Editor’s Note – On January 2, 2018, the Wisconsin Department of Transportation (WisDOT) announced that it would open a new DMV center on Excelsior Drive west
of the Beltline Hwy. and north of Old Sauk Road and permanently close its Hill Farm and Odana Road locations, leaving the only DMV locations on Madison’s far
west and far east sides. This move had the potential of creating accessibility issues for people dependent upon public transportation including communities of color,
the elderly and people with disabilities. And with the possible impact on people’s abilities to obtain driver’s licenses and state IDs, it also would have ramifications
on people’s ability to vote as driver’s licenses and state IDs are required for people to vote. On January 3, 2018, the city of Madison through the Department of Civil
Rights filed a civil rights complaint with the director of the U.S. Department of Justices’ Office of Civil Rights. The following is a reproduction of the contents of that

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 ("DMV") 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 a.m. and 3:30 p.m. 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 of Allied 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 nonwhite 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.

Norman D. Davis

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
Madison files Civil Rights Complaint
against WisDOT