Access to Services by persons with Limited English Proficiency (LEP)

Introduction

This Limited English Proficiency (LEP) Plan has been prepared to address Southeast Area Transit District’s responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964; Federal Transit Administration Circular 47052.1A dated May 13, 2007, which states that the level and quality of transportation service is provided without regard to race, color, or national origin.

Executive Order 13166, titled Improving Access to Services for Persons with Limited English Proficiency, indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discriminations do not take place. This order applies to all state and local agencies which receive federal funds.

Plan Summary

Southeast Area Transit District (SEAT) is the provider of public transportation service in New London County. SEAT has developed this LEP Plan to help identify reasonable steps for providing language assistance to persons with Limited English Proficiency who wish to access services provided by SEAT. As defined in Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write or understand English. This plan outlines how to identify a person who may need language assistance, and the ways in which assistance may be provided.

In order to prepare this plan, SEAT undertook the U.S. Department of Transportation (U.S.DOT) four-factor LEP analysis which considers the following factors:

1. The number and proportion of LEP persons in the service area who may be served or are likely to encounter a SEAT program, activity or service.
   The SEAT staff reviewed the 2011 U.S. Census American FactFinder Report and determined that approximately 35,518 persons in New London County [13.7% of the population] speak a language other than English. Of those 35,518 persons 54.7% speak English “very well” while 45.3% speak English less than “very well.” In New London County, of those persons with limited English proficiency, 14,846 speak Spanish, 12,813 speak Indo-European languages, 7,124 speak Asian and Pacific Island languages, and 770 speak “other languages.”
   
   
2. The frequency with which LEP persons come in contact with SEAT programs, activities or services.
   The SEAT staff reviewed the frequency with which office staff, dispatchers and drivers have, or could have, contact with LEP persons. To date, SEAT has at least 2 to 3 requests per month via telephone for an interpreter in Spanish. SEAT has an average of 1,300 calls per month.
   
   
3. The importance of programs, activities or services provided by SEAT to the LEP population.
   There is no large geographic concentration of any type of LEP individuals in the service area for New London County. The overwhelming majority of the population, 86.3%, speaks only English. 5.7% speak Spanish or Spanish Creole, 4.9% speak Indo-European languages 2.7% speak Asian and Pacific Island languages and .3% speaks “other languages.” SEAT staff are most likely to encounter LEP individuals through office visits, phone conversations and notifications from the office of impacts on services and fare increases.
4. The resources available to SEAT and overall cost to provide LEP assistance.
   SEAT staff reviewed its available resources that could be used for providing LEP assistance. SEAT utilizes the bi-lingual dispatcher to translate documents into a Spanish translation if needed. SEAT is currently researching a company which offers a language line to LEP individuals. Essentially other language translations would be provided through the telephone interpreter line for which SEAT would pay a fee.
   Based on the four-factor analysis, SEAT developed its LEP Plan as outlined in the following section.

Limited English Proficiency LEP Plan Outline

How SEAT and staff may identify an LEP person who needs language assistance:

• Examine records to see if requests for language assistance have been received in the past, either at meetings or over the phone to determine whether language assistance might be needed at future events or meetings.
• Have staff person greet participants as they arrive to SEAT sponsored events. By informally engaging participants in conversation it is possible to gauge each attendee’s ability to speak and understand English.
• Have Census Bureau Language Identification Flashcards available at SEAT meetings. This will assist SEAT in identifying language assistance needs for future events and meetings.
• Have Census Bureau Language Identification Flashcards on all transit vehicles to assist vehicle operators in identifying specific language assistance needs of passengers. If such individuals are encountered, vehicle operators will be instructed to try to obtain contact information to give to SEAT management for follow-up.

Language Assistance Measures

There are various ways in which SEAT staff responds to LEP persons, whether in person, by telephone or in writing.

• Post the SEAT Title VI Policy and LEP Plan on the agency website, www.seatbus.com
• To the extent feasible assign bilingual drivers to vehicle runs serving groups with a high concentration of LEP riders
• To the extent feasible assign bilingual staff for community events, public hearings and Board of Director meeting and on the customer service phone lines. Language assistance services will be arranged with a professional translation service. SEAT is currently researching a company which offers a language line to LEP individuals.
• Survey bus drivers, front-office staff, dispatchers, annually and Ops Supervisors related to their experience and contact with LEP persons during the previous year.

Staff Training

The following training will be provided to SEAT staff:

• Information on SEAT Title VI Procedures and LEP responsibilities
• Description of language assistance services offered to the public
• Use of Language Identification Flashcards
• Documentation of language assistance requests

Providing Notice to LEP Persons / Outreach Techniques

When staff prepares a document or schedules a meeting, for which the target audience is expected to include LEP individuals, documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population. Flyers shall be put in buses, the transit station and other main transfer areas in our services areas. Announcements will be posted on SEAT’s website at www.seatbus.com and in the two largest newspapers in the region.

Monitoring and Updating the LEP Plan

SEAT will update the LEP as required by U.S.DOT. At minimum, the plan will be reviewed and updated when it is clear that higher concentrations of LEP individuals are present in the SEAT service area. Updates included the following:

• How the needs of LEP persons have been addressed
• Determination of the current LEP population in the service area
• Determination as to whether the need for translation services has changed
• Determine whether local language assistance programs have been effective and sufficient to meet the needs
• Determine whether SEAT’s financial resources are sufficient to fund language assistance resources as needed.
• Determine whether SEAT has fully complied with the goals of this LEP Plan
• Determine whether complaints have been received concerning SEAT’s failure to meet the needs of LEP individuals.