GENERAL INFORMATION Grant Recipient: Hawaii Department of Transportation (HDOT) City/State: Honolulu, Hawaii Grantee Number: 1623 Executive Official: Mr. Brennon T. Morioka, Ph.D, P.E. Director of Transportation Hawaii Department of Transportation 869 Punchbowl Street Honolulu, HI 96813 Report Prepared By: THE DMP GROUP, LLC 2233 Wisconsin Avenue NW Suite 405 Washington, DC 20007 Site Visit Dates: February 16 – 19, 2010 Compliance Review Team Members: John Potts, Lead Reviewer Bridgett Gagné, Reviewer Khalique Davis, Reviewer 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. The Hawaii Department of Transportation (HDOT) 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 the following:
A review of HDOT’s LEP documents against the DOT Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient Persons, (December 14, 2005) identified the following: Elements Required for LEP Assessment (Per FTA C. 4702.1A, IV, 4. a. and DOT Policy Guidance) Included in HDOT’s Documents? Notes/Comments Part A – Four-Factor Assessment Demography –The number or proportion of LEP persons eligible to be served or likely to be encountered Yes Analysis gives proportion of LEP persons relative to the total county populations Frequency of Contact - the frequency with which LEP individuals come in contact with the program and/or activities No HDOT subrecipient frequency of contact information being developed; one method is by surveying drivers. Importance - the nature and importance of the program, activity, or service to people's lives; No Lack of analysis of services used by LEP and lack of input from community and LEP persons. Resources - the resources available and costs No No associated costs given. HDOT was able to show that it had appropriate Demographic data for the Four Factor Analysis. In its submittal prior to the site visit, HDOT’s LEP documents showed statewide LEP data by county for the City and County of Honolulu and Hawaii, Maui, Kauai, and Kalawao Counties. They used 2006 American Community Survey data to determine the percentages of homes that spoke a language other than English.
documentation that it has distributed the revised notice to the public in a manner other than its website. HDOT must document that its subrecipients have distributed an updated notice to beneficiaries that describes how members of the public could obtain additional information on HDOT’s Title VI obligations. Annual Title VI Certification and Assurance ND Environmental Justice Analysis of Construction Projects D HDOT must submit to the FTA Equal Opportunity Specialist in FTA’s Headquarters Office of Civil Rights documentation that it has established procedures to assure that all future EJ analyses address the requirements outlined in FTA Circular 4702.1A. 90 Days April 5, 2010 Submit Title VI Program D Lack detailed Title VI Program under FTA Circular 4702.1A HDOT must submit to the FTA Equal Opportunity Specialist in FTA’s Headquarters Office of Civil Rights a Title VI Program developed according to FTA Circular 4702.1A under the General Reporting 90 Days April 5, 2010
Requirements and Guidelines and Program-Specific Requirements and Guidelines for State DOTs and Other Administering Agencies. PROGRAM SPECIFIC REQUIREMENTS – FTA C.4702.1A VI, 1-4 Statewide Planning Activities D Lack statewide planning activities HDOT must submit to the FTA Equal Opportunity Specialist in FTA’s Headquarters Office of Civil Rights documentation that it has an analytical basis in place for certifying compliance of its FTA-funded programs with Title VI. 90 Days Program Administration D Lack program administration HDOT must submit to the FTA Equal Opportunity Specialist in FTA’s Headquarters Office of Civil Rights documentation that it has procedures in place to fulfill the Circular requirements for Program Administration. 90 Days April 5, 2010 Providing Assistance to Subrecipients ND Monitoring Subrecipients ND Findings at the time of the site visit: ND = No Deficiencies; D = Deficiency; NA = Not Applicable; NR = Not Reviewed; AC = Advisory Comment