**TITLE VI COMPLIANCE REVIEW**

**OF THE**

**LOUISIANA DEPARTMENT OF TRANSPORTATION AND DEVELOPMENT**

**(LADOTD)**

**Baton Rouge, Louisiana**

**Final Report**

**June 2004**

**Prepared For**

**U.S. DEPARTMENT OF TRANSPORATION**

**FEDERAL TRANSIT ADMINISTRATION**

**OFFICE OF CIVIL RIGHTS**

**Prepared By**

**MILLIGAN & CO., LLC**

**&**

**THE DMP GROUP, INC.**

TABLE OF CONTENTS

I. GENERAL INFORMATION [1](#__RefHeading___Toc23744325)

II\. JURISDICTION AND AUTHORITIES [2](#__RefHeading___Toc23744326)

III\. PURPOSE AND OBJECTIVES [3](#__RefHeading___Toc23744327)

IV\. BACKGROUND INFORMATION [6](#__RefHeading___Toc23744328)

V. SCOPE AND METHODOLOGY [8](#__RefHeading___Toc23744329)

VI\. FINDINGS AND RECOMMENDATIONS [14](#__RefHeading___Toc23744330)

A. Findings of the General Reporting Requirements
[14](#__RefHeading___Toc23744331)

B. Findings of the Program-Specific Requirements for States
Administering Elderly and Persons with Disabilities Program (Section
5310) [20](#__RefHeading___Toc23744332)

C. Findings of the Program-Specific Requirements for States
Administering Rural Funding Programs (Section 5311)
[24](#__RefHeading___Toc23744333)

VII\. SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
[28](#__RefHeading___Toc23744334)

VIII\. ATTENDEES [31](#__RefHeading___Toc23744335)

##  

I.  []{#__RefHeading___Toc23744325 .anchor}GENERAL INFORMATION

Grant Recipient: Louisiana Department of Transportation and Development
(LADOTD)

City/State: Baton Rouge, Louisiana

Grantee No: 1562

Executive Official: Ms. Carol Cranshaw

Administrator-Public Transportation

Louisiana Department of Transportation and Development

P.O. Box 94245

Baton Rouge, Louisiana 70804-9425

Report Prepared By: MILLIGAN & CO., LLC

105-107 N. 22^nd^ Street, 2^nd^ Floor,

Mulberry Atrium North

Philadelphia, PA 19103

THE DMP GROUP, INC.

2423 Killdeer Street

New Orleans, LA 70122

Site Visit Dates: May 15, 2002- May 17, 2002

Compliance Review

Team Members: John Potts, Lead Reviewer

Royal "Ed" Spurlark

> Joe Herzog

Jim Buckley

II. []{#__RefHeading___Toc23744326 .anchor}JURISDICTION AND AUTHORITIES

The Federal Transit Administration (FTA) Office of Civil Rights is
authorized by the Secretary of Transportation to conduct civil rights
compliance reviews. Reviews are undertaken to ensure compliance of
applicants, recipients, and subrecipients with Title VI of the Civil
Rights Act of 1964, as amended (42 U.S.C. 2000d); Section 22 of the
Master Agreement, Federal Transit Administration C.A. (3), October 1,
1996; and 49 U.S.C. 5332, "Non-Discrimination".

The Louisiana Department of Transportation and Development (LADOTD) is a
recipient of FTA funding assistance and is therefore subject to the
Title VI compliance conditions associated with the use of these funds
pursuant to FTA Circular 4704.1, "Title VI Program Guidelines for Grant
Recipients," dated July 26, 1988; Part II, Section 117(a) of the FTA
Agreement; and FTA Circular 4702.1, "Title VI Program Guidelines for
Federal Transit Administration Recipients," dated May 26, 1988. The
program guidelines of FTA Circular 4702.1 define the components that
must be addressed and incorporated in LADOTD's Title VI Program and were
the basis for the selection of compliance elements that were reviewed in
this document.

III. []{#__RefHeading___Toc23744327 .anchor}PURPOSE AND OBJECTIVES

**Purpose**

The Federal Transit Administration (FTA) Office of Civil Rights
periodically conducts discretionary reviews of grant recipients and
subrecipients to determine whether they are honoring their commitments,
as represented by certification, to comply with the requirements of 49
U.S.C. 5332. In keeping with its regulations and guidelines, FTA
determined that a Compliance Review of the Louisiana Department of
Transportation and Development (LADOTD) Title VI Program was necessary.
This review focused on LADOTD\'s role as a State administering transit
programs for the Elderly and Disabled funded by FTA under Section 5310
and for Rural and Small Urban Areas funded by FTA under Section 5311.

The Office of Civil Rights authorized Milligan & Co., LLC to conduct the
Title VI Compliance Review of LADOTD. The primary purpose of this
Compliance Review was to determine the extent to which LADOTD has met
its General Reporting and Program-Specific requirements, in accordance
with FTA Circular 4702.1, Program Guidelines for Federal Transit
Administration Recipients, as represented to FTA. The Compliance Review
had a further purpose to provide technical assistance and to make
recommendations regarding corrective actions, as deemed necessary and
appropriate.

FTA reviewed LADOTD\'s Title VI compliance activities during its State
Management and Triennial Review in 2000. LADOTD was found deficient with
the FTA requirements for Civil Rights. According to the State Management
and Triennial Review Report, LADOTD did not "obtain contracting
(purchasing) activity reports from Section 5311 subrecipients,
documenting the amount of Federal funds contracted and the amount
contracted to disadvantaged business enterprises. DOTD does not include
subrecipient activity with its reports to FTA." At the time of the State
Management and Triennial Review, LADOTD was given 90 days to develop and
implement procedures to obtain contracting activity reports from Section
5311 subrecipients and to submit contracting activity reports for itself
and its subrecipients to the FTA Regional Office.

#### Objectives

The objectives of FTA's Title VI requirements, as set forth in FTA
Circular 4702.1, "Title VI Program Guidelines for Federal Transit
Administration Recipients", are:

-   To ensure that FTA-assisted benefits and related services are made
    available and are equitably distributed without regard to race,
    color, or national origin;

```{=html}
<!-- -->
```
-   To ensure that the level and quality of FTA-assisted transit
    services are sufficient to provide equal access and mobility for any
    person without regard to race, color, or national origin;

```{=html}
<!-- -->
```
-   To ensure that opportunities to participate in the transit planning
    and decision-making process are provided to persons without regard
    to race, color, or national origin;

-   To ensure that decisions on the location of transit services and
    facilities are made without regard to race, color, or national
    origin; and

-   To ensure that corrective and remedial action is taken by all
    applicants and recipients of FTA assistance to prevent
    discriminatory treatment of any beneficiary based on race, color, or
    national origin.

The Compliance Review is to ascertain the extent to which LADOTD is
meeting the Title VI Program objectives.

IV. []{#__RefHeading___Toc23744328 .anchor}BACKGROUND INFORMATION

The Governor of Louisiana designated the Louisiana Department of
Transportation and Development (LADOTD) as the responsible agency for
administering FTA programs. The Public Transportation Section in the
Public Works and Intermodal Transportation Division administers the
Section 5310 and 5311 programs as well as Section 5313, planning, and
rail safety activities. Of the 64 parishes that constitute LADOTD's
service area, 41 parishes receive Section 5310 funding and 27 parishes
receive Section 5311 funding.

As shown on the following table, the minority population in Louisiana is
1.61 million of 4.47 million people, or 36 percent. Of the 64 parishes
(a parish is the same as a county), 25 (39 percent) have a minority
population that equals or exceeds this percentage.

In 2001, a total of 41 parishes received Section 5310 funds, including
sixteen parishes (39%), with a higher than average minority population.
A total of 27 parishes received Section 5311 funds, including nine
parishes (33%) with a higher than average minority population. Five
minority parishes received both Section 5310 and 5311 funding while four
minority parishes received neither type of funding*.* This analysis
shows that no significant disparity appears to exist in the distribution
of funds. However, as discussed later, LADOTD must increase its data
collection and analysis efforts, as set forth in FTA Circular 4702.1 to
ensure that minorities are not discriminated against in the distribution
and allocation of funds.

According to the 2002 Program of Projects, Section 5310 grant awards for
FY 2002 totaled \$1.61 million for 33 vehicles purchased for 23
parishes. Section 5311 grant awards for FY 2002 totaled \$8.78 million,
with federal share totaling \$5.18 million.

Racial Breakdown for the State of Louisiana

+---------------------------+-----------------+-----------------------+
| #### Race                 | #### Total      | **Percentage**        |
+---------------------------+-----------------+-----------------------+
| #### White                | #### 2,856,161  | #### 63.9             |
+---------------------------+-----------------+-----------------------+
| #### Black                | #### 1,451,944  | #### 32.5             |
+---------------------------+-----------------+-----------------------+
| #### American             | #### 25,477     | #### 0.6              |
| Indian and Alaska Native  |                 |                       |
+---------------------------+-----------------+-----------------------+
| #### Asian                | #### 54,758     | #### 1.2              |
+---------------------------+-----------------+-----------------------+
| #### Native Hawaiian a    | #### 1,240      | #### 0.0              |
| nd Other Pacific Islander |                 |                       |
+---------------------------+-----------------+-----------------------+
| ##                        | #### 107,738    | #### 2.4              |
| ## Hispanic (of any race) |                 |                       |
+---------------------------+-----------------+-----------------------+
| #### Other                | 31,131          | #### 0.7              |
+---------------------------+-----------------+-----------------------+
| #### Total Population     | #### 4,468,976  | ####                  |
+---------------------------+-----------------+-----------------------+
| #### Total Minorities     | **1,611,575**   | #### 36.1             |
+---------------------------+-----------------+-----------------------+
| #### Total, One Race      | 4,420,711       | #### 98.9             |
+---------------------------+-----------------+-----------------------+
| ####                      | 48,265          | #### 1.1              |
|  Total, Two or More Races |                 |                       |
+---------------------------+-----------------+-----------------------+

Source: U.S. Census Bureau, CENSUS 2000 DATA

[]{#__RefHeading___Toc23744329 .anchor}V. SCOPE AND METHODOLOGY

#### Scope

The Title VI Compliance Review of LADOTD's 5310 and 5311 transit
programs examined the following requirements as specified in FTA
Circular 4702.1:

1.  [General Reporting Requirements]{.underline} - all applicants,
    recipients and subrecipients shall maintain and submit the
    following:

```{=html}
<!-- -->
```
a.  A list of active Title VI lawsuits or complaints;

b.  A description of pending applications for financial assistance;

c.  A summary of recent civil rights compliance review activities;

d.  A signed FTA Civil Rights Assurance;

e.  A signed standard DOT Title VI Assurance; and

f.  A fixed-facility impact assessment analysis, if applicable, for
    construction projects.

```{=html}
<!-- -->
```
2.  [Program Specific Requirements]{.underline}

```{=html}
<!-- -->
```
a.  State Agencies Administering Transit Programs for the Elderly and
    Handicapped program funded under Section 5310 are required to comply
    with the following data collection and reporting requirements.

    i.  Grant Administration

    ii. Program Management Assurance

b.  State Agencies Administering Programs for Rural and Small Urban
    Areas program funded under Section 5311 are required to comply with
    the following data collection and reporting requirements.

i\. Title VI Program Management

> ii\. Title VI Reporting

3.  [Monitoring Procedures for Transit Providers]{.underline} -- all
    applicants, recipients and subrecipients that provide public transit
    service are required to develop and implement procedures to monitor
    their level and quality of transit service to determine compliance
    with Title VI.

4.  [Procedures for Filing Title VI Discrimination
    Complaints]{.underline} -- all applicants, recipients and
    subrecipients that provide public transit service are required to
    develop and implement procedures for filing Title VI discrimination
    complaints.

In addition, the Compliance Review had as an objective a review of the
progress of LADOTD in the completion of its State Management Plan to
properly address the Title VI deficiency described in the FY 2000 State
Management and Triennial Review.

#### Methodology

Prior to scheduling the Compliance Review, an interview was conducted
with the FTA Region VI Civil Rights Officer about specific Title VI
issues and concerns regarding LADOTD. Following the interview, a
detailed letter was sent to LADOTD advising it of the site visit and
indicating additional information that would be needed and issues that
would be discussed.

In the letter, LADOTD was requested to provide the following background
information:

-   A map or chart of the distribution of Section 5310 or 5311 funding
    throughout the State. The areas covered by each recipient and the
    number of vehicles or dollars awarded in the past three years should
    be noted on the map or chart. The map or chart should also identify
    areas where minority populations exceed the statewide averages.

-   Copies of the current funding contracts between LADOTD and Section
    5310 and 5311 recipients.

-   Copies of LADOTD's procedures to obtain Title VI general reporting
    information from Section 5311 subrecipients at least once every
    three years, per the 2000 State Management and Triennial Review.

In the letter, LADOTD was also requested to provide an update of the
following General Reporting requirements (Chapter III, Section 2 of FTA
Circular 4702.1) since its most recent Title VI submittal.

-   A list of any active lawsuits and complaints

```{=html}
<!-- -->
```
-   Pending grant applications

```{=html}
<!-- -->
```
-   Other civil rights compliance reviews during the last three years

```{=html}
<!-- -->
```
-   Fixed facility analysis and, if needed, a program or other measures
    to mitigate any identified adverse impact on the minority community

LADOTD was also requested to provide Program Specific requirements for
State Agencies administering Transit Programs for the Elderly and
Handicapped (Chapter III, Section 3.c of FTA Circular 4702.1):

-   A description of LADOTD's process and criteria for selecting private
    nonprofit organizations to receive financial assistance.

-   A list of applicants requesting assistance, identifying whether the
    applicant is a minority organization providing assistance to
    minority communities and whether the application was approved.

-   A description of LADOTD's methods for identifying and assisting
    nonprofit organizations operated by minorities or groups serving
    predominately minority communities.

-   A description of LADOTD's methods for ensuring that subrecipients
    satisfy the general data collection and reporting requirements of
    Title VI.

Additionally, LADOTD was requested to provide Program Specific
requirements for State Agencies administering Transit Programs for Rural
and Small Urban Areas (Chapter III, Section 3.d of FTA Circular 4702.1):

-   A description of the process LADOTD uses to develop its application
    for Section 5311 funding, especially the criteria used for selecting
    funding requests from rural and small transit providers. Native
    American tribes are eligible recipients and must be considered in
    the Section 5311 review process.

-   A description of LADOTD's efforts to assist subrecipients in
    applying for Section 5311 assistance, especially any efforts made to
    assist minority applicants.

-   A description of LADOTD's criteria for selecting transit providers
    to participate in the Section 5311 program, especially its efforts
    to include subrecipients with significant minority population.

-   A description of LADOTD's ongoing process to monitor subrecipients'
    compliance with Title VI.

Finally, LADOTD was requested to provide a description of the existing
Title VI complaint process, in accordance with Chapter VII, Section 1 of
FTA Circular 4702.1, and copies of materials, which are made available
to the public that describe the process for filing complaints.

The site visit to LADOTD occurred on May 15 to May 17, 2002. The
individuals participating in the review are listed in Section VIII of
this report. At the entrance conference, the purpose of the Title VI
Compliance Review and the review process were discussed. A detailed
schedule for conducting the site visit was discussed. After the entrance
conference, the review team initially focused on the status of the
information requested in the letter notifying LADOTD of the Compliance
Review. The review team also reviewed file information on selected
subrecipients. Logistics of site visits to selected subrecipients were
discussed, as were logistics of interviews with minority community
representatives. Arrangements were made for site visits to selected
subrecipients and interviews with minority community representatives.
These site visits and interviews took place on the second day of the
review.

Interviews were conducted with LADOTD's staff to provide information on
the extent to which Title VI requirements are incorporated in the
planning and implementation of the Section 5310 and Section 5311 program
by LADOTD.

During the site visit, interviews were conducted with community leaders
from four different parishes in the State of Louisiana to gain insight
on how the Section 5310 and Section 5311 Programs are being operated.
Names of the representatives from the organizations interviewed are in
Section VIII of this report. The reviewers contacted the following
organizations to obtain feedback regarding the Programs in each parish:
Ascension Council on Aging (COA), Pointe Coupee COA, St. Landry
Community Action Agency, and the St. Mary COA, all of which have 5310
and 5311 grants, and Bayou Industrial Maintenance Service, which has a
5310 grant. Of the organizations visited, Ascension COA was the only one
not located in a minority parish. All parishes expressed having good
communication with LADOTD program managers. Representatives from
Ascension COA and Bayou Industrial did not seem aware of the minority
population in their parishes or of local minority organizations.

At the exit conference, the review team and LADOTD's management
discussed the results of the site visit and the next steps.

[]{#__RefHeading___Toc23744330 .anchor}VI. FINDINGS AND RECOMMENDATIONS

The Title VI Compliance Review focused on LADOTD\'s role as the
administrator of FTA funded transit programs for the Elderly and Persons
with Disabilities (Section 5310) and for Rural and Small Urban Areas
(Section 5311). These are separate programs, with a common set of Title
VI General Reporting Requirements applicable to all FTA recipients and
different Program-Specific Requirements for each of the programs. This
section describes the requirements, findings at the time of the
Compliance Review site visit, and the current status of LADOTD\'s
compliance with requirements in each of the following categories:

-   General Reporting Requirements - applies to both the Section 5310
    and the Section 5311 programs (FTA C. 4702.1, Chapter III-2)

-   Program Specific Requirements for State Agencies Administering
    Transit Programs for the Elderly and Handicapped - Section 5310
    (FTA C. 4702.1, Chapter III- 4c)

-   Program Specific Requirements for State Agencies Administering
    Programs for Rural and Small Urban Areas - Section 5311 (FTA C.
    4702.1, Chapter III- 4d)

#### 

[]{#__RefHeading___Toc23744331 .anchor}A. Findings of the General
Reporting Requirements

1.  List of Active Complaints and Lawsuits

[Requirement]{.underline}**:** All applicants, recipients and
subrecipients shall maintain and submit a list of any active lawsuits or
complaints naming the applicant who alleges discrimination on the basis
of race, color, or national origin with respect to service or other
transit benefits.

[Finding]{.underline}**:** During this Title VI Compliance Review of
LADOTD, deficiencies were found with the general reporting requirement
regarding the List of Active Complaints and Lawsuits. At the time of the
Compliance Review site visit, there were no Title VI complaints or
lawsuits filed against LADOTD. In its Title VI submittal and information
provided at the site visit, LADOTD did report on its active complaints
and lawsuits, in conformance with FTA Circular 4702.1. However, LADOTD
did not report on its subrecipients. LADOTD does not collect a list of
active complaints and lawsuits from its 5310 and 5311 subrecipients. In
the case of the 5310 Program, LADOTD does not require its 5310
subrecipients to maintain or submit this information. In the case of the
5311 Program, LADOTD does describe the requirement in its State
Management Plan but does not require it as part of the application
process.

[Corrective Action and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer documentation that
it has revised its State Management Plan and applications to require the
reporting of the proper information from its subrecipients, including a
List of Active Complaints and Lawsuits.

2.  List of Pending Applications for Financial Assistance

[Requirement]{.underline}: All applicants, recipients and subrecipients
shall maintain and submit a description of all pending applications for
financial assistance, and all financial assistance currently provided by
other Federal agencies.

[Finding]{.underline}: During this Title VI Compliance Review of LADOTD,
no deficiencies were found with this requirement. In its Title VI
submittal and information provided at the site visit, LADOTD did report
on its pending applications for financial assistance, in conformance
with FTA Circular 4702.1. LADOTD does collect this information from its
subrecipients.

3.  Summary of Civil Rights Compliance Reviews

[Requirement]{.underline}: All applicants, recipients and subrecipients
shall maintain and submit a summary of all civil rights compliance
review activities conducted in the last three years.

[Finding]{.underline}: During this Title VI Compliance Review of LADOTD,
deficiencies were found with the general reporting requirement regarding
Summary of Civil Rights Compliance Reviews. In its Title VI submittal
and information provided at the site visit, LADOTD did report on its
summary of civil rights compliance reviews, in conformance with FTA
Circular 4702.1. However, LADOTD did not report on its subrecipients.
LADOTD does not collect information on civil rights compliance reviews
from its 5310 and 5311 subrecipients. In the case of the 5310 Program,
LADOTD does not require its 5310 subrecipients to maintain or submit
this information. In the case of the 5311 Program, LADOTD does describe
the requirement in its State Management Plan but does not require it as
part of the application process.

[Corrective Action and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer documentation that
it has revised its State Management Plan and applications to require the
reporting of the proper information from its subrecipients, including a
Summary of Civil Rights Compliance Reviews.

4.  FTA Civil Rights Assurance

[Requirement]{.underline}: All applicants, recipients and subrecipients
shall maintain and submit a signed FTA Civil Rights Assurance that all
of the records and other information required have been or will be
compiled, as appropriate.

[Finding]{.underline}: During this Title VI Compliance Review of LADOTD,
no deficiencies were found with this requirement. As a part of its
Annual Certifications and Assurances for FTA Assistance, LADOTD has
affirmed its compliance with FTA Civil Rights requirements. LADOTD also
had on file a signed FTA Civil Rights Assurances from each of its
Section 5310 and 5311 subrecipients.

5.  DOT Title VI Assurance

[Requirement]{.underline}: All applicants, recipients and subrecipients
shall maintain and submit a signed standard DOT Title VI Assurance. This
is a \"One-Time Submission\".

[Finding]{.underline}: During this Title VI Compliance Review of LADOTD,
no deficiencies were found with this requirement. LADOTD provided a copy
of its most recent signed standard DOT Title VI Assurance, dated March
2002. LADOTD also had on file signed DOT Title VI Assurances from each
of its Section 5310 and 5311 subrecipients.

6.  Fixed-Facility (Environmental Justice) Impact Analysis

[Requirement]{.underline}: For construction projects, all applicants,
recipients and subrecipients shall conduct a fixed-facility impact
analysis to assess the effects on minority communities. This information
can be included in the environmental assessment or environmental impact
statement.

[Finding]{.underline}: During this Title VI Compliance Review of LADOTD,
no deficiencies were found with this requirement. LADOTD did not
administer any funding during the past three years to plan or construct
any fixed facilities for its Section 5311 subrecipients. The Section
5310 program only provides funding for vehicles, so the requirements
would not apply to those subrecipients. LADOTD is aware that a fixed
facility/ environmental justice analysis must be performed to determine
if a project would have an adverse effect on minority communities.

7.  Monitoring Procedures

[Requirement]{.underline}: State agencies must develop and implement
procedures to ensure that participating subrecipients satisfy the
applicable Title VI general data collection and reporting requirements.
At a minimum, state agencies must have an ongoing process to monitor
whether the transit service provided to minority communities and
minority users is consistent with Title VI objectives.

[Findings]{.underline}: During this Title VI Compliance Review of
LADOTD, deficiencies were found with the general reporting requirements
regarding monitoring procedures. LADOTD does have a monitoring process
for its subrecipients, but the monitoring process in place does not
include procedures to ensure that subrecipients are providing transit
service consistent with Title VI objectives.

[Corrective Actions and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer documentation that
it has revised its monitoring procedures to ensure that subrecipients
are providing transit service consistent with Title VI objectives.

8.  Title VI Complaints

[Requirement]{.underline}: All applicants, recipients and subrecipients
shall have a process in place for receiving and resolving Title VI
complaints in a timely manner.

[Finding]{.underline}: During this Title VI Compliance Review of LADOTD,
no deficiencies were found with this requirement. LADOTD has a process
in place for handling Title VI complaints. Applicants for Section 5311
can submit a complaint to the Program Directorate who has the
responsibility of processing, investigation, and resolution of any
complaint. There are no outstanding Title VI complaints against LADOTD.

[]{#__RefHeading___Toc23744332 .anchor}B. Findings of the
Program-Specific Requirements for States Administering Elderly and
Persons with Disabilities Program (Section 5310)

1.  Documentation of Process for Developing POP to Ensure Equitable
    Distribution of Funds

[Requirement]{.underline}: State agencies must be able to provide a
description of the process by which it develops the annual (application)
program of projects submitted to FTA as part of its Section 5310 grant
application, especially the method used to ensure fair and equitable
distribution of funds.

[Findings]{.underline}: During this Title VI Compliance Review of
LADOTD, no deficiencies were found with this requirement. LADOTD was
able to provide a description of the process it uses to develop its
annual program of projects (POP) submitted to FTA. The process appears
to ensure that funds are distributed in an equitable manner and that
minority groups are served throughout the State at a level commensurate
with the size of the minority population.

A review of active 5310 grants at the time of the site visit showed that
minority parishes (those exceeding the statewide average of 36% minority
population) received a comparable number of grants, in relation to their
numbers, as did non-minority parishes. Specifically, a total of 41
parishes received Section 5310 grants, including sixteen parishes (39%),
with a higher than average minority population. This is the exact same
percentage of minority to non-minority parishes in the State. This
analysis shows that no disparity appears to exist in the distribution of
grants. However, as discussed in the following subsections of this
report, LADOTD must increase its data collection and analysis efforts,
as set forth in FTA Circular 4702.1 to ensure that minorities are not
discriminated against in the distribution and allocation of Section 5310
funds.

2.  Record of Funding Requests

[Requirement]{.underline}: State agencies shall maintain a record of
funding requests received from private nonprofit organizations and shall
advise FTA on the manner in which it selects applicants for funding. The
record should indicate whether the applicant is a minority organization
or an organization providing assistance to minority communities and
whether the application was approved.

[Findings]{.underline}: During this Title VI Compliance Review of
LADOTD, deficiencies were found with the program-specific requirements
regarding the record of funding requests. LADOTD provided no
documentation that it maintains a record of funding requests in
conformance with Title VI regulations. LADOTD does not have records that
indicate whether the applicant is a minority organization or an
organization providing assistance to minority communities and whether
the application was approved.

[Corrective Action and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer documentation that
it has developed a process to maintain a record of funding requests
received from private nonprofit organizations and shall advise FTA on
the manner in which it selects applicants for funding. The record should
indicate whether the applicant is a minority organization or an
organization providing assistance to minority communities and whether
the application was approved.

3.  Process and Criteria Used to Select Providers

[Requirement]{.underline}: State agencies must provide a description of
its process and criteria for selecting private nonprofit organizations
to receive financial assistance.

[Findings]{.underline}: During this Title VI Compliance Review of
LADOTD, deficiencies were found with the program-specific reporting
requirements regarding the process and criteria used to select
providers. LADOTD provided no documentation that it applies Title VI
criteria when selecting transit service providers to participate in the
Section 5310 program.

[Corrective Action and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer a written
description of how it will incorporate Title VI considerations into its
criteria for selecting transit providers to participate in the Section
5310 program.

4.  Efforts to Assist Minority Applicants

[Requirement]{.underline}: State agencies must provide a description of
its methods and/or procedures for identifying and assisting nonprofit
organizations operated by minorities or groups serving predominately
minority communities.

[Findings]{.underline}: During this Title VI Compliance Review of
LADOTD, deficiencies were found with the program-specific reporting
requirements regarding efforts to assist minority applicants. LADOTD
does not currently have a description of its methods and/or procedures
for identifying and assisting nonprofit organizations operated by
minorities or groups serving predominately minority communities.

[Corrective Action and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer a description of
its methods and/or procedures for identifying and assisting nonprofit
organizations operated by minorities or groups serving predominately
minority communities.

[]{#__RefHeading___Toc23744333 .anchor}C. Findings of the
Program-Specific Requirements for States Administering Rural Funding
Programs (Section 5311)

1\. Documentation of Process for Developing POP to Ensure Equitable
Distribution of Funds

[Requirement]{.underline}: State agencies must be able to provide a
description of the process by which it develops the annual program of
projects submitted to FTA as part of its Section 5311 grant application,
especially the method used to ensure fair and equitable distribution of
funds, including to Native American Tribes where applicable.

[Findings]{.underline}: During this Title VI Compliance Review of
LADOTD, no deficiencies were found with this requirement. LADOTD
provided a description of the process by which it develops the annual
program of projects to FTA as part of its Section 5311 grant
application. This process is in conformance with Title VI requirements.

A review of active 5311 grants at the time of the site visit showed that
minority parishes (those exceeding the statewide average of 36% minority
population) received a comparable number of grants, in relation to their
numbers, as did non-minority parishes. Specifically, a total of 27
parishes received Section 5311 grants, including nine parishes (33%)
with a higher than average minority population. This is comparable to
the number of total minority parishes (39%) in the State. This analysis
shows that no significant disparity appears to exist in the distribution
of grants. However, as discussed in the following subsections of this
report, LADOTD must increase its data collection and analysis efforts,
as set forth in FTA Circular 4702.1 to ensure that minorities are not
discriminated against in the distribution and allocation of Section 5311
funds.

2\. Process for Developing Application for Funding

[Requirement]{.underline}: State agencies must provide a description of
the process by which it develops its application for Section 5311
funding; especially the criteria used for selecting and/or recommending
approval of funding requests from rural and small transit providers.
Native American tribes are eligible recipients in the Section 5311
process.

[Findings]{.underline}: During this Title VI Compliance Review of
LADOTD, deficiencies were found with the program-specific requirement
regarding the process for developing its application for funding. LADOTD
provided no description of the process by which it develops its
application for Section 5311 funding, pursuant to Title VI requirements.

[Corrective Action and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer a description of
the process by which it develops its application for Section 5311
funding, pursuant to Title VI requirements.

3\. Efforts to Assist Minority Applicants

[Requirement]{.underline}: State agencies must provide a description of
its efforts to assist subrecipients in applying for federal assistance,
especially any efforts to assist minority applicants.

[Findings]{.underline}: During this Title VI Compliance Review of
LADOTD, deficiencies were found with the program-specific requirement
regarding efforts to assist minority applicants. LADOTD provided no
description of its efforts to assist minority applicants in applying for
federal assistance.

[Corrective Action and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer a description of
specific efforts it will make to assist minority applicants in applying
for federal assistance.

4\. Criteria for Selecting Transit Providers to Participate in the
Section 5311 Program

[Requirement]{.underline}: State agencies must provide a description of
its criteria for selecting transit providers to participate in the
Section 5311 program, especially its efforts to include subrecipients
with significant minority populations.

[Finding]{.underline}: During this Title VI Compliance Review of LADOTD,
deficiencies were found with the program-specific requirement regarding
criteria for selecting transit providers to participate in the Section
5311 program. LADOTD provided no description of its criteria for
selecting transit providers to participate in the Section 5311 program,
especially its efforts to include subrecipients with significant
minority populations.

[Corrective Action and Schedule]{.underline}: Within 60 days, LADOTD
must submit to the FTA Region VI Civil Rights Officer a description of
its criteria for selecting transit providers to participate in the
Section 5311 program, especially its efforts to include subrecipients
with significant minority populations.

VII. []{#__RefHeading___Toc23744334 .anchor}SUMMARY OF FINDINGS AND
     CORRECTIVE ACTIONS

**General Reporting Requirements For States Administering**

Section 5310 Programs and Section 5311 Programs

  -------------------------------------------------------------------------------------------
  **Title VI       **Site      **Description of **Corrective         **Response    **Date
  Requirements For Review      Deficiencies**   Action(s)**          Days/Date**   Closed**
  Transit          Finding**                                                       
  Providers**                                                                      
  ---------------- ----------- ---------------- -------------------- ------------- ----------
  1\. List of      D           LADOTD did not   LADOTD must submit   60 Days       
  Active                       report on its    to the FTA Region VI               
  Complaints and               subrecipients.   Civil Rights Officer               
  Lawsuits                     LADOTD does not  documentation that                 
                               collect a list   it has revised its                 
                               of active        State Management                   
                               complaints and   Plans and                          
                               lawsuits from    applications to                    
                               its 5310 and     require the                        
                               5311             reporting of the                   
                               subrecipients.   proper information                 
                                                from its                           
                                                subrecipients,                     
                                                including a List of                
                                                Active Complaints                  
                                                and Lawsuits.                      

  2\. List of      C                                                               
  Pending Grant                                                                    
  Applications                                                                     

  3\. Summary of   D           LADOTD did not   LADOTD must submit   60 Days       
  Civil Rights                 report on its    to the FTA Region VI               
  Compliance                   subrecipients.   Civil Rights Officer               
  Reviews                      LADOTD does not  documentation that                 
                               collect          it has revised its                 
                               information on   State Management                   
                               civil rights     Plans and                          
                               compliance       applications to                    
                               reviews from its require the                        
                               5310 and 5311    reporting of the                   
                               subrecipients.   proper information                 
                                                from its                           
                                                subrecipients,                     
                                                including a Summary                
                                                of Civil Rights                    
                                                Compliance Reviews.                

  4\. FTA Civil    C                                                               
  Rights Assurance                                                                 

  5\. DOT Title VI C                                                               
  Assurance                                                                        

  6\.              C                                                               
  Fixed-Facility                                                                   
  (Environmental                                                                   
  Justice) Impact                                                                  
  Analysis                                                                         

  7\. Monitoring   D           LADOTD does not  LADOTD must submit   60 Days       
  Procedures                   have procedures  to the FTA Region VI               
                               to monitor       Civil Rights Officer               
                               subrecipients to documentation that                 
                               ensure that they it has revised its                 
                               are providing    monitoring                         
                               transit service  procedures to ensure               
                               consistent with  that subrecipients                 
                               Title VI         are providing                      
                               objectives.      transit service                    
                                                consistent with                    
                                                Title VI objectives.               

  8\. Title VI     C                                                               
  Complaints                                                                       
  -------------------------------------------------------------------------------------------

Findings at the time of the site visit: C = In Compliance; D =
Deficiency; NA = Not Applicable; NR = Not Reviewed;

F = Follow-up

**Program Specific Requirements for States Administering**

**Section 5310 Programs**

+--------------+------+--------------+---------------+--------+------+
| **Re         | **   | *            | **Corrective  | **Re   | **   |
| quirements** | Site | *Description | Action(s)**   | sponse | Date |
|              | Re   | of           |               | Days/  | Clos |
|              | view | De           |               | Date** | ed** |
|              | F    | ficiencies** |               |        |      |
|              | indi |              |               |        |      |
|              | ng** |              |               |        |      |
+==============+======+==============+===============+========+======+
| 1\.          | C    |              |               |        |      |
| D            |      |              |               |        |      |
| ocumentation |      |              |               |        |      |
| of Process   |      |              |               |        |      |
| for          |      |              |               |        |      |
| Developing   |      |              |               |        |      |
| POP          |      |              |               |        |      |
+--------------+------+--------------+---------------+--------+------+
| 2\. Record   | D    | LADOTD       | LADOTD must   | 60     |      |
| of Funding   |      | provided no  | submit to the | Days   |      |
| Requests     |      | d            | FTA Region VI |        |      |
|              |      | ocumentation | Civil Rights  |        |      |
|              |      | that it      | Officer       |        |      |
|              |      | maintains a  | documentation |        |      |
|              |      | record of    | that it has   |        |      |
|              |      | funding      | developed a   |        |      |
|              |      | requests in  | process to    |        |      |
|              |      | conformance  | maintain a    |        |      |
|              |      | with Title   | record of     |        |      |
|              |      | VI           | funding       |        |      |
|              |      | regulations. | requests      |        |      |
|              |      |              | received from |        |      |
|              |      |              | private       |        |      |
|              |      |              | nonprofit     |        |      |
|              |      |              | organizations |        |      |
|              |      |              | and shall     |        |      |
|              |      |              | advise FTA on |        |      |
|              |      |              | the manner in |        |      |
|              |      |              | which it      |        |      |
|              |      |              | selects       |        |      |
|              |      |              | applicants    |        |      |
|              |      |              | for funding.  |        |      |
+--------------+------+--------------+---------------+--------+------+
| 3\. Process  | D    | LADOTD       | > LADOTD must | 60     |      |
| and Criteria |      | provided no  | > submit to   | Days   |      |
| Used to      |      | d            | > the FTA     |        |      |
| Select       |      | ocumentation | > Region VI   |        |      |
| Providers    |      | that it      | > Civil       |        |      |
|              |      | applies      | > Rights      |        |      |
|              |      | Title VI     | > Officer a   |        |      |
|              |      | criteria     | > written     |        |      |
|              |      | when         | > description |        |      |
|              |      | selecting    | > of how it   |        |      |
|              |      | transit      | > will        |        |      |
|              |      | service      | > incorporate |        |      |
|              |      | providers to | > Title VI    |        |      |
|              |      | participate  | > c           |        |      |
|              |      | in the       | onsiderations |        |      |
|              |      | Section 5310 | > into its    |        |      |
|              |      | program.     | > criteria    |        |      |
|              |      |              | > for         |        |      |
|              |      |              | > selecting   |        |      |
|              |      |              | > transit     |        |      |
|              |      |              | > providers   |        |      |
|              |      |              | > to          |        |      |
|              |      |              | > participate |        |      |
|              |      |              | > in the      |        |      |
|              |      |              | > Section     |        |      |
|              |      |              | > 5310        |        |      |
|              |      |              | > program.    |        |      |
+--------------+------+--------------+---------------+--------+------+
| 4\. Efforts  | D    | > LADOTD     | LADOTD must   | 60     |      |
| to Assist    |      | > does not   | submit to the | Days   |      |
| Minority     |      | > currently  | FTA Region VI |        |      |
| Applicants   |      | > have a     | Civil Rights  |        |      |
|              |      | >            | Officer a     |        |      |
|              |      |  description | description   |        |      |
|              |      | > of its     | of its        |        |      |
|              |      | > methods    | methods       |        |      |
|              |      | > and/or     | and/or        |        |      |
|              |      | > procedures | procedures    |        |      |
|              |      | > for        | for           |        |      |
|              |      | >            | identifying   |        |      |
|              |      |  identifying | and assisting |        |      |
|              |      | > and        | nonprofit     |        |      |
|              |      | > assisting  | organizations |        |      |
|              |      | > nonprofit  | operated by   |        |      |
|              |      | > o          | minorities or |        |      |
|              |      | rganizations | groups        |        |      |
|              |      | > operated   | serving       |        |      |
|              |      | > by         | predominately |        |      |
|              |      | > minorities | minority      |        |      |
|              |      | > or groups  | communities.  |        |      |
|              |      | > serving    |               |        |      |
|              |      | > p          |               |        |      |
|              |      | redominately |               |        |      |
|              |      | > minority   |               |        |      |
|              |      | >            |               |        |      |
|              |      | communities. |               |        |      |
+--------------+------+--------------+---------------+--------+------+

Findings at the time of the site visit: C = In Compliance; D =
Deficiency; NA = Not Applicable; NR = Not Reviewed;

F = Follow-up

**Program Specific Requirements for States Administering**

**Section 5311 Programs**

+--------------+------+--------------+---------------+--------+------+
| **Re         | **   | *            | **Corrective  | **Re   | **   |
| quirements** | Site | *Description | Action(s)**   | sponse | Date |
|              | Re   | of           |               | Days/  | Clos |
|              | view | De           |               | Date** | ed** |
|              | F    | ficiencies** |               |        |      |
|              | indi |              |               |        |      |
|              | ng** |              |               |        |      |
+==============+======+==============+===============+========+======+
| 1\.          | C    |              |               |        |      |
| D            |      |              |               |        |      |
| ocumentation |      |              |               |        |      |
| of Process   |      |              |               |        |      |
| for          |      |              |               |        |      |
| Developing   |      |              |               |        |      |
| POP          |      |              |               |        |      |
+--------------+------+--------------+---------------+--------+------+
| 2\. Process  | D    | LADOTD       | LADOTD must   | 60     |      |
| for          |      | provided no  | submit to the | Days   |      |
| Developing   |      | description  | FTA Region VI |        |      |
| Application  |      | of the       | Civil Rights  |        |      |
| for Funding  |      | process by   | Officer a     |        |      |
|              |      | which it     | description   |        |      |
|              |      | develops its | of the        |        |      |
|              |      | application  | process by    |        |      |
|              |      | for Section  | which it      |        |      |
|              |      | 5311         | develops its  |        |      |
|              |      | funding,     | application   |        |      |
|              |      | pursuant to  | for Section   |        |      |
|              |      | Title VI     | 5311 funding, |        |      |
|              |      | r            | pursuant to   |        |      |
|              |      | equirements. | Title VI      |        |      |
|              |      |              | requirements. |        |      |
+--------------+------+--------------+---------------+--------+------+
| 3\. Efforts  | D    | LADOTD       | > LADOTD must | 60     |      |
| to Assist    |      | provided no  | > submit to   | Days   |      |
| Minority     |      | description  | > the FTA     |        |      |
| Applicants   |      | of its       | > Region VI   |        |      |
|              |      | efforts to   | > Civil       |        |      |
|              |      | assist       | > Rights      |        |      |
|              |      | minority     | > Officer a   |        |      |
|              |      | applicants   | > description |        |      |
|              |      | in applying  | > of specific |        |      |
|              |      | for federal  | > efforts it  |        |      |
|              |      | assistance.  | > will make   |        |      |
|              |      |              | > to assist   |        |      |
|              |      |              | > minority    |        |      |
|              |      |              | > applicants  |        |      |
|              |      |              | > in applying |        |      |
|              |      |              | > for federal |        |      |
|              |      |              | > assistance. |        |      |
+--------------+------+--------------+---------------+--------+------+
| 4\. Criteria | D    | > LADOTD     | LADOTD must   | 60     |      |
| for          |      | > provided   | submit to the | Days   |      |
| Selecting    |      | > no         | FTA Region VI |        |      |
| Transit      |      | >            | Civil Rights  |        |      |
| Providers to |      |  description | Officer a     |        |      |
| Participate  |      | > of its     | description   |        |      |
| in the       |      | > criteria   | of its        |        |      |
| Section 5311 |      | > for        | criteria for  |        |      |
| Program      |      | > selecting  | selecting     |        |      |
|              |      | > transit    | transit       |        |      |
|              |      | > providers  | providers to  |        |      |
|              |      | > to         | participate   |        |      |
|              |      | >            | in the        |        |      |
|              |      |  participate | Section 5311  |        |      |
|              |      | > in the     | program,      |        |      |
|              |      | > Section    | especially    |        |      |
|              |      | > 5311       | its efforts   |        |      |
|              |      | > program,   | to include    |        |      |
|              |      | > especially | subrecipients |        |      |
|              |      | > its        | with          |        |      |
|              |      | > efforts to | significant   |        |      |
|              |      | > include    | minority      |        |      |
|              |      | > s          | populations.  |        |      |
|              |      | ubrecipients |               |        |      |
|              |      | > with       |               |        |      |
|              |      | >            |               |        |      |
|              |      |  significant |               |        |      |
|              |      | > minority   |               |        |      |
|              |      | >            |               |        |      |
|              |      | populations. |               |        |      |
+--------------+------+--------------+---------------+--------+------+

Findings at the time of the site visit: C = In Compliance; D =
Deficiency; NA = Not Applicable; NR = Not Reviewed;

F = Follow-up

VIII. []{#__RefHeading___Toc23744335 .anchor}ATTENDEES

  ---------- ------------------------ -------------- -------------- ------------------------------
  **NAME**   **TITLE/ORGANIZATION**   **PHONE**      **FAX**        **E-MAIL**

  Blaise     Deputy Secretary/LADOTD  221-274-4302   225-274-4314   <bcarrier@dotd.state.la.us>
  Carriere                                                          

  Carol      Administrator/LADOTD     221-274-4302   225-274-4314   <ccranshaw@dotd.state.la.us>
  Cranshaw                                                          

  Donna      Assistant                221-274-4302   225-274-4314   <dlavigne@dotd.state.la.us>
  Lavigne    Administrator-Public                                   
             Transportation/ LADOTD                                 

  Darlene    Manager-Rural Public     221-274-4308   225-274-4314   <dstromain@dotd.state.la.us>
  St. Romain Transportation Program/                                
             LADOTD                                                 

  Harold     Manager-E & D Program    221-274-4305   225-274-4314   <hbeck@dotd.state.la.us>
  L.Beck     Manager/ LADOTD                                        

  Grace      Executive Director/      225-473-3759                  <Ascencoa@eatel.net>
  Garow      Ascension Parish Public                                
             Transit                                                

  Jane       Director/ St. Mary COA   337-828-4100                  
  Powers                                                            

  Marge      Transportation           337-828-4100                  
  Williams   Coordinator/ St. Mary                                  
             COA                                                    

  O. Jay     Executive Director/      337-384-0323                  <bims@petronet.net>
  Barbier    Bayou Industrial                                       
             Maintenance Services,                                  
             Inc. (BIMS)                                            

  Becky      Executive Director/      225-638-4402   225-638-4403   <ptccoa@eatel.net>
  Bergeron   Pointe Coupe COA                                       

  Donald     Executive Director/ St.  337-948-3651   337-948-4153   
  Robinson   Landry Community Action                                
             Agency                                                 

  Ruby Woltz Transportation Director/ 337-948-3651   337-948-4153   
             St. Landry Community                                   
             Action Agency                                          

  John Potts Lead Reviewer/ The DMP   504-283-7661   504-283-0791   <johnpotts@thedmpgroup.com>
             Group, Inc.                                            

  Royal "Ed" Reviewer/ The DMP Group, 301-681-0258   301-681-5586   <royaleiii@thedmpgroup.com>
  Spurlark   Inc.                                                   

  Jim        Reviewer/ Milligan &     410.732.4626   215.496.9100   <jbuckley@milligancpa.com>
  Buckley    Company LLC                                            

  Joseph     Reviewer/ Milligan &     215-496-9100   215-496-0980   <jherzog@milligancpa.com>
  Herzog     Company LLC                                            
  ---------- ------------------------ -------------- -------------- ------------------------------