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Intermodal Civil Rights

What are Intermodal Civil Rights?

ODOT's Intermodal Civil Rights Program (IMCR) ensures that public transportation and passenger rail programs comply with civil rights laws and executive orders that prevent discrimination in programs that receive federal money. ODOT respects the civil rights of all the people we serve. We operate our programs without regard to race, color, national origin, religion, gender, sex, sexual orientation, age, marital status, and disability, in accordance with applicable law.

The Intermodal Civil Rights Program provides technical support and compliance measures for ODOT and our subrecipients. Since the types of modal projects and services can differ, the requirements on a project may differ as well.

Public Transportation Provider Resources

Public transportation providers and other entities that receive FTA funds for planning, capital, and operating assistance have compliance obligations under the Disadvantaged Business Enterprise (DBE) program, Title VI of the Civil Rights Act of 1964, and the Americans with Disabilities Act (ADA).

In October 2025, the USDOT published a DBE Interim Final Rule (IFR). To read more about the impact and guidance, the FTA Office of Civil Rights has the most current guidance on their website.

The federal Disadvantaged Business Enterprise program ensures nondiscrimination in the award and administration of federally funded contracts. The DBE program also creates a level playing field for certified firms to compete fairly for these contracts. ODOT monitors the use of Disadvantaged Business Enterprises through the Disadvantaged Business Enterprise Program.

ODOT sets two annual DBE goals, one for FHWA funding and one for FTA funding. The proposed DBE goal for FTA funds during federal fiscal years 2024-2026 is 3.39%. This goal is expected to be met with DBE firms hired through race-neutral methods. The proposed ODOT Intermodal DBE Goal Methodology FFY24-26.pdf is under evaluation.

Public transportation providers that receive federal funding from ODOT are required to report on contracting and subcontracting as part of their agency periodic reports (APR). As of November 2025, the DBE reporting requirement is on hold until further notice.

Title VI of the Civil Rights Act of 1964 establishes that no person in the United States shall be discriminated against under any federally funded program or activity based on race, color, or ​national origin. All entities that receive FTA funding from ODOT must comply with Title VI by establishing a nondiscrimination policy and a discrimination complaint process and maintaining an up-to-date Title VI Plan. Title VI Plans must be updated and submitted to ODOT on a three-year basis. IMCR provides technical assistance, review, and acknowledgement of a complete and compliant plan.


​The Americans with Disabilities Act of 1990 and amendments prohibit discrimination and provide equal opportunity and access for persons with ​disabilities. Public transportation providers are required to ensure their services, vehicles, and facilities are accessible to and usable by individuals with disabilities. IMCR provides assistance to public transportation providers in interpreting ADA requirements and guidance.

Equal Employme​nt Opportunity

The Federal Transit Administration is responsible for ensuring that its recipients do not engage in discrimination in the workplace based on federal requirements.

A Federal Transit Administration applicant, recipient, subrecipient​, or contractor must implement all EEO Program​ elements if they meet the following criteria:
  • Employs 100 or more transit-related employees and;
  • Requests or receives capital or operating assistance over $1 million in the previous Federal fiscal year; or planning assistance over $250,000 in the previous Federal fiscal year.
Agencies that meet the monetary requirement but employ 50-99 transit-related employees must maintain an abbreviated EEO Program, which does not need to be submitted unless requested by the Federal Transit Administration or Intermodal Civil Rights.

Agencies must include all part-time employees and employees that have duties that support the transportation system in their calculations. For example, a budget analyst who processes payments for the transit program would be considered a transit-related employee.

For further information on Equal Employment Opportunity:


Langu​age Access

Public transportation providers satisfy language access compliance obligations by having a Language Access Plan as part of their Title VI program.

Americans with Disabilities Act (ADA) and accessibility:

If you're experiencing a barrier to access to Oregon state transportation systems or services, please let us know by completing our Comments, Questions, Concerns, and Requests (CQCR) online form.

Title VI and Discrimination:

Discrimination occurs when someone treats another person unfairly or harasses that person because of what they believe about the person's protected class status. Protected classes under Title VI of the Civil Rights Act of 1964 are race, color, national origin, age, disability, sex, income level or Limited English Proficiency (LEP). Oregon recognizes additional protected classes.

If you need help from ODOT related to a discrimination concern, or if you want to file a discrimination complaint with ODOT, please visit our Civil Rights Concerns and Discrimination Complaints at ODOT​ page. This page provides information about our different concern and complaint options and links to online forms and more resources.

​​You can email our Administrative Office, our ADA Program Manager, or our Title VI Officer for assistance. You can also reach us using one of the following methods:
  • Administrative Office Phone: 503-986-4350
  • Title VI/ADA Toll Free Line: 855-540-6655
  • TTY: 800-735-2900
  • Oregon Relay Service: 7-1-1
  • Fax: 503-986-6382​


Contact Information:
Intermodal Civil Rights Program Manager

ODOT
Office of Engagement and Civil Rights
800 Airport Road SE
Salem, OR 97301
503-302-4524