Crawford Area Transportation Authority Limited English Proficiency Policy Plan
The purpose of this limited English proficiency policy guidance is to clarify the responsibilities of recipients of federal financial assistance from the U.S.Department of Transportation (DOT) and assist them in fulfilling theirresponsibilitiestolimitedEnglishproficient(LEP)persons, pursuant to Title VI of the Civil Rights Act of 1964 and implementing regulations. It was prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq., and its implementing regulations provide that no person shall be subjected to discrimination on the basis of race, color, or national origin under any program or activity that receives federal financial assistance, and;
Executive Order 13166
Executive Order 13166 “Improving Access to Services for Persons With Limited English Proficiency,” reprinted at 65 FR 50121 (August 16, 2000), directs each Federal agency that is subject to the requirements of Title VI to publish guidance for its respective recipients clarifying that obligation. Executive Order 13166 further directs that all such guidance documents be consistent with the compliance standards and framework detailed in the Department of Justice’s (DOJ’s) Policy Guidance entitled “Enforcement of Title VI of the Civil Rights Act of l964-National Origin Discrimination against Persons with Limited English Proficiency.” (See 65 FR 50123, August 16, 2000 DOJ’s General LEP Guidance). Different treatment based upon a person’s inability to speak, read, write, or understand English may be a type of national origin discrimination. Executive Order 13166 applies to all federal agencies and all programs and operations of entities that receive funding from the federal government, including state agencies, local agencies such as the Crawford Area Transportation Authority (CATA) and governments, private and non-profit entities, and sub recipients.
CATA has developed this Limited English Proficiency Plan (LEP) to help identify reasonable steps to provide language assistance for LEP persons seeking meaningful access to CATA services as required by Executive Order 13166. A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English. This plan details procedures on how to identify a person who may need language assistance, the ways in which assistance may be provided, training staff, how to notify LEP persons that assistance is available, and information for future plan updates. In developing the plan while determining CATA’s extent of obligation to provide LEP services, CATA conducted a U.S. Department of Transportation four factor LEP analysis which considers the following: 1) The number or proportion of LEP persons eligible in the CATA service area who may be served or likely to encounter an CATA program, activity, or service; 2) the frequency with which LEP individuals come in contact with CATA services; 3) the nature and importance of the program, activity or service provided by the CATA to the LEP population; and 4) the resources available to the CATA and overall costs to provide LEP assistance. A brief description of these considerations is provided in the following section.
Four Factor Analyses
1. The number or proportion of LEP persons eligible in the CATA service area who may be served or likely to encounter a CATA program, activity, or service.
The CATA examined the US Census report from 2010, and, using data from Census tracts in the CATA service area, was able to determine that approximately 96.1% of people within CATA’s service area age 5 and older spoke English as the primary or only language. Approximately 3.9% or 517 speak a language other than English.
2. The frequency with which LEP individuals come in contact with a CATA program, activity, or service.
CATA assesses the frequency at which staff and drivers have or could possibly have contact with LEP persons. This includes documenting phone inquiries and surveying drivers and customer service personnel. CATA has had no requests for interpreters and zero requests for translated CATA documents. CATA staff and drivers have had very little to no contact with LEP individuals.
3. The nature and importance of the program, activity, or service provided by the CATA to LEP community.
There is no large geographic concentration of any one type of LEP individuals in the CATA service area. The overwhelming majority of the populations, 96.1% of residents speak English. Therefore, for the most part, LEP individuals do not use CATA’s services. However, international students from nearby Allegheny College do use CATA’s fixed-route system. While none of these students have ever required language assistance, and do speak English very well, CATA’s services are very important to these individuals in order to provide access to shopping and leisure activities outside of the Allegheny College Campus.
4. The resources available to CATA and overall costs
CATA assessed its available resources that could be used for providing LEP assistance. This included identifying costs associated with subscription to the Language Line service, the costs of additional translation services such as a professional interpreter on an as needed basis, which documents would be the most valuable to be translated if and when the populations supports, taking an inventory of available organizations that CATA could partner with for outreach and translation efforts, and what level of staff training is needed. After analyzing the four factors, the CATA developed the plan outlined in the following section for assisting persons of limited English proficiency at a low cost.
LIMITED ENGLISH PROFICENCY PLAN OUTLINE
How to Identify an LEP Person who Needs Language Assistance
Below are tools to help identify persons who may need language assistance:
- Examine records requests for language assistance from past meetings and events to anticipate the possible need for assistance at upcoming meetings;
- When CATA sponsored meetings are held, set up a sign-in sheet table, have a staff member greet and briefly speak to each attendee. To informally gauge the attendee’s ability to speak and understand English, ask a question that requires a full sentence reply;
- Survey drivers and other first line staff on an annual basis at the beginning of each fiscal year regarding their experience on having any direct or indirect contact with LEP individuals.
Language Assistance Measures
CATA has or will implement the following LEP procedures. The creation of these steps are based on the very low percentage of persons speaking other languages or not speaking English at least “well,” and the lack of resources available in the CATA service area:
- CATA’s Website has been redesigned to include a translator software program which is able to be used at the sidebar of the webpage.
- When an interpreter is needed, in person or on the telephone, staff will utilize the Language Line Service.
CATA Staff Training
All CATA staff will be made available a copy of the LEP Plan and will be educated on procedures to follow. This information will also be part of the CATA staff orientation process for new hires. Training topics are listed below:
- Understanding the Title VI policy and LEP responsibilities;
- Documentation of language assistance requests;
- How to handle a Title VI and/or LEP complaint
CATA does not have a formal practice of outreach techniques due to the lack of LEP population and resources available in the service area. However, the following are a few options that CATA will incorporate when and/or if the need arises for LEP outreach:
- If staff knows that they will be presenting a topic that could be of potential importance to an LEP person or if staff will be hosting a meeting or a workshop in a geographic location with a known concentration of LEP persons, meeting notices, fliers, advertisements, and agendas will be printed in an alternative language, based on known LEP population in the area.
- Key print materials will be translated and made available at the CATA Administration facility and in communities when a specific and concentrated LEP population is identified
Monitoring and Updating the LEP Plan
This plan is designed to be flexible and is one that can be easily updated. At a minimum, CATA will follow the Title VI Program update schedule for the LEP Plan.
Each update should examine all plan components such as:
- How many LEP persons were encountered?
- Were their needs met?
- What is the current LEP population in CATA service area?
- Has there been a change in the types of languages where translation services are needed?
- Is there still a need for continued language assistance for previously identified CATA programs? Are there other programs that should be included?
- Have CATA’s available resources, such as technology, staff, and financial costs changed?
- Has CATA fulfilled the goals of the LEP Plan?
- Were any complaints received?
As part of the monitoring and update plan, CATA will track the activity of usage of its services by LEP persons and requests for assistance from Customer Service and Operator staff, and record information from passenger surveys which will identify the language spoken by passengers and their need for assistance. CATA will also maintain communication with municipalities in its service area to identify LEP individuals who may have moved into a part of CATA’sserviceareaandmayrequireassistance.These municipalities will also be instructed to contact CATA with any requests that they may receive for language assistance.
Dissemination of the CATA Limited English Proficiency Plan
CATA includes the LEP plan on the CATA website together with its Title VI Policy and Complaint Procedures. CATA’s Notice of Rights under Title VI to the public is available in the CATA Administration facility.
Any person, including social service, non-profit, and law enforcement agencies, along with other community partners with Internet access will be able to access the plan.
Copies of the LEP Plan will be provided upon request. LEPpersonsmayobtain copies/translations of the plan upon request.
Any questions or comments regarding this plan should be directed to the CATA Title VI Coordinator.
CATA Title VI Coordinator
Crawford Area Transportation Authority
214 Pine Street
Meadville, PA 16335