5100-145 FAA Title VI Pre-Grant Award Checklist

U.S. Department
of Transportation
Federal Aviation
Administration

FAA Form 5100-145, FAA Title VI Pre-Grant Award Checklist
Paperwork Reduction Act Statement
A federal agency may not conduct or sponsor, and a person is not required to respond to, nor
shall a person be subject to a penalty for failure to comply with a collection of information
subject to the requirements of the Paperwork Reduction Act unless that collection of information
displays a currently valid OMB Control Number. The OMB Control Number for this information
collection is 2120-0569. Public reporting for this collection of information is estimated to be
approximately 8 hours per response, including the time for reviewing instructions, searching
existing data sources, gathering, and maintaining the data needed, completing and reviewing
the collection of information.
All responses to this collection of information are required under 49 U.S.C. Section 47105 to
retain a benefit and to meet the reporting requirements of 2 CFR 200. Send comments
regarding this burden estimate or any other aspect of this collection of information, including
suggestions for reducing this burden to: Information Collection Clearance Officer, Federal
Aviation Administration, 10101 Hillwood Parkway, Fort Worth, TX 76177-1524

Instructions for Form 5100-145,
FAA Title VI Pre-Grant Award Checklist
This Checklist must be completed and submitted by the sponsor as a part of each FAA grant
application.
"Yes" responses mean that the sponsor is currently in compliance or has a corrective action
plan approved by the FAA Office of Civil Rights (FAA) to come into compliance. "No" responses
mean there is a potential compliance issue. Compliance issues will be brought to the attention
of the FAA to determine if corrective actions are necessary. If there are any questions, please
contact [email protected].
References to "Title VI" in this checklist include Title VI of the Civil Rights Act of 1964 and
related authorities that expand or clarify nondiscrimination protections in FAA assisted
programs, identified in FAA Order 1400.11
[https://www.faa.gov/regulations_policies/orders_notices/index.cfm/go/document.current/docum
entNumber/1400.11].

FAA Form 5100-145 (11/22)

OMB CONTROL NUMBER: 2120-0569
EXPIRATION DATE: 6/30/2023

U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION

FAA Title VI Pre-Grant Award Checklist
Submission information
Submission date (Pick a date):
Name of airport sponsor:
Submitter’s name:
Title:
Phone number:

Section 1: Questions Concerning Prior Approval of Title VI Program
By selecting "Yes" below, the sponsor certifies that the following documents were provided to, and approved by, the FAA Office of Civil Rights, and
documentation of FAA's approval has been received by the sponsor. The FAA Office reviewing this grant application will confirm the FAA's approval
of the documents in this Section prior to approving the grant application.
A sponsor that has both a Title VI* Plan and a Community Participation Plan, both of which are approved by the FAA and current, and has already
received approval for the information outlined in this Checklist, does not need to complete the remaining questions in Sections 2 and 3 of this
Checklist.
This information is required based on DOT Order 1000.12C, Ch. II, Secs. 3 and 4
[https://www.transportation.gov/mission/us-department-transportation-title-vi-program].

FAA Form 5100-145 (11/22)

Page 1 of 8

Criterion

Notes

1.1 The sponsor has a written
Title VI Plan, approved by the
FAA Office of Civil Rights, and
subsequently adopted by the
recipient, and documentation of
the approval and adoption.

Sponsors must develop and adopt a Title VI Plan
that outlines the recipient’s measures to ensure
compliance with Title VI. A current Title VI Plan on
file with the FAA is sufficient if the Plan is no more
than 3 years old.

1.2 The sponsor has a written
Community Participation Plan
(CPP), or an equivalent public
participation plan (PPP), and
documented approval or
concurrence of the plan from the
FAA Office of Civil Rights.

Sponsors must satisfy CPP requirements as a
condition of receiving an award of federal financial
assistance. To the extent the sponsor has already
prepared a PPP as part of planning or other
requirements of FAA or DOT, that plan or plans may
satisfy the CPP requirement so long as the plan has
incorporated the Title VI requirements as provided
in DOT Order 1000.12C, Ch. II, Sec. 4(a-j).

Response

Comments

Yes
No

If the sponsor does not have an approved Title VI
Plan, select "No" and complete Sections 2 and 3 of
this Checklist.

Yes
No

If the sponsor does not have an approved CPP or
PPP, select "No" and answer question 3.5 in
Section 3 of this Checklist.

If the answers to 1.1 and 1.2 above are both “Yes,” do not complete Sections 2 and 3.
FAA Form 5100-145 (11/22)

Page 2 of 8

Section 2: Questions Concerning Applicant Data
By selecting "Yes" below, the sponsor certifies that the following documents have been collected in its records prior to submitting this grant
application and will be timely made available to FAA staff, including from the FAA Offices of Airports, Chief Counsel, and Civil Rights, upon request.
"Timely available" usually means within 1 week or less, depending on the scope and circumstances. The data should already be available in a
format that can be forwarded, as-is. No further data collection or summarization efforts should be necessary to respond to the request.
This information is required by DOT Order 1000.12C, Ch. II, Sec. 2; 49 CFR 21.9; and FAA Order 1400.11.
Criterion

Notes

2.1 The sponsor has, on file,
demographic information for the
surrounding community and
communities otherwise affected
by the sponsor’s facilities and
operations, including any airport
noise and relocations.

At a minimum, data is required for race, color,
national origin, and limited English proficiency
(LEP) populations. The collected data must
include the most current U.S. Census Bureau data,
where available, such as American Community
Survey data.

2.2 The sponsor has, on file,
demographic information for
beneficiaries. For example, if the
applicant is an airport operator, it
has collected information for its
airport customers.

In most cases, this type of information is available
through voluntary disclosures by customers,
lessees, community meeting attendees, and
businesses seeking opportunities with the
applicant.

FAA Form 5100-145 (11/22)

Response

Comments

Yes
No

EJScreen [www.epa.gov/ejscreen] is a useful
resource for assessing project areas.

Yes
No

If not applicable or after reasonable efforts, no
information was collected, respond, "Yes."

Page 3 of 8

Criterion

Notes

2.3 The sponsor has, on file,
demographic information for their
staff.

In most cases, this type of information is available
through voluntary disclosures. See also 49 CFR §
21.5(c).

Response

Comments

Yes
No

If not applicable or after reasonable efforts, no
information was collected, respond, "Yes."

2.4 The sponsor has, on file,
demographic information for
individuals who are members of
planning or advisory boards
overseeing the applicant’s
programs, including its airport
operations (if applicable).

Airport sponsors, the most common FAA grant
applicants, commonly have appointed boards or
are overseen directly by elected bodies, such as
city councils. In addition, input for specific projects
or sponsor priorities is often provided by standing
appointed committees. If not already available, the
information can be requested on a voluntary basis.

Yes
No

If not applicable or after reasonable efforts, no
information was collected, respond, "Yes."

FAA Form 5100-145 (11/22)

Page 4 of 8

Section 3: Questions about the Sponsor's Programs
By choosing "Yes" below, the sponsor certifies that the related statements are true.
This information is required by DOT Order 1000.12C, Ch. II, Secs. 2, 3, and 4.
Criterion

Notes

3.1 The sponsor’s programs,
including any airport operations,
have been evaluated for potential
impact based on race, color,
national origin (including limited
English proficiency (LEP)), or lowincome status as part of an
environmental review process
consistent with FAA requirements.

Relevant requirements include Title VI of the Civil
Rights Act of 1964 (42 U.S.C. 2000d, et seq.)
(“Title VI”), DOT’s Title VI regulations at 49 CFR
part 21, Executive Order 12898, and DOT Order
on Environmental Justice (Order 5610.2C).

Response

Comments

Yes
No

See Title VI of the Civil Rights Act of 1964
[www.justice.gov/crt/fcs/TitleVI];
49 CFR part 21 [www.ecfr.gov]
DOT Order on Environmental Justice
[www.transportation.gov/transportationpolicy/environmental-justice]

3.2 The sponsor has evaluated
Checklist Section 2 data to identify
any potential disparities based on
race, color, or national origin
(including LEP), as part of an
analysis to identify potential
discriminatory effects, consistent
with FAA requirements.

FAA Form 5100-145 (11/22)

Relevant requirements include Title VI of the Civil
Rights Act of 1964 (42 U.S.C. 2000d, et seq.)
(“Title VI”), DOT’s Title VI regulations at 49 CFR
part 21, Executive Order 12898, and DOT Order
on Environmental Justice (Order 5610.2C).

Yes
No

Page 5 of 8

Criterion

Notes

3.3 The sponsor has performed a
“Four-Factor” LEP analysis for the
sponsor’s programs, including its
airport operations (if applicable).
Plans and procedures and
resources are in place to meet the
identified LEP needs, consistent
with the analysis.

A "Yes" response means yes to both parts of the
question. The LEP analysis must be consistent
with Executive Order 13166 and DOT Policy
Guidance Concerning Recipients' Responsibilities
to LEP Persons (70 FR 74087, December 14,
2005).

3.4 If the sponsor is an airport
sponsor, the FAA Unlawful
Discrimination Poster is displayed
at its public airport facilities.

For airport sponsors, areas where the posters
should be displayed include, as applicable, airport
terminals, fixed base operator facilities, and at
businesses that are open to the public and
operating on airport property, such as hotels. For
larger facilities, posters should be placed so that
people can reasonably be expected to see them,
no matter where they are in the facility. The poster
is available at Airport Civil Rights Program –
National Airport Policy and Compliance
[https://www.faa.gov/about/office_org/headquarter
s_offices/acr/com_civ_support/national_airport_po
licy_compliance/].

If the sponsor is not an airport
sponsor, it uses other effective
methods to inform its customers,
clients, beneficiaries, etc., that it
will not discriminate based on
race, color, national origin
(including LEP), age, sex
(including sexual orientation and
gender identity), or creed, and of
how to file a complaint of
discrimination under Title VI
against the applicant.

FAA Form 5100-145 (11/22)

Response

Comments

Yes
No

See DOT's LEP Guidance
[https://www.transportation.gov/civil-rights/civilrights-awareness-enforcement/dots-lep-guidance].

Yes
No

If applicant is not an airport, the method used to
inform the public must be ongoing and
documented.

Page 6 of 8

Criterion

Notes

3.5 The sponsor's practices for
obtaining proactive and
meaningful public participation to
ensure that (1) beneficiaries, as
well as contractors and subrecipients (if applicable), are
adequately informed about how
programs, projects, and other
activities will potentially affect
them, and
(2) diverse views are heard and
considered throughout all stages
of consultation, planning, and
decision-making processes.

To demonstrate compliance with Title VI, the
sponsor must specifically be able to show how it
affords all members of the community equal
opportunity to provide input, regardless of race,
color, national origin (including LEP), sex
(including sexual orientation and gender identity),
creed, or age, in accordance with Title VI, 49
U.S.C. § 47123, Executive Orders 12898 and
13166, DOT Order 5610.2C, and the DOT LEP
guidance at 70 FR 74087.

3.6 Detailed information for all of
the sponsor's Title VI lawsuits,
investigations, and complaints
filed or pending within the last 2
years been uploaded to the FAA
Civil Rights Connect System or
sent to [email protected],
with receipt acknowledged.

Sponsors must provide the FAA with both the
initial notifications for the individual lawsuits,
investigation, and complaints, and status updates.
The updates are required until at least the time of
grant closeout. The updates must include at least
the outcome of the lawsuits, investigation, and
complaint, and confirmation for resolution of
identified deficiencies.

Response

Comments

Yes
No

Please skip this question if the sponsor has an
FAA-approved community participation plan.

Yes
No

See Appendix C to 49 CFR 21, Sub-part (b)(3)
[available through www.ecfr.gov].
"Title VI lawsuits, investigations, and complaints"
include those alleging discrimination based on
race, color, national origin (including LEP), sex
(including sexual orientation and gender identity),
creed or age.
FAA Form 5100-145 (11/22)

Page 7 of 8

Criterion

Notes

3.7 Detailed information for all
Title VI oversight activities
(including audits, compliance
reviews, and assessments for the
sponsor) performed or pending
within the last 2 years, has been
sent to [email protected],
with receipt acknowledged. This
requirement does not apply to
oversight activities conducted by
FAA.

Sponsors must provide the FAA with both the
initial notifications for the individual audits,
compliance reviews, and assessment, and status
updates. The updates are required until at least
the time of grant closeout. The updates must
include at least the outcome of the audits,
compliance reviews, and assessment, and
confirmation for resolution of identified
deficiencies.

3.8 Detailed information for any
pending grant applications with
Federal agencies other than FAA
identified in the grant application.

FAA Form 5100-145 (11/22)

Response

Comments

Yes
No

See Appendix C to 49 CFR 21, Sub-part (b)(3)
[available through www.ecfr.gov].

The information should be included in narrative
fields of the pending application.

Yes
No

Page 8 of 8