Transportation Services: Better Dissemination and Oversight of DOT's Guidance Could Lead to Improved Access for Limited English-Proficient Populations
Published: 2005-11-02T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: More than 10 million people in the United States are of limited English proficiency (LEP), in that they do not speak English at all or do not speak English well. These persons tend to rely on public transit more than English speakers. Executive Order 13166 directs federal agencies to develop guidance for their grantees on making their services accessible to LEP persons. The Department of Transportation (DOT) issued its guidance in 2001, with revised guidance pending issuance. This report reviews (1) the language access services transit agencies and metropolitan planning organizations have provided, and the effects and costs of these services; (2) how DOT assists its grantees in providing language access services; and (3) how DOT monitors its grantees' provision of these services.
section_title: What GAO Found
paragraphs: Transit agencies and metropolitan planning organizations provide a variety of language access services, predominantly in Spanish, but the effects and costs of these services are largely unknown. Types of services provided included, among other things, translated brochures and signs; multilingual telephone lines; bilingual drivers; and interpreters at public meetings. However, few agencies we visited had conducted an assessment of the language needs in their service areas, or had conducted an evaluation of their language access efforts. As a result, it is unclear whether agencies' efforts are comprehensive enough to meet the needs of LEP persons, and community groups in the areas we visited saw important gaps in agencies' services. In addition, although those costs are largely unknown, several agencies saw providing language access as a cost of doing business, not as an additional cost. However, if efforts were to be expanded to include additional services or languages, agency officials told us that costs could become prohibitive. DOT assists grantees in providing language access through its guidance and other activities, but DOT has made limited efforts to ensure that grantees are aware of the available assistance, which was not often accessed by the agencies we visited. This assistance includes DOT's guidance--which provides a five-step framework for how to provide meaningful language access--as well as workshops and peer-exchange programs that include language access practices, and training courses that touch on language issues. DOT also participates in a federal LEP clearinghouse, www.lep.gov . However, few agencies we visited had accessed these resources. Several local officials stated that easily accessible training and assistance specific to language access and examples of how to implement DOT's guidance could help them more effectively provide access to LEP populations. Transit agencies' and metropolitan planning organizations' provision of language access services are monitored through in-depth civil rights compliance reviews and two broader reviews--triennial reviews of transit agencies and planning certification reviews. However, these reviews do not have consistent criteria for determining whether an agency is deficient in providing such services. Furthermore, these reviews do not fully reflect Executive Order 13166 or DOT's guidance. Without thorough and consistent monitoring that takes into account the guidance, local agencies' language access activities will likely remain varied and inconsistent.

section_title: Letter
paragraphs: The United States has a highly diverse population representing cultures  from all over the world. English is not the primary language of many people  living in the United States, and significant numbers have little or no English  skills. 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.  These persons of limited English proficiency (LEP), like English speakers,  may depend on government for a wide range of services, including public  transportation. For many LEP persons, public transit is a key means of  achieving mobility. According to the 2000 Census, more than 11 percent of  LEP persons aged 16 years and over reported using public transit as their  primary means of transportation to work, compared with about 4 percent  of English speakers.
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. As figures 1  and 2 demonstrate, while LEP populations tend to be largest in counties in  border and coastal states, the largest growth in these populations is  occurring in the Midwest and the South. Among limited English speakers,  Spanish is the language most frequently spoken, followed by Chinese  (Cantonese or Mandarin), Vietnamese, and Korean.
Title VI of the Civil Rights Act of 1964 prohibits recipients of federal  financial assistance from discriminating on the basis of race, color, or  national origin. Executive Order 13166, which was signed by President  Clinton in 2000, sought to clarify the responsibilities of federal agencies  and their grant recipients under Title VI to make their programs and  activities accessible to LEP populations, and it required federal agencies to  issue guidance to their funding recipients to avoid discriminating on the  basis of national origin. The Department of Transportation (DOT) issued  guidance in 2001, which discusses strategies for providing services to LEP  persons, based on guidelines put forth by the Department of Justice (DOJ).  This guidance, while in effect for grantees since 2001, was subsequently  revised by DOT after public comments were received on it. The revised  guidance was approved by DOJ on August 25, 2005, and DOT is preparing  to publish and release this revised guidance.
Advocacy organizations and others have raised concerns over the extent to  which DOT’s guidance to its funding recipients is being implemented. A  lack of English skills has the potential to hinder many LEP persons from  fully utilizing public transit services and meaningfully participating in the  transportation planning process. The inability to effectively access public  transit services can result in an array of harmful consequences for LEP  persons, including a reduction in employment opportunities, increased  difficulty in accessing other needed services, the perpetuation of social  isolation, and the diminishment of overall quality of life. In light of these  issues, this report discusses (1) the types of language access services that  transit agencies and metropolitan planning organizations (MPO) have  provided to the LEP populations in their service areas, and the effects and  costs of these services; (2) how DOT and its modal administrations assist  grantees in providing language access services for LEP populations; and (3)  how DOT and the responsible modal administrations monitor grantees’  provision of language access services for LEP populations.
To determine the types of language access services that transit agencies  and MPOs provided to LEP populations, we visited seven metropolitan  statistical areas in Arkansas, California, Illinois, North Carolina, and  Texas. We used census data to select these site visit locations on the basis  of the size, proportion, and growth of the LEP population, the number of  languages spoken, and the extent of public transit use. We conducted  semistructured interviews with officials from 20 transit agencies, 7 MPOs,  and 16 community and advocacy groups and reviewed various documents  and other information. We complemented these case studies and  interviews with findings from a 2004 study, conducted for the New Jersey  Department of Transportation, which included a survey of 32 transit  agencies around the country, and surveys and focus groups with LEP  persons in New Jersey. To understand how DOT assists transit agencies  and MPOs in providing language access services, we interviewed DOT  officials with knowledge of the resources available on language access. We  reviewed and analyzed the assistance provided by DOT as well as other  federal resources related to language access. To document how DOT’s  Federal Transit Administration (FTA) and Federal Highway Administration  (FHWA) monitor transit agencies’ and MPOs’ provision of language access  services, we interviewed FTA officials responsible for Title VI compliance  reviews and triennial reviews, FTA and FHWA officials responsible for  planning certification reviews, and regional officials in the areas we visited.  We reviewed the documentation and results of these three review  processes and analyzed the extent to which language access is considered  by the reviews and norms have been developed for reviewers to use in  identifying deficiencies related to language access. Furthermore, we  reviewed the status and outcomes of LEP complaints that were made to  FTA against transit agencies and MPOs. We conducted our work from  February 2005 through October 2005 in accordance with generally  accepted government auditing standards. Appendix I contains more  information about our scope and methodology.
subsections: section_title: Background
paragraphs: The statutory and regulatory framework for improving access to services  for LEP persons stems from Title VI of the Civil Rights Act of 1964, an  executive order, DOJ regulations and guidance, and DOT regulations and  guidance. Section 601 of Title VI provides that no person shall “on the  ground of race, color, or national origin, be excluded from participation in,  be denied the benefits of, or be subjected to discrimination under any  program or activity receiving Federal financial assistance.” Section 602 of  Title VI directs federal agencies to implement section 601 of the act by  issuing rules, regulations, or orders. In its efforts to implement section 601,  DOJ has issued regulations that bar unjustified disparate impact on the  basis of national origin.
On August 11, 2000, President Clinton issued Executive Order 13166 to  improve access to federally conducted and federally assisted programs and  activities for persons who, as a result of national origin, are limited in their  English proficiency. The order encouraged all federal agencies to take  steps to ensure that any recipients of federal financial assistance under  their purview provide meaningful access to their LEP applicants and  beneficiaries. The order further requires that each federal agency providing  federal financial assistance to prepare guidance specifically tailored to its  recipients. The agencies’ guidance must then be reviewed and approved by  DOJ before being issued.
DOJ released guidance in 2000 that set forth general principles for federal  agencies to apply to ensure that their programs and activities provide  reasonable access to LEP persons and, thus, do not discriminate on the  basis of national origin. The DOJ guidance explains that, with respect to  federally assisted programs and activities, Executive Order 13166 “does not  create new obligations, but rather, clarifies existing Title VI  responsibilities.” Although Title VI and its implementing regulations require  that recipients take reasonable steps to ensure meaningful access by LEP  persons, federal agencies’ LEP guidance recognize that each situation is  fact-specific, and that it would not make sense for the guidance to mandate  specific approaches to comply with Title VI. Rather, the purpose of federal  agencies’ guidance is to provide recipients with a framework for assessing  their obligations under Title VI, while maintaining flexibility for the  recipients to determine how best to comply with those obligations. Thus,  the guidance outlines steps federal-funds recipients can take to avoid  administering programs in a way that results in discrimination on the basis  of national origin, which would be in violation of Title VI regulations. In  general, the test for assessing the existence of national origin  discrimination on the basis of language under Title VI is to determine  whether the failure to provide a service in a language that a recipient  understands will prevent the recipient from receiving essentially the same  level of service benefit as an English speaker.
DOJ’s guidance established a four-factor analysis to help determine the  extent of a funding recipient’s obligation to provide LEP services. These  four factors are (1) the number or proportion of LEP persons eligible to be  served or likely to be encountered by the program or grantee; (2) the  frequency with which LEP persons come in contact with the program; (3)  the nature and importance to people’s lives of the program, activity, or  service provided by the grantee; and (4) the resources available to the  grantee and costs. According to DOJ, the intent of the analysis is to suggest  a balance that ensures meaningful access by LEP persons to critical  services, while not imposing undue burdens on small businesses, local  governments, or nonprofits.
DOT issued its guidance in 2001. This guidance was generally consistent  with DOJ’s guidance but included three additional factors, as well as the  four factors previously outlined, suggesting that funding recipients should  also consider (1) the level of services provided to fully English-proficient  people; (2) whether LEP persons are being excluded from services, or are  being provided a lower level of services; and (3) whether the agency has  adequate justification for restrictions, if any, on special language services.  The guidance states that such restrictions would be accepted only in rare  circumstances. On the basis of public comments, DOT subsequently  revised its guidance, and the revised guidance was approved by DOJ on  August 25, 2005. DOT is currently preparing to publish and release its  revised guidance.
In addition to describing factors that funding recipients should consider in  assessing their obligations to provide LEP services, DOT’s guidance  outlines several key components to an effective language access program,  stating that grantees should (1) conduct an assessment of the language  groups within their service areas and the language needs of these groups;  (2) develop and implement written plans outlining their strategies for  ensuring access to services for LEP populations; (3) make staffs aware of  the LEP access plan, and train the staffs and provide them with the tools  necessary to carry out the plan; (4) ensure that language access services  are actually provided in a consistent manner, and that LEP populations are  aware of the services; and (5) develop monitoring programs that allow  grantees to assess the success of their LEP access programs and to identify  needed modifications. These five steps are designed to help DOT grantees  ensure that they are not administering their programs in a way that results  in discrimination in violation of Title VI.
Several offices within DOT, particularly the Office of Civil Rights within  FTA, have responsibility for ensuring that transit operators and  transportation planning entities receiving DOT funds are in compliance  with Title VI and responsibility for monitoring and overseeing their  language access activities.
section_title: Several Types of Language Access Services Are Provided, but Little Is Known about the Effects and Costs of Services
paragraphs: The types of language access services provided by the transit agencies and  MPOs we visited included translated service brochures, multilingual  telephone lines, translated Web sites, bilingual customer service staffs, and  a host of other services. However, the effects and costs of these services  are largely unknown. The extent of language access provided varied across  the areas we visited during our case studies, and services provided often  varied across agencies within the same metropolitan area. Almost all of the  transit agencies and MPOs we visited provided at least some language  access services in Spanish, the largest LEP language group, and some  agencies provided services in other languages. Little is known about the  effects of these services on improving access to public transportation and  the transportation planning and decision-making process for LEP  populations, but community and advocacy groups in the areas we visited  identified several gaps in the language access services provided by  agencies, such as a lack of awareness in the community about the services  available. Given such problems, community groups told us that more  proactive agency outreach to LEP communities to determine specific needs  and advertise existing services might improve the effectiveness of language  access services, whereas a lack of outreach and poor publicizing of  available services could likely reduce the impact and utilization of the  materials and services provided. One agency cited the positive benefits it  received by improving its outreach to non-English-speaking populations,  including increased ridership and enhanced public support for the agency.  Little is also known about the costs of providing such services, and most  agencies saw the language access they provide as a cost of doing business  as opposed to an additional cost; however, agencies told us that costs could  become prohibitive if services were substantially expanded or provided in  several additional languages.
subsections: section_title: Types and Level of Language Access Services Varied, Although Core Services Are Offered in Spanish by Most Agencies We Visited
paragraphs: During our case studies, we found that providing language access to LEP  populations can be incorporated into all of the different ways in which  transit agencies and MPOs communicate with the public, not only  regarding the transportation services they provide but regarding how  agencies provide LEP communities with access to the transportation  planning and decision-making process. Transit riders and potential transit  riders may need a variety of different types of information to plan their  trips, use the transit system, and participate in the transportation planning  and decision-making process. For example, potential riders may need to  know about the existence of available services, destinations, and travel  options, and about time schedules, route options, and transfer policies.  When in the transit system, riders may need to know where stops are  located, whether service changes have occurred, about available fare and  payment options, and about emergency and safety information. Riders may  also need confirmation that they are on the right route or are exiting at the  correct stop. To participate in the transportation planning and decision- making process, individuals need to know how the process works, what is  the purpose and effect of their participation, and when and where public  meetings are being held, in addition to needing to be able to understand the  proceedings of public meetings and to make statements and participate in  those discussions.
To provide such access to LEP populations, transit agencies and MPOs  employed a host of different communication strategies, including the  following: providing bilingual or multilingual telephone services;  translating written materials; translating signs or notices posted at stations,  at stops, or on vehicles; providing in-person language assistance through  drivers, interpreters, or multilingual customer service staffs; advertising in  other languages on television, on radio, or in newspapers; translating  materials on their Web sites; translating recorded announcements or  electronic signs; or making ticket machines accessible in other languages.  In providing language access, the agencies in each of the areas we visited  faced different challenges. In North Carolina and northwest Arkansas,  agencies are facing a substantial recent growth in the size of the Spanish- speaking population. (See app. I for more information on the size and  growth of LEP populations in these two areas.) In parts of California—the  San Francisco Bay Area and the Los Angeles and Orange County areas— and in Chicago, Illinois, the predominance of a number of Asian and other  language groups, in addition to a large percentage of Spanish-speakers,  presents further challenges. Agencies in Austin, Texas, have also  experienced growth in Asian languages spoken in the area. Figure 3 shows  the percentages of the transit agencies and MPOs we visited that provided  services in at least Spanish for each of these communication strategies.  However, in some cases, agencies may not utilize these communication  strategies, even in English, and these agencies are not included in the  percentage calculation.
The following sections discuss transit agency and MPO activities within  each of the broad categories shown in figure 3, and highlight examples  from the seven metropolitan statistical areas we visited. Following the  discussion of these activities, we further discuss agencies’ community  outreach activities related to LEP populations and to the community and  advocacy groups that represent them.
subsections: section_title: Bilingual or Multilingual Telephone Services
paragraphs: All but 1 of the 20 transit agencies we visited had at least some telephone  operators who were bilingual in English and Spanish, but the availability of  telephone information in other languages varied. In contrast, a survey of 32  transit agencies conducted for the New Jersey Department of  Transportation found that only one-half of responding agencies used  multilingual telephone lines or bilingual or multilingual persons in call  centers. A few transit agencies we visited in highly diverse areas, such as  San Francisco and Los Angeles, had operators fluent in other languages.  For example:   The Metropolitan Transportation Authority in Los Angeles and San  Francisco’s Municipal Transportation Agency have operators that speak  Tagalog and Chinese.
The Bay Area Rapid Transit has Chinese-speakers available in its call  center.
In other cases, telephone services were not language accessible. For  example, the San Francisco Bay Area’s 511 traveler information line, which  provides information on all of the transportation options available in the  area, is currently only accessible in English.
Transit agencies in Chicago; Los Angeles; Orange County; and Greensboro,  North Carolina, had access to a three-way call translation service in  numerous languages. While this service is available through these agencies’  general transit information lines, which are advertised on most agency  materials, the fact that translation services are available through the three- way call service is not well publicized. Therefore, LEP persons may not be  aware of these translation services. For example, representatives of a  Chinese community center in Chicago were not aware that Chinese  translators were available through the Chicago Regional Transportation  Authority’s language line, although those representatives said they often  assist new Chinese immigrants in learning how to use the transit system. In  addition, the New Jersey study found, through its surveys and focus groups  with LEP persons, that awareness of the existence of the translation  services available in New Jersey was very low, although the study found  such services to be valued by LEP persons. Some community groups also  pointed to the availability of bilingual or multilingual operators as one of  the most critical and useful services that agencies can provide to LEP  persons. Without such services, LEP persons must rely on family, friends,  or other transit riders who speak their language to provide assistance.
Transit agencies told us that complaints in other languages could also be  taken through their bilingual or multilingual telephone services; many  agencies had received complaints in languages other than English,  primarily in Spanish. However, specific complaints about language access  were rare, with only 1 agency reporting such a complaint in relation to a  rider’s having trouble communicating with a driver.
In some areas we visited, other nontransportation agencies receiving  federal financial assistance also had contracts for multilingual telephone  translation services. Because those agencies also are subject to the  executive order and federal agency LEP guidance, the existence of such  contracts presents an opportunity for local agencies to coordinate in order  to more efficiently provide such services. Few of the transit agencies or  MPOs we visited had coordinated with any other nontransportation  agencies in their service areas in this regard. However, in North Carolina,  transit agencies in Raleigh, Durham, Chapel Hill, and Greensboro all have  relationships with other city departments that can assist with language  access needs, such as sharing bilingual operators.
section_title: Translated Printed Service Information
paragraphs: All but 2 of the 20 transit agencies we visited printed at least some  schedules and maps, how-to-ride guides, applications for specialized  transportation, or other service information materials in Spanish, and many  transit agencies provided extensive amounts of printed materials in  Spanish. (See fig. 4 for a sample of a translated service information  brochure.) In addition, the New Jersey survey of 32 transit agencies found  that two-thirds of responding agencies provided translated timetables and  route maps. However, officials at 3 transit agencies indicated that they  often do not translate the language on maps and schedules because most of  the information consists of numbers, which are universal.
Seven transit agencies we visited also provided selected guides and maps in  languages other than Spanish that are prevalent in their service areas, and 4  agencies are able to provide translated materials upon request. Some  examples include the following:  The Alameda-Contra Costa Transit District in the San Francisco Bay  Area regularly prints service information in Spanish and Chinese.
Also in the San Francisco Bay Area, the Bay Area Rapid Transit’s rider’s  guide is printed in Spanish and Chinese.
On request, the Los Angeles County Metropolitan Transportation  Authority can provide information in several other languages, although  the agency acknowledged that such requests were very rare. The agency  also produced informational brochures in Chinese to advertise the  opening of its Gold Line light-rail service, which passes through  Chinatown in downtown Los Angeles.
Some community groups we spoke with indicated that, if service  information materials are not translated, many LEP transit riders will likely  learn to use the system from family, friends, or others in their community.  However, a lack of translated printed materials may discourage use of the  system or participation in the transportation planning and decision-making  process by affected language groups. Officials at 1 agency told us that  providing information in the language the community is most comfortable  with sends a message that they are welcome on the system and in the  planning process, while not doing so may send the message that they are  unwelcome. Community groups also told us that more translated service  information could encourage greater ridership and make the system more  welcoming to LEP persons. In addition, the New Jersey study found that,  next to having a staff person speaking their native language, LEP groups  most preferred to have timetable, schedule, and other information in their  native language.
While MPOs can serve a variety of functions and may provide a wide  variety of services related to transportation, we specifically focused on  informational materials related to transportation planning and public  involvement provided by MPOs we visited. Three of the 7 MPOs we visited  had translated a summary of their transportation plan into Spanish, with 1  MPO, the Metropolitan Transportation Commission in the San Francisco  Bay Area, also translating the document into Chinese. Two MPOs had  translated a citizen’s guide to participation in the transportation planning  process into Spanish. Another MPO had translated a transportation needs  survey into Spanish.
section_title: Bilingual or Multilingual Signs and Service Change Notices
paragraphs: Transit agencies we visited provided several different types of translated  signs in vehicles or at stations and stops. Of the 4 agencies out of 20 that  did not have such signs, 2 were primarily paratransit operators whose  vehicles are operated by contractors. The types of translated signs  provided included basic service information on bus stop signs, postings of  service changes, fare box signs, emergency exit and priority-seating signs,  public meeting notices, and posters for informational campaigns. Without  translated postings of service changes, bus stop closures, or fare policies,  LEP persons are at a disadvantage in accessing the transit system. One  community group cited an instance of LEP persons waiting at a bus stop  that had been closed due to a city event. This situation occurred because  the transit agency had not posted translated notices at the bus stop  announcing the closures.
Of the transit agencies we visited, 8 had some basic service information  signs at rail stations or bus stops available in languages other than English,  and 1 agency we visited had such information available in languages other  than Spanish at selected bus stops. For example, Transportation  Authorities in Orange County and Los Angeles provide some information at  some bus stops in Spanish (such as the direction of travel and information  on their telephone lines). One agency, the Alameda-Contra Costa Transit  District in Oakland, estimates that approximately 750 of its 1,200 signs are  translated in Chinese and Spanish, with signs in bus shelters in the city of  Oakland, California, now being replaced with seven-language signs, an  example of which is shown in figure 5.
Officials at 3 transit agencies stated that they had not translated street  signs, or did not translate the entire sign, because much of the information  is numeric and because including several languages on such signs would  become unwieldy for transit riders to effectively use. Agency officials also  indicated that cost could become an issue in replacing all of the signs  throughout their systems, and some agencies were looking into utilizing  more pictograms in order to avoid the use of multiple languages while  providing more universal access. However, some community group  representatives told us that, although the use of pictograms can be a useful  way to communicate with non-English speakers, some translated language  may need to accompany the pictograms in order for the information to be  communicated effectively.
Several of the transit agencies we visited posted or provided, in languages  other than English, information on service changes or closures at rail  stations, at bus stops, and in vehicles. Some examples include the  following:  The Orange County Transportation Authority puts service change flyers  in English and Spanish in vehicles on affected bus routes.
The Golden Gate Transit in San Francisco posts Spanish and English  service change notices at its central transit hub.
The Alameda-Contra Costa Transit District provides service change  brochures in Chinese and Spanish.
Ten transit agencies had on-board signs that included information on fares  or emergency exits and priority-seating signs for elderly and disabled  persons, and 10 agencies posted public meeting notices on their vehicles,  translated into at least Spanish. A few agencies also provided fare  information or posted public meeting notices on buses or in stations in  other languages. For example:  The San Francisco Municipal Transportation Agency and the Alameda- Contra Costa Transit District both provide fare information in Chinese  and Spanish.
The San Francisco Municipal Transportation Agency posts some  meeting notices on its vehicles in Chinese and English, as shown in  figure 6.
In addition, some transit agencies we visited had translated other types of  signs, such as posters in English and Spanish, generally designed under the  auspices of new initiatives or information campaigns. For example,  METRA Commuter Rail in Chicago and the Los Angeles County  Metropolitan Transportation Authority both placed posters in English and  Spanish that highlight safety issues on those systems. Orange County  Transportation Authority officials credit the wide acceptance of the  agency’s new “no pennies” fare policy to the bilingual “Hasta Luego  Pennies” campaign, as shown in figure 7.
While all but 3 of the transit agencies we visited had bilingual drivers on  staff, some agency officials noted that those drivers are generally not  required or instructed to make announcements in other languages and are  generally not assigned to routes where their language skills may be useful.  Some agency officials indicated that union rules allow drivers to select  preferred routes on the basis of seniority. Therefore, there is no indication  of the number of bilingual drivers that are utilizing their languages skills,  although agency officials knew of individual occurrences. Three agencies  we visited—Golden Gate Transit in California; Capital Metro in Austin,  Texas; and Chapel Hill Transit in North Carolina—had provided their  drivers with useful phrase or word guides in Spanish, an example of which  is shown in figure 8. A few other agencies, including the Capital Area Rural  Transportation System and the Capital Metro in Austin, Texas, and the  Ozark Regional Transit in northwest Arkansas, have bilingual employees  available to translate over the radio on the bus.
Many of the transit agencies reported that they had some bilingual staffs in  customer information booths or ticket offices, although agencies tended  not to look for bilingual customer service staffs in particular. Agency  officials in several areas stated that customer service personnel have  language skills because their employees reflect the ethnic and language  diversity of their region. For public meetings related to the transportation  planning and decision-making process, 12 transit agencies and 4 MPOs had  Spanish interpreters or bilingual employees or board members available if  needed at most public meetings, while 6 transit agencies and 3 MPOs had  Spanish interpreters available by request. In areas where there is a  preponderance of other languages spoken, interpreters in languages other  than Spanish were generally provided on a “by-request” basis, although 1  agency reported that it regularly provided Chinese translators.
While 16 transit agencies we visited had cultural sensitivity included in  their staff training, only 9 provided training or technical assistance to their  employees that directly related to LEP issues. The New Jersey survey of  transit agencies found that only one-quarter of the responding agencies had  training for customer service employees that was specific to LEP service.  Five agencies we visited offered free Spanish classes to employees. For  instance, Chapel Hill Transit hired a contractor to teach conversational  Spanish to supervisors, dispatchers, and those employees who answer  telephones during work hours. The agency has not been able to offer the  course to drivers because of budgeting issues, since attending the course  would be considered part of the drivers’ work week and they would have to  be paid overtime. However, the town of Chapel Hill does offer tuition  reimbursement to drivers who want to take Spanish classes on their own  time.
Community groups regularly pointed out the importance of having as many  bilingual bus drivers and customer service staff as possible. At a  community meeting in Aurora, Illinois, held by the Chicago Area  Transportation Study, the need for more bilingual bus drivers was  highlighted as a community transportation need. The New Jersey focus  groups with LEP travelers also found that the inability to communicate  with bus drivers was one of the chief complaints of the LEP travelers in  New Jersey. In terms of the availability of interpreters at public meetings,  community groups we met with criticized the fact that interpreters are  frequently only provided on a “by-request” basis. Agencies generally require  that requests be made 3 days in advance of the meeting, but community  groups told us that if an agency is advertising the meeting in different  languages, as many of the agencies we visited did, they should be prepared  to provide access to the proceedings of the meeting in those languages,  rather than relying on the public to request translation.
section_title: Bilingual or Multilingual Television, Radio, and Newspaper Advertisements
paragraphs: Fourteen transit agencies and 6 MPOs we visited posted notices of public  meetings in newspapers printed in languages other than English—with 10  posting notices in more than one language. A few agencies posted such  notices in as many as five different language newspapers. For example, the  Los Angeles County Metropolitan Transportation Authority publishes its  “Metro Briefs,” which includes notices of public meetings and other  information, in Thai, Korean, Chinese, Armenian, and Spanish language  newspapers. Spanish radio and television advertisements were also placed  by several agencies, sometimes in relation to ongoing information  campaigns, such as rail safety campaigns. For example, METRA Commuter  Rail in Chicago advertised its rail safety campaign on television and radio in  Spanish.
section_title: Bilingual or Multilingual Translated Materials on Web sites
paragraphs: Eleven of the 20 transit agencies we visited had some information on their  Web sites that was available in other languages; however, 4 of the 11 made  no indication on their home pages that translated materials were available.  Of the 7 MPOs we visited, 3 had such translated information posted on their  Web sites, and 2 had links on their home pages indicating that translated  materials were available. Some examples of translated Web sites include  the following:  The Alameda-Contra Costa Transit District’s Web site provides basic  rider information in Spanish, Vietnamese, and Chinese—the three  largest LEP populations in its service area—that is directly accessible  through links in those languages on the home page.
The Regional Transportation Authority in Chicago, and the Bay Area  Rapid Transit and the Golden Gate Transit in San Francisco, have basic  transit information available in seven and eight other languages,  respectively, indicated by country flag icons on the agencies’ home  pages. The languages chosen are not fully reflective of the major LEP  groups in these areas, however, because these Web sites also serve  tourism purposes. For example, in Chicago, the Regional Transportation  Authority’s Web site is translated into French, German, and Japanese,  although these are not major LEP groups in the city. However, the site is  not accessible in Chinese, although Chinese is the third largest LEP  population in Chicago.
Four transit agencies and 1 MPO had posted translated materials to their  Web sites but did not indicate on the home pages that those materials were  available. For example, materials translated into Spanish are posted on the  Los Angeles County Metropolitan Transportation Authority’s Web site, but  a user must navigate through links that are in English to get to them. Also,  the San Francisco Municipal Transportation Agency has part of its Title VI  plan translated into Spanish and Chinese, but the user must navigate  through at least two links in English to find the translations. Only 1 agency  we visited, the Ozark Regional Transit, a small urban operator in northwest  Arkansas managed by First Transit, had made its entire Web site accessible  in another language, Spanish, as seen in figure 9. A link in Spanish on the  home page leads to a fully translated version of the Web site. Furthermore,  while many agencies have Web-based trip planners, none of the agencies  we visited had made that function fully available in other languages.
Translated Web sites were not frequently identified by community groups  as being particularly useful for LEP persons because LEP persons often do  not have access to the Internet, according to the community group  representatives we met with. In addition, the New Jersey study found that  LEP focus groups did not often rate translated Web sites as a major  resource in addressing mobility needs. However, providing translated  information on an agency Web site without indication in that language that  it is available is likely to reduce the usefulness of that information to those  LEP persons who do have Internet access.
section_title: Translated Recorded Announcements and Electronic Signs
paragraphs: Only 3 of the transit agencies we visited had recorded announcements in  other languages on their vehicles or at their facilities, although many  agencies do not utilize recorded announcements at all. Also, although a few  transit agencies employ electronic media, such as televisions or ticker-tape  style displays, only 1 provided translated information on its ticker-tape  display. Examples of translated recorded announcements include the  following:  The Capital Metro in Austin provides recorded announcements on its  buses in English and Spanish, which are also broadcast outside the bus  at bus stops.
The Bay Area Rapid Transit has Spanish and Chinese announcements  recorded and available for use in the event of an emergency in its train  stations or on its trains.
The Gold Line light-rail line in Los Angeles has recorded announcements  of stops and rider instructions in English and Spanish.
section_title: Bilingual or Multilingual Electronic Ticket Machines
paragraphs: Of the transit agencies that utilize electronic ticket machines for rail  services—the Chicago Transit Authority, the METRA Commuter Rail in  Chicago, the Los Angeles County Metropolitan Transportation Authority,  the Bay Area Rapid Transit, and the San Francisco Municipal  Transportation Agency—only the Los Angeles County Metropolitan  Transportation Authority had some machines accessible in English and  Spanish. This agency has installed ticket machines that are accessible in  Spanish on a newer light-rail line that passes through a predominantly  Hispanic neighborhood, and officials told us they were considering  replacing all ticket machines with machines that will be accessible in six to  eight languages. One group we met with pointed out that, without  translated information on fare discounts and without ticket machines that  are language accessible, LEP persons may not be aware of the fare options  available to them in the same manner that English speakers would be,  potentially leading to LEP persons’ paying more than needed for their trips.
section_title: Communicating Directly with LEP Communities or Community and Advocacy Groups Representing LEP Persons
paragraphs: Almost all of the transit agencies and MPOs we visited had made at least  some effort to communicate more directly with communities and to  conduct outreach with LEP communities and the community and advocacy  groups that serve LEP persons. For example, in Greensboro, the city  recently started a new program with Lutheran Family Services, a  community group that works with many LEP persons, to provide an  orientation for recent immigrants and refugees to the area. Under the  program, city departments identified as having the most public interaction  with LEP persons, make an interactive presentation of services provided.  These presentations are given in English and simultaneously translated into  several languages, including Spanish, Vietnamese, Arabic, and Russian,  depending on the availability of translators. The city is also producing a  video on its services, including public transit, which will be translated into  Spanish and into other languages upon request. In Orange County, the  Orange County Transportation Authority conducts a program that includes  visiting Spanish-speaking senior centers to inform seniors about the agency  and its services. As part of the program, the agency will bring a bus to the  centers and walk the seniors through every step of riding the bus, including  getting on, paying the fare, and exiting. In addition, 2 agencies reported  holding information sessions at bus terminals when service changes or fare  adjustments are about to occur. For example, the Durham Area Transit  Authority publicizes such information sessions in the Spanish community,  and then has translators on hand at bus terminals to explain service  changes and answer any questions.
In terms of transportation planning and decision making, federal law and  regulations require transit agencies and MPOs to involve the public in  transportation planning and decision-making processes, and Title VI, as  well as DOT’s guidance, suggests that agencies should also make this  process accessible to non-English speakers. Providing language access to  planning and decision making can include all of the communication  strategies used by transit agencies and MPOs in this process. Some  communication strategies for public participation will fall into the  strategies previously outlined, such as providing interpreters at public  meetings and posting translated notices of community or public meetings  on Web sites, at stations, in vehicles, in newspapers, or on television or  radio. Some agencies also employed more direct tactics to include LEP  groups in the planning process. For example, several transit agencies and  MPOs we visited mailed out notices of community and public meetings to  community and advocacy groups representing LEP persons, although in  some cases, these notices were not sent out in languages other than  English. In addition, several agencies we visited distributed translated  public meeting notices in various establishments throughout the  community. For example, the Golden Gate Transit in the Bay Area  distributes meeting notices in Spanish at convenience stores, restaurants,  and laundromats in predominantly Hispanic neighborhoods. Some transit  agencies and MPOs also kept in regular contact with community and  advocacy groups representing LEP persons or created specific advisory  boards that occasionally influenced language access activities. For  example, the Orange County Transportation Authority created a citizen’s  advisory committee that pushed for the agency to provide translated  notices of service changes. In addition, some agencies reached out directly  to LEP communities with regard to the planning and decision-making  process. For example, Capital Metro in Austin started an outreach  campaign that involved sending teams of staff and volunteers, many of  whom were bilingual, into the community to provide information on new  transportation projects face-to-face. Capital Metro found that this outreach  resulted in greater public support for the agency and in increased ridership.
Despite some of these efforts, community group representatives we spoke  with were often critical that agencies’ outreach efforts related to planning  and decision making were generally not proactive and inclusive of LEP  persons. For example, one representative we spoke with told us that  attendance at a public meeting on transportation projects in a  predominantly Chinese-speaking neighborhood was not well attended by  members of that community, and that no Chinese translator was on hand at  the meeting. This representative believed that better outreach to that  community to encourage community involvement would have led to higher  attendance. A representative of another group explained that community  meetings are often very difficult to access for Spanish-speaking members  of the community, and that the local MPO tends to work with elected  officials rather than working more directly with members of the  community.
In the New Jersey surveys and focus groups of LEP travelers, some LEP  groups in New Jersey indicated that a lack of adequate transportation  services was the biggest impediment to their mobility. Without access to  and involvement with local transit agencies and planning entities, the needs  of this community are not likely to be heard by these agencies.  Furthermore, failing to provide language access to decision making can  lead to complaints of discrimination. FTA has received one complaint that  LEP persons were not given adequate access to the planning and decision- making process.
section_title: Effects of Language Access Services on Meeting Needs Are Not Well Known
paragraphs: The efficacy of the LEP access services provided is largely unknown due to  a lack of data. Most transit agencies and MPOs we visited could provide  only limited information about the utilization or effectiveness of their  language access services. Furthermore, few of the agencies we visited had  conducted a formalized assessment of the needs of the LEP populations in  their service areas, or had assessed the success of their language access  activities in meeting these needs, although DOT’s LEP guidance  recommends that they do so. Data limitations were present in analyzing the  effects of all types of LEP access services. For example, although some  transit agencies print thousands of translated brochures, they do not keep  track of how many brochures are placed on buses or in stations. In  addition, because many brochures are printed with English and another  language in the same booklet, it is impossible to know whether the  language accessible section is being utilized. Data on the utilization of  bilingual or multilingual telephone operators were also generally not  available for the majority of the transit agencies because they do not  formally track calls received in languages other than English. In those  instances where calls were tracked, they were predominantly in Spanish,  and calls in other languages were generally not common. For 1 transit  agency, of the 378 calls in languages other than English that were received  in 2004, 90 percent of them were in Spanish. For another, just 3 percent of  calls were in languages other than English and Spanish. One agency in Los  Angeles did receive a relatively large percentage of calls in Russian, Farsi,  and Armenian to its language line. For Web sites, data on the utilization of  multilingual pages were only available in some instances. Even when  tracked, these Web site data were often inconclusive regarding how often  the translations were accessed relative to English portions of the sites.  Finally, information on the effectiveness of translated signs was not  determined by any of the transit agencies or MPOs we visited.
Although little effort had been made by the transit agencies and MPOs we  visited to closely examine the impact of their LEP activities, a few agencies  were considering language issues as part of their more comprehensive  assessments of ongoing communication and outreach efforts. For example,  the Regional Transportation Authority in Chicago has started a long-term  study of the overall communication strategies of all the transit agencies in  Chicago, including language access issues. Part of the study’s methodology  was for a researcher to ride along with a LEP rider to identify areas where  communication was lacking and the rider encountered problems. The  study found that language barriers made it difficult to understand changes  to schedules or service, or changes in how to navigate through the system.
The study is looking at an increased use of pictograms as one potential  solution to making access easier for LEP populations.
Despite the lack of supporting data, most agencies felt that they were  adequately responding to the demand for language access services in their  areas. Agency officials believed that because no complaints had been  recorded concerning the level of language access provided, and because  they generally did not receive many requests for translated materials or  interpreters, they were doing a reasonable job of providing such access.  Several agency officials did state that there was still room for  improvement, and some were considering providing more information in  languages other than Spanish. Agency officials also recognized the need for  greater outreach efforts in general, especially for ethnic communities that  may have language barriers, since turnout at public meetings by these  groups is typically low. However, some agency officials told us that  agencies may lack the needed staff to regularly conduct proactive  community outreach activities.
By contrast, community and advocacy groups we met with generally saw  several shortcomings in the provision of language access services,  sometimes within the larger context of how transit agencies and MPOs  communicate with the public in general. In their opinion, a lack of  complaints regarding LEP issues did not necessarily mean that transit  agencies were doing a satisfactory job, but rather might reflect the fact that  many LEP persons were not likely to complain about the provision of  language access services, due to cultural differences and wariness about  interacting with government agencies. Many community group  representatives we spoke with complained of a lack of knowledge in the  community about the materials and services that were available, and a lack  of materials in languages other than Spanish. Even in areas where transit  agencies do provide translated materials, representatives of community  groups stated that these materials were often not readily available or easy  to locate. In addition, many community groups were unaware of the  existence of multilingual telephone lines, or they complained that Spanish- speaking operators were often not available when they called.
In addition to questioning the level of service information available to LEP  populations, community groups cited concerns about the lack of actual  transit services available to certain communities where large LEP  populations reside, as well as concerns about a lack of effective  involvement of these communities in the planning and decision-making  process, as previously discussed in this report. Many representatives we  spoke with were unaware of public meetings held by transit agencies and  MPOs, and they complained about the lack of ongoing communication with  them and the communities they represent. Furthermore, representatives of  community groups told us that these agencies rarely used them as a  resource or consulted with them on LEP transportation issues.
These representatives made several suggestions regarding how language  access services could be improved, and which types of activities would  likely be most effective in meeting community needs. Several suggestions  involved facilitating the inclusion of ethnic communities, including LEP  persons, in the planning process. For example, representatives from one  group stated that public meetings should have agendas that are clear,  specific, and of value to the community, and that these communities should  be sought out and included early in the process. Other representatives  stated that established community and advocacy groups should be used  more effectively as a conduit to the community. Regarding language access  services, community group representatives recommended having ticket  machines and discount fare information available in other languages so  that LEP communities could take advantage of fare discounts. They also  said that having spoken announcements in other languages or having bus  drivers or other personnel available to communicate in other languages  would be highly effective in improving access for LEP persons.
The New Jersey survey and focus groups of LEP travelers provided some  data on the needs of LEP transit users. Like the community group  representatives, some LEP groups in this study reported that inadequate  service in their neighborhoods was their chief concern. In terms of travel  assistance needed, LEP groups most often cited having a driver or staff  person available to assist them in their own language. Reaction was split  among LEP travelers on whether multilingual telephone lines were helpful.  Some travelers felt they were helpful, and others felt that if the information  is prerecorded, it is not effective. While New Jersey Transit does have a  multilingual telephone line (not prerecorded), most of the respondents in  this study were not aware of the service, which was likely due to a lack of  advertising. Finally, LEP groups stated that Web sites were also not  particularly helpful because many of the respondents did not have access  to the Internet.
section_title: Costs May Not Be Burdensome at the Current Level of Activity, but They Could Escalate with Additional Languages and Services
paragraphs: On the basis of our site visit data, we determined that agencies generally  did not believe that the costs for existing language access activities were  burdensome. Many transit agencies believed that providing services to  LEP populations makes sound business sense. Such agencies recognize  that LEP populations represent a significant portion of both their current  and their potential ridership. Thus, making services more accessible to LEP  persons could increase ridership. For instance, officials at Austin’s Capital  Metro told us that their outreach efforts to LEP communities has resulted  in increased ridership and greater public support for the agency.
While several of the transit agencies we interviewed did not view LEP  language access costs as burdensome, the majority of agencies were  unable to provide much data on many of the costs associated with their  LEP access services. Sometimes these costs were simply not tracked  because they were spread out over several departments, or because LEP  access activities were not separated from broader costs. The New Jersey  survey of transit agencies also found little available data on costs, with only  one-third of respondents sharing cost information. Of the respondents to  that survey providing cost information, about one-half of them reported  annual costs of between $10,000 and $30,000; one-quarter reported costs of  under $5,000; and one-quarter reported costs greater than $100,000.
Transit agencies and MPOs were able to avoid incurring substantial  additional costs by utilizing existing staff. For instance, many agencies  stated that rather than contracting out for interpreters at public meetings,  they bring in bilingual staff members, use bilingual board members, or rely  on community groups or individuals to bring their own interpreters as  needed. A similar situation occurs in providing interpreters for customer  service telephone lines. While 7 transit agencies have access to some form  of a language line with formalized services, many agencies have operators  who are bilingual or who will utilize various bilingual staff members  throughout their operations to field LEP calls when needed. In terms of  printed documents and materials, many of the transit agencies and MPOs  we visited have their translations done in-house using bilingual staff  members. Often, translation is not part of these staff members’ official  responsibilities, but it is done on a voluntary basis at no cost to the agency  beyond the use of staff time.
Although several transit agencies and MPOs did not report unduly  burdensome costs, the cost of providing LEP access has the potential to  increase significantly if agencies seek to undertake more comprehensive  programs. As we previously discussed, many agencies rely on existing  staff to do their translations of materials and to act as interpreters. Utilizing  existing staff becomes more difficult when an agency attempts to provide  access beyond just one or two languages. In that case, agencies would  likely have to contract out for translation and translator services, or have to  expend additional time and effort during the hiring process to find qualified  candidates fluent in the languages desired. Contracting out for both  translation and translator services can be costly. For example, the Capital  Metro in Austin estimates that it spends between $10,000 and $15,000 a year  for outside translations of materials. The Chicago Transit Authority stated  that it spent over $1,100 for interpreters at four public hearings in 2004.
Costs will also rise for agencies if they seek to make more comprehensive  translated information about their services and programs available through  multiple sources. For example, only 1 agency we visited had developed a  comprehensively Web site. In addition to any translation costs incurred,  developing fully translated Web sites is likely to require modifications to an  agency’s Web site architecture, which has the potential to be costly. For  instance, the Chicago Transit Authority estimated that the initial costs of  translating its Web site into Spanish, Chinese, and Polish could potentially  be between $74,000 and $99,000. In addition, the ongoing costs for  maintaining the translated sites could also be substantial. Agency officials  told us that the capability to update just the Spanish section of a translated  Web site on a regular basis would require a new full-time employee and the  purchase of additional software, costing an estimated $47,000 to $60,000  annually. In addition, providing language line service that covers multiple  languages could raise costs significantly for transit agencies, depending on  the usage of the line. Costs for language line services vary, depending on  the provider as well as the language being translated, but generally costs  per minute range from $1.00 to $1.50, which can add up to significant  amounts. For example, the Chicago Regional Transportation Authority’s  language line cost about $16,000 in 2004, and Access Services in Los  Angeles spent $3,500 in the first 3 months of 2005. In addition, to the extent  that agencies seek to provide printed materials in languages other than  Spanish, there would be increased typesetting and formatting issues that  would give rise to higher costs as well. This is especially true with  languages using non-Roman alphabets. For example, officials at the Orange  County Transportation Authority estimated that the cost of producing  materials in Chinese would be significantly more than for Spanish  materials. Finally, in terms of public outreach, a shift to more proactive  strategies may lead to higher costs. Transit agencies and MPOs that take  the initiative to actively reach out to various community groups and LEP  populations would likely need to dedicate a greater amount of staff time  and resources.
section_title: DOT Assists Grantees on Language Access Services through Its Guidance and Other Activities, but These Resources Are Not Often Accessed by Local Agencies
paragraphs: DOT’s LEP guidance provides grantees with a five-step framework for how  to provide meaningful access to LEP populations, along with some  information on how to implement such a framework; however, officials at  the majority of the 20 transit agencies and 7 MPOs we visited were not  aware of the LEP guidance. Of the agencies that were aware of the  guidance, only 3 had changed their language access activities in response  to it, and only 1 transit agency appeared to have fully implemented the five- step framework. DOT and DOJ have also provided other types of assistance  on language access services—such as workshops, a DOJ-sponsored  interagency Web site, and other resources—but most of the transit  agencies and MPOs we visited had not accessed these resources. Officials  at transit agencies and MPOs we visited stated that training and technical  assistance that is widely available, and specific to language access and how  to implement DOT’s LEP guidance, could help them more effectively  provide access to LEP populations.
subsections: section_title: DOT’s LEP Guidance Provides Steps to Meaningful Access, but DOT Took Limited Steps to Make Grantees Aware of Guidance
paragraphs: DOT’s 2001 LEP guidance outlines five steps funding recipients should take  to provide meaningful access for LEP persons, including (1) conducting an  assessment of the language groups within their service areas and the  language needs of these groups; (2) developing and implementing written  plans outlining their strategies for ensuring access to services for LEP  populations; (3) making staff aware of the LEP access plan, training them,  and providing them with the tools necessary to carry out the plan; (4)  ensuring that language access services are actually provided in a consistent  manner and that LEP populations are aware of these services; and (5)  developing monitoring programs that allow agencies to assess the success  of their LEP access programs and to identify needed modifications. The  guidance gives some information on how to implement the framework and  examples of promising practices. For example, the guidance lists  components that a written plan should generally include, although it does  not provide examples of such a plan.
DOT made its guidance available to its funding recipients through the  Federal Register, its Web site, and the DOJ interagency Web site; however,  DOT headquarters officials did not distribute the guidance through any  other direct method to ensure that grantees were aware of it, such as  through a policy memorandum or other outreach to grantees. According to  a DOT official, DOT relies on its operating agencies to make grantees  aware of the guidance, and, in turn, these operating agencies may rely on  regional representatives to make grantees aware of the guidance. In the  areas we visited, however, FTA regional representatives had not  disseminated the guidance or made grantees in their areas aware of the  guidance. Staff turnover in DOT’s agencies, as well as in local transit  agencies and MPOs, likely complicate agency awareness of the guidance,  since newer employees may not be aware of documents issued years  earlier. Although, according to a DOT official, DOT has not done much to  reinforce awareness of the guidance, or grantees’ responsibilities under it,  since its original publication in the Federal Register in 2001.
As a result, the majority of officials we visited during our site visits who are  primarily responsible for implementing aspects of DOT’s guidance were not  aware of the guidance. Some of the officials we visited who were aware of  the guidance had not made significant changes in response to it. Rather  than citing DOT’s guidance, officials at the transit agencies and MPOs we  visited indicated that they provide language access activities in response to  their customer base and demographics, as a result of the Environmental  Justice initiative, or as a result of requests from community groups or  board members. Officials at many transit agencies and MPOs we visited  said they had been providing language access services for many years prior  to the executive order and DOT’s guidance. Other officials indicated that  they were not sure what their responsibilities were under the guidance.
Of the 9 transit agencies and 3 MPOs we visited that were aware of DOT’s  guidance, only 2 transit agencies and 1 MPO made changes to their  languages access activities as a result. Examples of agency responses to  the guidance include the following:  The Alameda-Contra Costa Transit District developed an inventory of its  language access activities, with several proposals for improving  language access services that are now being implemented.
The Metropolitan Transportation Commission in the San Francisco Bay  Area indicated that, while it had not significantly changed its practices  as a result of the guidance, it had increased its efforts.
The Chicago Transit Authority formed a committee to examine LEP  issues after the release of the guidance in 2001. This committee  determined the languages spoken in its service area from Census data  and has discussed the idea of implementing a survey to determine what  language needs exist. No current plan or timeline for developing or  implementing the proposed survey exists.
Officials from the California, North Carolina, and Texas state departments  of transportation reported that they had begun to monitor their small urban  and rural grantees’ LEP activities as a result of the executive order and  DOT’s guidance. As a result, some materials have been provided to grantees  about their responsibilities under the guidance.
Some of the transit agencies and MPOs we visited told us that technical  assistance and information would be helpful in implementing DOT’s  guidance, and 1 transit agency cited a lack of funds and time to conduct an  assessment of language access needs and to provide and evaluate language  access activities. For example, an MPO in North Carolina said it would  benefit from the ability to easily access practical resources on language  access services for LEP persons. In addition, agency officials at a transit  agency in California told us that an example of a needs assessment—with  estimates of the cost to conduct one and effective ways to outreach to LEP  persons—would be very helpful. A DOT official told us that, in anticipation  of issuing DOT’s revised guidance, additional training and assistance was  being considered within DOT.
section_title: Other Federal Resources Address Language Access Issues to Varying Degrees, but They Are Not Frequently Used by Grantees
subsections: section_title: DOT’s Workshops at Conferences and Federal Web Sites Provide Some Assistance on DOT’s LEP Guidance
paragraphs: FTA and FHWA have hosted a few workshops at annual conferences that  have provided assistance on how to implement portions of the framework  described in the guidance. Presentations held by FTA and FHWA reviewed  the LEP executive order, and DOT’s LEP guidance, and provided workshop  participants with real-world LEP information, including how to identify  LEP populations in their service areas. For example, workshops included  the following:  Strategies for Complying with FHWA LEP Requirements, was held at the  Southern Transportation Civil Rights Conference in Orlando in August  2005. This training identified strategies to ensure that LEP persons  have access to programs, services, and information through the  application of DOT’s guidance. In addition to this presentation, a “train  the trainer” curriculum was developed regarding LEP awareness.  Training attendees were provided with a manual with resources on  providing language access, which included DOT’s guidance, language  identification flash cards, language statistical data, language assistance  self-assessment tools, and commonly asked questions and answers.
Fair Transportation: Incorporating Equity Concerns into Transit  Planning and Operations, presented to the Conference of Minority  Transportation Officials by FTA’s Office of Civil Rights, occurred in July  2005. This presentation discussed the changing demographics and  growing multicultural nature of the American population and the  increase in the number of LEP persons nationwide. FTA staff  summarized the requirements of DOT’s LEP guidance, and  recommended that transit agencies incorporate attention to the needs of  LEP persons into elements of their routine planning and operations,  such as their complaint procedures, marketing, customer surveys, and  community outreach.
LEP: A Lesson in Redefining Public Involvement was given at the 2003  Conference of Minority Transportation Officials National Meeting and  Training Conference. This presentation provided information about the  LEP executive order and DOT’s guidance, and used real-world examples  to illustrate the complications an agency may face as a result of not  providing information to LEP populations during the planning process.  The presentation also defined compliance with the LEP executive order  by listing important components in DOT’s guidance (i.e., a needs  assessment, a written language assistance plan, language assistance,  and monitoring).
How to Identify LEP Populations in Your Locality was given by FHWA at  the American Association of State Highway and Transportation  Officials’ 2004 Civil Rights Conference. This presentation also provided  information on the LEP executive order; DOT’s guidance; and specific  information about what resources can be used to identify LEP  populations, which is the first step of conducting a needs assessment.  For example, the presentation highlighted using Census and state  departments of education data to identify the size and location of LEP  populations. This presentation is available on FHWA’s Civil Rights Web  site.
Besides offering workshops, DOT also participates in the Federal  Interagency Working Group on Limited-English Proficiency, which  provides resources to federal grantees mainly through its Web site,  http://www.lep.gov. The resources available on the Web site are generally  not specific to transportation, with the exception of DOT’s LEP guidance  and a multilingual video on using public transit, “Making Public Transit  Work for You,” which was produced by the Contra Costa Commute  Alternative Network. The Web site, which is maintained by DOJ, serves as a  clearinghouse by providing and linking information; tools; and technical  assistance about LEP and language services for federal agencies, recipients  of federal funds, users of federal programs and federally assisted programs,  and other stakeholders. While most of the information on the Web site is  not specifically about transportation, some of it could be applicable to  transit agencies. For example, the Web site contains a variety of tools— including a self-assessment—to help local agencies assess their current  language services and plan for the provision of additional language  assistance to LEP individuals. The Web site also provides an overview of  how to develop a language assistance plan, and it contains performance  measures, such as a measure of the extent of ongoing feedback from the  community, in order to evaluate the effectiveness of LEP activities. In  addition, there is a video on the Web site regarding LEP access issues that  could be used in training for customer service personnel at transit  agencies. FTA’s Title VI Web page provides a link to this Web site.
section_title: Other DOT Resources Have Few Language Access Activities or Touch on Language Issues in a Broader Context
paragraphs: FTA and FHWA have two peer-exchange programs through which local  agencies can share innovative or effective practices on various topics that  have sometimes included language access. FTA’s peer-exchange program,  called Innovative Practices for Increased Ridership, and FTA and FHWA’s  collaborative peer-exchange program, called the Transportation Planning  Capacity Building Program, allow agencies to easily share information over  the Internet. FTA’s Innovative Practices Web site serves as a central  information resource for innovative strategies on various topics. Innovative  practices are submitted by transit organizations and reviewed by FTA, and  these practices are then made available for other transit organizations to  search records, review innovations, and potentially implement similar  programs. A search of FTA’s Innovative Practices Web site revealed some  assistance on language access issues. In one example, a transit agency in  Maine created a multilingual brochure that provided basic information  about riding its bus service in eight languages, including Spanish, Serbo- Croatian, Russian, Khmer, Somali, Vietnamese, French, and English, and  plans to translate the brochure into six more languages, including Farsi,  Arabic, Acholi, Swahili, Chinese, and Bulgarian. The transit agency credits  this effort with increasing its ridership.
The Transportation Planning Capacity Building Program provides  resources to local agencies through its Web site, where users can search  various topics to find out if any other agency has posted helpful  information on those topics. LEP resources are not directly available  through an explicit link on this Web site. However, a search of the  program’s Web site under Title VI and Environmental Justice issues  revealed some assistance on language access. For example, the materials  from a workshop called Identifying and Engaging Low Literacy and Limited  English Proficiency populations in the Transportation Decision-making  Process, which was held in Atlanta in May 2004, was made available to  users on the Web site. The workshop refers to the LEP executive order and  describes innovative and effective practices that some agencies have  employed to improve awareness among communities and transportation  planning agencies of the existence of low-literacy and LEP populations in  their areas.
FTA and FHWA also provide federal grantees with training and technical  assistance—through the National Transit Institute (NTI) and the National  Highway Institute (NHI), respectively—that address language access issues  to some extent in training on other subjects, such as public participation in  the transportation planning process. Funded by grants from FTA, NTI  provides training, education, and clearinghouse services in support of  public transportation. Representatives from NTI identified five training  courses in which language issues were discussed in the broader context of  other issues. In addition, NTI is developing a course for transit employees  that will specifically address cross-cultural communications, including tips  for overcoming language barriers, such as speaking slowly, being patient,  and not using slang words. NHI also provides training, resource materials,  and technical assistance to the transportation community, although, like  NTI training, language issues are addressed as they relate to the course  content. An official from NHI identified two training courses in which  language issues were discussed. An example is NHI’s course called  Fundamentals of Title VI/Environmental Justice, in which LEP issues are  woven into the course materials. The training gives examples of outreach  done by various agencies, which includes providing meeting materials and  flyers in Spanish. Another course, entitled Public Involvement Techniques  for Transportation Decision Making, describes the importance of including  LEP populations in the planning process; provides suggestions on effective  ways to reach out to LEP populations, such as through community groups  and informal meetings; and outlines ways to continue communication with  LEP groups once a connection has been established. For example, the  training states that providing translated materials and interpreters at  meetings is essential in reaching non-English speakers. NHI and NTI  representatives told us that they are working to combine their relevant  training courses on public involvement in the transportation planning  process into one course.
section_title: Other Available Federal Resources Are Rarely Used by Grantees
paragraphs: The majority of transit agencies and MPOs we visited did not access the  federal resources previously discussed because many officials were  unaware that these resources exist. Only a few agencies we visited had  reported attending workshops held at annual conferences on language  access issues, and no agency we met with had reported accessing  information available through http://www.lep.gov. Furthermore, statistics  on the number of Internet users that accessed LEP resources on the Web- based peer-exchange programs indicate that these resources are not  accessed often in comparison to other resources on those Web sites. A few  transit agencies we visited were aware of or had accessed the NTI training  entitled Public Involvement in Transportation Decision-Making, which  includes a section on ensuring that nontraditional participants—that is,  minority, low-income, and LEP populations—are included in the public  involvement process associated with transportation planning.
section_title: Three Review Processes Provide Limited Monitoring of Language Access Activities, and Criteria for Finding a Deficiency Are Inconsistent
paragraphs: Language access activities of transit agencies and MPOs are monitored  through three review processes—FTA’s Title VI compliance reviews, FTA’s  triennial reviews, and planning certification reviews conducted jointly by  FTA and FHWA (described in table 1). However, these reviews do not fully  take into account Executive Order 13166 or DOT’s LEP guidance, and the  criteria for finding a deficiency with regard to providing language access  are inconsistent.
The Title VI compliance review—an in-depth review of a limited number  of transit agencies, MPOs, and state DOTs—does not assess language  access activities using the LEP guidance, but rather assesses them using  guidelines in an FTA circular, which asks agencies to describe the language  access they provide. However, the circular does not provide agencies with  a framework, and does not have much specificity regarding what agencies  should provide in terms of language access. FTA officials told us that the  circular is used for the compliance review because it is a requirement for  agencies, while agencies are not required to implement all aspects of DOT’s  LEP guidance. The officials further stated that they have considered  including more aspects of DOT’s guidance in the compliance review.
We reviewed Title VI compliance reviews completed between 2002 and  2004 and found that the scope of these reviews of language access activities  varied, and may not assess local agencies’ language activities across the  entire breadth of communication strategies previously outlined in this  report. For example, in one review, an agency was found deficient because  it did not have safety and emergency information translated, yet in other  reviews it was unclear whether safety and emergency information was  included in the scope of the review. Furthermore, the scope of the  multilingual communications portions of the Title VI compliance reviews  has varied on the basis of the primary objective of the endeavor. Some of  these reviews considered only the extent to which language assistance was  provided to persons wanting to involve themselves in the transit system’s  planning and decision-making processes because the scope of the reviews  focused solely on these processes. Other reviews evaluated only the extent  to which language assistance was provided to persons wanting to use the  transit system. Table 2 provides examples of deficiency findings related to  language access from these Title VI reviews.
In March of 2003, FTA’s Office of Civil Rights conducted a pilot Title VI  compliance review of the Brownsville Urban System in Texas, specifically  looking at the extent to which the agency had implemented DOT’s LEP  guidance. This pilot was initiated as part of a refocusing of Title VI  compliance reviews on more specific issues within Title VI, including  multilingual communications, fare increases, service changes, and  equitable allocation of resources. Brownsville was selected by FTA’s Office  of Civil Rights for the pilot assessment for multilingual communication  because of its large Spanish-speaking community. The assessment  guidance used in the pilot incorporated sections of DOT’s guidance in  addition to the multilingual facilities section of the FTA circular used in  other Title VI compliance reviews. The assessment focused on whether the  Brownsville system had ensured meaningful access to LEP persons by  assessing 11 different aspects of providing greater access to LEP persons.  For example, the review focused on whether the agency had a needs  assessment and a written language assistance plan; the agency’s provision  of language services (e.g., oral interpretation; written translations; and  alternative, nonverbal methods); and its provision of language access to its  grievance or complaint procedures. Brownsville was found deficient in 5 of  the 11 areas, as shown in table 3.
FTA’s Office of Civil Rights has also recently developed an initiative that  focuses on fare and service changes, but FTA’s advice to agencies related to  this initiative has not always been consistent. While this initiative is based  on the Executive Order on Environmental Justice, it does include an LEP  component. In 2004, FTA developed and disseminated a self-assessment  (also posted on the FTA’s Title VI Web site) to about 20 transit agencies  considering fare and service changes. This assessment included questions  about the public involvement process and asked the transit agency whether  it believed outreach to the LEP population was warranted, and, if so, what  steps the transit agency had taken or was planning to take to inform its LEP  population about the service or fare changes and to offer this population  the chance to comment on the changes. The majority of the agencies that  returned this self-assessment reported that they had taken steps to reach  out to their LEP populations using methods similar to those previously  noted in this report, such as posting information about the upcoming fare  increases in multiple languages in vehicles and stations, advertising the  changes in other-language newspapers, and including interpreters at public  meetings established to discuss the changes. Several of the transit agencies  responding to this initiative stated that they had not engaged in LEP  outreach because the number and proportion of LEP persons in their  service areas were very small (i.e., less than 1 percent). For 1 agency, FTA  encouraged the agency to conduct a further assessment of the LEP  population, even though the agency reported that only 119 residents in its  service area (less than ½ of 1 percent) did not speak English well. Yet, in  another location, where the agency reported that only ½ of 1 percent of the  service area population was LEP, FTA encouraged the transit agency to  monitor demographic trends to determine whether limited English  proficiency may become more relevant in the future, rather than conduct a  further assessment.
Another of the review processes, the triennial review, looks at whether  transit agencies that receive Urbanized Area Formula Grants have  complied with statutory and administrative requirements in 23 areas, one  of which is Title VI. Because this review covers a wide variety of activities  and federal requirements, it is not as in-depth with regard to Title VI as Title  VI compliance reviews. However, the triennial review serves as the basic  review of FTA’s oversight program. Under the Title VI section of the  triennial review, specific questions make reference to DOT’s LEP guidance:  “Has the grantee assessed and addressed the ability of persons with limited  English proficiency to use transit services? Are schedules and other public  information provided in languages other than English? If yes, what other  languages are provided?” In the triennial review, the grantee is found  deficient only if a complaint has been made and the grantee has not  conducted an assessment of the population and the need for LEP materials.  However, several community and advocacy groups we met with indicated  that there may be language barriers to making a complaint, and, as we  previously discussed, there may be different cultural or social norms that  preclude LEP persons from making complaints (i.e., some persons may feel  that it is not their place to question the government, or may feel  uncomfortable doing so).
Because a deficiency is found only if a complaint has been made and the  agency has not conducted an assessment, findings of deficiencies are rare;  although our case studies and the New Jersey survey of transit agencies  suggest that most agencies have not conducted a language needs  assessment. We reviewed 34 triennial reviews conducted in fiscal year  2005 that identified one or more deficiencies in the area of Title VI and  found only one deficiency related to LEP. In 2005, the Fayetteville Area  System of Transit was found deficient for not conducting an assessment of  the extent to which there are LEP persons in its service area. Within 90  days, the agency was to provide FTA with documentation that it had  conducted an LEP assessment and with information on the steps it would  take to address any needs identified.
The third of the three review processes that monitor language access  activities is the planning certification review, which looks at how well state  and regional planning processes comply with DOT planning regulations.  This review is conducted jointly by FTA and FHWA and is also not as in- depth with regard to Title VI as Title VI compliance reviews. One section of  the review guidelines is directed at LEP issues with regard to public  participation in the planning process, but the review does not incorporate  the LEP guidance. The section states that agencies should “if necessary,  make available communications for the hearing impaired and provide sign  and foreign language interpreters.” It is not clear what constitutes a  deficiency in these reviews, and during the past 2 years, there have been no  deficiency findings regarding language.
In addition to the review processes, FTA investigates Title VI complaints  filed by the public alleging national origin discrimination against LEP  persons. These investigations focus on whether a recipient has taken  reasonable steps to provide meaningful access to LEP persons. However,  FTA has received only one complaint related to language access to date.  The complaint—which was made by West Harlem Environmental Action,  Inc., against New York City Transit in November 2000—stated that no  opportunity had been given for community groups to comment on New  York City Transit’s capital plan to construct additional bus parking facilities  next to an existing bus depot. The complaint further stated that the capital  plan was not published in Spanish and no monolingual Spanish-speaking  resident of northern Manhattan was afforded the opportunity to comment  on the capital plan. New York City Transit noted that since Executive Order  13166 and the LEP guidance were issued after the development of its 2000- 2004 capital program, there was no requirement to issue the plan in any  language other than English at that time. FTA responded that although the  executive order and the LEP guidance were issued subsequent to the  issuance of the plan, New York City Transit should have provided language  access under its 1988 Circular on Multilingual Facilities. In resolving the  complaint, FTA requested (1) copies of Spanish translations of public  hearing notices and summaries of the capital program and (2) a report on  what steps New York City Transit had taken to involve the public, including  minority, low-income, and LEP populations, in its 2005-2009 capital  planning process. FTA closed its investigation of this complaint in letters of  finding transmitted in January 2005.
section_title: Conclusions
paragraphs: Transit agencies and MPOs across the country are providing a wide variety  of language access services. Determining and providing reasonable and  effective language access to transportation services, however, is not a  clear-cut matter. To do so, an agency must have a strong understanding of  the size and location of the LEP community in its area as well as the  information needs of this community, although such assessments are rarely  done. The agency must then deal with a whole host of issues, such as  determining which language access services to provide and in what  quantity, how translations are to be accomplished, where such materials or  services are best distributed, and how such materials and services are best  publicized to the LEP communities. For agencies in very diverse areas, the  challenges grow exponentially. Specifically, some of the questions they may  need to address are as follows: How many languages should materials and  services be translated into? Is there a threshold with regard to the size or  proportion of different language groups before translations should be  provided? Will translated signs be too complex for transit users to  effectively use? Will the costs of translations, telephone, and Web services  be burdensome, given the relatively light use some of these services may  receive? Furthermore, providing language access is just one part of a larger  communication strategy for these agencies, which can include determining  how to provide useful information in English, how to communicate with  the hearing or sight impaired, or how to deal with communication to  persons with cognitive disabilities. One clear need in all of these instances  is for agencies to outreach to these various communities and work in  partnership to determine and meet a variety of information needs.
DOT’s LEP guidance, and many of the available federal resources, can  provide some assistance to transit agencies and MPOs when facing these  challenges and making decisions about the level of language access to  provide; however, the absence of local agency awareness of the existence  of these resources limits their usefulness. In addition, for some transit  agencies and MPOs, the available assistance was not effective in helping  them answer some of the difficult questions previously outlined, because  the assistance does not provide much information on what a good language  and needs assessment contains, or how one is done. It also does not  provide templates or examples of effective language access plans, nor does  it provide much help in determining how to monitor and judge the  effectiveness of agencies’ language access activities. Given the lack of data  available on the effectiveness of services, the availability of such assistance  takes on greater importance. More direct dissemination of the LEP  guidance and available assistance, and the development of additional  assistance related to conducting assessments, developing plans, and  monitoring the effectiveness of language access activities could help  connect local agencies with information and resources that may help them  improve access to their services for LEP persons.
While complaints concerning language access are rare, transit agencies’  and MPOs’ language access efforts are often perceived by community  groups to be lacking in certain areas, particularly with regard to the  inclusion of such communities in decision-making processes, thus opening  up the potential for further complaints against these agencies for not  providing reasonable language access. At present, however, monitoring and  oversight activities conducted by FTA and, to a lesser extent, FHWA, are  not likely to remedy perceived gaps in the provision of language access,  due to the inconsistencies in scope and criteria for what constitutes a  deficiency. For example, one of the chief complaints of community groups  is the lack of involvement of LEP communities or the community groups  that represent them, in decision-making processes; however, planning  certification reviews do not look at involvement per se, but rather they  focus on whether interpreters were provided at public meetings “if  necessary.” Furthermore, FTA’s pilot review of language access, which used  DOT’s LEP guidance, revealed several deficiencies that would not have  been found under current review processes, and these deficiencies can  commonly be found across countless numbers of agencies. It is important,  though, to consider that findings of deficiency, such as those found under  the pilot review, do not necessarily indicate that an agency has been  discriminatory. Nonetheless, further incorporation of key aspects of DOT’s  LEP guidance in existing review processes and consistent criteria for what  constitutes a deficiency could help transit agencies and MPOs understand  their responsibilities under the executive order and DOT’s LEP guidance  and lead to improved services for LEP persons.
section_title: Recommendations for Executive Action
paragraphs: To improve awareness and understanding of DOT funding recipients’  responsibilities to provide language access services, we recommend that,  upon final issuance of DOT’s LEP guidance, the Secretary of the  Department of Transportation ensure that the guidance is distributed to all  DOT funding recipients through a policy memorandum or other direct  methods and direct regional personnel to make grantees in their areas fully  aware of the existence of the guidance, and of grantee responsibilities  under the guidance.
To enhance and improve transit agencies’ and MPOs’ language access  activities, we recommend that the Secretary, when issuing DOT’s revised  LEP guidance, take the following two actions:  Provide additional technical assistance, such as templates or examples,  to aid these agencies in developing assessments of the size, location,  and needs of the LEP population; plans for implementing language  access services; and evaluations of the effectiveness of agencies’  language access services.
Publicize the availability of existing federal resources on LEP issues,  including workshops, http://www.lep.gov, peer-exchange programs, and  available training to transit agencies and MPOs, and make these  resources easily accessible through an explicit link to LEP Assistance  on the Transportation Planning Capacity Building Program’s Web site.
To ensure that transit agencies and MPOs understand their responsibilities  to provide language access, and to ensure that they are providing adequate  language access to their services and their transportation planning and  decision-making processes, we recommend that the Secretary more fully  incorporate the revised LEP guidance into current review processes by  taking the following three actions:   Include questions on whether agencies have conducted assessments,  have language access plans, and have evaluation and monitoring  mechanisms in place in Title VI compliance reviews and triennial  reviews.
Include more specific questions regarding language access to the  planning process and involvement of LEP communities in planning  certification reviews.
Establish consistent norms for what constitutes a deficiency in the  provision of language access across and within these review processes,  ensuring that what constitutes a deficiency could directly lead to lesser  service for LEP persons or complaints against the agency.
section_title: Agency Comments
paragraphs: We obtained comments on a draft of this report from DOT officials who  generally agreed with the findings and recommendations in the report.  These officials also provided technical clarifications, which we  incorporated in the report as appropriate. In particular, the officials said  that DOT is already planning to take actions to address some of our  recommendations, including ensuring that its revised LEP guidance is fully  and appropriately distributed, and enhancing its training and technical  assistance to grantees.
We also provided DOJ with an opportunity to comment on segments of the  report that pertain to DOJ processes and policies. DOJ provided technical  clarifications, which we incorporated in the report as appropriate.
We are sending copies of this report to the appropriate congressional  committees and to the Secretary and other appropriate officials of the  Department of Transportation. We will also make copies available to others  upon request. The report will be available at no charge on the GAO Web site  at http://www.gao.gov. In addition, translated summaries of this report in  Spanish, Chinese, Vietnamese, and Korean will be available at no charge on  the GAO Web site at http://www.gao.gov/special.pubs/translations.
If you or your staff have any questions about this report, please contact me  at (202) 512-2834 or at siggerudk@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made major contributions to this report are  listed in appendix III.
section_title: Scope and Methodology
paragraphs: To determine the types of language access services that transit agencies  and metropolitan planning organizations (MPO) provide to limited English- proficiency (LEP) populations, we visited seven metropolitan statistical  areas in Arkansas, California, Illinois, North Carolina, and Texas. We used  U.S. Census Bureau data to select site visit locations, on the basis of the  size and proportion of the LEP population, the number of languages  spoken, the growth of the LEP population, and the extent of public transit  use, to capture a variety of different circumstances agencies may face in  providing language access services. We eliminated from our site visits areas  that had recently had in-depth reviews by the Federal Transit  Administration (FTA), as well as agencies that had been highlighted in a  recent report for best practices in providing LEP access, to broaden the  limited amount of research and data available in this area. Notable areas  eliminated from our potential site visits for these reasons included New  York, New York; Washington, D.C.; Portland, Oregon; and Seattle,  Washington. The relevant statistics for the seven areas we visited are  presented in table 4.
We conducted semistructured interviews with officials from 20 transit  agencies and 7 MPOs in these locations who were responsible for some  facet of providing language access services. We interviewed officials from  various departments, including operations, marketing, public affairs,  community relations, training, civil rights, and planning. At smaller  agencies, we interviewed the general managers as well as other agency  officials. We chose agencies in each location according to their size and  characteristics. For example, we interviewed the largest transit agency in  each location, and where there were several transit agencies operating, we  then interviewed the next largest agencies. In certain locations, such as the  Southern California area and the San Francisco Bay Area, we were unable  to interview all of the agencies in the area due to the large number of  transit agencies. In these areas, we chose additional agencies on the basis  of different operating characteristics. For example, in Los Angeles,  California, we chose to interview the major provider of specialized transit  services for persons with disabilities, whereas, in the San Francisco Bay  Area, we chose a suburban bus system to complement the urban systems  we were obtaining information on. We also interviewed officials from the  major MPOs in areas we visited. In some cases, an MPO also may provide  some level of transportation service. For example, the Metropolitan  Transportation Commission in the San Francisco Bay Area operates the  region’s 511 transportation information lines. In these instances, we did not  count such agencies as transit agencies, but we included the services they  provide in the appropriate section of this report.
We structured the agency interviews on the basis of the elements of the  Department of Transportation’s (DOT) LEP guidance and the findings of  previous research and surveys conducted of the language access activities  of transit agencies. During our interviews, we discussed the types of  language access activities provided in terms of day-to-day transportation  services and in the planning and decision-making process; we also  discussed the costs and effects of these services. We also reviewed  documents and other information in support of the language access  services provided by transit agencies and MPOs.
We also interviewed representatives from 16 community and advocacy  groups in the areas we visited as well as representatives from national  advocacy groups, such as the National Council of La Raza, the Center for  Community Change, and the National Asian Pacific American Legal  Consortium. We chose groups in the locations we visited on the basis of  recommendations from these national groups, FTA regional officials,  transit agency officials, and our own research into the transportation issues  in these areas. We structured these interviews in order to understand the  perspectives of these community and advocacy groups with regard to how  transit agencies and MPOs in the areas are providing access to their  services to the communities these groups serve, and the effects of these  services on meeting the needs of LEP communities. The agencies and  groups we included in our interviews are listed in table 5.
We also conducted interviews with officials within the Texas, California,  and North Carolina departments of transportation and conducted  additional Internet research of state departments of transportation, to  determine how these agencies were involved in providing or monitoring  language access. Furthermore, we requested that the Community  Transportation Association of America, which operates a list-serve of Job  Access and Reverse Commute grantees, send a query requesting that any  grantees involved in providing language access services under those grants  provide information on the types of services they offer. We received two  responses from this query.
We complemented these case studies and interviews with findings from a  survey of transit agencies across the country and surveys and focus groups  with LEP persons in New Jersey conducted for the New Jersey Department  of Transportation. We reviewed the methodology of this study and found it  to be sufficiently reliable for the purposes of our report. However, the  results of the surveys and focus groups reported in this study cannot be  generalized to the full universe of transit agencies or LEP persons. Rather,  we used the findings in this study to provide additional information on the  types of strategies that agencies use as well as the types of challenges that  LEP populations face.
We synthesized the information we collected from the site visits, structured  interviews, and the New Jersey study. We analyzed this information to  identify major themes, commonalities, and differences in the level of  language access provided by transit agencies and MPOs. We observed that  almost all transit agencies and MPOs we visited provided some level of  language access services, although levels varied across agencies and  locations. Because these findings are based on a nonprobability sample of  case studies and a survey of 32 transit agencies, they cannot be generalized  to the full universe of transit agencies or MPOs across the country. These  case studies are meant to highlight the variety of different strategies  agencies may use to improve communication with LEP persons, as well as  key themes that emerge under various circumstances.
To understand how DOT assists local agencies in providing language  access services, we interviewed officials at the Offices of Civil Rights in  FTA and the Federal Highway Administration (FHWA), representatives  from the National Transit Institute and the National Highway Institute, and  DOT regional officials. During our interviews, we identified and discussed  various resources available that may include information on language  access activities, including training curricula and workshops. We  interviewed officials from FHWA offices in California, Maryland, and New  Jersey regarding some of their LEP activities, such as hosting workshops at  annual conferences and other assistance they have provided grantees. We  reviewed Executive Order 13166, the Department of Justice’s (DOJ) and  DOT’s draft LEP guidance, other federal laws and regulations, and research  related to providing access to services to LEP populations. We requested  copies of identified trainings and reviewed them. We also identified and  reviewed other various DOT resources and other federal resources to  determine whether language access issues were addressed, including  http://www.lep.gov and peer-exchange programs maintained by FTA and  FHWA.
To understand the extent to which local agencies are accessing DOT’s  resources, we discussed with local agency officials their awareness and  implementation of DOT’s LEP guidance. We also discussed with these  officials whether the agency has accessed DOT’s resources and, if so, had  the resources been helpful in the provision of language access activities. In  addition, we reviewed Web statistics for materials available on the Internet  for additional information on how often those materials were accessed.
To document how FTA and FHWA monitor transit agencies’ and MPOs’  provision of language access services for LEP populations, we interviewed  officials from the FTA Office of Civil Rights; the FTA Office of Program  Management; and FHWA’s Office of Planning, Environment and Realty. We  also interviewed FTA regional representatives from Arkansas, California,  Illinois, North Carolina, and Texas. We reviewed oversight documents  pertaining to Title VI compliance reviews, triennial reviews, and planning  certification reviews to determine how language access is considered by  these reviews (i.e., specific questions regarding language access activities)  and to what degree these reviews incorporate DOT’s LEP guidance. In  addition, we collected available data on any findings from these reviews to  analyze the extent to which norms have been developed for reviewers to  determine whether deficiencies are found and reported. Furthermore, we  reviewed the status and outcomes of LEP complaints.
We conducted our work from February 2005 through October 2005 in  accordance with generally accepted government auditing standards.
section_title: Resources Available on Providing Language Access for Transportation Services
subsections: section_title: Provision of Language Access Services
paragraphs: 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 under Title VI, to make their services  accessible to LEP populations. http://usdoj.gov/crt/cor/Pubs/eolep.htm    DOT Guidance to Recipients on Special Language Services to Limited  English Proficient (LEP) Beneficiaries: DOT’s guidance was issued in  2001. It discusses strategies for providing services to LEP persons and  outlines a five-step framework to an effective language access program  as well as innovative practices. http://usdoj.gov/crt/cor/lep/dotlep.htm    Federal Interagency Working Group on Limited-English Proficiency:  The http://www.lep.gov Web site, maintained by DOJ, serves as a  clearinghouse, providing and linking information, tools, and technical  assistance regarding LEP and language services for federal agencies,  recipients of federal funds, and users of federal programs and federally  assisted programs. The Web site includes a self-assessment tool and an  overview of how to develop a language assistance plan with  performance measures. There is also a video available from the Web site  on LEP access issues that could be used in training for customer service  personnel at transit agencies.  http://www.lep.gov   FTA Title VI Web site: FTA’s Title VI Web site provides information and  resources on Title VI, including links to Executive Order 13166, DOT’s  LEP guidance, and http://www.lep.gov. http://fta.dot.gov/16241_ENG_HTML.htm   FHWA Office of Civil Rights Web site: FHWA’s Office of Civil Rights Web  site provides links to Title VI, Executive Order 13166, and DOT’s LEP  guidance. http://fhwa.dot.gov/civilrights/nondis.htm   Workshop entitled How to Identify Limited English Proficient (LEP)
Populations in Your Locality: This workshop was given by FHWA at the  American Association of State Highway and Transportation Official’s  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. http://fhwa.dot.gov/civilrights/confworkshops04.htm   FTA’s Innovative Practices to Increase Ridership: The Web site serves  as a central information resource on innovative strategies on various  topics. Innovative practices 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. http://ftawebprod.fta.dot.gov/bpir/   FTA and FHWA’s Transportation Planning Capacity Building  Program: Users can search various topics to find out if like sized or any  type of agency has posted any helpful information on those topics.  Information regarding language access services is available. http://planning.dot.gov/   National Transit Institute course entitled Public Involvement in  Transportation Decision-Making: This course includes is a section on  ensuring that nontraditional participants, that is, minority, low-income,  and LEP populations are included in the public involvement process  that is associated with transportation planning.  http://ntionline.com/   National Highway Institute course entitled Fundamentals of Title  VI/Environmental Justice and Public Involvement in the Transportation  Decision-Making Process: These courses include a discussion on  language access issues in the planning process. http://nhi.fhwa.dot.gov/   Caltrans Title VI Web site: Caltrans’ Title VI Web site includes  information and resources on Title VI and links to FHWA’s Office of Civil  Rights training resources, the Web site for the Civil Rights Division of  DOJ, and lep.gov. In addition, there are three training videos available  for free, one specifically on the language assistance for LEP persons. http://dot.ca.gov/hq/bep/title_vi/t6_index.htm   Mobility Information Needs of Limited English Proficiency (LEP)
section_title: Community Involvement in Transportation Planning
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Rita Grieco, Assistant Director;  Michelle Dresben; Edda Emmanuelli-Perez; Harriet Ganson; Joel  Grossman; Diane Harper; Charlotte Kea; Grant Mallie; John M. Miller; Sara  Ann Moessbauer; Marisela Perez; Ryan Vaughan; Andrew Von Ah; Mindi  Weisenbloom; and Alwynne Wilbur made key contributions to this report.