

Each office within the Iowa DOT that administers a federal-aid program has certain Title VI responsibilities and shall have a designated Title VI liaison or committee. The liaison or committee shall be responsible for ensuring compliance with Title VI, also program monitoring, reporting and education in relationship to their respective programs. All liaisons are responsible for:

• Identifying applications of Title VI nondiscrimination laws and regulations in their program areas; and incorporating these requirements into program area policies, procedures, directives and manuals.
• Leading the development and implementation of the Title VI Program in their program area.
• Collecting and reviewing Title VI data from federal-aid subrecipients.
• Conducting compliance reviews of subrecipients.
• Collecting, maintaining and analyzing data related to Title VI nondiscrimination efforts.
• Preparing documentation for inclusion in the Iowa DOT’s Title VI annual report; and preparing other reports and summaries, as needed.
• Supporting and cooperating with the Title VI coordinator in developing and implementing the department's Title VI Program.
• Assisting in Title VI compliance reviews and complaint investigations.

Exhibit 1 - Title VI Committee description

The Office of Construction works with the Iowa DOT’s district offices and construction residencies to administer highway construction contracts administered by the department. This office inspects and accepts the work; authorizes payments and change orders; and interacts and responds to the traveling public and property owners throughout the construction phase. Consultants are also used to provide these same services.

Assurance

• Review the contract administration responsibilities of consultants for compliance.
• Provide opportunities for female and minority consultants.

The Office of Contracts is responsible for conducting contract bid lettings for the Iowa DOT’s highway construction projects, as well as federally assisted highway projects for local governmental jurisdictions. The office monitors contractor compliance with equal employment opportunity/affirmative action (EEO/AA) and administers the Disadvantaged Business Enterprise (DBE) Program.

Assurance

• Develop and implement the DBE Program in compliance with federal regulations.
• Include required contract provisions (FHWA-1273) related to letting and awarding of contract documents. Ensure contractors adhere to those provisions.
• Investigate complaints against a contractor's compliance with nondiscrimination contract requirements.
• Ensure bidding and contract award procedures are consistent with nondiscrimination and equal opportunity requirements.
• Ensure DBE policy statements and appendixes (A, B and C) are included in all contracts.
• Ensure contractor compliance with on-the-job training (OJT) requirements.
• Conduct EEO and Title VI pre- and post-reviews.

Technical design work and the preparation of plans used for the construction of highway improvements is the responsibility of the Ooffices of Bridges and Structures, and Design and Bridges and Structures. Both of these offices also coordinate work in their areas that is done by outside consultants.

Assurance

• Ensure that environmental justice considerations are addressed during route and project selection.
• Ensure full and fair participation of minority, low income, elderly and disabled people in public involvement activities for project development activities.
• Demonstrate a consistent application of design standards to eliminate, minimize or mitigate adverse impacts among affected groups; and to provide equitable levels of service to those groups.
• Provide opportunities for DBE firms on consultant contracts.
• Ensure compliance with the Americans with Disabilities Act (ADA).

Personnel with the Iowa DOT’s district offices are a critical component in supporting the highway transportation system throughout Iowa. They are involved with future transportation project selection and project programming.

District personnel  take a lead role in project development, starting with an initial project concept, continuing through design and construction phases, and finally with ongoing maintenance following completion of the project. As facilitators of highway development and maintenance, district personnel make every effort to coordinate with local agencies, the public and private sector.

Assurance

• Ensure, through coordination with other Iowa DOT offices, that all people have an opportunity to participate fairly in the project development process. District personnel, based on their knowledge and familiarity with the local communities, shall take steps to ensure that low-income, elderly and minority groups impacted by projects are identified and that disproportionate adverse impacts to their health or environment are avoided, minimized or mitigated.
• Utilize the local governmental agency, MPO or regional planning authority (RPA) review tool to monitor and review these agencies for compliance with Title VI in respect to their transportation systems and programs (Attachment F and Attachment G).
• Document instances where Title VI issues were identified and discrimination was prevented or corrective actions taken.
• Assist in compliance with limited-English proficiency requirements to improve access and understanding of all construction projects. ( On August 11, 2000, the President signed Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency" HTML or  PDF)
• Provide notice of public consultation forums in minority newspapers and newsletters, when applicable; and in languages other than English, when needed.
• Administer transportation-related construction contracts on behalf of the State of Iowa.
• Work with other offices to ensure that all aspects of a project's location selection process comply with Title VI nondiscrimination requirements.
• Ensure that facilities are designed in accordance with current ADA accessibility requirements.
• Provide opportunities for female and minority consultants.
• Make efforts to balance programmed projects so all affected groups have an opportunity to benefit from the transportation system without disparate impacts.

The Office of Local Systems serves as a liaison for the department to local governmental agencies. The office provides guidance and assistance to local agencies in all phases of the highway project development process. This office also coordinates and provides support for developing project agreements with local jurisdictions.

Assurance

• Support other department staff with implementation of Title VI requirements with respect to local governmental jurisdictions.
• Ensure that nondiscrimination requirements are properly addressed in policies, procedures, reference materials and agreements produced for local governmental jurisdictions.

The Office of Location and Environment secures and reports environmental, cultural, historical and related information necessary for decision-makers to approve the location of projects constructed by the Iowa DOT. The office works with district offices, project designers, consultants and other outside agencies. This office is responsible for preparing environmental documents for potential federal-aid projects and obtaining 404 permits for all projects that have wetland impacts.

This office is also responsible for location and prelocation studies on large projects, as well as coordinating and managing public involvement activities during the development phase. Staff members work with the State of Iowa’s Native American liaison, Department of Natural Resources, State Historical Preservation Office, and other state and federal agencies in carrying out their duties.  

Assurance

• Work, in collaboration with other offices, during the selection of project alternatives to identify impacts to low-income and minority populations; address disproportionately high impacts in the final project design; and record these efforts in the environmental document.
• Ensure that environmental justice considerations are addressed during highway route and project selection.
• Ensure full and fair participation of minority, low-income, elderly, disabled, hearing impaired and limited-English proficient individuals in public involvement activities during project development.
• Provide opportunities for minority and female consultants, and address DBE goals on consultant contracts.

The Office of Maintenance, working with the field maintenance offices, is responsible for maintenance activities along Primary Highway System and interstate roadways throughout the state. This includes snow removal, pavement and bridge maintenance, and vegetation control. This office also administers the Adopt-A-Highway litter removal program.

Assurance

• Provide appropriate level of service based on established policy and procedure regardless of the nature of the population being served by any particular roadway.
• Ensure that all people have an opportunity to participate in the Adopt-A-Highway program.
• Consistently administer the utility and access policies independent of race, color or national origin of the applicant.

The Office of Maintenance, working with the field maintenance offices, is responsible for maintenance activities along Primary Highway System and interstate roadways throughout the state. This includes snow removal, pavement and bridge maintenance, and vegetation control. This office also administers the Adopt-A-Highway litter removal program.

Assurance

• Ensure consistent administration of testing and specifications, regardless of race, color, national origin or gender. Do not discriminate in the selection of material suppliers and sources.
• Encourage opportunities for females and minorities in research activities by external sources (consultants or universities).

The Motor Vehicle Division provides services, administers programs and enforces regulations pertaining to the operation of motor vehicles in the State of Iowa. It is comprised of four offices:

1. The Office of Driver Services conducts testing and issues licenses for all drivers, maintains driver and accident data, and conducts driver safety training. This office also suspends, revokes and reinstates driving privileges, as provided by law.
2. The Office of Motor Carrier Services administers fuel tax and registration programs for commercial motor carriers based in Iowa. The office also issues operational permits and designates routes for over-dimensional loads on the interstate and Primary Highway System.
3. The Office of Motor Vehicle Enforcement conducts commercial motor vehicle enforcement and investigative activities. This includes commercial motor vehicle and driver inspections; industry educational outreach; and enforcement of size, weight, travel authority, fuel and registration laws. The office investigates driver license and title fraud, and odometer tampering.
4. The Office of Vehicle Services oversees licensing and registration of motor vehicles in Iowa, including the registration of noninterstate and governmental vehicles by the county treasurers. The office also regulates motor vehicle dealers and recyclers; and issues registrations for vehicles with special or personalized plates.

Assurance

• Ensure  that the motor vehicle licensing and permitting processes are available to all persons, regardless of race, color, national origin or gender. Motor vehicle licensing and permit station locations and hours shall be provided on an equitable basis for the affected persons. Efforts will be made to accommodate limited-English proficient applicants, as needed.
• Enforcement and investigative functions shall be performed equitably to all persons.

The Office of Support Services’ purchasing section secures all equipment, supplies and materials the department uses in its operations.

Assurance

• Ensure that minority and female contractors and suppliers have opportunities to work with the department, and processes and procedures are implemented without discrimination.
• Ensure applicable nondiscrimination language and appendixes are included in contracts and agreements.

The Research and Technology Bureau facilitates coordination and management of research activities for the department. The bureau helps identify research needs, and develop and implement research and technology transfer programs. Work is performed by and coordinated with many other agencies.

Assurance

• Address DBE goals on consultant contracts.
• Encourage minority and female student participation on projects performed at universities.
• Include Title VI language in all research contracts.
• Consider utilization of minority institutes of higher education, and historically black colleges and universities.
• Conduct federal-aid subrecipient reviews of universities most frequently involved in research projects with the Iowa DOT.
• Establish goals for employment of minority and female students on university research projects.
• Include language in contracts requiring universities to demonstrate good faith efforts to employ minority and female faculty and students on Iowa DOT research projects.
• Monitor contract compliance with respect to Title VI requirements.

The Office of Right of Way is responsible for securing property required for highway construction. This includes identification of impacted properties, appraisal, acquisition and relocation assistance. The office also manages and disposes of excess property. This work may be performed by department staff or consultants. The office also reviews the right-of-way processes of local governmental jurisdictions.

Assurance

• Make every reasonable effort to ensure clear communication when engaging in transactions with limited-English proficient, and visually or hearing impaired persons. This includes the use of interpreters, when necessary.
• Identify, through cooperation with other Iowa DOT offices, low-income, elderly and minority populations; and take steps to appropriately address disproportionately high adverse affects to their health and environment.
• Ensure equitable treatment of all affected property owners, egardless of race, color, national origin or gender. This includes, among other impacts, appraisal values, relocation assistance and opportunities for purchase of excess property.
• Provide opportunities for minority and female consultants.
• Monitor and review the right-of-way activities of cities and counties to verify compliance with Title VI in their right-of-way processes.
• Ensure applicable nondiscrimination language and appendixes are included in contracts and agreements.

In addition to the program offices described above, there are a number of administrative areas that have Title VI implications. These include agency staff composition by race and gender; policies, procedures and directives; contracts, agreements, other legal instruments and proposed legislation; Title VI training; dissemination of information to the public; and public involvement programs.

Assurance

• Make continued progress on agency-wide affirmative action goals and encourage diversity with respect to protected classes in each of the pertinent program areas.
• Review policies, procedures, department directives and proposed legislation for Title VI issues.
• Contracts, agreements and other legal instruments shall be reviewed for appropriate Title VI language.
• Conduct periodic Title VI training for district engineers, division directors and Title VI committee members.
• Publications and other information disseminated to the public should include Title VI policy reference.
• Public involvement activities should take into account Title VI requirements.

The Office of Aviation advocates for and delivers services that promote and enhance Iowa’s air transportation system. Included in these activities is the administration of state-funded aviation programs, and ranking and submitting preapplications for federal improvement funds for general aviation airports in Iowa. The office is also the direct recipient of federal funds for statewide planning projects and installation of automated weather observing system units at local airports. The primary responsibility of the Office of Aviation as it relates to Title VI will be to ensure compliance in statewide contracts administered by the office and in contracts administered for locally owned airports.

Assurance

• Determine DBE goals and monitor accomplishments on contracts involving Federal Aviation Administration funding.
• Review and update publications to ensure clear communications with limited-English proficient persons.
• Assure that environmental justice and Title VI impacts are addressed in airport improvement projects. .

The Office of Program Management, in working with other department offices, districts, and various state and local agencies, prepares the Five-Year Transportation Improvement Program and Statewide Transportation Improvement Program (STIP). The office manages federal and state program funds.

The distribution of funds is critical to ensuring an opportunity for all to receive benefits of federal transportation dollars. That is especially evident in project selection and programming.

Assurance

• Take positive steps to encourage full and fair participation by all affected groups in development of the Five-Year Transportation Improvement Program and STIP.
• Ensure that the project selection and programming process results in a program that provides opportunities for minority, low-income, disabled and elderly populations to receive benefits and avoid disparate impacts from individual projects.
• Monitor and review the programming activities of subrecipients to verify that Title VI environmental justice is being properly addressed.

The Office of Systems Planning leads statewide planning for the department and administers the project selection of special grant programs, such as Iowa's Clean Air Attainment Program, Revitalize Iowa's Sound Economy, Transportation Enhancement, Safe Routes to School, Iowa’s Byways Program, and state and federal recreational trails. Office personnel prepare both long- and short-range system plans through cooperation with other Iowa DOT’s offices and districts, various state and local agencies, MPOs and RPAs. These plans provide the framework for the Five-Year Transportation Improvement Program and STIP.

Title VI must be considered throughout the planning process to ensure adequate public involvement, and that potential impacts to the human environment are identified and addressed.
Assurance

• Ensure full and fair participation in the planning process from minority, elderly, disabled and low-income residents.
• Ensure that the project selection process functions so that minority, low income, disabled and elderly populations are not subject to disparate impacts from the individual projects. Avoid, minimize or mitigate disproportionately high adverse impacts.
• Consider both positive and negative effects of various transportation system alternatives on impacted groups.
• Review grant agreements to ensure required nondiscrimination language is included.
• Review grant selection criteria for compliance with Title VI requirements.

Transit services in Iowa are provided by 35 urban and regional public transit systems. The Office of Public Transit administers federal and state transit funding programs and provides technical assistance to these public transit systems.

Because the Iowa DOT does not directly operate any of these transit systems, Title VI responsibilities will be focused on monitoring the operation of urban or regional transit agencies. It should be noted that urban transit systems serving areas with populations greater than 50,000 work directly with, and are monitored by, the Federal Transit Administration (FTA), although the Office of Public Transit does provide guidance.

Assurance

• Verify, through periodic compliance reviews of regional and urban transit agencies serving populations of less than 50,000, that no person is denied access and that transit systems comply with Title VI regulations.
• Ensure that the public is made aware of their rights and of the transit systems' responsibilities under Title VI.
• Verify that information, such as fare and route schedules, is available in formats to communicate with limited-English proficient individuals.  
• Include limited-English proficiency analysis requirement in the Passenger Transportation Plan.
• Ensure that contracting opportunities are available for minorities and females.
• Determine, with transit agency input, DBE goals and monitor accomplishments on contracts involving FTA funding.

Complete program administration