Federal Contracting Requirements March 28, 2012 CLE. Jose Ramiro Salazar and Minming Wu Morri San Francisco Bay Area Rapid Transit District (BART) Office of the General Counsel Mary Richardson Port of Oakland, Office of the Port Attorney. Overview Title VI Local Hire Buy America
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Jose Ramiro Salazar and Minming Wu MorriSan Francisco Bay Area Rapid Transit District (BART)
Office of the General Counsel
Mary RichardsonPort of Oakland, Office of the Port Attorney
Intentional discrimination on the basis of race, color, or national origin. 42 USC § 2000d et seq; Cal. Gov. Code § 11135 et seq.
Programs or activities “with the purpose or effect of” discrimination. 49 CFR part 21.5 (DOT); GC § 11135; 22 Cal. Code Reg. 98000; FTA Circular
Minority and low-income populations. EO 12898; DOT Order on EJInclusive Public Participation
Providing English-only services may constitute national origin discrimination. EO 13166; DOT Policy Guidance; GC § 11135; 22 Cal. Code Reg. 98000; Dymally-Alatorre Bilingual Services Act
Title VI applies institution-wide, not solely to the recipients operations receiving Federal funding.
Inclusive Public Participation (DOT-Wide)
Public Participation Plan (FTA)
Title VI Program (FTA-Specific)
Eight (8) Minimum Requirements
Title VI Equity Analysis (FTA)
Siting of Facilities
Major Service & Fare Changes
Affirmative Actions to Ensure Against Disproportionate Impacts of Programs & Activities. (DOT-Wide, 49 CFR 21.5(b)(7))
LEP Requirements (DOT-Wide)
Federal & State
Recipient’s Title VI Plans, Reports, and Documents
49 USC Section 5323(j)
49 CFR Part 661
49 CFR Part 26