![](media/image1.wmf){width="0.45in" height="0.4465277777777778in"}

U.S. Department

of Transportation

**Federal Transit**

**Administration**

Implementing the Department of Transportation's Policy Guidance
Concerning Recipients' Responsibilities to Limited English Proficient
(LEP) Persons

A Handbook for Public Transportation Providers

Prepared by:

The Federal Transit Administration Office of Civil Rights

April 13, 2007

**TABLE OF CONTENTS**

**CONTENTS PAGE**

I
INTRODUCTION........................................................................\...3

1\. Who should use this handbook

2\. How to use this handbook

3\. Background information

II APPLYING THE FOUR-FACTOR
FRAMEWORK...........................................................................\...8

1\. Assessing the number and proportion of LEP persons served or
encountered in the eligible service population

2\. Assessing the frequency with which LEP individuals come into contact
with the program, activity, or service

3\. Assessing the nature and importance of the program, activity, or
service provided by the program

4\. Assessing the resources available to the recipient and costs

III DEVELOPING AN IMPLEMENTATION PLAN ON LANGUAGE
ASSISTANCE............................................................................23

1.  Identifying LEP persons who need language assistance

2.  Providing language assistance

3.  Training staff

4.  Providing notice to LEP persons

5.  Monitoring/updating the plan

    IV LANGUAGE ASSISTANCE
    CHECKLISTS........................................34

    1\. Questions to ask community organizations serving LEP persons

    2\. LEP survey/focus group questions

    3\. Language assistance measures currently provided by transit
    agencies

    4\. Language assistance monitoring checklist

    V LANGUAGE ASSISTANCE
    RESOURCES....................................... 41

    1\. Policy and guidance documents

    2\. Websites

    3\. Reports

    4\. Presentations and teaching tools

    5\. Instructions on accessing data from the U.S. Census

    **SECTION I**

    **INTRODUCTION**

**[Overview]{.underline}**

This document provides technical assistance to help public
transportation providers receiving Federal Transit Administration (FTA)
funding implement the U.S. Department of Transportation's Policy
Guidance Concerning Recipients' Responsibilities to Limited English
Proficient (LEP) Persons (DOT LEP Guidance, Federal Register, vol. 70,
no. 239, pp. 74087--74100, December 14, 2005).

By following the recommendations and using the resources in this
handbook, transit agencies will be better able to apply the DOT LEP
guidance's four-factor framework for determining an appropriate mix of
language assistance and prepare language assistance implementation plans
that are consistent with the DOT LEP Guidance. The information in this
handbook is advisory and does not establish new requirements for FTA
recipients or subrecipients.

**Who should use this handbook**

This document was written for transit agency staff responsible for
ensuring that their agency provides language assistance to LEP persons.
These individuals will likely need to share this manual's suggestions
and coordinate with their colleagues throughout their agency. FTA
encourages its grantees to designate an individual or team of people to
coordinate language services for their agency.

**How to use this handbook**

Users should review Section II of this document, which discusses how to
apply the four-factor framework consistent with the DOT LEP Guidance and
Section III, which discusses how to develop a language implementation
plan. These sections provide step-by-step suggestions on how to put the
DOT LEP Guidance into practice. Each section includes relevant passages
from the DOT LEP Guidance as well as recommendations on how to interpret
and implement these passages.

Users should also take note of Section IV, which provides checklists for
conducting the four-factor analysis and developing a language
implementation plan. Section V provides further resources for serving
people with limited English proficiency.

**Background Information**

Individuals who have a limited ability to read, write, speak, or
understand English are limited English proficient, or ''LEP." According
to the 2000 U.S. Census, more than 10 million people reported that they
do not speak English at all, or do not speak English well. The number of
persons reporting that they do not speak English at all or do not speak
English well grew by 65 percent from 1990 to 2000. Among limited English
speakers, Spanish is the language most frequently spoken, followed by
Chinese (Cantonese or Mandarin), Vietnamese, and Korean.

Public transit is a key means of achieving mobility for many LEP
persons. According to the 2000 Census, more than 11 percent of LEP
persons aged 16 years and over reported use of public transit as their
primary means of transportation to work, compared with about 4 percent
of English speakers. Recent immigrants to the United States (including
those persons who may not be limited English proficient) use public
transportation at higher rates than native-born adults, however, transit
use among recent arrivals decreases with length of residence in the
United States. Many immigrants desire to switch from transit to
automobile use because personal vehicles are a symbol of assimilation
and cars can provide greater mobility or access to economic and social
opportunities that are beyond a transit system's service area. Recent
immigrants might elect to continue using transit for at least a portion
of their trips if their experience with public transportation is
positive. For transit agencies seeking to increase their "choice
riders," it may be easier to retain riders who have past, positive
impressions of the system than to attract those persons who have never
or rarely used transit.

Agencies that provide language assistance to persons with limited
English proficiency in a competent and effective manner will help ensure
that their services are safe, reliable, convenient, and accessible to
those persons. These efforts may attract riders who would otherwise be
excluded from participating in the service because of language barriers
and, ideally, will engender riders to continue using the system after
they are proficient in English and/or have more transportation options.
Catering to LEP persons may also help increase and retain ridership
among the agency's broader immigrant communities in two important
ways: 1) agencies that reach out to recent immigrant populations in
order to conduct a needs assessment and prepare a language
implementation plan (pursuant to the DOT LEP Guidance ) will send a
positive message to these persons that their business is valued; and 2)
community outreach designed to identify appropriate language assistance
measures can also assist the agency in identifying the transportation
needs of immigrant populations and ensuring that an agency's transit
routes, hours and days of service, and other service parameters are
responsive to the needs of these populations.

**Legal basis for language assistance requirements**

Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq., and
its implementing regulations provide that no person in the United States
shall, on the grounds of race, color, or national origin, be excluded
from participation in, be denied the benefits of, or be otherwise
subjected to discrimination under any program or activity that receives
Federal financial assistance. The Supreme Court, in *Lau v. Nichols*,
414 U.S. 563 (1974), interpreted Title VI regulations promulgated by the
former Department of Health, Education, and Welfare to hold that Title
VI prohibits conduct that has a disproportionate effect on LEP persons
because such conduct constitutes national origin discrimination.

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 to examine the services it provides
and develop and implement a system by which LEP persons can meaningfully
access those services. Federal agencies were instructed to publish
guidance for their respective recipients in order to assist them with
their obligations to LEP persons under Title VI. The Executive Order
states that recipients must take reasonable steps to ensure meaningful
access to their programs and activities by LEP persons.

President Bush affirmed his commitment to Executive Order 13166 through
a memorandum issued on October 25, 2001 by Assistant Attorney General
for Civil Rights, Ralph F. Boyd, Jr. Federal agencies were directed to
provide guidance and technical assistance to recipients of Federal funds
as to how they can provide meaningful access to limited English
proficient users of Federal programs.

The U.S. DOT published revised guidance for its recipients on December
14, 2005. This document states that Title VI and its implementing
regulations require that DOT recipients take responsible steps to ensure
meaningful access to the benefits, services, information, and other
important portions of their programs and activities for individuals who
are Limited English Proficient (LEP) and that recipients should use the
DOT LEP Guidance to determine how best to comply with statutory and
regulatory obligations to provide meaningful access to the benefits,
services, information, and other important

portions of their programs and activities for individuals who are LEP.

The FTA references the DOT LEP guidance in its Circular 4702.1A, "Title
VI and Title VI-Dependent Guidelines for FTA Recipients," which was
published on April 13, 2007. Chapter IV part 4 of this Circular
reiterates the requirement to take responsible steps to ensure
meaningful access to benefits, services, and information for LEP persons
and suggests that FTA recipients and subrecipients develop a language
implementation plan consistent with the provisions of Section VII of the
DOT LEP guidance.

The DOT LEP Guidance, as well as FTA Circular 4702.1A, state that
certain FTA recipients or subrecipients, such as those serving very few
LEP persons or those with very limited resources may choose not to
develop a written LEP plan. However, the absence of a written LEP plan
does not obviate the underlying obligation to ensure meaningful access
by LEP persons to a recipient's program or activities. Recipients or
subrecipients electing not to prepare a written language implementation
plan should consider other ways to reasonably provide meaningful access.

While the DOT LEP guidance discusses specific language assistance
techniques and lists promising practices implemented by DOT recipients,
it does not provide detailed instructions on how transit agencies, in
particular, can put the Guidelines into practice. Likewise, Circular
4702.1A references provisions of the DOT LEP Guidance but does not
establish specific procedures on how to carry out this Guidance.

**Congressional oversight of language assistance in transportation**

On November 2, 2005, the Government Accountability Office (GAO) issued
its report, "Transportation Services: Better Dissemination and Oversight
of DOT's Guidance Could Lead to Improved Access for Limited
English-Proficient Populations" (GAO-06-52). This report, which was
informed by interviews in selected metropolitan areas with transit
providers, metropolitan planning organizations, and nonprofit
organizations serving LEP persons, found that few agencies had assessed
the language needs in their service area or evaluated their language
access efforts and, as a result, it is unclear whether agencies' efforts
are comprehensive enough to meet the needs of LEP persons. Several
agencies interviewed by GAO stated that technical assistance and
information would be helpful in implementing the DOT LEP Guidance.

The GAO recommended that DOT provide technical assistance (such as
templates and examples) to aid transit agencies and MPOs in assessing
the size, location, and needs of the LEP population; implementing
language access services; and evaluating the effectiveness of these
services. DOT concurred with this recommendation in its response to the
GAO report and this document is part of FTA's strategy to implement the
report's recommendations.

**For More Information Contact:**

Title VI Coordinator

The Federal Transit Administration's Office of Civil Rights

\(202\) 366-4018

**SECTION II**

**APPLYING THE FOUR-FACTOR FRAMEWORK**

**[Overview]{.underline}**

This section provides grantees with step-by-step suggestions for
conducting an LEP needs assessment based on the four-factor framework in
Section V of the DOT LEP Guidance. After conducting the four-factor
analysis transit agencies will be in a better position to implement a
cost-effective mix of language assistance measures and to target
resources appropriately.

**[Factor 1: The Number and Proportion of LEP Persons Served or
Encountered in the Eligible Service Population]{.underline}.**

**[What the Guidance Says]{.underline}**

*"[The greater the number or proportion of LEP persons from a particular
language group served or encountered in the eligible service population,
the more likely language services are needed]{.underline} (emphasis
added). Ordinarily, persons \`\`eligible to be served, or likely to be
directly affected, by'' a recipient's programs or activities are those
who are in fact, served or encountered in the eligible service
population. This population will be program-specific, and includes
persons who are in the geographic area that is part of the recipient's
service area...When considering the number or proportion of LEP
individuals in a service area, recipients should consider LEP parent(s)
whose English proficient or LEP minor children and dependents encounter
the services of DOT recipients.*

*Recipients should first examine their prior experiences with LEP
individuals and determine the breadth and scope of language services
that are needed. In conducting this analysis, it is important to:
Include language minority populations that are eligible beneficiaries of
recipients' programs, activities, or services but may be underserved*

*because of existing language barriers; and consult additional data, for
example, from the census, school systems and community organizations,
and data from state and local governments, community agencies, school
systems, religious organizations, and legal aid entities.*

*The focus of the analysis is on lack of English proficiency, not the
ability to speak more than one language. Note that demographic data may
indicate the most frequently spoken languages other than English and the
percentage of people who speak that language but speak or understand
English less than well. People who are also proficient in English may
speak some of the most commonly spoken languages other than English."
(DOT LEP Guidance Section V (1)).*

**[Suggestions on Implementing this Guidance]{.underline}**

Grantees should first examine their prior experiences with LEP
individuals and then determine the number and proportion of LEP persons
served or encountered within their service area. Agencies should strive
to assess this number and proportion through a mix of data sources,
including the following: 1) data from the U.S. Census; 2) data from
state and local government agencies; and 3) information from
organizations that serve LEP persons.

Data from the 2000 Census provides statistics on the number of people
who speak English less than well for every census tract in the
recipients' service area. The Census can also provide data on households
that are linguistically isolated.[^1] State and local departments of
education and school districts as well as other local sources may be
able to provide additional statistics. Organizations that serve LEP
persons may not be able to provide you with rigorous statistics, however
these organizations should be able to help you confirm or identify gaps
in the data you have obtained from the Census and other sources. These
organizations may also be able to help you identify the specific
languages spoken by the LEP population in your area.

**Task 1, Step 1: Examine prior experiences with LEP individuals**

This task involves reviewing the relevant benefits, services, and
information provided by your agency and determining the extent to which
LEP persons have come into contact with these functions. Your agency
probably has come into contact or could come into contact with LEP
persons through one or more of the following channels:

-   Contact with transit vehicle operators;

-   Contact with transit station managers;

-   Calls to your agency's customer service telephone line;

-   Visits to your agency's headquarters;

-   Access to your agency's website ;

-   Attendance at community meetings or public hearings hosted by your
    agency;

-   Contact with your agency's ADA complementary paratransit system
    (including applying for eligibility, making reservations, and
    communicating with drivers).

Agency staff may be able to provide you with relevant (if anecdotal)
information on

how frequently they come into contact with LEP persons. You may want to
contact your agency's customer service representatives, vehicle
operators, station managers, and community outreach staff to obtain this
information and to find out if the staff person is able to identify the
LEP persons' native language, how successful the agency has been in
communicating with LEP persons, and common questions directed to the
agency by LEP persons. Your agency may also want to review any available
records on the number of hits it receives on its non-English web pages
or requests for interpreters at public meetings or results of ridership
surveys that capture the experiences of LEP persons.

**Task 1, Step 2: Become familiar with data from The U.S. Census**

Data from the 2000 Census and the Census Bureau's American Community
Survey (ACS) is currently available at
[www.census.gov](http://www.census.gov/). The 2000 Census, which was
designed to measure the count of the population and housing as of April
1, 2000, includes data on the number of persons who indicated that they
spoke English "very well," "well," "less than well," and "not at all"
which can be accessed at the national, state, county, census tract,
census block group, and census block level. The 2005 American Community
Survey produced a period estimate of the characteristics of the
population and housing for the period from January through December of
2005. The ACS provides single-year estimates for geographic areas with
populations of 65,000 or more and provides estimates for smaller
geographic areas. Unlike the 2000 Census, the 2005 ACS does not include
data at the census tract, block group, or block level. As of April,
2007, data on ability to speak English is available at the state level
and for some counties. As future annual ACS surveys become available,
data will become available at smaller geographic levels.

The ACS includes a table that divides the non-English speaking into the
four major language categories ("very well," "well," "less than well,"
and "not at all") and an additional table that provides greater detail
than the 2000 census on the specific languages of populations who speak
English less than very well. The ACS also provides information on the
age, place of birth, citizenship status, poverty status, and educational
attainment of persons who do speak languages other than English at
home..

Specific instructions on how to access Census data at
[www.census.gov](http://www.census.gov/) and are included in Section V
of this handbook. If you have difficulty accessing Census data, you can
call the Census Bureau's regional office in your region.

**Task 1, Step 2A: Identify the geographic boundaries of the area that
your agency**

**serves**

In many cases, the geographic boundaries of a transit agency's service
area are identical to the geographic boundaries of specific
municipalities or counties. If this is the case for your agency, you can
access census data on the LEP population at the county level.

In some cases, a transit agency is authorized to provide service to
portions of one or more jurisdiction(s) but not the entire jurisdiction.
If this is the case, you will need to identify the census tracts that
correspond to the geographic area(s) that your agency is authorized to
serve. The total population and total LEP population of your agency's
service area can be estimated by adding the populations of each census
tract.

In general, it is useful for you to know the census tracts that are
served by your agency. You can use the census website to identify the
LEP population on a census tract-by-census tract basis, which will allow
your agency to determine if LEP persons are concentrated in specific
neighborhoods within your service area.

**Task 1, Step 2B: Obtain Census data on the LEP population in your
service area**

Information from the 2000 Census and the American Community Survey can
be found at the "American Fact Finder" link on the Census website,
[www.census.gov](http://www.census.gov/). The relevant table from the
2000 Census is QT-P17, "Population 5 years and Over by Language Spoken
at Home and Ability to Speak English, 2000." Below is an example of this
table from the State of California:

+-----------------------------------------------------------+------+---+
| **POPULATION 5 YEARS AND OVER BY LANGUAGE SPOKEN AT HOME  |      |   |
| AND ABILITY TO SPEAK ENGLISH**                            |      |   |
+-----------------------------------------------------------+------+---+
| > **Population 5 years and over**                         | **   | * |
|                                                           | 31,4 | * |
|                                                           | 16,6 | 1 |
|                                                           | 29** | 0 |
|                                                           |      | 0 |
|                                                           |      | . |
|                                                           |      | 0 |
|                                                           |      | * |
|                                                           |      | * |
+-----------------------------------------------------------+------+---+
| Speak only English                                        | 19   | 6 |
|                                                           | ,014 | 0 |
|                                                           | ,873 | . |
|                                                           |      | 5 |
+-----------------------------------------------------------+------+---+
| Speak a language other than English                       | 12   | 3 |
|                                                           | ,401 | 9 |
|                                                           | ,756 | . |
|                                                           |      | 5 |
+-----------------------------------------------------------+------+---+
|                                                           |      |   |
+-----------------------------------------------------------+------+---+
| > **Spanish**                                             | *    | * |
|                                                           | *8,1 | * |
|                                                           | 05,5 | 1 |
|                                                           | 05** | 0 |
|                                                           |      | 0 |
|                                                           |      | . |
|                                                           |      | 0 |
|                                                           |      | * |
|                                                           |      | * |
+-----------------------------------------------------------+------+---+
| Speak English "very well"                                 | 3    | 4 |
|                                                           | ,801 | 6 |
|                                                           | ,556 | . |
|                                                           |      | 9 |
+-----------------------------------------------------------+------+---+
| Speak English "well"                                      | 1    | 2 |
|                                                           | ,792 | 2 |
|                                                           | ,446 | . |
|                                                           |      | 1 |
+-----------------------------------------------------------+------+---+
| Speak English "not well"                                  | 1    | 1 |
|                                                           | ,561 | 9 |
|                                                           | ,403 | . |
|                                                           |      | 3 |
+-----------------------------------------------------------+------+---+
| Speak English "not at all"                                | 950  | 1 |
|                                                           | ,100 | 1 |
|                                                           |      | . |
|                                                           |      | 7 |
+-----------------------------------------------------------+------+---+
|                                                           |      |   |
+-----------------------------------------------------------+------+---+
| > **Other Indo-European languages**                       | *    | * |
|                                                           | *1,3 | * |
|                                                           | 35,3 | 1 |
|                                                           | 32** | 0 |
|                                                           |      | 0 |
|                                                           |      | . |
|                                                           |      | 0 |
|                                                           |      | * |
|                                                           |      | * |
+-----------------------------------------------------------+------+---+
| Speak English "very well"                                 | 881  | 6 |
|                                                           | ,743 | 6 |
|                                                           |      | . |
|                                                           |      | 0 |
+-----------------------------------------------------------+------+---+
| Speak English "well"                                      | 274  | 2 |
|                                                           | ,073 | 0 |
|                                                           |      | . |
|                                                           |      | 5 |
+-----------------------------------------------------------+------+---+
| Speak English "not well"                                  | 136  | 1 |
|                                                           | ,822 | 0 |
|                                                           |      | . |
|                                                           |      | 2 |
+-----------------------------------------------------------+------+---+
| Speak English "not at all"                                | 42   | 3 |
|                                                           | ,694 | . |
|                                                           |      | 2 |
+-----------------------------------------------------------+------+---+
|                                                           |      |   |
+-----------------------------------------------------------+------+---+
| > **Asian and Pacific Island languages**                  | *    | * |
|                                                           | *2,7 | * |
|                                                           | 09,1 | 1 |
|                                                           | 79** | 0 |
|                                                           |      | 0 |
|                                                           |      | . |
|                                                           |      | 0 |
|                                                           |      | * |
|                                                           |      | * |
+-----------------------------------------------------------+------+---+
| Speak English "very well"                                 | 1    | 4 |
|                                                           | ,270 | 6 |
|                                                           | ,591 | . |
|                                                           |      | 9 |
+-----------------------------------------------------------+------+---+
| Speak English "well"                                      | 801  | 2 |
|                                                           | ,472 | 9 |
|                                                           |      | . |
|                                                           |      | 6 |
+-----------------------------------------------------------+------+---+
| Speak English "not well"                                  | 508  | 1 |
|                                                           | ,756 | 8 |
|                                                           |      | . |
|                                                           |      | 8 |
+-----------------------------------------------------------+------+---+
| Speak English "not at all"                                | 128  | 4 |
|                                                           | ,360 | . |
|                                                           |      | 7 |
+-----------------------------------------------------------+------+---+
|                                                           |      |   |
+-----------------------------------------------------------+------+---+
| > **All other languages**                                 | **2  | * |
|                                                           | 51,7 | * |
|                                                           | 40** | 1 |
|                                                           |      | 0 |
|                                                           |      | 0 |
|                                                           |      | . |
|                                                           |      | 0 |
|                                                           |      | * |
|                                                           |      | * |
+-----------------------------------------------------------+------+---+
| Speak English "very well"                                 | 170  | 6 |
|                                                           | ,087 | 7 |
|                                                           |      | . |
|                                                           |      | 6 |
+-----------------------------------------------------------+------+---+
| Speak English "well"                                      | 52   | 2 |
|                                                           | ,878 | 1 |
|                                                           |      | . |
|                                                           |      | 0 |
+-----------------------------------------------------------+------+---+
| Speak English "not well"                                  | 20   | 8 |
|                                                           | ,817 | . |
|                                                           |      | 3 |
+-----------------------------------------------------------+------+---+
| Speak English "not at all"                                | 7    | 3 |
|                                                           | ,958 | . |
|                                                           |      | 2 |
+-----------------------------------------------------------+------+---+
|                                                           |      |   |
+-----------------------------------------------------------+------+---+
| **ABILITY TO SPEAK ENGLISH**                              |      |   |
+-----------------------------------------------------------+------+---+
| > **Population 5 years and over**                         | **   | * |
|                                                           | 31,4 | * |
|                                                           | 16,6 | 1 |
|                                                           | 29** | 0 |
|                                                           |      | 0 |
|                                                           |      | . |
|                                                           |      | 0 |
|                                                           |      | * |
|                                                           |      | * |
+-----------------------------------------------------------+------+---+
| Speak a language other than English                       | 12   | 3 |
|                                                           | ,401 | 9 |
|                                                           | ,756 | . |
|                                                           |      | 5 |
+-----------------------------------------------------------+------+---+
| > 5 to 17 years                                           | 2    | 9 |
|                                                           | ,879 | . |
|                                                           | ,695 | 2 |
+-----------------------------------------------------------+------+---+
| > 18 to 64 years                                          | 8    | 2 |
|                                                           | ,537 | 7 |
|                                                           | ,488 | . |
|                                                           |      | 2 |
+-----------------------------------------------------------+------+---+
| > 65 years and over                                       | 984  | 3 |
|                                                           | ,573 | . |
|                                                           |      | 1 |
+-----------------------------------------------------------+------+---+
| > Speak English less than "very well"                     | 6    | 2 |
|                                                           | ,277 | 0 |
|                                                           | ,779 | . |
|                                                           |      | 0 |
+-----------------------------------------------------------+------+---+
| > 5 to 17 years                                           | 1    | 3 |
|                                                           | ,111 | . |
|                                                           | ,387 | 5 |
+-----------------------------------------------------------+------+---+
| > 18 to 64 years                                          | 4    | 1 |
|                                                           | ,559 | 4 |
|                                                           | ,970 | . |
|                                                           |      | 5 |
+-----------------------------------------------------------+------+---+
| > 65 years and over                                       | 606  | 1 |
|                                                           | ,422 | . |
|                                                           |      | 9 |
+-----------------------------------------------------------+------+---+
|                                                           |      |   |
+-----------------------------------------------------------+------+---+
| **ABILITY TO SPEAK ENGLISH IN HOUSEHOLD**                 |      |   |
+-----------------------------------------------------------+------+---+
| Linguistically isolated households^1^                     | 1    | \ |
|                                                           | ,107 | ( |
|                                                           | ,222 | X |
|                                                           |      | \ |
|                                                           |      | ) |
+-----------------------------------------------------------+------+---+
|                                                           |      |   |
+-----------------------------------------------------------+------+---+
| > **Population 5 years and over in households**           | **   | * |
|                                                           | 30,6 | * |
|                                                           | 01,2 | 1 |
|                                                           | 99** | 0 |
|                                                           |      | 0 |
|                                                           |      | . |
|                                                           |      | 0 |
|                                                           |      | * |
|                                                           |      | * |
+-----------------------------------------------------------+------+---+
| In linguistically isolated households^1^                  | 3    | 1 |
|                                                           | ,472 | 1 |
|                                                           | ,270 | . |
|                                                           |      | 3 |
+-----------------------------------------------------------+------+---+
| > 5 to 17 years                                           | 906  | 3 |
|                                                           | ,231 | . |
|                                                           |      | 0 |
+-----------------------------------------------------------+------+---+
| > 18 to 64 years                                          | 2    | 7 |
|                                                           | ,261 | . |
|                                                           | ,448 | 4 |
+-----------------------------------------------------------+------+---+
| > 65 years and over                                       | 304  | 1 |
|                                                           | ,591 | . |
|                                                           |      | 0 |
+-----------------------------------------------------------+------+---+

Information from the 2005 ACS provides more detail on the specific
languages that are

spoken by those who report that they speak English less than very well.
Below is an example of ACS Data Set B16001, "Language Spoken at Home by
Ability to Speak English for the Population Five Years or Older," for
the state of California:

+-----------------------+-----+---------------------------------------+
|                       | **  |                                       |
|                       | Cal |                                       |
|                       | ifo |                                       |
|                       | rni |                                       |
|                       | a** |                                       |
+-----------------------+-----+---------------------------------------+
|                       | Es  | Margin of Error                       |
|                       | tim |                                       |
|                       | ate |                                       |
+-----------------------+-----+---------------------------------------+
| Total:                | 3   | +/-3,023                              |
|                       | 2,5 |                                       |
|                       | 99, |                                       |
|                       | 457 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak only English  | 1   | +/-59,716                             |
|                       | 8,8 |                                       |
|                       | 08, |                                       |
|                       | 277 |                                       |
+-----------------------+-----+---------------------------------------+
| > Spanish or Spanish  | 9,1 | +/-46,687                             |
| > Creole:             | 92, |                                       |
|                       | 012 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 4,6 | +/-43,969                             |
| > \"very well\"       | 26, |                                       |
|                       | 485 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 4,5 | +/-47,849                             |
| > than \"very well\"  | 65, |                                       |
|                       | 527 |                                       |
+-----------------------+-----+---------------------------------------+
| > French (incl.       | 1   | +/-8,684                              |
| > Patois, Cajun):     | 27, |                                       |
|                       | 539 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 1   | +/-8,268                              |
| > \"very well\"       | 07, |                                       |
|                       | 163 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 20, | +/-2,663                              |
| > than \"very well\"  | 376 |                                       |
+-----------------------+-----+---------------------------------------+
| > French Creole:      | 5,  | +/-1,685                              |
|                       | 001 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 4,  | +/-1,646                              |
| > \"very well\"       | 501 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 500 | +/-354                                |
| > than \"very well\"  |     |                                       |
+-----------------------+-----+---------------------------------------+
| > Italian:            | 64, | +/-5,275                              |
|                       | 991 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 50, | +/-4,880                              |
| > \"very well\"       | 560 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 14, | +/-2,158                              |
| > than \"very well\"  | 431 |                                       |
+-----------------------+-----+---------------------------------------+
| > Portuguese or       | 73, | +/-7,681                              |
| > Portuguese Creole:  | 130 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 47, | +/-5,690                              |
| > \"very well\"       | 986 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 25, | +/-4,181                              |
| > than \"very well\"  | 144 |                                       |
+-----------------------+-----+---------------------------------------+
| > German:             | 1   | +/-6,974                              |
|                       | 14, |                                       |
|                       | 971 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 98, | +/-6,363                              |
| > \"very well\"       | 405 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 16, | +/-1,862                              |
| > than \"very well\"  | 566 |                                       |
+-----------------------+-----+---------------------------------------+
| > Yiddish:            | 3,  | +/-997                                |
|                       | 594 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 3,  | +/-862                                |
| > \"very well\"       | 264 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 330 | +/-471                                |
| > than \"very well\"  |     |                                       |
+-----------------------+-----+---------------------------------------+
| > Other West Germanic | 28, | +/-2,937                              |
| > languages:          | 633 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 24, | +/-2,893                              |
| > \"very well\"       | 479 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 4,  | +/-1,073                              |
| > than \"very well\"  | 154 |                                       |
+-----------------------+-----+---------------------------------------+
| > Scandinavian        | 26, | +/-3,255                              |
| > languages:          | 271 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 23, | +/-3,267                              |
| > \"very well\"       | 087 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 3,  | +/-822                                |
| > than \"very well\"  | 184 |                                       |
+-----------------------+-----+---------------------------------------+
| > Greek:              | 22, | +/-3,227                              |
|                       | 712 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 18, | +/-2,686                              |
| > \"very well\"       | 014 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 4,  | +/-1,252                              |
| > than \"very well\"  | 698 |                                       |
+-----------------------+-----+---------------------------------------+
| > Russian:            | 1   | +/-12,229                             |
|                       | 42, |                                       |
|                       | 734 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 70, | +/-6,883                              |
| > \"very well\"       | 957 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 71, | +/-8,321                              |
| > than \"very well\"  | 777 |                                       |
+-----------------------+-----+---------------------------------------+
| > Polish:             | 18, | +/-3,101                              |
|                       | 378 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 13, | +/-2,791                              |
| > \"very well\"       | 108 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 5,  | +/-1,154                              |
| > than \"very well\"  | 270 |                                       |
+-----------------------+-----+---------------------------------------+
| > Serbo-Croatian:     | 24, | +/-4,979                              |
|                       | 661 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 15, | +/-3,653                              |
| > \"very well\"       | 915 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 8,  | +/-2,563                              |
| > than \"very well\"  | 746 |                                       |
+-----------------------+-----+---------------------------------------+
| > Other Slavic        | 35, | +/-7,022                              |
| > languages:          | 373 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 17, | +/-3,662                              |
| > \"very well\"       | 885 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 17, | +/-4,415                              |
| > than \"very well\"  | 488 |                                       |
+-----------------------+-----+---------------------------------------+
| > Armenian:           | 1   | +/-14,696                             |
|                       | 61, |                                       |
|                       | 221 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 81, | +/-9,216                              |
| > \"very well\"       | 789 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 79, | +/-8,617                              |
| > than \"very well\"  | 432 |                                       |
+-----------------------+-----+---------------------------------------+
| > Persian:            | 1   | +/-12,393                             |
|                       | 52, |                                       |
|                       | 418 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 92, | +/-8,862                              |
| > \"very well\"       | 487 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 59, | +/-6,786                              |
| > than \"very well\"  | 931 |                                       |
+-----------------------+-----+---------------------------------------+
| > Gujarathi:          | 35, | +/-5,187                              |
|                       | 093 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 26, | +/-4,083                              |
| > \"very well\"       | 088 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 9,  | +/-1,929                              |
| > than \"very well\"  | 005 |                                       |
+-----------------------+-----+---------------------------------------+
| > Hindi:              | 1   | +/-9,007                              |
|                       | 06, |                                       |
|                       | 728 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 86, | +/-8,239                              |
| > \"very well\"       | 499 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 20, | +/-3,266                              |
| > than \"very well\"  | 229 |                                       |
+-----------------------+-----+---------------------------------------+
| > Urdu:               | 34, | +/-7,769                              |
|                       | 620 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 21, | +/-4,564                              |
| > \"very well\"       | 897 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 12, | +/-5,902                              |
| > than \"very well\"  | 723 |                                       |
+-----------------------+-----+---------------------------------------+
| > Other Indic         | 1   | +/-14,944                             |
| > languages:          | 60, |                                       |
|                       | 408 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 98, | +/-8,895                              |
| > \"very well\"       | 188 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 62, | +/-8,487                              |
| > than \"very well\"  | 220 |                                       |
+-----------------------+-----+---------------------------------------+
| > Other Indo-European | 40, | +/-6,420                              |
| > languages:          | 121 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 26, | +/-5,047                              |
| > \"very well\"       | 362 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 13, | +/-2,725                              |
| > than \"very well\"  | 759 |                                       |
+-----------------------+-----+---------------------------------------+
| > Chinese:            | 9   | +/-21,815                             |
|                       | 05, |                                       |
|                       | 679 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 3   | +/-12,302                             |
| > \"very well\"       | 88, |                                       |
|                       | 506 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 5   | +/-14,822                             |
| > than \"very well\"  | 17, |                                       |
|                       | 173 |                                       |
+-----------------------+-----+---------------------------------------+
| > Japanese:           | 1   | +/-9,429                              |
|                       | 60, |                                       |
|                       | 285 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 82, | +/-6,231                              |
| > \"very well\"       | 839 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 77, | +/-5,645                              |
| > than \"very well\"  | 446 |                                       |
+-----------------------+-----+---------------------------------------+
| > Korean:             | 3   | +/-16,439                             |
|                       | 33, |                                       |
|                       | 539 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 1   | +/-7,095                              |
| > \"very well\"       | 24, |                                       |
|                       | 184 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 2   | +/-13,799                             |
| > than \"very well\"  | 09, |                                       |
|                       | 355 |                                       |
+-----------------------+-----+---------------------------------------+
| > Mon-Khmer,          | 71, | +/-9,587                              |
| > Cambodian:          | 630 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 32, | +/-5,540                              |
| > \"very well\"       | 195 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 39, | +/-6,012                              |
| > than \"very well\"  | 435 |                                       |
+-----------------------+-----+---------------------------------------+
| > Hmong:              | 60, | +/-8,140                              |
|                       | 017 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 28, | +/-4,850                              |
| > \"very well\"       | 805 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 31, | +/-6,034                              |
| > than \"very well\"  | 212 |                                       |
+-----------------------+-----+---------------------------------------+
| > Thai:               | 41, | +/-4,691                              |
|                       | 241 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 15, | +/-2,747                              |
| > \"very well\"       | 926 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 25, | +/-3,107                              |
| > than \"very well\"  | 315 |                                       |
+-----------------------+-----+---------------------------------------+
| > Laotian:            | 41, | +/-6,584                              |
|                       | 438 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 19, | +/-4,378                              |
| > \"very well\"       | 636 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 21, | +/-3,626                              |
| > than \"very well\"  | 802 |                                       |
+-----------------------+-----+---------------------------------------+
| > Vietnamese:         | 4   | +/-22,432                             |
|                       | 57, |                                       |
|                       | 510 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 1   | +/-13,122                             |
| > \"very well\"       | 80, |                                       |
|                       | 465 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 2   | +/-14,332                             |
| > than \"very well\"  | 77, |                                       |
|                       | 045 |                                       |
+-----------------------+-----+---------------------------------------+
| > Other Asian         | 97, | +/-8,520                              |
| > languages:          | 800 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 69, | +/-6,584                              |
| > \"very well\"       | 537 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 28, | +/-3,840                              |
| > than \"very well\"  | 263 |                                       |
+-----------------------+-----+---------------------------------------+
| > Tagalog:            | 6   | +/-24,411                             |
|                       | 70, |                                       |
|                       | 203 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 4   | +/-17,310                             |
| > \"very well\"       | 36, |                                       |
|                       | 269 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 2   | +/-15,587                             |
| > than \"very well\"  | 33, |                                       |
|                       | 934 |                                       |
+-----------------------+-----+---------------------------------------+
| > Other Pacific       | 1   | +/-9,968                              |
| > Island languages:   | 10, |                                       |
|                       | 879 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 70, | +/-7,564                              |
| > \"very well\"       | 635 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 40, | +/-4,570                              |
| > than \"very well\"  | 244 |                                       |
+-----------------------+-----+---------------------------------------+
| > Navajo:             | 1,  | +/-763                                |
|                       | 037 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 1,  | +/-763                                |
| > \"very well\"       | 037 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 0   | +/-293                                |
| > than \"very well\"  |     |                                       |
+-----------------------+-----+---------------------------------------+
| > Other Native North  | 6,  | +/-1,643                              |
| > American languages: | 349 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 5,  | +/-1,624                              |
| > \"very well\"       | 715 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 634 | +/-338                                |
| > than \"very well\"  |     |                                       |
+-----------------------+-----+---------------------------------------+
| > Hungarian:          | 16, | +/-3,868                              |
|                       | 905 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 11, | +/-2,334                              |
| > \"very well\"       | 200 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 5,  | +/-2,474                              |
| > than \"very well\"  | 705 |                                       |
+-----------------------+-----+---------------------------------------+
| > Arabic:             | 1   | +/-12,157                             |
|                       | 27, |                                       |
|                       | 603 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 83, | +/-8,788                              |
| > \"very well\"       | 427 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 44, | +/-5,485                              |
| > than \"very well\"  | 176 |                                       |
+-----------------------+-----+---------------------------------------+
| > Hebrew:             | 42, | +/-8,342                              |
|                       | 330 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 35, | +/-7,332                              |
| > \"very well\"       | 049 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 7,  | +/-2,520                              |
| > than \"very well\"  | 281 |                                       |
+-----------------------+-----+---------------------------------------+
| > African languages:  | 52, | +/-6,707                              |
|                       | 123 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 40, | +/-5,728                              |
| > \"very well\"       | 841 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 11, | +/-2,287                              |
| > than \"very well\"  | 282 |                                       |
+-----------------------+-----+---------------------------------------+
| > Other and           | 24, | +/-3,924                              |
| > unspecified         | 003 |                                       |
| > languages:          |     |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English       | 14, | +/-2,991                              |
| > \"very well\"       | 993 |                                       |
+-----------------------+-----+---------------------------------------+
| > Speak English less  | 9,  | +/-1,931                              |
| > than \"very well\"  | 010 |                                       |
+-----------------------+-----+---------------------------------------+

**Task 1, Step 2C: Analyze the data you have collected**

Once you have downloaded the Census data, you can determine the number
and proportion of LEP persons in your agency's service area as well as
the languages most frequently spoken by LEP persons.

When using the 2000 Census data, this total number of LEP persons can be
obtained by totaling the number of persons who speak English "well,"
"not well," or "not at all" in the "Spanish," "Other Indo-European
Language," "Asian-Pacific Island Language," and "All Other Language"
categories.

For example, the above 2000 Census table for the state of California
shows that 4,303,949 Spanish speakers also speak English either "well,"
"not well" or "not at all." In addition, 453,589 speakers of other
Indo-European Languages, 1,438,588 speakers of Asian-Pacific Island
Languages, and 81,653 speakers of other languages speak English in a
category other than "very well.". The total number of persons in
California who reported to the 2000 Census that they speak English in a
category other than "very well" is, 6,277,779 or 19.9% of the total
population of persons 5 years and older.

The ACS data can also be used to provide a second estimate of the number
and proportion of LEP persons. The above ACS table for the state of
California gives a total population of 32,599,457. Of this population,
the Census estimates that 6,585,792 people, or 20.2% of the state's
population speak English "less than 'very well'". This represents the
sum of the persons in each of the table's 38 language categories that
are estimated to speak English less than "very well." Of these persons,
4,565,527 (or 69% of the LEP population) speak Spanish, 517,173 (7.8%)
speak Chinese, 277,045 (4.2%) speak Vietnamese, 233,934 (3.5%) speak
Tagalog and 209,355 (3.1%) speak Korean.

**Task 1, Step 2D: Identify any concentrations of LEP persons within
your service area**

We recommend that agencies use 2000 Census data to identify specific
census tracts where the proportion of LEP persons exceeds the proportion
of LEP persons in the service area as a whole. This information should
help agencies identify if their LEP population is concentrated around
specific stations or transit routes. It may also help agencies determine
if concentrations of LEP persons speaking different languages are
concentrated around different stations or routes.

Agencies can identify LEP concentrations by highlighting those census
tracts in their table where the proportion of LEP persons is higher than
the service-area average.

Agencies with access to Geographic Information System (GIS) mapping
software can produce maps showing where the LEP population is
concentrated. These maps can also

display an agency's routes and facilities over the map highlighting
concentrations of LEP persons.

**Task 1, Step 3: Consult state and local sources of data**

State Departments of Education may have a bilingual education office
that collects LEP student enrollment data from all the school districts
in a state and State bilingual education staff may be able to help you
identify LEP populations and types of languages spoken in the area that
your agency provides service.

In addition, school districts have a responsibility to identify those
students who are LEP and whose primary language is other than English
and provide assistance to these students. Newly registered students and
parents complete Home Language Surveys that identify the primary
language spoken by the student and his or her family.

The Department of Labor has sponsored a special tabulation of Census
data on Limited English proficient (LEP) populations as a resource for
One Stop Career Centers and other providers of employment and training
services. Information is broken out for 39 Census languages and language
clusters, and the tabulations are designed to match the service areas of
states and local Workforce Investment Areas. (Local Workforce Investment
Areas are jurisdictions comprised of one or more county within a state
and these jurisdictions may match or overlap with your agency's transit
service area). This data can be found at
<http://www.doleta.gov/reports/CensusData/>.

**Task 1, Step 4: Reach out to community organizations that serve LEP
persons**

Data from the U.S. Census as well as state and local agencies provide a
good starting place for identifying individuals who are limited English
proficient, but keep in mind that Census data includes the following
drawbacks:

1.  The Census Bureau's survey methodology may undercount the actual
    number of people who speak English less than very well;

2.  The Census records people who report that they speak English less
    than very well, but does not contain information on the extent to
    which people read, write, or understand English, which are also
    elements of limited English proficiency;

3.  The Census has limited information on what languages are spoken by
    LEP people at the census tract, block group, or block level;

Given these limitations, FTA recommends that your agency conduct
community outreach to organizations that work with LEP populations.
These may be able to provide you with information that is not included
in the Census, such as information on specific languages spoken by the
LEP population, population trends, and what services are most frequently
sought by the LEP population.

The DOT LEP Guidance recommends that recipients consult data from the
following entities:

-   School systems;

-   Community organizations;

-   State and local governments;

-   Religious organizations;

-   Legal aid entities.

Given the time and resource constraints on you and your agency, and
depending on the number and variety of community organizations in your
service area, you may likely not be able to contact all of the relevant
organizations in your jurisdiction. Your agency may want to focus its
outreach on those organizations that are located in areas with high
proportions of LEP persons, or you may want to contact organizations
with which your agency has worked in the past, or develop a
representative sample of organizations to contact.

**Task 1, Step 4A: Identify community organizations**

Your agency's previous outreach and marketing initiatives may have
yielded a list of community organizations that serve populations with
limited English proficiency.. Agencies that have not historically
conducted outreach to organizations that serve or represent LEP persons
can generate a list of potential community partners by reviewing
information in the local phone directory or by obtaining referrals from
local government agencies.

If LEP population is comprised of persons who speak one language but
have immigrated from multiple nations or regions within nations, you may
need to work with community organizations that serve people who speak
the same language but who have arrived from different countries of
origin to ensure that your outreach and assistance will resonate equally
well among all nationalities and subcultures within the intended
audience.

**Task 1, Step 4B: Contact relevant community organizations**

Once your agency has developed a list of community organizations that
serve LEP persons, you should contact the organization to explain your
agency's objectives and request information about the population served
by the organization. You may want to place a phone call or transmit a
letter to the organization that describes your agency's mission,
discusses your attempt to improve the language services it provides, and
invites the organization to partner with your agency. You may also want
to clarify that you are not seeking information on specific individuals
but are looking for general information on the area's LEP community in
order to provide better transportation service. Although most community
organizations include multilingual staff members or volunteers, your
agency may want to translate the letter or have an interpreter present
on a phone call.

**Task 1, Step 4C: Obtain information**

Once you have made contact with the community organization, we recommend
that you hold a meeting or phone call with its representatives in order
to gather relevant information and also discuss the services your agency
provides. You should seek feedback from the organization on the size of
the population it serves, the transportation and other needs of the
population, any demographic trends among this population, and effect
ways to obtain input from this population. Section IV of this handbook

contains a list of questions that you may want to ask organizations
serving LEP persons.

**[Factor 2: The Frequency with Which LEP Individuals Come into Contact
with your programs, activities, and services]{.underline}**

**[What the Guidance Says]{.underline}**

*"Recipients should assess, as accurately as possible, the frequency
with which they have or should have contact with LEP individuals from
different language groups seeking assistance, as [the more frequent the
contact, the more likely enhanced language services will be
needed]{.underline} (emphasis added). The steps that are reasonable for
a recipient that serves an LEP person on a one-time basis will be very
different than those expected from a*

*recipient that serves LEP persons daily. Recipients should also
consider the frequency of different types of language contacts, as
frequent contacts with Spanish-speaking people who are LEP may require
certain assistance in Spanish, while less frequent contact with
different language groups may suggest a different and/or less
intensified solution. If an LEP individual accesses a program or service
on a daily basis, a recipient has greater duties than if the same
individual's program or activity contact is unpredictable or infrequent.
However, even recipients that serve LEP persons on an unpredictable or
infrequent basis should use this balancing analysis to determine what to
do if an LEP individual seeks services under the program in question.
This plan need not be intricate. It may be as simple as being prepared
to use a commercial telephonic interpretation service to obtain
immediate interpreter services. Additionally, in applying this standard,
recipients should consider whether appropriate outreach to LEP persons
could increase the frequency of contact with LEP language groups."(DOT
LEP Guidance Section V (2)).*

**[Suggestions on Implementing This Guidance]{.underline}**

Although the Census includes some data on the extent to which recent
immigrants use public transportation, the Census will not contain
information on how frequently LEP persons inquire about, use, or are
affected by the specific services your agency provides. Individuals
within your agency, as well as the community organizations identified in
Task 1 and LEP persons themselves will be the best sources of
information on frequency of contact with your agency's programs,
activities, and services.

**Task 2, Step 1: Review the relevant programs, activities, and services
you provide**

Agencies conducting the review of their prior experiences with LEP
persons, per the guidance in Task 1 Step 1 will have listed the
programs, activities, and services with which LEP persons most
frequently come in contact.

**Task 2, Step 2: Review information obtained from community
organizations**

Your interviews with community organization representatives, per Task 1,
Step 4, will likely yield information on how frequently LEP persons use
transit service, and what modes of service or particular routes are used
most frequently.

**Task 2, Step 3: Consult directly with LEP persons**

Another way to obtain relevant information is to hold face-to-face
meetings, such as focus groups or individual interviews, with LEP
individuals. In order to hold a successful meeting, your agency will
likely need to partner with community organizations to advertise the
event and hold meetings during times of day and at locations that are
convenient and accessible to the LEP population. Oral language
interpreters should be present at the meeting and any written material
you distribute should be translated.

In addition to, or in lieu of holding face-to-face meetings, your agency
may elect to conduct a survey of LEP persons. You will likely need to
coordinate with community organizations to administer the survey and
will need to translate the information in the survey. Section IV of this
handbook contains a list of questions that your agency can consider
using in focus groups and in questionnaires.

Agencies would be well advised to ask LEP persons whether they are aware
of the types of language assistance the agency provides, which of these
forms are most beneficial, and what, if any, additional language
assistance measures would be most beneficial.

**[Factor 3: The Importance to LEP Persons of Your Program, Activities
and Services]{.underline}**

**[What the Guidance Says]{.underline}**

*"[The more important the activity, information, service, or program, or
the greater the possible consequences of the contact to the LEP
individuals, the more likely language services are needed]{.underline}
(emphasis added). The obligations to communicate rights to an LEP person
who needs public transportation differ, for example, from those to
provide recreational programming. A recipient needs to determine whether
denial or delay of access to services or information could have serious
or even life-threatening implications for the LEP individual..." (DOT
LEP Guidance Section V(3)).*

"...*providing public transportation access to LEP persons is crucial.
An LEP person's inability to utilize effectively public transportation
may adversely affect his or her ability to obtain health care,
education, or access to employment."* (DOT LEP Guidance Section V (4)).

**[Suggestions on Implementing this Guidance]{.underline}**

**Task 3, Step 1: Identify your agency's most critical services**

Your agency should identify what programs or activities would have
serious consequences to individuals if language barriers prevent a
person from benefiting from the activity. Your agency should also
determine the impact on actual and potential beneficiaries of delays in
the provision of LEP services.

For example, your agency may provide emergency evacuation instructions
in its stations and vehicles or may provide information to the public on
security awareness or emergency preparedness. If this information is not
accessible to people with limited English proficiency, or if language
services in these areas are delayed, the consequences to these
individuals could be life threatening.

**Task 3, Step 2: Review input from community organizations and LEP
persons**

Your agency's contact with community organizations that serve LEP
persons, as well as contact with LEP persons themselves, should provide
information on the importance of the modes or types of service you
provide to LEP populations. Depending on the results of your fieldwork,
you may conclude that some particular routes or modes of transportation
are of particular importance to the LEP population.

**[Factor 4: The Resources Available to the Recipient and
Costs]{.underline}**

This last step in the four-factor analysis will allow your agency to
weigh the demand for language assistance against the agency's current
and projected financial and personnel resources. This analysis should
help your agency determine if the language services it currently
provides are cost effective and should also help agencies plan future
investments that will provide the most needed assistance to the greatest
number of LEP persons within the limits of agency resources.

**[What the Guidance Says]{.underline}**

*"[A recipient's level of resources and the costs imposed may have an
impact on the nature of the steps it should take in providing meaningful
access for LEP persons]{.underline}. (emphasis added). Smaller
recipients with more limited budgets are not expected to provide the
same level of language services as larger recipients with larger
budgets. In addition, \`\`reasonable steps'' may cease to be reasonable
where the costs imposed substantially exceed the benefits. Recipients
should carefully explore the most cost-effective means of delivering
competent and accurate language services before limiting services due to
resource concerns.*

*Resource and cost issues, however, can often be reduced by
technological advances, reasonable business practices, and the sharing
of language assistance materials and services among and between
recipients, advocacy groups, affected populations, and Federal
agencies." (Section V(4)).*

The DOT LEP Guidance also notes that, *"large entities and those
entities serving a significant number or proportion of LEP persons
should ensure that their resource limitations are well substantiated
before using this factor as a reason to limit language assistance. Such
recipients may find it useful to be able to articulate, through
documentation or in some other reasonable manner, their process for
determining what language services would be limited based on resources
or costs."* (Section V (4)).

**[Suggestions on Implementing this Guidance]{.underline}**

**Task 4, Step 1: Inventory language assistance measures currently being
provided, along with associated costs.**

As part of your agency's evaluation of its past experience with LEP
persons, you should have developed a record of language assistance
services currently being provided. Your agency's marketing, customer
relations, and community outreach offices may be able to determine the
costs associated with translating documents, contracting with language
interpreters, producing pictographs, installing multilingual technology,
and other language assistance measures your agency is taking or plans to
implement. It may also be helpful for your agency to estimate whether
these costs have increased in recent years or are expected to increase.

In addition to estimating the financial cost of providing language
assistance, agencies should estimate the number of staff and percentage
of staff time that is associated with providing language assistance.

**Task 4, Step 2: Determine what, if any, additional services are needed
to provide meaningful access**

Based on your analysis of demographic data and contact with community
organizations and LEP persons, your agency may determine that
information may need to be translated into additional languages, that
additional oral or written language services should be provided, or that
existing language assistance needs to be made available on a more
widespread basis. If this is the case, your agency should create a list
of specific measures that it determines are needed to provide meaningful
access to its programs and activities.

**Task 4, Step 3: Analyze your budget**

To the extent practicable, you should consider what percentage of the
agency's capitol and/or operating budget could be devoted to additional
language assistance expenses, if needed, and whether the agency's budget
for these expenses will remain stable over time or whether it may be
subject to reduction. Your agency can estimate the cost of providing new
or additional measures by getting price quotes from translating and
interpreting firms or by consulting with similar transit agencies that
have implemented the assistance measures in question.

**Task 4, Step 4: Consider cost effective practices for providing
language services**

Your agency may have access to language assistance products that have
been developed and paid for by local, regional, or state government
agencies and may also have bilingual staff that could provide language
assistance on an ad hoc or regular basis. These resources should be
inventoried and taken into consideration as part of your assessment of
total resources available.

Your agency may already have, or be able to establish arrangements with
qualified community volunteers to provide written or oral language
translation. Although these volunteers may be willing to provide their
services free of charge, your agency will need to verify that they can
provide competent interpretation service and train them on their role
within the agency. Your agency may need to explain to volunteers any
specialized terms and concepts (such as "vehicle headway," "span of
service," or "bus rapid transit") that pertain to your agency's programs
and activities. Section VI of the DOT LEP Guidance contains instructions
on how to ensure competency in oral and written language services.

Other potential cost saving measures, which are listed in Section V(4)
of the DOT LEP Guidance, include telephonic and video conferencing
interpretation services, translating vital documents posted on Web
sites, pooling resources and standardizing documents to reduce
translation needs, centralizing interpreter and translator services to
achieve economies of scale.

**[Conclusion: Developing the Right Mix of LEP Services]{.underline}**

Your agency's four-factor analysis should help you develop new language
assistance services or alter the mix of services currently provided.
What specific steps should be taken will depend on the information you
have gathered from Census and other data, from fieldwork with LEP
individuals and the organizations that serve them, and from your
analysis of agency resources and the costs of providing language
assistance. Section IV part 3 of this handbook contains a menu of
written and oral language assistance measures that transit agencies have
implemented.

**SECTION III**

**DEVELOPING AN IMPLEMENTATION PLAN ON LANGUAGE ASSISTANCE**

**[Overview]{.underline}**

The DOT LEP Guidance recommends that recipients develop an
implementation plan to address the needs of the LEP populations they
serve. The DOT LEP Guidance notes that effective implementation plans
typically include the following five elements: 1) identifying LEP
individuals who need language assistance; 2) providing language
assistance measures; 3) training staff; 4) providing notice to LEP
persons; and 5) monitoring and updating the plan (See Section VII,
"Elements of an Effective Implementation Plan on Language Assistance for
LEP Persons").

This section summarizes the DOT LEP Guidance on language implementation
plans and describes how transit agencies can put this guidance into
practice.

**[Task 1: Identifying LEP Individuals Who Need Language
Assistance]{.underline}**

**[What the Guidance Says]{.underline}**

*"There should be an assessment of the number or proportion of LEP
individuals eligible to be served or encountered and the frequency of
encounters pursuant to the first two factors in the four-factor
analysis.*

*One way to determine the language of communication is to use language
identification cards (or \`\`I speak cards''), which invite LEP persons
to identify their language needs to staff. Such cards, for instance,
might say, \`\`I speak Spanish'' in both Spanish and English, or \`\`I
speak Vietnamese'' in both English and Vietnamese. To reduce costs of
compliance, the Federal Government has made a set of these cards
available on the Internet. The Census Bureau's \`\`I speak card'' can be
found and downloaded at
[http://www.usdoj.gov/crt/cor/13166.htm](http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://www.usdoj.gov/crt/cor/13166.htm).*

*When records are normally kept of past interactions with members of the
public, the language of the LEP person can be included as part of the
record. In addition to helping employees identify the language of LEP
persons they encounter, this process will help in future applications of
the first two factors of the four-factor analysis. In addition, posting
notices in commonly encountered languages notifying LEP persons of
language assistance will encourage them to self-identify." (DOT LEP
Guidance Section VII(1)).*

**[Suggestions on Implementing this Guidance]{.underline}**

This guidance overlaps to a great extent with the recommendations
provided in Section V of the DOT LEP Guidance concerning the four-factor
analysis. In this part of a language implementation plan, agencies
should identify the number and proportion of LEP individuals eligible to
be served and the frequency of encounters, pursuant to the first two
factors of the four-factor analysis. Agencies should consider including
the following information in their implementation plan:

1.  Data collected from the U.S. Census as well as state and local
    demographic data;

2.  Information gathered from community organizations that serve LEP
    persons;

3.  Information gathered from face-to-face meetings with LEP persons or
    from surveys of LEP persons;

4.  Information gathered from interviews with agency staff who typically
    come in contact with LEP persons;

5.  Information kept by the agency on past interactions with members of
    the public who are LEP.

In its assessment of the number and proportion of LEP persons eligible
to be served, the plan should distinguish the native language spoken by
these populations and geographic areas (if any) where LEP persons are
concentrated. Where there are concentrations of LEP persons who speak
different native languages (such as Spanish, Vietnamese, or Korean) the
plan should identify where each group is concentrated. It should also
describe, as accurately as possible, the frequency with which LEP
individuals come into contact with the agency's particular services.

**[Task 2: Language Assistance Measures]{.underline}**

**[What the Guidance Says]{.underline}**

*"An effective LEP plan would likely include information about the ways
in which language assistance will be provided. For instance, recipients
may want to include information on at least the following:*

-   *Types of language services available.*

-   *How recipient staff can obtain those services.*

-   *How to respond to LEP callers.*

-   *How to respond to written communications from LEP persons.*

-   *How to respond to LEP individuals who have in-person contact with
    recipient staff.*

-   *How to ensure competency of interpreters and translation
    services."(DOT LEP Guidance Section VII (2)).*

    **[Suggestions on Implementing this Guidance]{.underline}**

Pursuant to this guidance, transit agencies should consider including
the following information in their implementation plan:

1.  A list of what written and oral language assistance products and
    methods the agency has implemented and how agency staff can obtain
    those services;

2.  Instructions to customer service staff and other agency staff who
    regularly take phone calls from the general public on how to respond
    to an LEP caller. (Ideally, the call taker will be able to forward
    the caller to a language line or to an in-house interpreter who can
    provide assistance);

3.  Instructions to customer service staff and others who regularly
    respond to written communication from the public on how to respond
    to written communication from an LEP person. (Ideally, the agency
    staff person will be able to forward the correspondence to a
    translator who can translate the document into English and translate
    the agency's response into the native language);

4.  Instructions to vehicle operators, station managers, and others who
    regularly interact with the public on how to respond to an LEP
    customer;

5.  Policies on how the agency will ensure the competency of
    interpreters and translation services. Such policies could include
    the following provisions:

-   The agency will ask the interpreter or translator to demonstrate
    that he or she can communicate or translate information accurately
    in both English and the other language;

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-   The agency will train the interpreter or translator in specialized
    terms and concepts associated with the agency's policies and
    activities;

-   The agency will instruct the interpreter or translator that he or
    she should not deviate into a role as counselor, legal advisor, or
    any other role aside from interpreting or translator;

-   The agency will ask the interpreter or translator to attest that he
    or she does not have a conflict of interest on the issues that they
    would be providing interpretation services.

It may be difficult for a non-bilingual bus or rail operator to provide
assistance to an LEP person who boards the vehicle and requests
information. In such circumstances, the operator could ask if another
passenger on the vehicle could serve as a translator or the driver could
provide the phone number to the agency's customer service office, which
would provide translation services. The driver could also direct the LEP
person to any translated schedule and route information that has been
placed aboard the vehicle. Drivers in some agencies have volunteered to
learn Spanish in order to assist LEP Spanish-speaking customers and the
Colorado Department of Transportation has published "Basic Spanish for
Transit Employees," which provides transit personnel with relevant words
and phrases that would be useful in encounters with customers (more
information on this resource is included in Section IV of this
handbook).

Transit station managers who encounter LEP persons requesting assistance
may be able to provide the above resources and, in addition, may have
telephone access to a language line in order to provide assistance.

**[Task 3: Training Staff]{.underline}**

**[What the Guidance Says]{.underline}**

"*Staff members should know their obligations to provide meaningful
access to information and services for LEP persons, and all employees in
public contact positions should be properly trained. An effective LEP
plan would likely include training to ensure that:*

-   *Staff knows about LEP policies and procedures.*

-   *Staff having contact with the public (or those in a recipient's
    custody) is trained to work effectively with in-person and telephone
    interpreters.*

*Recipients may want to include this training as part of the orientation
for new employees. Recipients have flexibility in deciding the manner in
which the training is provided, and the more frequent the contact with
LEP persons, the greater the need will be for in-depth*

*training. However, management staff, even if they do not interact
regularly with LEP persons, should be fully aware of and understand the
plan so they can reinforce its importance and ensure its implementation
by staff." (DOT LEP Guidance Section VII (3)).*

**[Suggestions on Implementing this Guidance]{.underline}**

In this part of the language assistance plan, agencies should describe
the training that is conducted to ensure that appropriate staff members
know about LEP policies and procedures and are ready to provide
assistance.

**Task 3, Step 1: Identify agency staff that are likely to come into
contact with LEP persons as well as management staff.**

This handbook recommends that agencies identify those members of their
staff---or job positions---that have frequent contact with LEP persons
in order to target training to the appropriate staff. Management staff,
even if they do not interact regularly with LEP persons, should be
included on the list to ensure they are fully aware of the language
assistance plan.

**Task 3, Step 2: Identify existing staff training opportunities**

It may be cost-effective to integrate training on their responsibilities
to persons with limited English proficiency into agency training that
occurs on an ongoing basis. The DOT LEP Guidance suggests that
recipients consider including this training as part of the orientation
for new employees. Existing employees, especially managers and those who
work with the public may periodically take part in re-training or new
training sessions to keep up to date on their responsibilities to LEP
persons.

**Task 3, Step 3: Design and implement LEP training for agency staff**

Agencies are encouraged to develop a standard presentation concerning
recipients' responsibilities to persons with limited English proficiency
that could be used at multiple agency trainings. While agencies have
flexibility in designing language assistance training, FTA recommends
that such training include the following information:

-   A summary of the transit agency's responsibilities under the DOT LEP
    Guidance;

-   A summary of the agency's language assistance plan;

-   A summery of the number and proportion of LEP persons in the
    agency's service area, the frequency of contact between the LEP
    population and the agency's programs and activities, and the
    importance of the programs and activities to the population;

-   A description of the type of language assistance that the agency is
    currently providing and instructions on how agency staff can access
    these products and services; and

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-   A description of the agency's cultural sensitivity policies and
    practices.

Transit agencies designing their staff training may want to take
advantage of the following resources:

-   "Breaking Down the Language Barrier: Translating Limited English
    Proficiency into Practice." This video, which is available on DVD
    and as a streaming video link on [www.lep.gov](http://www.lep.gov/),
    explains the language access requirements of Title VI and Executive
    Order 13166 through vignettes that expose the problems resulting
    from the absence of language assistance. The video goes on to show
    how these same situations could have been handled more appropriately
    if the service provider took reasonable steps to provide meaningful
    access.

-   "Providing Language Access for Persons with Limited English
    Proficiency," a PowerPoint presentation produced by the FTA Office
    of Civil Rights and available at
    <http://www.fta.dot.gov/civilrights/title6/civil_rights_5102.html>.

-   "How to Engage Low-Literacy and Limited English Proficient
    Populations in Transportation Decisionmaking," available at
    <http://www.fhwa.dot.gov/hep/lowlim>. This report documents "best
    practices" in identifying and engaging low-literacy and LEP
    populations in transportation decisionmaking. These "best practices"
    were collected during telephone interviews with individuals in 30
    States.

-   "Basic Spanish for Transit Employees" this flip guide was produced
    by the Roaring Fork Transit Authority and the Colorado Mountain
    College. It includes requests and commands that vehicle operators
    use every day in English and in Spanish and written phonetically in
    English. Copies of this guide can be obtained by calling
    970-945-8691.

-   "Guidelines for Developing Traffic Safety Educational Materials for
    Spanish-Speaking Audiences," a manual developed by the Education in
    Traffic Safety project, Education Development Center, Inc., with
    funding from the National Highway Traffic Safety Administration. The
    manual is organized into three sections: research and planning,
    creating materials, and dissemination and evaluation. Available at
    <http://www.nhtsa.dot.gov/people/injury/airbags/TESM/index.htm>.

    These and additional resources are listed in Section V of this
    manual.

    **[Task 4: Providing Notice to LEP Persons]{.underline}**

    **[What the Guidance Says]{.underline}**

*["Once an agency has decided, based on the four factors, that it will
provide language services, it is important that the recipient notify LEP
persons of services available free of charge]{.underline} (emphasis
added). Recipients should provide this notice in languages LEP persons
would understand. Examples of notification that recipients should
consider include:*

-   *Posting signs in intake areas and other entry points. This is
    important so that LEP persons can learn how to access those language
    services at initial points of contact. This is particularly true in
    areas with high volumes of LEP persons seeking access to certain
    transportation safety information, or other services and activities
    run by DOT recipients*

> *For instance, signs in intake offices could state that free language
> assistance is available. The signs should be translated into the most
> common languages encountered and should explain how to get the
> necessary language assistance. The Social Security Administration has
> made such signs available at
> [http://www.ssa.gov/multilanguage/langlist1.htm](http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://www.ssa.gov/multilanguage/langlist1.htm).
> DOT recipients could, for example, modify these signs for use in
> programs, activities, and services.*

-   *Stating in outreach documents that language services are available
    from the agency. Announcements could be in, for instance, brochures,
    booklets, and in outreach and recruitment information. These
    statements should be translated into the most common languages and
    could be \`\`tagged'' onto the front of common documents.*

-   *Working with community-based organizations and other stakeholders
    to inform LEP individuals of the recipients' services, including the
    availability of language assistance services.*

-   *Using an automated telephone voice mail attendant or menu system.
    The system could be in the most common languages encountered. It
    should provide information about available language assistance
    services and how to get them.*

-   *Including notices in local newspapers in languages other than
    English.*

-   *Providing notices on non-English-language radio and television
    stations about the available language assistance services and how to
    get them.*

-   *Providing presentations and/or notices at schools and religious
    organizations." (DOT LEP Guidance Section VII (4)).*

    **[Suggestions on Implementing this Guidance]{.underline}**

This part of the plan should identify how the agency will advertise its
language services to the LEP community.

**Task 4, Step 1: Inventory the existing public service announcements
and community outreach the agency currently performs.**

Transit agencies typically communicate to the public through one or more
of the following methods:

-   Signs and handouts available in vehicles and at stations

-   Announcements in vehicles and at stations

-   Agency websites

-   Customer service lines

-   Press releases

-   Newspaper, radio, and television advertisements

-   Announcements and community meetings.

-   Information tables at local events.

Some of these communications tools are geared towards riders who are
using the system, while other methods are intended to reach members of
the public at large, who may or may not use the transit system. Both
methods can be used to inform people of the availability of language
assistance.

**Task 4, Step 2: Incorporate notice of the availability of language
assistance into existing outreach methods**

Agencies should consider developing non-English outreach documents that
notify people of the availability of language assistance and
incorporating this outreach into the public relations materials
routinely disseminated by the agency. Agencies should provide notice of
the availability of language assistance on a regular basis, in order to
reach the greatest number of potential riders.

Agencies might, for example, decide to specify in their plan that where
documents are available in languages other than English, the English
version will include a notice of such availability translated into other
languages in which the document is available.

**Task 4, Step 3: Conduct targeted community outreach to LEP
populations.**

Targeted community outreach can consist of meeting with agencies that
serve LEP populations and attending community meetings and events to
inform people of the agency's service in general and that language
assistance is available. Your agency may wish to partner with its
existing community contacts and other agencies that are seen by your
audience as credible and trusted to notify the LEP population of the
availability of language services. Notification can also be distributed
through programs used by LEP persons, such as English classes for
speakers of other languages.

**[Task 5: Monitoring and Updating the LEP Plan]{.underline}**

Evaluation can help you track your outreach efforts, discover
dissemination problems early, make corrections, and find out whether
your language services have impacted your ridership and/or relations
with local immigrant communities. The results can help you improve
future efforts. Regardless of your budget, some level of evaluation can
be done.

**[What the Guidance Says]{.underline}**

*"Recipients should, where appropriate, have a process for determining,
on an ongoing basis, whether new documents, programs, services, and
activities need to be made accessible for LEP individuals, and they may
want to provide notice of any changes in*

*services to the LEP public and to employees.*

*In addition, recipients should consider whether changes in
demographics, types of services, or other needs require annual
reevaluation of their LEP plan. Less frequent reevaluation may be more
appropriate where demographics, services, and needs are more static. One
good way to evaluate the LEP plan is to seek feedback from the*

*community.*

*In their reviews, recipients may want to consider assessing changes
in:*

-   *Current LEP populations in the service area or population affected
    or encountered.*

-   *Frequency of encounters with LEP language groups.*

-   *Nature and importance of activities to LEP persons.*

-   *Availability of resources, including technological advances and
    sources of additional resources, and the costs imposed.*

-   *Whether existing assistance is meeting the needs of LEP persons.*

-   *Whether staff knows and understands the LEP plan and how to
    implement it.*

-   *Whether identified sources for assistance are still available and
    viable.*

*In addition to these five elements, effective plans set clear goals,
management accountability, and opportunities for community input and
planning throughout the process."(DOT LEP Guidance Section VII (5)).*

**[Suggestions on Implementing this Guidance]{.underline}**

Transit agencies can implement this portion of the DOT LEP Guidance by
undertaking the following steps:

**Task 5, Step 1: Establish a process to obtain feedback on your
agency's language assistance measures.**

How frequently an agency should consult with community organizations
representing LEP persons as well as the staff that is responsible for
providing language assistance will depend on the size and complexity of
the agency's LEP program as well as the resources available to the
transit provider. Agency staff can combine meetings to obtain feedback
on its language assistance program with regularly scheduled community
outreach events as well as regularly scheduled staff meetings.

**Task 5, Step 2: Obtain feedback from community members and from agency
staff.**

Transit agencies should consider conducting follow-up meetings and focus
groups or surveys with the community organizations and individuals they
contacted in order to develop their needs assessment. This outreach
would allow agency staff to determine if there have been any noticeable
changes in the demographics of the LEP population in their service area,
to receive input on whether their language assistance measures and
efforts to inform the LEP community of the availability of language
assistance are working, and to continue to inform the LEP community of
new or updated language assistance.

Agencies should also meet with staff that are in contact with LEP
persons to determine whether the written and oral assistance measures
are effective. Agency staff may also be in a position to comment on
whether the numbers of LEP persons they have encountered are increasing
or decreasing and whether they are interacting more frequently with
members of a particular language group.

**Task 5, Step 3: Conduct internal monitoring**

Agencies can conduct internal monitoring of their system to determine
whether language assistance measures and staff training programs are
working. Such monitoring might be best accomplished if the monitors pose
as riders and observe how agency staff respond to their requests.
Agencies can work with multilingual staff or community members to
determine if employees are responding appropriately to requests made
with limited English or in a language other than English. Section 4 of
Section IV provides an internal monitoring template.

**Task 5, Step 4: Make changes to the language assistance plan based on
feedback received**

Based on the feedback received from community members and agency
employees, agencies will likely need to make incremental changes to the
type of written and oral language assistance provided as well as to
their staff training and community outreach programs. Agencies may take
into account the cost of proposed changes and the resources available to
them. Depending on their evaluation, agencies may choose to disseminate
more widely those language assistance measures that are particularly
effective or modify or eliminate those measures that have not been
effective.

**Task 5, Step 5: Consider new language assistance needs when expanding
service**

Transit agencies that are expanding service into areas with high
concentrations of LEP persons should consider modifying their
implementation plan to provide language assistance measures to areas not
previously served by the agency.

**SECTION IV**

**LANGUAGE ASSISTANCE CHECKLISTS**

**1. QUESTIONS TO ASK COMMUNITY GROUPS SERVING LEP PERSONS**

The DOT LEP Guidance states that the nature of language assistance an
agency provides should be based in part on the number and proportion of
LEP persons served by the recipient, the frequency of contact between
the recipient and the LEP population, and the importance of the service
provided by the recipient to the LEP population.

In order to better analyze these factors, transit agencies are
encouraged to consult with community organizations serving LEP persons
and ask some or all of the following questions:

-   What geographic area does your agency serve?

-   How many people does your agency provide services to?

-   Has the size of the population you serve increased, stayed the same,
    or decreased over the past five years?

-   What are the countries of origin from which your population has
    immigrated?

-   Does your population come from an urban or rural background?

-   What are the languages spoken by the population you serve?

-   What is the age and gender of your population?

-   What is the education and literacy level of the population you
    serve?

-   What needs or expectations for public services has this population
    expressed?

-   Has the population inquired about how to access public
    transportation or expressed a need for public transportation
    service?

-   What are the most frequently traveled destinations?

-   Are there locations that the population has expressed difficulty
    accessing via the public transportation system?

-   Do the transit needs and travel patterns of the population vary
    depending on the age or gender of the population members?

-   What is the best way to obtain input from the population?

-   Who would the population trust most in delivering language
    appropriate messages?

    **2. LEP SURVEY/FOCUS GROUP QUESTIONS**

Transit agencies implementing the four-factor analysis described in the
DOT LEP Guidance are encouraged to consult directly with LEP persons to
determine how frequently these persons use the agency's service and the
importance of the service to LEP persons.

Section II of this handbook recommends that agencies gather input from
LEP persons using focus groups and surveys. Agencies using these methods
should consider asking some or all of the following questions:

-   Do you use public transportation?

> If a person answers "yes," ask the following questions:

-   How often do you use public transportation?

-   What kinds of public transportation do you use---trains, buses, the
    city subway?

-   When do you use public transportation? For what purpose?

-   Are you satisfied with the transportation you use?

-   Do you have any suggestions how the people who run the
    transportation services could improve it to make it work better for
    you? Please be as specific as you can.

> If a person answers "no" to the first question, ask the following
> questions:

-   How do you travel if you have to go somewhere in your area?

-   Would you use public transportation if the trains or buses were set
    up differently?

-   If the person answers "yes," to this question, then ask:

-   Which transit systems would you use?

-   How can the people who run that system improve it to make it work
    better for you?[^2]

When possible, survey or focus group questions should be provided to
advocacy groups and other interested organizations so that they may
provide feedback on the instrument and offer additional suggestions.

**3. LANGUAGE ASSISTANCE MEASURES CURRENTLY BEING OFFERED BY TRANSIT
PROVIDERS**

The Government Accountability Office and the New Jersey Department of
Transportation have identified the following language assistance
measures that have been deployed by public transportation providers.
Each agency should determine its appropriate mix of services after
conducting the DOT LEP Guidance's four-factor analysis.

More information about these assistance measures, including which
measures are most frequently used, can be found in the GAO report,
"Transportation Services: Better Dissemination and Oversight of DOT's
Guidance Could Lead to Improved Access for Limited English-Proficient
Populations," and the New Jersey Department of Transportation report,
"Mobility Information Needs of Limited English Proficiency (LEP)
Travelers in New Jersey." Web links to these documents are available in
Section V of this handbook.

I---Written Language Assistance (check all that applies):

Bilingual or multilingual versions of the following information:

\_\_\_\_"How to ride" brochures

\_\_\_\_Fare payment instructions

\_\_\_\_System maps and timetables

\_\_\_\_Public service announcements

\_\_\_\_Safety and security announcements

\_\_\_\_Service change announcements

\_\_\_\_Notices pertaining to upcoming events

\_\_\_\_Complaint/commendation forms

\_\_\_\_Pictographs in stations and in vehicles

\_\_\_\_Ticket vending machines with multilingual functions

\_\_\_\_"I Speak" cards to be used by station managers

\_\_\_\_Translated information on agency websites

\_\_\_\_Translated electronic signs

II\--Oral language Assistance (check all that applies)

\_\_\_\_ Hiring permanent, full-time staff interpreters

\_\_\_\_Contracting for interpreters on an "as needed" basis

\_\_\_\_Using community volunteers to interpret information

\_\_\_\_Using bilingual staff to interpret information on an "as needed"
basis

\_\_\_\_Using telephone interpreter services

\_\_\_\_Translated recorded announcements in stations and in vehicles

III-Community Outreach (check all that applies)

\_\_\_Translated TV advertisements

\_\_\_Translated radio advertisements

\_\_\_Translated newspaper advertisements

\_\_\_Advertisements in ethnic media

**4. LANGUAGE ASSISTANCE MONITORING CHECKLIST**

Periodic monitoring of language assistance measures that have been
implemented can help an agency determine if assistance is being provided
competently and effectively. Agencies can use the following checklist to
monitor their services. Actual monitoring should be tailored to what
services the agency has implemented. Depending on the language
assistance provided, the following questions could be answered by
periodic monitoring:

[Stations]{.underline}

\_\_\_Are translated instructions on how to make fare payments
available?

\_\_\_Are translated schedules, route maps, or information on how to use
the system available?

\_\_\_Has the information been placed in a visible location?

\_\_\_How many units of the material have been distributed?

\_\_\_If such information is available, are station managers aware that
they have this information?

\_\_\_Are announcements audible?

\_\_\_Are any announcements, such as security awareness announcements,
made in languages other than English?

\_\_\_Does the station display information or instructions using
pictographs?

\_\_\_Can a person who speaks limited English or another language
receive assistance from a station manager when asking for directions?
How is this assistance provided?

[Vehicles]{.underline}

\_\_\_Are translated instructions on how to make fare payments
available?

\_\_\_Are translated schedules, route maps, or information on how to use
the system available?

\_\_\_Has the information been placed in a visible location?

\_\_\_How many units of the material have been distributed?

\_\_\_If such information is available, are vehicle operators aware that
they have this information?

\_\_\_Are announcements audible?

\_\_\_Are any announcements, such as security awareness announcements,
made in languages other than English?

\_\_\_Can a person who speaks limited English or another language
receive assistance from a bus operator when asking about the destination
of the vehicle? How is this assistance provided?

[Customer Service]{.underline}

[\_\_\_]{.underline}Is the customer service telephone line equipped to
handle callers speaking languages other than English?

\_\_\_Can customer service representatives describe to a caller what
language assistance the agency provides and how to obtain translated
information or oral interpretation?

\_\_\_Can a person speaking limited English or a language other than
English request information from a customer service representative?

[Community Outreach]{.underline}

\_\_\_Are translators present at community meetings?

\_\_\_Are translated versions of any written materials that are handed
out at a meeting provided?

\_\_\_Can members of the public provide oral as well as written
comments?

[Press/Public Relations]{.underline}

\_\_\_Are meeting notices, press releases, and public service
announcements translated into languages other than English?

\_\_\_Does the agency website have a link to translated information on
its home page?

**SECTION V**

**LANGUAGE ASSISTANCE RESOURCES**

**LANGUAGE ASSISTANCE RESOURCES**

**[1. Policy and Guidance Documents]{.underline}**

**Executive Order 13166, Improving Access to Services for Persons with
Limited English Proficiency.** Executive Order 13166 was signed by
President Clinton in 2000. It clarifies federal agencies' and their
grant recipients' responsibilities to make their services available to
LEP populations. A link to this executive order can be found at FTA's
Title VI web page,
<http://www.fta.dot.gov/civilrights/civil_rights_5088.html>.

**DOT Policy Guidance Concerning Recipients' Responsibilities to**

**Limited English Proficient (LEP) Persons.** DOT's Guidance was issued
in 2001 and updated in 2005. It discusses strategies for providing
services to LEP persons and outlines a framework for providing an
effective language assistance program. A link to this document can be
found at FTA's Title VI web page,
<http://www.fta.dot.gov/civilrights/civil_rights_5088.html>.

**FTA Circular 4702.1A, "Title VI and Title VI-Dependent Guidelines for
Federal Transit Administration Recipients."** This document provides
recipients and subrecipients of FTA financial assistance with guidance
and instructions necessary to carry out the U.S. Department of
Transportation's Title VI regulations (49 CFR part 21) and to integrate
into their programs and activities considerations expressed in the
Department's Order on Environmental Justice (Order 5610.2), and Policy
Guidance Concerning Recipients' Responsibilities to Limited English
Proficient ("LEP") Persons (70 FR 74087, December 14, 2005). A link to
this document can be found at FTA's Title VI web page,
<http://www.fta.dot.gov/civilrights/civil_rights_5088.html>.

**[2. Websites]{.underline}**

**Federal Interagency Working Group on Limited English Proficiency**,
[www.lep.gov](http://www.lep.gov/). LEP.gov promotes a cooperative
understanding of the importance of language access to Federal programs
and federally assisted programs. The site acts as a clearinghouse,
providing and linking to information, tools, and technical assistance
regarding limited English proficiency and language services for Federal
agencies, recipients of Federal funds, users of Federal programs and
federally assisted programs, and other stakeholders.

**The Modern Language Association**,
[http://www.mla.org](http://www.mla.org/). The MLA has produced a
Language Map intended for use by students, teachers, and anyone
interested in learning about the linguistic and cultural composition of
the United States. The MLA Language Map uses data from the 2000 Census
to display the locations and numbers of speakers of 30 languages and
three groups of less commonly spoken languages in the United States. The
census data are based on responses to the question, "Does this person
speak a language other than English at home?" The Language Map
illustrates the concentration of language speakers in zip codes and
counties. The MLA's Data Center provides census data on more than 300
languages spoken in the United States.

**The U.S. Census**, [http://www.census.gov](http://www.census.gov/).
The "American Fact Finder" link at this website provides a wide range of
demographic information collected at the 2000 Census at multiple
geographic levels. The Census Bureau's regional contacts can be found at
<http://www.census.gov/field/www>.

**Special Tabulation of LEP Information from Census 2000,**
<http://www.doleta.gov/reports/CensusData/>. The Department of Labor has
sponsored a special tabulation of Census data on Limited English
proficient (LEP) populations as a resource for One Stop Career Centers
and other providers of employment and training services. Information is
broken out for 39 Census languages and language clusters, and the
tabulations are designed to match the service areas of states and local
Workforce Investment Areas.

**The FTA's Title VI Website**,
<http://www.fta.dot.gov/civilrights/civil_rights_5088.html>. This
website includes copies of DOT Title VI policies, guidance, and
procedures, links to Title VI compliance reviews conducted of FTA
grantees, and sources of technical assistance.

**FTA and FHWA's Transportation Planning Capacity Building (TPCB)
Program**, [http://www.planning.dot.gov](http://www.planning.dot.gov/).
Information regarding language access services is available at this
site.

**FTA's Innovative Practices to Increase Ridership,**
<http://ftawebprod.fta.dot.gov/bpir>. This website serves as a central
information resource on innovative strategies that are submitted by
transit organizations, reviewed by FTA, and are then made available for
other transit organizations to search records, review innovations, and
potentially implement similar programs. Innovative practices regarding
language access services are available.

**[3. Reports]{.underline}**

**Federal Highway Administration,** **"How to Engage Low-Literacy and
Limited English Proficient Populations in Transportation
Decisionmaking,"** available at <http://www.fhwa.dot.gov/hep/lowlim>.
This report documents best practices" in identifying and engaging
low-literacy and limited-English-proficiency populations in
transportation decisionmaking. These "best practices" were collected
during telephone interviews with individuals in 30 States.

**Government Accountability Office, "Transportation Services: Better
Dissemination and Oversight of DOT's Guidance Could Lead to Improved
Access for Limited English-Proficient Populations,"** GAO-06-52
(November 2005) available at [www.gao.gov](http://www.gao.gov/). This
report summarizes the language assistance measures implemented by 20
transit agencies and seven metropolitan planning organizations and
contains recommendations to the U.S. Department of Transportation.

**New Jersey Department of Transportation,** "**Mobility Information
Needs of Limited English Proficiency (LEP) Travelers in New Jersey**,"
available at
[**http://www.transportation.njit.edu/nctip/final_report/LEP.htm**](http://www.transportation.njit.edu/nctip/final_report/LEP.htm).
This report surveys the needs of LEP persons in New Jersey, surveys best
practices of peer transit agencies in bi- or multilingual populations,
and surveys selected transportation providers outside the United States
along with various airports, tourism centers, and other locales catering
to multilingual clientele. The report includes examples of multilingual
web pages, publications and announcements, telephone lines, pictograms,
visual aids and personal assistance.

U.S. Department of Education, **"The State of Literacy in America
(2003),"** available at <http://www.nifl.gov/reders/reder.htm>. This
report provides the first assessment of the nation's progress in adult
literacy since 1992. In addition to describing the status and progress
of literacy in the nation and in each of the six participating states
(Kentucky, Maryland, Massachusetts, Missouri, New York, and Oklahoma),
the 2003 NAAL provides information about background factors associated
with literacy, the skill levels of the least-literate adults, and the
application of literacy skills to health-related materials. It seeks to:
describe the status of adult literacy in the United States; report on
national trends; and identify relationships between literacy and
selected characteristics of adults.

**[4. Presentations, Guides, and Teaching Tools]{.underline}**

**"Breaking Down the Language Barrier: Translating Limited English
Proficiency into Practice."** This video, which is available on DVD and
as a streaming video link on [www.lep.gov](http://www.lep.gov/) explains
the language access requirements of Title VI and Executive Order 13166
through vignettes that expose the problems resulting from the absence of
language assistance. The video goes on to show how these same situations
could have been handled more appropriately if the service provider took
reasonable steps to provide meaningful access.

**"Providing Language Access for Persons with Limited English
Proficiency,"** a power point presentation produced by the FTA Office of
Civil Rights and available at
<http://www.fta.dot.gov/civilrights/title6/civil_rights_5102.html>.

**"How to Identify Limited English Proficient (LEP) Populations in Your
Locality,"** a presentation given by the Federal Highway Administration
at the American Association of State Highway and Transportation
Officials (AASHTO) 2004 Civil Rights Conference. The workshop provides
information on the LEP Executive Order, DOT's LEP Guidance , and
specific information about what resources can be used to identify LEP
populations. The presentation is available at
http://www.fhwa.dot.gov/civilrights/confworkshops04.htm.

**"Basic Spanish for Transit Employees,"** a flip guide funded by the
Colorado Department of Transportation and produced by the Roaring Fork
Transit Authority and the Colorado Mountain College. It includes
requests and commands that vehicle operators use every day in English
and in Spanish and written phonetically in English. Copies of this guide
can be obtained by contacting the Colorado Mountain College at
970-945-8691 or www.coloradomtn.edu.

**Guidelines for Developing Traffic Safety Educational Materials for
Spanish-Speaking Audiences,** created by the Education Development
Center for the National Highway Traffic Safety Administration, These
*Guidelines* were developed as part of a larger project, *Educación de
seguridad en el tránsito/Education in Traffic Safety (EST).* The goal of
the project was to foster the development of effective traffic safety
educational materials to serve the growing Spanish-speaking population
in the United States. Although most of the demographic and cultural
information in this document is specific to Latinos, the nine steps and
much of the expert advice can be used to develop educational materials
for other populations or materials that deal with other safety and
health topics.

**Language Assistance Self-Assessment and Planning Tool for Recipients
of Federal Financial Assistance**, created by the U.S. Department of
Justice. This document is intended to assist organizations that receive
Federal financial assistance in their strategic planning efforts to
ensure that program goals and objectives address meaningful access for
all of the people they serve or encounter, including those who are
limited English proficient. This tool assists recipients in assessing
their current other-than- English language services capabilities and
planning for the provision of language servies.

**[Accessing and Using Language Data from the U.S. Census
Bureau]{.underline}**

**(Adopted from materials provided by the U.S. Census at the March 15,
2007 Federal Interagency Conference on Limited English Proficiency)**

**I. How can I use the American FactFinder to find Census Bureau
Language data?**

**1.** Start at our main Web site,
[www.census.gov](http://www.census.gov/)

2\. On the left-hand side, click on the blue bar for American FactFinder
(AFF)

3\. On the AFF main site, click on the lef-hand side, scroll your mouse
over the blue bar DATA SETS.

4\. Click on the second bullet that says "American Community Survey."

5\. Click on the radio button for the year you want.

6\. On the second bullet labeled "Select a geographic type," pull the
menu down and click on the geography you want.

7\. Once your geography is highlighted, click the ADD button, then click
the NEXT button.

8\. Click on the second tab that says "by keyword."

9\. Type in "language" in the box and click SEARCH (note: you can
isolate any other information you're looking for by typing the word or
looking at the "by subject" tab).

10\. You'll get a the list of all tables with language data.

11\. Highlight the table(s) you want and click the ADD button.

12\. Click SHOW RESULTS.

**II. How Can I download tables from American FactFinder**

1\. Near the top right side of the page where you have your output
table, you'll see three choices: OPTIONS, PRINT/DOWNLOAD, and RELATED
ITEMS.

2\. Scroll your mouse over the PRINT/DOWNLOAD choice.

3\. Click on DOWNLOAD.

4\. On the pop-up window, keep the settings as they are and click OK.

5\. Once you have it saved on your hard drive, you can open it up and do
whatever tabulations you want.

**III. Where can I find documentation on the Accuracy of the Data,
including instructions on how to calculate confidence intervals?**

1\. Start on the main Web site,
[www.census.gov](http://www.census.gov/).

2\. On the middle of the page, click on the link for American Community
Survey.

3\. Inside the Using the Data tab, click on the link for Accuracy of the
Data---2005.

4\. Click on the document that corresponds with the data of the year you
want.

**IV. What are the key ACS language tables that are avail able from
American FactFinder?**

The Detailed Tables are the data products with the most detailed
information on language. Two key tables include:

-   B16001. Language Spoken at Home by Ability to Speak English for the
    Population 5 Years and Over. This table gives the most detailed
    language data available by English --speaking ability.

-   B16004. Age by Language Spoken at Home by Ability to Speak English
    for the Population 5 Years and Over. This table gives the four major
    language categories by English-speaking ability for the 5-17 year
    olds, 18-64 year olds, and 65 years and older populations.

    **V. Where can I find information about other language-related
    products?**

    The Language Use Web page includes a list of Census 2000 products.
    Use the following directions to find that Web page.

1.  Start at main Web site, [www.census.gov](http://www.census.gov/)

2.  On the top right-hand side, click on Subjects A to Z

3.  Click on L for language

4.  Click on the link for Language Use Data.

The most detailed language data available are accessible from the
Language Use Web site using Census 2000 data. Choose link F\-\--STP 224.
Data are not available by English-speaking ability but are available
down to the census tract level. Also, under Related Reports, the
document [How Good is "How Well?" An Examination of the Census English
--Speaking Ability Question]{.underline} is available.

**VI. What should I do if I need language information for a small
geographic area?**

In 2010, the ACS will release 5-year estimates for the smallest
geographic areas. The most recent ACS data available at this time are
based on one year of sample and cannot support the production of most
small area data. You should therefore continue to use Census 2000 data
following the step-by-step instructions in section I. You should select
"2000 Decennial Census---Summary File 3" as the DATA SET.

**VII. Where can I find information about special tabulations?**

1\. For Census 2000

a\. Look at the Language Use Web site at

> i.http://www.census.gov/population/www/socdemo/lang_use.html.
>
> ii\. Those labeled STP indicate special tabulations.

b\. Go the Gateway to Census 2000 at

i.  <http://www.census.gov/main/www/cen2000.html>

ii. On the left-hand side, under Information Links, click on the link
    for Special Tabulations.

2\. For the ACS

> a\. Please visit the Custom Tabulations Web site to get more
> information on requesting special tabulations from ACS.

i\. http//www.census.gov/www/Products/psec_tabs/

**VIII. Who Can I contact if I have questions?**

For specific questions about the American Community Survey, contact

Deborah H. Griffin, Special Assistant to the Chief of the American
Community Survey Office

U.S. Census Bureau

HQ-3H159

Washington, DC 20233

301-763-2855

<Deborah.H.Griffin@census.gov>

For questions about Census 2000 and ACS data on language, contact

Hyon B. Shin, Demographic Statistician

U.S. Census Bureau

Housing and Household Statistics Division

HQ-7H070H

Washington DC 20233

301-763-6169

<Hyon.B.Shin@census.gov>

.

[^1]: The U.S. Census classifies as "linguistically isolated" those
    households in which no person 14 years old and over speaks only
    English and no person 14 years old and over who speaks a language
    other than English speaks English "very well." Individuals in these
    households may face significant language barriers because they may
    not be able to rely on an adult relative who speaks English well to
    provide translation assistance.

[^2]:
    ####  These questions are adopted from "Mobility Information Needs of Limited English Proficiency (LEP) Travelers in New Jersey" a report produced by the New Jersey Institute of Technology for the New Jersey Department of Transportation