Susan Bok - Comments

The proposal to require that Title VI Programs be approved by "the board of directors or appropriate governing entity" is puzzling. Is there a material basis for this new requirement, a pattern of accountability and transparency problems that need to be resolved? FTA should understand that this new requirement could disrupt and jeopardize the Title VI compliance process at the local level. The Program would be ripe for over-politicization, resulting in unintended consequences and uncontrollable delays in the preparation process. This imay not be a problem for transportation authorities with boards of directors comprised of elected officials from other jurisdictions, but when elected officials are on their home turf and holding agendas that range far beyond transportation governance, anything can happen. The problem is exacerbated by the proposed new requirement to submit Title VI Programs at least 30 days before the expiration date. What would be the consequences of late submittal? We recommend that the proposed Circular exempt local recipients from the political approval process where the governing entity is a city council or similar directly-elected body. We also recommend that the due date requirement allow for submittal of a draft document by the expiration date pending any required political approvals.