# Transportation civil-rights certifications of the State of Minnesota *Federal nondiscrimination certifications and reporting requirements bearing on the State of Minnesota* The record assembled for this article contains no transportation civil-rights certification submitted by the State of [[Minnesota]]. It also contains no Minnesota filing under the federal programs described below, and no federal review, complaint or finding about any such certification. The record therefore does not establish what Minnesota certified, on what date, or to which agency.[^1][^2] The evidence pack lists the Federal Transit Administration's certifications-and-assurances page and the Federal Highway Administration's [[Title VI]] program page, but it quotes neither.[^1][^2] It also lists an eCFR extract of 28 C.F.R. 42.302 and the api.fac.gov endpoint, with no text from either.[^3][^4] What the record does contain is two federal instruments that set reporting and planning duties for state governments. The first is the Equal Employment Opportunity Commission's EEO-4 workforce report. By its terms, it applies to all state and local governments with 100 or more employees.[^5] The second is the Department of Justice's checklist for state implementation plans under the STOP Formula Program.[^6] Neither document names Minnesota.[^5][^6] Neither concerns transportation programs.[^5][^6] ## What The EEOC describes the State and Local Government Information Report (EEO-4) as a mandatory data collection. Covered governments must report the demographics of their workforce by race/ethnicity, sex, job category and salary band.[^5] The EEOC gives the legal basis for the filing as section 709(c) of [[Title VII]] of the [[Civil Rights Act of 1964]], 42 U.S.C. 2000e-8(c), together with 29 CFR 1602.30 and .32–.37.[^5] The STOP checklist was issued by the Office on Violence Against Women (OVW). It lists the elements that the STOP statute and regulations require in a state's implementation plan. The plan is a required part of the state's STOP application under 34 U.S.C. 10446(c)(2), (d)(5) and (i), and 28 C.F.R. 90.12 and 90.19.[^6] The checklist states that it "only includes those elements that the statute and regulations require." It adds that a state may include further information.[^6] ## When The EEO-4 is collected every two years.[^5] The EEOC offers a public use file covering 2005 to 2023.[^5] The STOP checklist is marked "Updated April 2019."[^6] Each plan must state the date the state gave it final approval and the period it covers. Under 28 C.F.R. 90.12(g)(3), the plan must describe how the state will meet victims' needs across a four-year implementation period.[^6] ## How Under section 709(e) of Title VII, the EEOC may not release individually identifiable information.[^5] Its EEOC Explore tool publishes data only in aggregate. Public use files show employment characteristics only where no employer or employee can be identified.[^5] The EEOC also notes that Hawaii reports under different race/ethnic categories, so Hawaii's data are left out of the aggregated tables.[^5] The STOP plan must include demographic data on the state's population from the most recent [[United States Census Bureau]] data. That includes data on race, ethnicity, age, disability and limited English proficiency.[^6] The plan must also explain how the state identified underserved populations. The statutory definition of that term, at 34 U.S.C. 12291(a)(39), includes "underserved racial and ethnic populations."[^6] Each member of the planning committee must document their participation: whether they were told of meetings, attended them, reviewed drafts, submitted comments, and received the final plan.[^6] The plan must also describe the state's consultation with tribes, including which tribes and which tribal officials were contacted.[^6] OVW states that it uses a similar tool to review each state's implementation plan.[^6] ## How many The EEO-4 filing duty applies to state and local governments with 100 or more employees.[^5] Under the STOP checklist, a state must say how it will meet the set-aside for culturally specific community-based organizations. That set-aside is 10% of the victim services allocation.[^6] A state must also explain how it will meet the sexual assault set-aside across two or more allocations: law enforcement, prosecution, victim services and courts.[^6] ## Notes [^1]: Federal Transit Administration, *Certifications and Assurances* (undated) — listed in the evidence pack; the record contains no passage from this page. https://www.transit.dot.gov/funding/grantee-resources/certifications-and-assurances/certifications-assurances [^2]: Federal Highway Administration, *Title VI* civil-rights program page (undated) — listed in the evidence pack; the record contains no passage from this page. https://www.fhwa.dot.gov/civilrights/programs/civil-rights/title_vi/ [^3]: Electronic Code of Federal Regulations, *28 C.F.R. 42.302* (eCFR version dated 2026-10-01) — listed in the evidence pack; the record contains no passage from this section. https://www.ecfr.gov/api/versioner/v1/full/2026-10-01/title-28.xml?part=42&section=42.302 [^4]: *api.fac.gov* (undated) — listed in the evidence pack; the record contains no passage from this endpoint. https://api.fac.gov/ [^5]: U.S. Equal Employment Opportunity Commission, *EEO-4 (State and Local Government Information Report) Statistics* (undated web page) — establishes the mandatory biennial EEO-4 filing for state and local governments with 100 or more employees, its basis in section 709(c) of Title VII and 29 CFR 1602.30 and .32–.37, the confidentiality rule in section 709(e), the 2005–2023 public use file, and the exclusion of Hawaii data. https://www.eeoc.gov/data/eeo-4-state-and-local-government-information-report-statistics [^6]: Office on Violence Against Women, U.S. Department of Justice, *STOP Formula Program Implementation Plan Checklist* (updated April 2019) — establishes the required implementation-plan elements under 34 U.S.C. 10446 and 28 C.F.R. 90.12 and 90.19, including Census demographic data, planning-committee documentation, tribal consultation, the four-year implementation period, the 10% culturally specific set-aside, and OVW's review of each state's plan. https://www.justice.gov/ovw/page/file/1575031/dl