Title VI Limited English Proficiency Guidance

Federal fund recipients are required to take reasonable steps to ensure meaningful access to programs, services and activities by those who do not speak English proficiently.  To determine the extent to which LEP services are required and in which languages, the law requires analysis of four factors:

  1. The number or proportion of Limited English Proficient (LEP) persons eligible to be served or likely to be encountered by the City’s programs or activities.

    Using census data, the City has determined that approximately 5.9% of the community speaks a language other than English.  Based on daily interactions at the City, the language other than English that is most often spoken in the community is Spanish.  Additionally, the City contacted local public schools to determine the proportion of LEP served by those entities, and once again, Spanish was reported to be the prevalent LEP language.  
  2. The frequency with which LEP individuals come in contact with these programs, or activities.

    City staff reviewed the frequency with which City staff has, or could have, contact with LEP persons.    To date, the City has had no requests for translated program documents.   With respect to individuals requesting verbal interpretations, the City has determined that Community Services staff typically have approximately two such interactions with Spanish LEP individuals per year.  The City’s Utility Customer Service Division recently implemented a new telephone system that directs Spanish LEP individuals to a designated Spanish translator.  By offering this service to our customers it has increased interactions with Spanish LEP individuals to nearly daily.  Additionally, Customer Service provides Spanish translating services three to four times monthly in the Customer Service area of City Hall.  There have not been requests for interpretations in languages other than Spanish.
  3. The nature and importance of the program or activity to people’s lives.

    The City believes that City services are of critical importance to its public, as access to certain emergency services, utilities, and other essentials would be difficult without City services.  In that spirit, the City’s website is available in Spanish and most languages other than English simply by engaging a website link.  The City Council and staff are most likely to encounter LEP individuals through office visits, phone conversations, and attendance at City Council meetings.  There are City staff members that speak Spanish.  Such City staff is usually available to assist LEP persons.  Other language translation, if needed, would be provided through a telephone interpreter line for which the City would pay a fee.
  4. The resources available to the City and the likely costs of the LEP services.

    The City has reviewed its available resources that could be used for providing LEP assistance and which of its documents would be most valuable if translated if the need should arise. As noted above, the City’s website is available in Spanish and most languages other than English simply by engaging a website link.  The City Council and staff are most likely to encounter LEP individuals through office visits, phone conversations, and attendance at City Council meetings.  There are City staff members that speak Spanish.  Such City staff are usually available to assist LEP persons.  Other language translation if needed would be provided through a telephone interpreter line for which the City would pay a fee.

Updated April 2019