Covered agencies can only benefit from a clear explanation within the T6 Circular or a separate directive on how age and sex are addressed in FTA civil rights regulations, but outside of T6. For example, via nondiscrimination authorities Age Discriminaton Act of 67, 75; Civil Rights Restoration of 87; 49 USD 5332; or signed agreements between FTA and agencies. Primary users of transit and transit facilities fall within these two groups, i.e. female head of household, children, elderly, etc. Agencies should be clear about their obligations to these groups. FTA should also reconsider how complaints from such users would be handled based on those protections outside of T6.
Aketa Emptage - Comments
This is comment on Notice
Proposed Circulars: Title VI
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