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City of Santa Ana Limited English Proficiency (LEP) Plan November 2017 III. BACKGROUND Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq. and its implementing regulations provide that no person shall be subjected to discrimination on the basis of race, color, or national origin under any program or activity that receives federal financial assistance. In order to avoid discrimination against LEP persons on the grounds of national origin, we must take reasonable steps to ensure that such persons have meaningful access to the programs, services, and information. Language barriers prohibit LEP persons from obtaining services and information relating to a variety of services and programs because they may not be able to read instructions or correspondence written in English and may not understand verbal information. Many times, they are not aware of regulatory requirements and legal implications of the services they seek. When LEP persons receive legal documents, they often do not understand the contents of the correspondence and its implication to their daily lives. LEP •persons may not be able to take advantage of services, which could affect their job and social opportunities. When individuals do not understand or read English, they can be hampered in seeking employment opportunities. IV. GOALS It is essential that City staff be informed about their diverse clientele from a linguistic, cultural and social perspective. These individuals will be culturally competent so they can encourage vulnerable LEP minority populations to access and receive appropriate services with more knowledge and confidence. The key to providing meaningful access to LEP persons is to ensure that LEP persons can communicate effectively and act appropriately based on that communication. Minimum reasonable measures would be to ensure that LEP persons are given adequate information, are able to understand that information, and are able to participate effectively in programs or activities. Spanish and Vietnamese are the two most requested languages for interpreters in the City of Santa Ana. City staff will make designated publications available in languages other than English and provide interpretation/translation services to persons who are not proficient in English. The City will take reasonable steps to ensure that LEP persons are given adequate information, are able to understand that information, and are able to participate effectively in recipient programs or activities, where appropriate. V. FOUR FACTOR ANALYSIS The DOT Four Factor Analysis provides guidance to agencies receiving federal financial assistance in taking reasonable steps to ensure meaningful access to all of its services, programs and activities used by LEP persons. The City received a $200,000 grant to purchase two fuel-efficient shuttle buses for the City's Seniors on the Go Transportation Program. This program will offer transportation to and from the seniors' home to both of the City's Senior Recreation Centers. Transportation will not be provided to the general public, therefore, an analysis of public demographic 55C-21 15