Minnesota Department of Transportation Title VI Implementing Plan Report FFY 2013

Transcription

1 Minnesota Department of Transportation Title VI Implementing Plan Report FFY 2013 Prepared by: Maria M. Conley, JD October 1, 2013

2 Table of Contents MnDOT Title VI Policy Statement... 1 MnDOT Standard U.S. DOT Title VI Assurances... 2 Title VI Implementing Plan Report... 4 FFY 2013 Title VI Highlights and 2014 Goals... 8 Complaint Form... 9 Complaint Procedures MnDOT Title VI Liaison List ADA Policy & Accessibility Memo Environmental Justice Limited English Proficiency Four Factor Analysis...19 Office of Civil Rights Organizational Chart.23 MnDOT Organizational Chart..24

3 1 MnDOT Title VI Implementing Plan Report FFY 2013

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6 October 1, 2013 Mr. Derrell Turner Division Administrator Minnesota Division Federal Highway Administration Galtier Plaza, Box East 5 th Street, Suite 500 St. Paul, MN RE: The Minnesota Department of Transportation Title VI Implementing Plan Report for Federal Fiscal Year (FFY) 2013 Dear Mr. Turner: In accordance with the 23 CFR 200.9(b) the Minnesota Department of Transportation (MnDOT) submits this Title VI Implementing Plan for Federal Fiscal Year Accomplishments for FFY 2013 are highlighted in the document following this letter. State actions to implement the Title VI program as required by 23 CFR (b) 1-15 are as follows: (1) and (2) Establish a civil rights unit and designate a coordinator and Adequately staff the civil rights unit to effectively implement the State civil rights requirements. The authority to manage MnDOT s Title VI Program is delegated to the Office of Civil Rights under the direction of D. Kimberly Collins, JD, who appoints the Title VI Coordinator. Ms. Collins is the Acting Director of the Office of Civil Rights, having been appointed to the position in July, In addition, Maria M. Conley, JD, was hired as the Contract Compliance Supervisor and Title VI Coordinator in April, Jeffrey Pabarcus, JD was hired in September 2013 to implement additional activities under the requirements for Title VI. The Office of Civil Rights currently has a vacancy in the Deputy Director position. In addition to these changes, the Commissioner of Transportation has made significant changes to his cabinet in July 2013, streamlining the hierarchy and reporting structure. Kimberly Collins, as the Acting Director of the Office of Civil Rights is committed to ensuring that MnDOT maintains a proactive, interdisciplinary approach to Title VI, requiring that decision makers at MnDOT fully implement Title VI in all project planning and business decisions. MnDOT s Title VI Program requires the appointment of a Title VI Liaison for each District and Department where Title VI is applicable. The Title VI Liaison is responsible for identifying Title VI issues, monitoring Title VI application, supplying Title VI guidance or connecting to resources that can supply guidance, acting as liaison to the Office of Civil Rights, and reporting on Title VI implementation. 4

7 (3) Develop procedures for prompt processing and disposition of Title VI and Title VIII complaints complaints shall be investigated by State civil rights personnel trained in compliance investigations. Identify each complainant by race, color, sex, or national origin; the recipient; the nature of the complaint; the dates the complaint was filed and the investigation completed; the disposition; the date of the disposition The complaint form and procedure for processing and disposition of complaints is included in this report and has not changed in the current fiscal year. Staff who has been hired in the past six months for complaint investigation are both trained attorneys. A log has been developed during this fiscal year to track each complaint as per the statutory requirements and is included as well. (4) Develop procedures for the collection of statistical data (race, color, religion, sex, and national origin) of participants in, and beneficiaries of State highway programs, i.e. relocates, impacted citizens and affected communities. Such procedure for the collection of statistical data regarding individuals has been completed via annual reports from pertinent departments within MnDOT in the past year. Copies of those reports are available for review. (5) and (6) and (7) Develop a program to conduct Title VI reviews of program areas. and Conduct annual reviews of special emphasis program areas to determine the effectiveness or program area activities at all levels. and Conduct Title VI reviews of cities, counties, consultant contractors, suppliers. In prior year reports the Office of Civil Rights has not identified with specificity those program areas in need of review nor the process by which those programmatic reviews would take place. In FFY 2013 the Office is committed to completing Title VI reviews of each numbered District office throughout the state (D1, D2, D3, D4, D6, D7, and D8). All MnDOT departments will be reviewed on a five year cycle, resulting in approximately 7 departmental reviews annually. The District offices have been chosen for immediate review as they are arguably of greatest impact throughout the state, if not at least greatest visibility. The Office of Civil Rights will work with FHWA liaison Mary Walker-Johnson to identify for review appropriate cities, counties, consultant contractors or other recipients of Federal-aid highway funds. (8) Review State program directives in coordination with State program officials and, where applicable, include Title VI and related requirements. MnDOT maintains a Memorandum of Understanding with the Minnesota Department of Human Rights which requires interagency communication and collaboration with meetings between supervisors of each agency s contract compliance unit at least quarterly to evaluate and coordinate construction monitoring and compliance efforts. These meetings have taken place on May 6, 2013; May 28, 2013; July 15, 2013; August 1, In August a new Assistant Commissioner of Human Rights for the Department of Human Rights contract compliance division was hired. The next meeting between MDHR and MnDOT OCR is tentatively scheduled for November 1,

8 (9) The State highway agency Title VI designee shall be responsible for conducting training programs on Title VI and related statutes for State program and civil rights officials. Several trainings took place throughout the state this year for both prime contractors and District engineers, District office managers, and resident engineers. The training plan for 2014 includes District update meetings throughout the state which will include specific Title VI training as well as development of a possible annual event for EEO officers who are employed by MnDOT prime contractors related to best practices for workforce participation, affirmative action, on the job training and apprenticeship programs, and Title VI requirements and responsibilities. (10) Prepare a yearly report of Title VI accomplishments for the past year and goals for the next year. and (11) Beginning October 1, 1976, each State highway agency shall annually submit an updated Title VI implementing plan to the Regional Federal Highway Administrator for approval or disapproval. Although this report has not been filed on a timely basis in the past, the Office of Civil Rights is proud to establish timely reporting effective immediately, with this report. See the FFY 2013 Highlights and (12) Develop Title VI information for dissemination to the general public and, where appropriate, in languages other than English. One new Title VI poster was developed in FFY Planning is underway with the assistance of the Affirmative Action Office to translate several documents including those meeting the Safe Harbor Threshold. The Safe Harbor Provision requires that when persons speaking English less than well are represented as either 5% or 1,000 persons to be served or likely to be affected or encountered, then documents which are considered to be vital are to be translated into those languages. This applies only to written document, not to oral interpreters. However, when it is determined that persons in the affected Safe Harbor Provision groups lack literacy in their native written language of origin, oral interpretation may be provided. Title VI requires that meaningful access to persons with limited English proficiency. Data regarding the changing demographics of Minnesota s immigrant population are kept and regularly updated in order to prioritize services such as linguistic translation of vital documents, website information, signage and diversifying the availability of interpreters. Forms that are currently being translated under the Safe Harbor Provision are the Discrimination Complaint Form, Discrimination Complaint Procedure, Notice of Rights Under Title VI, and notices advising individuals of free language assistance services. The above listed forms will be translated into Spanish, Somali, and Hmong. The State of Minnesota contracts with various vendors to provide the language services necessary to the agency s achievement of its statutory responsibilities. MnDOT remains committed to providing the following language services: Foreign Language Interpreting/Translation: As Minnesota s population becomes more diverse, the need for quality interpretation and/or translation in other languages continues to grow. The State of Minnesota is contracted with Garden & Associates, a market leader in providing top quality comprehensive language services. Sign Language Interpreting: MnDOT is dedicated to providing quality communication services for the hearing impaired. The State of Minnesota is contracted with Dynamic Communications working together to provide interpreters who are ethical and professional, allowing us to meet the communication preferences of each hearing impaired person we employ. 6

9 Accent Modification: Speech and language training can help address communication challenges that arise when employees with different accents try to communicate with each other or with the public. (13) Establishing procedures for pre-grant and post-grant approval reviews of State programs and applicants for compliance with Title VI requirements See (5), (6), and (7) above. (14) Establish procedures to identify and eliminate discrimination when found to exist. and (15) Establishing procedures for promptly resolving deficiency status and reducing to writing the remedial action agreed to be necessary, all within a period not to exceed 90 days. See the attached Minnesota Department of Transportation Title VI Discrimination Complaint Procedure. If there are questions regarding the Mn/DOT Title VI update, please call me at (651) Sincerely, Maria M. Conley, JD Workforce and Contract Compliance Supervisor/Title VI Coordinator Office of Civil Rights cc: Jeff Pabarcus, JD D. Kimberly Collins, JD Elizabeth Parker, JD 7

10 Federal Fiscal Year 2013 Title VI Highlights Began work towards getting OCR website translated into Hmong, Somali, and Spanish. Training provided to Transit Department to clarify roles related to Title VI implementation for subrecipients. Updated design of Title VI posters. Training provided to Transportation System Management Department related to public outreach for bicycle paths. Investigated several potential Title VI complaints. Reviewed the Title VI compliance of Consultant Services Department. Offered Title VI training to City Engineer s Committee at MnDOT. Updated MnDOT s Title VI Assurances document. Working with the MnDOT Affirmative Action Office to update the agency s policy on discrimination and harassment. In process of updating MnDOT s Complaint Form and Discrimination Complaint Procedure to ensure prompt processing and disposition of all complaints. In process of translating MnDOT s Complaint Form and Discrimination Complaint Procedure into Spanish, Somali, and Hmong. Created an initial Language Assistance Plan for Limited English Proficiency clients and consumers based upon a Four Factor Analysis completed in August, Attended Council on Tribal Employment Rights meeting. Created a tracking log document for complaints to collect statistical data Designed a schedule for monitoring Title VI activities and conducting annual reviews of pertinent program areas, as well as cities, counties, consultant contractors, and others receiving Federal-aid highway funds to determine the effectiveness of program areas and compliance with Title VI requirements. Served on review panel for Office of Environmental Stewardship Complete Streets program FFY 2014 Goals Conduct agency-wide Title VI training through Districts and Departments. Plan and carry out an EEO Officer s best practices training. Working towards establishing data collection method regarding how many individuals are requesting language assistance and what languages are being requested for translation services to better gauge the needs of our customers as well as requests for accommodations related to accessibility. Develop a program to provide comprehensive public outreach and involvement activities in conjunction with MnDOT Districts and Departments, as well as with stakeholder agencies and organizations. 8

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16 TITLE VI LIAISON LIST as of Linda Christen Administration Cassandra Isackson Aeronautics Lynette Geschwind Affirmative Action Nancy Daubenberger Bridges Vacant Chief Counsel Kevin Gutknecht Communications Vacant Controller/Financial Management Tom Raven Construction and Innovative Contracting Karla Rains Customer Relations Denise Baublitz D1 Brad Scott D2 Betty Jo Winterowd D3 James Schmidt D4 Patty Eckdahl D6 Rebecca Arndt D7 Brenda Wrobel D8 Lynn Clarkowski Environmental Stewardship Ericca Erhard Freight & Commercial Vehicle Operations Scott Peterson Government Affairs Karen Van Dyck Human Resources Tim Leister Information & Technology Services Mike Moran Land Management Ernest Lloyd Maintenance Lisa Bilotta Materials & Road Research Keith Baker Metro Vacant Ombudsman Julie Carr Passenger Rail Steve Ryan Project Management and Tech Support Lynette Roshell State Aid Kirby Becker Modal Planning & Program Management Shane Chatleain Statewide Radio Communications John Peters Traffic, Safety, & Technology Sarah Lenz, Deborah Ellis Transit Peter Morey Transportation System Management 14

17 Americans with Disabilities Act (ADA) Title II of the Americans with Disabilities Act prohibits state and local government agencies from discriminating against individuals with disabilities in access to and use of their services, programs or activities (Subpart A), and prohibits state and local government transportation agencies from discriminating against individuals with disabilities in access to and use of their transportation services, programs or activities. Ken Rodgers, MnDOT s Disability Programs Coordinator has the responsibility for monitoring and enforcing ADA requirements for MnDOT. Mr. Rodgers disseminates a memo (see following document, Annual Accessibility Memo ) that is distributed annually to all MnDOT employees. The memo outlines the Department s and individual s responsibilities in regards to ADA compliance. A copy of this memo has been included as part of this report. 15

18 Minnesota Department of Transportation Affirmative Action Office Office Tel: 651/ MS 200 Fax: 651/ John Ireland Boulevard Saint Paul, MN Memo TO: All MnDOT Employees FROM: Kristin Jorenby Kristin Jorenby Disability Programs Assistant DATE: October 18, 2012 SUBJECT: ADA Title II Accessibility Requirements (MMB PERSL 1358) MnDOT as a public agency must ensure that all of its programs, services and activities are accessible to and usable by individuals with disabilities. Title II of the Americans with Disabilities Act (ADA) requires all state and local government agencies to take appropriate steps to ensure that communications with applicants, participants and members of the public with disabilities are as effective as communications with others. To ensure that persons with disabilities have an opportunity to request auxiliary aides and services to participate in agency programs, services and activities, MnDOT must follow the following state/agency policies: Written Communications Policy All agencies, departments, divisions and units that develop, use and/or purchase written materials for distribution to the public must ensure that each document contain a statement indicating that the information is available in alternative formats to individuals with disabilities upon request. Include the following statement on each document that is distributed: To request this document in an alternative format, please contact the Affirmative Action Office at or (Greater Minnesota); 711 or (Minnesota Relay). You may also send an to ADArequest.dot@state.mn.us. (Please request at least one week in advance). 16

19 Meeting/Program/Event Accessibility Policy Anyone who holds a public meeting, training, program or other event must select an accessible location and indicate this in the meeting notice. All meeting or event notices must include the following statement: To request an ASL or foreign language interpreter or other reasonable accommodation, call Janet Miller at or (Greater Minnesota); 711 or (Minnesota Relay). You may also send an to janet.rae.miller@state.mn.us. (Please request at least one week in advance). If you would like more information on reasonable accommodations or have any questions regarding the ADA, the Minnesota Human Rights Act, or Mn/DOT Disability Programs in the workplace, please contact your District HR/ADA professional or me via at kristin.jorenby@state.mn.us or phone at (711 Minnesota Relay). 17

20 ENVIRONMENTAL JUSTICE INITIATIVES The Office of Environmental Services (OES) has had oversight of MnDOT s Context Sensitive Solutions (CSS) flagship initiative leadership and support as well as co-leadership and co-support for MnDOT s Complete Streets initiative. Both efforts embrace and advocate the needs of and provision of accessibility for all modes and transportation users of all ages and abilities. MnDOT s CSS Director (within OES) also participates in monthly ADA leadership team meetings. The Office of Environmental Stewardship is the home to the Scenic Byways Program. The Scenic Byway Program is grassroots program which uses CSD within communities for all applicable projects. CSS is a comprehensive framework to address all stakeholders in the context of a planning and project development. MnDOT s Office of Civil Rights, MnDOT s Tribal Liaison and Wanda Kirkpatrick from Met Council (Central Corridor Project) all played key roles in a February 2012 Forum on Integrating CSS in MnDOT Services & Programs: Improving Our Abilities to Identify and Address the Needs of Internal & External Customers. Panelists presented and discussed approaches and case studies demonstrating how diversity and changing demographics can be addressed in a more customer-sensitive manner in MnDOT s work force, our contractor s work forces and in working with DBE firms, tribal governments, and other stakeholders. The audience then participated in (4) facilitated break-out groups to identify further issues, problems, opportunities and actions to better address diversity and changing demographics in a more context-sensitive and customer-sensitive manner. The OES Environmental Planning and Design Unit continue to provide both CSS and Complete Streets technical support to MnDOT Central Office and District program and project managers and teams. The Scenic Byways Program and its many partners, including Tribal communities, serve many aspects of economic development and related enrichment of visitor experiences and resident quality of life. The 21 Minnesota Scenic Byways and their perspective organizations are a grassroots organization where all are welcome to participate. This is in accordance with Title VI of the Civil Rights Act of 1964, requires that no person, because of race, color, or national origin, be excluded from participation in, denied the benefits of, or in any other way be subjected to discrimination under any program or activity receiving Federal assistance. Cultural Resources Unit Consultation Agreements Over the last nine years the Cultural Resources Unit has been working with MnDOT Tribal Liaison and the FHWA Environmental Specialist to develop Programmatic Agreements with the 11 federally recognized tribes in Minnesota concerning consultation on federally funded MnDOT projects. Consultation is part of the responsibilities pursuant to Section of the 36 CFR 800 regulations in the implementation of Section 106 of the National Historic Preservation Act. These are agreements between FHWA and the Tribe with MnDOT as a signatory as MnDOT Cultural Resources Unit, in the Office of Environmental Stewardship, provides assistance to the FHWA in complying with environmental law including NEPA and NHPA. We now have Programmatic Agreements in place with six of the tribes including Lower Sioux, Upper Sioux, White Earth, Bois Forte, Fond du Lac, and Grand Portage. We have an agreement waiting for signature with Prairie Island and two currently in the works with Leech Lake and Mille Lacs. Red Lake and Shakopee have been contacted but declined to participate in a formal PA but wish to be consulted if work is proposed within their reservation boundaries. In addition, we consistently consult with five additional tribes, who originally resided in Minnesota, located in North and South Dakota, and Montana. 18

21 August 8, 2013 MEMORANDUM FOR RECORD - UPDATE Subject: MnDOT s LEP policy and implementation 1. Promoting inclusive public participation Given the broad geographic area as well as diverse population across the state, MnDOT uses a variety of methods to promote inclusive public participation in projects. There are 8 MnDOT district offices located throughout the state. This affords more access to a localized point of information on projects as well as participation in public interest meetings regarding significant projects in each district. These meetings are coordinated with assistance from the MnDOT Affirmative Action Office so that interpreters and accessible meeting spaces can be arranged. MnDOT Affirmative Action Office also provides ASL and deaf/blind interpreters, including information in braille. Notices for meetings are sent with invitations to the public to request foreign language interpreters, intended to reach underserved populations including minorities and those with limited English proficiency. Staff who interact with the public on a regular basis such as administrative assistants and reception staff are provided with Language Line information in order to assist callers with translation services, as well as Language Identification Flashcards that include 38 languages indicating Mark this box if you speak so that the appropriate interpreter can be summoned. 2. Requirements to provide meaningful access to LEP persons In addition to full time staffing of the Affirmative Action Office, Minnesota Department of Transportation supports an in-house Office of Civil Rights, including a full time staff position dedicated to Title VI training and investigations. Data regarding the changing demographics of Minnesota s immigrant population are kept and regularly updated in order to prioritize services such as linguistic translation of vital documents, website information, signage and diversifying the availability of interpreters. Forms that are currently being translated under the Safe Harbor Provision are the Discrimination Complaint Form, Discrimination Complaint Procedure, Notice of Rights Under Title VI, and notices advising LEP individuals of free language assistance services. The above listed forms will be translated into Spanish, Somali, and Hmong. The State of Minnesota contracts with various vendors to provide the language services necessary to the agency s achievement of its statutory responsibilities. MnDOT remains committed to providing the following language services: Foreign Language Interpreting/Translation: As Minnesota s population becomes more diverse, the need for quality interpretation and/or translation in other languages continues to grow. The State of Minnesota is contracted with Garden & Associates, a market leader in providing top quality comprehensive language services. Sign Language Interpreting: MnDOT is dedicated to providing quality communication services for the hearing impaired. The State of Minnesota is contracted with Dynamic Communications working together to provide interpreters who are ethical and professional, allowing us to meet the communication preferences of each hearing impaired person we employ. Accent Modification: Speech and language training can help address communication challenges that arise when employees with different accents try to communicate with each other or with the public. 19

22 The availability of language services is communicated through MnDOT s Affirmative Action Plan which is available on both MnDOT s internal and external website, as well as on the Discrimination Complaint Form, Discrimination Complaint Procedures, and Notices of Rights Under Title VI. In addition, public meeting and open house notices are available on MnDOT s external website where there is language with instruction on how to request language assistance. Some examples of interpreting services include but are not limited to: Interpreter for MnDOT Open House Cantonese Phone conference with Business Owner Mandarin Interpreters to translate information to homeowners Spanish, Vietnamese, Cantonese The Safe Harbor Provision requires that when persons speaking English less than well are represented as either 5% or 1,000 persons to be served or likely to be affected or encountered, then documents which are considered to be vital are to be translated into those languages. This applies only to written document, not to oral interpreters. However, when it is determined that persons in the affected Safe Harbor Provision groups lack literacy in their native written language of origin, oral interpretation may be provided. 3. Four Factor Analysis a. The number or proportion of LEP persons eligible to be served or likely to be encountered by the program or recipient. i. How LEP persons interact with MnDOT Persons with Limited English Proficiency interact in several ways with MnDOT; through public meetings, through the website, via walk-in requests for information, and via telephonic inquiries. ii. Identification of LEP communities, and assessing the number or proportion of LEP persons from each language group to determine the appropriate language services for each language group Based on data from the 2010 Census, Minnesota contains six counties with 20% or more persons of color, and 17 counties with 10-20% persons of color. Four counties in Minnesota have foreign born populations in excess of 10%, these include Nobles County (15%), Ramsey County (13%), Hennepin County (12.6%), and Watonwan County (12%). Both Ramsey and Hennepin are metropolitan counties inclusive of the two most populous cities in the state of Minnesota, St. Paul and Minneapolis. Given that the US Census is only conducted every ten years, data was also gathered from the American Community Survey, which is collected annually. Nationwide, over 3.5 million households are asked to participate in the survey. In 2011, of the state population in Minnesota, 210,126 residents indicate that they speak English less than very well. Of those, 84,894 speak Spanish. However, the American Community Survey only provides data for other languages predominantly spoken as aggregate Other Indo European Language and Asian Pacific Islander Language and Other Languages. To identify the most predominant foreign languages spoken in Minnesota information was gathered from the US Department of Education, Consolidated State Performance Reports the five top foreign languages in Minnesota are 20

23 Spanish, Hmong, Somali, Vietnamese and Russian. Those five languages encompass 81.7 percent of all foreign language learners in Minnesota. An annual LEP questionnaire is sent to various Departments within MnDOT to assist in the identification of current internal office practices that may not be sufficient to meet the needs of the LEP community and how the Office of Civil Rights and Affirmative Action Office can be of assistance. Each office within MnDOT has an assigned Title VI representative who is tasked with serving as a liaison to the Office of Civil Rights. When offices are reviewed for Title VI compliance they are asked to explain how their employees are informed about their specific responsibilities under Title VI and asked how the office systematically captures data regarding minorities, women, elderly, disabled, and low income citizens, as well as limited English proficiency residents. iii. The literacy skills of LEP persons in their native languages, in order to determine whether translation of documents will be an effective practice. This is an area that has not been analyzed by MnDOT. iv. Whether LEP persons are underserved by the recipient due to language barriers. MnDOT is working on an ongoing basis to continually identify and direct services to citizens with language barriers to ensure that LEP persons are not further marginalized due to a language barrier. b. The frequency with which LEP persons come into contact with MnDOT i. Use of bus and rail service-mndot does not operate a bus or rail service. ii. Purchase of passes and tickets through vending machines, outlets, websites, and over the phone-not applicable, as MnDOT does not operate a bus or rail service. iii. Participation in public meetings-persons of limited English proficiency may regularly participate in public meetings with MnDOT. iv. Customer service interactions-customer service interactions also regularly occur, including both via phone and in person. v. Ridership surveys-not applicable, as MnDOT does not operate a bus or rail service. vi. Operator surveys-not applicable, as MnDOT does not operate a bus or rail service. c. The nature and importance of the program, activity, or service provided by the program to people s lives. Given that MnDOT s activities affect transportation systems of all kinds, the impact on limited English proficiency persons cannot be overstated. Additionally, the activities of MnDOT at times include eminent domain actions. 21

24 d. The resources available to MnDOT for LEP outreach, as well as the costs associated with that outreach. The importance of information to be provided and potential impact on the daily lives of residents with limited English proficiency has led MnDOT to staff a full time Language Services Program Manager through the Affirmative Action Office. MnDOT has assigned the LEP plan expansion to this staff person who will assist district offices with identifying their roles and responsibilities in facilitating services for limited English proficiency residents. Expanding the knowledge base and awareness of internal project managers and engineers regarding the obligations of MnDOT to provide assistive services to LEP individuals is just one function of the Language Service Program Manager. The office is also working with the Communications Department to make the thousands of pages of website information accessible and translated into Spanish, Hmong, and Somali. In addition the Department supports district offices in partnering with local agencies to assist in outreach to traditionally underserved communities. MnDOT anticipates that this will be a growth area for the Department, and the current focus is on expanding awareness of the needs of LEP community members as well as the legal obligations of the Department as well. If there are any questions or concerns regarding this document, please contact the undersigned at (651) or maria.conley@state.mn.us. Maria Conley, JD Contract Compliance Supervisor MnDOT Office of Civil Rights 22

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