Failure to comply with Federal Highway Administration (FHWA) Title VI regulations can render agencies ineligible for Federal assistance. North Highland helped a major multi-modal, bi-state transportation agency develop a roadmap and related deliverables that would secure Federal funds and demonstrate compliance with Title VI.
A Public Sector Case Study
The client—a major multi-modal, bi-state transportation agency— designs, builds, operates, and maintains infrastructure that support a robust trade and transportation network. The agency is responsible for one of America’s busiest airport systems, marine terminals and ports, a rail transit system, and multiple interstate tunnels. As a recipient of Federal funding from the U.S. Department of Transportation (USDOT), the agency needed to develop a nondiscrimination program that would ensure compliance with Title VI of the Civil Rights Act and related legislation and Executive Orders that prohibit discrimination based on race, color, or national origin in programs and operations.
To meet Federal Highway Administration (FHWA) requirements, the client needed to develop and implement a public participation plan, an internal monitoring program, and ongoing Title VI training. The FHWA also required the submission of formal deliverables including a Title VI Plan and Accomplishment Report and Work Plan.
Using prior experience and analysis of Federal regulations, the North Highland team developed a Title VI compliance roadmap designed to address FHWA’s most recent and urgent citations. With the roadmap, timelines, and task ownership in place, North Highland engaged stakeholders around the agency, project managing the activities and articulating value and urgency.
Incorporating outside best practices, North Highland also researched other transportation entities with Title VI accountability to FHWA, ultimately connecting the client with a network of agencies that could provide additional insight into effective ways of working with USDOT.
A key roadmap activity to ensure sustainable compliance was developing the framework for ongoing process reviews. This workstream involved interpreting regulation requirements, working with the FHWA liaison to ensure accurate interpretation, and creating a comprehensive Process Review Manual that included evaluation rubrics for each Title VI activity. Facilitating consensus from multiple stakeholders—including the agency COO—North Highland developed a review schedule to cover a three-year timeframe.
Taking the client from development through implementation, North Highland led four process reviews, working with departments including Government and Public Affairs, Environment, and Engineering to review project samples for compliance with Title VI requirements. North Highland also created a Title VI nondiscrimination training module and led a “train-the-trainer” session for Title VI department liaisons.
The FHWA accepted the title VI implementation plans, accomplishment report, and workplans that North Highland facilitated for the client, ensuring the client’s continued eligibility to receive federal funding.
The FHWA accepted the Title VI Implementation Plans, Accomplishment Report, and Workplans that North Highland facilitated for the client, ensuring the client's continued eligibility to receive Federal funding.
More broadly, the project team helped foster a new mindset about departments’ role in ensuring compliance. The team’s work enabled the Civil Rights Program Manager to reimagine each department’s role in the completion of FHWA deliverables. North Highland helped the Program Manager, along with the Civil Rights Department Director, prioritize the work and focus the Civil Rights Department on providing technical assistance. With this new approach in place, departments such as Public Affairs and Environment took ownership of developing new agency guidance documents that ensured the highest degree of Title VI compliance.
Because of the quality of the framework that the team put into place, the client now considers North Highland a long-term, trusted partner and advisor, engaging the team for ongoing process reviews in its Title VI program through 2019.