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Virginia Department of Rail and Public Transportation Virginia Department of Rail and Public Transportation Language Assistance Plan August 10, 2021 1 TABLE OF CONTENTS BACKGROUND ................................................................................................................................. 3 LANGUAGE ASSISTANCE REQUIREMENTS ...................................................................................... 4 FOUR-FACTOR ANALYSIS ................................................................................................................. 6 Factor 1: Assessment of the Number and Proportion of LEP Persons Likely to be Served or Encountered in the Eligible Service Population .......................................................................... 6 Number and Proportion of LEP Persons in the State of Virginia ................................................ 6 Number and Proportion of LEP Population by County ............................................................... 8 Factor 2: Assessment of Frequency with Which LEP Individuals Come Into Contact with the Transit Services or System .......................................................................................................... 9 Factor 3: Assessment of the Nature and Importance of the Transit Services to the LEP Population ................................................................................................................................. 11 Factor 4: Assessment of the Resources Available to the Agency and Costs ............................ 12 DRPT’S LEP IMPLEMENTATION PLAN ........................................................................................... 13 Providing Notice to LEP Persons ............................................................................................... 13 Written Language Assistance .................................................................................................... 14 Vital Documents ........................................................................................................................ 15 DRPT Staff Training ................................................................................................................... 16 Monitoring and Updating the LEP Plan..................................................................................... 16 SUMMARY OF PLAN ...................................................................................................................... 17 APPENDIX A: LEP POPULATION PER JURISDICTION ...................................................................... 18 APPENDIX B: PUBLIC SIGN-IN SHEET/SURVEY .............................................................................. 81 2 BACKGROUND As the recipient of Federal funds from the U.S. Department of Transportation (DOT), the Virginia Department of Rail and Public Transportation (DRPT) is required to comply with Title VI of the Civil Rights Act of 1964. This section includes the Language Assistance Plan (LAP) for persons with Limited English Proficiency (LEP) for DRPT’s Title VI Plan. It documents the four-factor analysis that includes the identification of individuals served by DRPT who need language assistance, the nature and importance of DRPT services to LEP individuals and available resources and costs to provide language assistance services. It also includes DRPT’s LAP which is composed of descriptions of language assistance measures employed by DRPT and the status of current and future efforts to implement the LAP. The DRPT LAP conforms to Executive Order #13166, Improving Access to Services for Persons with Limited English Proficiency (August 11, 2000) and follows the U.S. DOT Guidance implementing the Executive Order, Policy Guidance Concerning Recipients’ Responsibility to Limited English Proficient (LEP) Persons (Dec 14, 2005)(70 Fed Reg 74087). 3 LANGUAGE ASSISTANCE REQUIREMENTS All recipients of U.S. DOT funding are required to take reasonable steps to ensure meaningful access to their programs and activities by LEP persons. All recipients must comply with Executive Order #13166, Improving Access to Services for Persons with Limited English Proficiency (August 11, 2000) and the U.S. DOT Guidance implementing the Executive Order, Policy Guidance Concerning Recipients’ Responsibility to Limited English Proficient (LEP) Persons (Dec 14, 2005)(70 Fed Reg 74087). These require that, when receiving Federal funds, recipients are expected to conduct a four-factor analysis to prevent discrimination based on race, color, and national origin and take steps to ensure LEP persons are provided meaningful access. The guidance applies to all U.S. DOT funding recipients, which include state departments of transportation, state motor vehicle administrations, airport operators, metropolitan planning organizations, and regional, state, and local transit operators, among many others. Coverage extends to a recipient’s entire program or activity, i.e., to all parts of a recipient’s operations. This is true even if only one part of the recipients receives Federal assistance. For example, if the U.S. DOT provides assistance to a state department of transportation to rehabilitate a particular highway on the National Highway System, all operations of the entire state department of transportation—not just the particular highway program or project—are covered by the U.S. DOT guidance. Among other requirements outlined in the FTA C.4702.1B – Title VI Requirements and Guidelines for Federal Transit Administration Recipients, DRPT is responsible for providing meaningful access to LEP Persons to comply with FTA requirements. The steps in this meaningful access are three-fold: 1. Conduct a four-factor analysis to determine the specific language services that are appropriate to provide. 2. Determine written translations needed under the “Safe Harbor Provision” which outlines both which written materials are vital documents – and thus need written translations – and which languages they need to be translated into. 3. Develop an LAP and identify which language assistance services are appropriate. The U.S. DOT guidance outlines four factors that recipients should apply to the various kinds of contacts they have with the public to assess language needs and decide what reasonable steps they should take to ensure meaningful access for LEP persons (referred to as the “four-factor analysis”): 1. The number or proportion of LEP persons eligible to be served or likely to be encountered by a program, activity, or service of the recipient or grantee. 2. The frequency with which LEP individuals come in contact with the program. 3. The nature and importance of the program, activity, or service provided by the recipient to people’s lives. 4. The resources available to the recipient and costs. 4 The greater the number or proportion of eligible LEP persons, the greater the frequency with which they have contact with a program, activity, or service, and the greater the importance of that program, activity, or service, the more likely enhanced language services will be needed. Smaller recipients with more limited budgets are typically not expected to provide the same level of language service as larger recipients with larger budgets. The intent of the U.S. DOT’s guidance is to suggest a balance that ensures meaningful access by LEP persons to critical services while not imposing undue burdens on small organizations and local governments. After completing the above four-factor analysis, recipients can determine which LEP services are appropriate. Recipients have two main ways to provide language services: oral interpretation (in person or via telephone interpretation service) and written translation. The correct array of services should be based on what is deemed both necessary and reasonable in the four-factor analysis. The languages spoken by LEP individuals with whom the recipient has frequent contact often determine the languages into which documents will be translated and the types of interpretation provided. 5 FOUR-FACTOR ANALYSIS This section includes the results of the four-factor analysis (including the Safe Harbor Provision) performed to identify LEP populations for whom DRPT should be providing language assistance services. The results of the four-factor analysis were used to develop the DRPT LAP. Factor 1: Assessment of the Number and Proportion of LEP Persons Likely to be Served or Encountered in the Eligible Service Population This factor considers the number and proportion of persons with limited English proficiency on both a statewide and city/county basis from each language group. Statewide data was extracted from the 2015-2019 U.S American Community Survey (ACS) 5-year estimates. The 2015-2019 estimates did not provide detailed LEP data was not available at the city/county level, so the most recent detailed dataset from the 2011-2015 ACS 5-year estimates was used for local analysis. The language data for the state is presented first along with a review of languages spoken in each city/county. The language data presented for this analysis is used to determine which languages DRPT will translate written materials into under the DOJ’s Safe Harbor Provision (Safe Harbor stipulates that DRPT provide written translation of vital documents for each eligible LEP language group that constitutes five percent (5%) or 1,000 persons, whichever is less ). Number and Proportion of LEP Persons in the State of Virginia The U.S. Census Bureau has a range of two classifications of how well people speak English. The classifications are (1) “very well,”
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