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Title VI and Environmental Justice

Planning must be done with the involvement and for the benefit of all the region's residents. DVRPC is guided by federal Title VI and environmental justice mandates, and the Commission strives to not only meet these mandates, but to create an overall transparent, inclusive planning process. As the metropolitan planning organization (MPO) for the nine-county region, DVRPC is committed to making Title VI and environmental justice a part of our planning process, integrated in all our programs and plans, and a guide for our public participation efforts. On the horizon, we see a Delaware Valley with an enhanced quality of life and a healthful environment for all of its residents.

Title VI of the 1964 Civil Rights Act

Title VI of the Civil Rights Act states 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 subjected to discrimination under any program or activity receiving federal financial assistance."

DVRPC, as the MPO for the Delaware Valley region, serves as the primary forum where state departments of transportation, transit providers, local agencies, and the public work together to develop local transportation plans and programs that address the region's needs. To meet the requirements of Title VI, the Commission must:

  • Enhance its analytical capabilities to ensure that the Long-Range Plan and the Transportation Improvement Program (TIP) comply with Title VI;
  • Identify residential, employment, and transportation patterns of low-income and minority populations so that their needs may be identified and addressed, and the benefits and burdens of transportation can be fairly distributed; and
  • Evaluate and, where necessary, improve the public involvement process to eliminate barriers and engage minority, disabled, elderly, and low-income populations in regional decision-making.

Title VI Statement

Title VI Compliance Plan

In January 2007, the DVRPC Board approved the Commission's Title VI Compliance Plan, which establishes a framework for DVRPC's efforts to ensure compliance with Title VI, as well as with other environmental justice and nondiscrimination mandates.

The Plan outlines how Title VI and environmental justice considerations are reflected in the Commission's Work Program, publications, communications, public involvement efforts, and our general way of doing business.

Title VI Compliance Plan

Title VI Complaint Procedure

Purpose

The DVRPC Title VI Complaint Procedure is written to specify the process employed by DVRPC to investigate complaints, while ensuring due process for Complainants and respondents. The process does not preclude DVRPC from attempting to informally resolve complaints. This procedure applies to all external complaints relating to any program or activity administered by DVRPC and/or its subrecipients, consultants, and contractors, filed under Title VI of the Civil Rights Act of 1964 (including its DBE and Equal Employment Opportunity components), as well as other related laws that prohibit discrimination on the basis of race, color, disability, sex, age, or national origin. Additional statutes include, but are not limited to, Section 504 of the Rehabilitation Act of 1973, the Civil Rights Restoration Act of 1987, and the ADA of 1990. These procedures are part of an administrative process that does not provide for remedies that include punitive damages or compensatory remuneration for the Complainant. Intimidation or retaliation of any kind is prohibited by law.

Process

An individual, or his or her representative, who believes that he or she has been subject to discrimination or retaliation prohibited by Title VI and other nondiscrimination provisions, has a right to file a complaint. Complaints need to be filed within 180 calendar days of the alleged occurrence, when the alleged discrimination became known to the Complainant, or when there has been a continuing course of conduct, the date on which the conduct was discontinued or the latest instance of the conduct.

Complaints shall be in writing and signed by the Complainant or the Complainant’s representative. If complaints are received by telephone or in person, the DVRPC Title VI Compliance Manager or other authorized representative shall formally interview the person to provide the basis for the written complaint. If necessary, an authorized person will assist the Complainant in writing the complaint. The complaint form can be made available in alternative languages or formats, if requested. Please call 215-238-2871 for more information.

Generally, the written complaint includes the following information:

  • name, address, telephone number, and e-mail of the Complainant;
  • basis of the complaint, (e.g. race, color, national origin, sex, age, disability, retaliation);
  • a detailed description of the circumstances of the incident that led the Complainant to believe discrimination occurred;
  • name(s), title(s), and address(es) of the person(s) who discriminated against the Complainant;
  • names, addresses, and phone numbers of people who may have knowledge of the alleged incident or are perceived as parties in the complained-of incident;
  • date or dates on which the alleged discrimination occurred; and
  • agencies where the complaint was filed.

As an investigation moves forward, additional information may be required. Although this process does not preclude DVRPC from attempting to informally resolve complaints, the decision to resolve informally always rests with the complainant, who may withdraw from the informal process at any time.

If a complaint is filed against DVRPC, the Commission will acknowledge receipt of the complaint by notifying the Complainant and immediately transmitting the complaint to the proper state and federal agency (e.g. Federal Highway Administration, Federal Transit Administration, Pennsylvania Department of Transportation, New Jersey Department of Transportation) for investigation and disposition pursuant to that agency’s Title VI complaint procedure. Complaints against DVRPC may also be sent directly to a federal agency. If a complaint is filed with an agency that does not have jurisdiction over the particular reason for discrimination, the complaint will be forwarded to an agency that does.

Complaints against DVRPC subrecipients, consultants, and contractors will be investigated directly by the Commission as follows:

  • Within 10 days, the DVRPC Manager of Title VI Compliance will acknowledge receipt of the complaint to the Complainant, and notify the appropriate state and/or federal agency that a Title VI complaint has been received by the Commission;
  • Within 60 days, the DVRPC Manager of Title VI Compliance will conduct and complete an investigation and, based on the information obtained, will render a recommendation for action in a report of findings to the DVRPC Executive Director. This report will include the nature of the complaint, remedy sought, and a summary of the investigative findings and activities. The complaint should be resolved by informal means whenever possible. Such informal attempts and their results will be summarized in the report findings;
  • Within 90 days of receipt of the complaint, the DVRPC Title VI Compliance Manager will notify the complainant in writing of the final decision reached, including the proposed disposition of the matter. The notification will advise the complainant of his/her appeal rights with state and federal agencies, if they are dissatisfied with the final decision rendered by DVRPC.

The DVRPC Title VI Compliance Manager will maintain a log of all complaints received by the Commission.

The Title VI Complaint form may be submitted directly to the following agencies:

Civil Rights Specialist
U.S. Department of Transportation
Federal Highway Administration
New Jersey Division
840 Bear Tavern Road, Suite 202
West Trenton, NJ 08628
(609) 637-4200
Title VI Manager
Division of Civil Rights/Affirmative Action
New Jersey Department of Transportation
P.O. Box 600
1035 Parkway Avenue
Trenton, NJ 08625-0600
(609) 530-2336
Title VI Manager
Bureau of Equal Opportunity
DBE / Title VI Division
Pennsylvania Department of Transportation
PO Box 3251
Harrisburg, PA 17105-3251
(717) 783-0301
Civil Rights Specialist
U.S. Department of Transportation
Federal Highway Administration
Pennsylvania Division
228 Walnut Street, Room 508
Harrisburg, PA 17101-1720
(717) 221-3461
Title VI Program Coordinator
Federal Transit Administration
Office of Civil Rights
East Building, 5th Floor - TCR
1200 New Jersey Ave., SE
Washington, DC 20590
(202) 366-4043
Title VI Coordinator
Federal Transit Administration - Region 3
U.S. Department of Transportation
1760 Market Street, Suite 500
Philadelphia, PA 19103-4124
(215) 656-7100
 
Title VI Program Coordinator
Federal Highway Administration
U.S. Department of Transportation
Office of Civil Rights
1200 New Jersey Avenue, SE
8th Floor E81-314
Washington, DC 20590
(202) 366-0693
U.S. Department of Justice
Office of Justice Programs
Office for Civil Rights
810 7th Street, NW
Washington, DC 20531
(202) 307-0690
 
 
Title VI Compliance Manager
Delaware Valley Regional Planning Commission
190 N. Independence Mall West, 8th Fl.
Philadelphia, PA 19106
(215) 238-2871
 

Title VI Complaint Form [0.1 MB pdf]

Environmental Justice

The federal government defines environmental justice as, "the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies." Fair treatment means that no group of people, including a racial, ethnic, or socioeconomic group, should bear a disproportionate share of the negative environmental consequences resulting from industrial, municipal, and commercial operations or the execution of federal, state, local, and tribal programs and policies.

Environmental Justice Analysis

Interactive Web Map and Data Application

Use this interactive map to view and identify Environmental Justice (EJ) sensitive areas within the DVRPC region. Review the Indicators of Potential Disadvantage (IPD) analysis, 2010 Census tract level population and household demographics, as well as download Census tract level data.
(Last Updated: October 2014)

EJ Maps

As the MPO for the nine-county region, DVRPC is charged with evaluating plans and programs for environmental justice (EJ) sensitivity. This process includes:

  • examining the allocation of benefits and burdens, both for the current context and for the planned future;
  • ensuring that minority and low-income communities are treated equitably in the provision of transportation services and projects; and
  • providing ample opportunity for full participation for minority and low-income communities to advise the MPO during its planning and decision-making process.

Title VI of the Civil Rights Act and the Executive Order on Environmental Justice (#12898) do not provide specific guidance to evaluate EJ issues within a region's transportation planning process. Therefore, MPOs must devise their own methods for ensuring that EJ issues are investigated and evaluated in transportation decision-making. In 2001, DVRPC developed an EJ technical assessment to identify direct and disparate impacts of its plans, programs, and planning process on defined population groups in the Delaware Valley region. This assessment, the Indicators of Potential Disadvantage, formerly called the Degrees of Disadvantage (DoD) Methodology, is utilized in a variety of DVRPC plans and programs.

Using U.S. Census data, a snapshot of the region is created, mapping the locations of identified EJ populations. The current list of populations identified by DVRPC's IPD methodology are:

  • non-Hispanic minority;
  • Hispanic;
  • Limited English Proficiency (LEP);
  • persons with a physical disability;
  • elderly over 75 years of age;
  • carless households;
  • female head of household with child; and
  • households in poverty.

Broadly speaking, DVRPC's methodology:

  • identifies the impacted groups;
  • locates them in the region;
  • plots key destinations — such as employment or health care locations — that these population groups would access;
  • overlays these destinations with the region's existing and proposed transportation network; and
  • determines what transportation service gaps exist for these disadvantaged groups.

Environmental Justice at DVRPC

Background on and a full definition of the IPD Methodology, as well as an overview and highlights of DVRPC Title VI and EJ activities are included in Environmental Justice at DVRPC, a report created by DVRPC staff every fiscal year. Descriptions for each project or program that utilize DVRPC's IPD Methodology are discussed, including a TIP analysis and corridor studies. Additional Title VI staff education and public participation efforts are also included in the report.

Copies of the report are available as PDF below:

Planner's Methodology

DVRPC has developed a Planner's Methodology, which is designed to provide guidance to staff in meeting Title VI and EJ mandates and structuring a public participation plan at the project or study level. How meaningful public participation is gathered and implemented into a planning process may differ widely, depending on the type and scope of the project. The Planner's Methodology sets a framework for developing individual public participation plans for specific projects, offers a "tool kit" of public participation strategies, and offers instruction on how to utilize DVRPC's IPD methodology, as well as an overview of Title VI and EJ mandates. Overall, the Planner's Methodology builds upon DVRPC's philosophy and intent to place public participation, Title VI, and EJ at the forefront of the Commission's priorities.