Receipt of Complaint
The coordinator will log in the complaint and promptly send copies of the complaint to any office named in the complaint, the City’s Law Department, and the Airport CEO. Complaints must be filed within 180 days of the alleged discriminatory event, must be in writing, and must be delivered to the physical or email address below:
Denise Bailey, Deputy Director of Aviation for Business Diversity and Accessibility
Department of Aviation – Office of Business Diversity
2 International Plaza, Suite 400
Philadelphia, PA 19113
Phone: 215-937-1801
Email: [email protected]
If a complaint is initially made by phone, it must be supplemented with a written complaint before 180 days after the discriminatory event has passed. If a verbal complaint is received, the complainant should be given a copy of the Airport Discrimination Complaint Procedures and instructed to submit a written complaint. Accommodation will be provided upon request to individuals unable to file a written complaint due to a disability.
Initial Procedure
The coordinator may meet with the complainant to clarify the issues, obtain additional information, and determine if informal resolution might be possible in lieu of an investigation. If successfully resolved, the coordinator will issue a closure letter to the complainant, record the disposition in the complaints log, and report the resolution to FAA.
Discrimination Complaint Referral Procedure
Internal Complaint Referral
All Title VI complaints must be promptly forwarded to the coordinator within one day of receipt.
Initial FAA Notification
A copy of each Title VI complaint will be forwarded to the FAA within 15 days of initial receipt (not the date that the coordinator was notified). The coordinator will forward a copy of the complaint and a statement describing all actions taken to resolve the matter, and the results thereof to the FAA Civil Rights staff, if available at that time. If not available at that time, results thereof will be forwarded once complete. (Note: complaints based on disability do not have to be forwarded to FAA.) To transmit complaint information to the FAA, the Coordinator will upload it to the FAA Civil Rights Connect System and confirm receipt via email. The coordinator will also seek technical assistance from FAA, as needed, throughout complaint intake, investigation and resolution process.
Investigation Procedure
Assignment of Investigator
The coordinator will immediately begin the investigation or designate an investigator.
Cooperation with FAA
The coordinator will promptly investigate all Title VI complaints, including those referred by the FAA for investigation. If the FAA is investigating a complaint against the Department of Aviation, the Coordinator will avoid interfering with the FAA investigation, cooperate with the FAA when needed, and share factual information with the FAA.
Prompt Investigation
The coordinator will make every effort to complete discrimination complaint investigations within 60 calendar days after the complaint is received. Some investigations may take longer with a justification for the delay and assurance that the investigation is being completed as quickly as possible.
Contact with Complainant
The coordinator will meet with the complainant to clarify the issues and obtain additional information, and speak with community members and potential witnesses, as appropriate.
Investigation Report
After completing the investigation, the coordinator will prepare a written report.
Consultation with Legal Counsel
In each case, the coordinator will consult with Legal Counsel regarding the investigation and the report. Airport Legal Counsel will ensure that the report is consistent with the DOT and FAA Title VI nondiscrimination requirements.
Prompt Resolution of Disputes
The coordinator will emphasize voluntary compliance and quickly and fairly resolve disputes with complainants, or with contractors, tenants, or other persons, through mediation with the complainant and contractor/tenants/other persons involved in the dispute.
Forwarding Report and Response to Complainant
At the completion of the investigation, the complainant and respondent will receive a letter of findings and determination of the investigation and any applicable resolution. The letter transmitting the findings and any applicable resolution will state the Department of Aviation’s conclusion regarding whether unlawful discrimination occurred and will describe the complainant’s appeal rights. A summary of the investigation report, any appeal, or follow-up actions will be sent to the FAA via the FAA Civil Rights Connect System.
Appeal Rights
The complainant must be notified of their right to appeal the findings or determinations, and of the procedures and requirements for an appeal:
- The complainant may appeal in writing to the Airport CEO.
- The written appeal must be received within 30 business days after receipt of the written decision.
- The written appeal must contain all arguments, evidence, and documents supporting the basis for the appeal.
- The CEO will issue a final written decision in response to the appeal.
Avoiding Future Discrimination
In addition to acting with respect to any specific instances of discrimination, the Airport will identify and implement measures to reduce the chances of similar discrimination in the future.
Intimidation and Retaliation Prohibited
Airport employees, contractors, and tenants will not intimidate or retaliate against a person who has filed a complaint alleging discrimination.
For information on filing a complaint with DOT/FAA, please contact Denise Bailey, Deputy Director of Aviation, Business Diversity and Accessibility.
PHL's Title VI Plan