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Intermodal Civil Rights

What is Intermodal Civil Rights?

The 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 the technical support and compliance measures for ODOT to follow civil rights laws and policies. Since the types of modal projects and services can differ, the requirements on a project may differ as well. 

Resources for Public Transportation Providers

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).

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 minority and traditionally underrepresented 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 goals 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 available for review and feedback.

Under the DBE Program, public transportation providers that receive federal funding from ODOT are required to report semi-annually on contracting and subcontracting to identify contracts that were awarded to firms certified by Oregon's Certification Office for Business Inclusion and Diversity (COBID). Semi-annual reports are due May 15 and November 15.

Additional DBE Program resources:

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 future 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 useable by individuals with disabilities. IMCR provides assistance to public transportation providers in interpreting ADA requirements and guidance.

Equal Employment Opportunity

The Federal Transit Administration is responsible for ensuring that its recipients do not engage in discrimination in the workplace based on race, color, religion, national origin, sex, gender identity, sexual orientation, genetic information, disability, or veteran status.

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:

Environmental Justice

Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," directs Federal agencies to promote environmental justice (EJ) in agency policies, programs, and activities. Public transportation providers need to identify and address, as appropriate, disproportionately high and adverse human health or environmental effects of their programs, policies, and activities​ on minority and/or low-income populations; ensure full and fair participation by all potentially affected communities in the transportation decision-making process; and prevent the denial of, reduction in, or significant delay in the receipt of benefits by minority am/or low-income populations.

Public transportation providers must consider EJ principles during planning activities and service delivery, including consideration as part of the environmental review required by the National Environmental Policy Act (NEPA).

For further information on Environmental Justice:​

Limited English Proficiency​​

​Executive Order 13166, "Improving Access to Services for Persons with Limited English Proficiency" requires that federal agencies and recipients of federal funding provide services that can be accessed by persons with limited English proficiency. Public transportation providers satisfy most LEP compliance obligations by having a Language Access Plan as part of their Title VI program.

For further information on Limited English Proficiency:

Contact Information:

Carroll Cottingham

Intermodal Civil Rights Manager

Oregon Department of Transportation

800 Airport Road SE

Salem, OR 97301