Department of Civil Rights Norman D. Davis, Director City?County Building, Room 523 Affirmative Action Division 210 Martin Luther King, Jr. Boulevard Disability Rights and Services Program Madison, Wisconsin 53703 . Equal Opportunities Division Phone: (608) 266-4910 Racial Equity and Social Justice Fax: (608) 266-6514 7 dcr@cityofmadison.com January 3, 2018 Charles E. James Sr., Director, FTA Office of Civil Rights East Building, 5th Floor? TCR 1200 New Jersey Avenue, SE Washington, DC 20590 Dear Director James, The Wisconsin Department of Transportation is a federal transportation fund recipient that is subject to Title VI of the 1964 Civil Rights Act and the Americans with Disabilities Act. Please accept this letter as a Civil Rights Complaint in relation to the Wisconsin Department of Transportation's (?WisDoT?) recent decision to close, combine, and relocate two key Department of Motor Vehicle services centers on the west side of Madison, Wisconsin. The basis of the Complaint is that WisDoT?s decision disparately impacts racial minorities and disabled persons who live near the existing service centers and/or rely on public transit to obtain services from them. The purpose of this brief letter is to describe the Complaint and provide details that will assist your office investigate this issue. For decades, WisDoT has maintained a comprehensive DMV service center on the West side of Madison at 4802 Sheboygan Avenue in Madison. WisDoT also maintains a second DMV service center on the West side of Madison at 6514 Odana Road. Both of these locations are on major transit lines of service and are located immediately adjacent to bus stops. Moreover, both service centers are located near and, in some cases, within walking distance of affordable housing that is occupied primarily by racial minorities, the elderly, and people of low income. For example, as noted on the attached City of Madison Demographic map, the Sheboygan Avenue DMV Center is located in voting Ward 84, which is a ward classified as containing one the greatest number of non-white populations in Madison according to the 2010 U.S. Census. In 2017, in conjunction with the construction of a new Department of Transportation building, WisDoT decided to close both west side services centers and relocate them to a single location on the west side of Madison. WisDoT issued a Request for Proposals for the new location. Ultimately, WisDoT, through the Wisconsin Building Commission, chose to combine the Sheboygan Avenue and Odana Road DMV service centers at 8417 Excelsior Drive in Madison. This transition is due to take place in January 2018. As pointed out by the Madison Area Transportation Planning Board in a November 15, 2017 letter to the Secretary of WisDoT: ?The Excelsior Drive location, in contrast [to the current service centers], is relatively inaccessible by transit. Only one route Madison Metro Route 15 directly serves Excelsior Drive. However, the Route 15 does not serve the location between 9:30 am. and 3:30 pm. The location is also indirectly served by Route 73 operating from the West Transfer Point once per hour, but this requires a .3 January 3, 2018 Page 2 mile walk from the nearest bus stop.? This assertion is confirmed by data provided by the City?s bus system, Madison Metro Transit, which shows significantly increased transit times to the Excelsior address. For example, a round trip from the intersection of Badger Road and Cypress Road to the current DMV Center on Sheboygan Avenue takes approximately 41 minutes. A round trip from the same location to the new Excelsior Drive location will take 64 minutes (+23 minutes). Metro Transit data shows a similar increase in service time from the intersection ofAllied Drive and Lovell Lane (+21 minutes). Importantly, both of these points of origin (Badger Road and Allied Drive) are neighborhoods in Madison with predominately racial minority residents who rely heavily on public transit for all of their transportation needs, including traveling to the DMV for services. As noted on the attached demographic map, Badger Road (Ward 73) and Allied Drive (Ward 76), like Sheboygan Avenue, are two wards containing the highest number of non-white populations in Madison. In addition to increased travel time, the new DMV Center at Excelsior Drive will require customers to walk.3 miles after disembarking their bus, thus disparately impacting the elderly and disabled who may not be capable of walking that far on their own. Finally, whereas the previous DMV service centers were located adjacent to or near housing occupied by racial minorities and the disabled, the new DMV location on Excelsior Drive is located in a predominately white neighborhood. As noted on the attached demographic map, Excelsior Drive is located in Ward 110, which is noted as containing a significantly lower number of non- white residents. Thus, the decision to combine and move the west side DMV service centers to an area that is relatively inaccessible by transit disparately impacts racial minority residents who rely primarily on transit to reach the DMV for services, including, for example, obtaining a driver's license for the first time or obtaining a voter ID. DMV customers who already drive and do not rely on transit are not similarly impacted. In fact, WisDoT ensured that driving customers were accommodated by providing more than 167 parking spaces at the new DMV Center. in reviewing the documents related to the decision to relocate to Excelsior Drive, access to transit played a minimal role in WisDoT?s deliberations and even reveal that WisDoT was aware that Excelsior Drive was not nearly as accessible to public transit as other locations under consideration. Whether WisDoT intentionally chose a less transit friendly location is unclear. What is clear is that clear disparate impact the decision will have on racial minorities and disabled persons who rely on public transit to obtain DMV services. Please let us know if you have any questions. We stand ready to provide further information upon request. Sincerely, %0 Norman D. Davis Director Cc: Mayor Paul Soglin Madison Common Council Mike May, City Attorney Bill Schaefer, Metropolitan Planning Organization Yvette Rivera, Associate Director, USDOT Departmental Office of Civil Rights