Civil Rights Requirements
Third Party Procurement
Frequently Asked Questions
Q = Question; A = Answer
Q. FTA previously had a circular that dealt with the employment requirements for third party contractors as it related to work hours for minorities and females. What is the circular number and where can a copy be obtained?
A. The Circular you referenced is the Equal Employment Opportunity Program Guidelines for Grant Recipients, Circular 4704.1. (Revised: May 2010)
Q. What is the extent of the translation services that must be provided in the land acquisition and relocation services process? One commercial tenant is Chinese and does not speak English. The son of the tenant does speak English. Is it mandatory for the City to have all documents (letters, relocation survey, relocation procedures and benefits) translated into Chinese, or is it sufficient to engage the services of a translator to provide verbal translation as requested by the tenant?
A. The FTA Office of Civil Rights and the FTA Chief Counsel's Office have reviewed your question and it is their opinion that the relevant documents must be translated in writing. Following is their opinion:
National origin discrimination is prohibited under Title VI. Specifically a person who is limited English proficient (LEP) could allege national origin discrimination if they are denied equal access to a benefit of a vital document.
A land acquisition document would be considered a vital document. Therefore, it needs to be translated so that the LEP can make a decision as to whether they should accept any property acquisition offer. If the documents are not translated, then the individual may not be able to make an important decision that could result in their denial of monetary resources. (Posted: September, 2010)