2017-086 - Approving the Title VI Compliance Plan

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City of Santa Ana Limited English Proficiency (LEP) Plan November 2017 into 80 different languages. All of the City's public counters are staffed with bilingual speakers for the two most common languages requested in the City of Santa Ana, Spanish and Vietnamese. Costs for marketing materials and translation of documents for outreach are minimal and have not been quantified. S. Summary Based on the four -factor analysis, the City of Santa Ana has identified the language needs and services required to provide meaningful access to information for the LEP residents of Santa Ana. This LEP Plan will be reviewed on an annual basis and incorporate LEP information that further identify additional language needs for the top languages identified. VI. PLANNING— DEVELOPING A LANGUAGE ASSISTANCE PROGRAM (LAP) A. Identification of LEP Persons City staff will use the following methods to identify LEP persons: • Examine records to see if requests for language assistance have been ,received in the past, either at meetings or from referrals to determine whether language assistance might be needed for future events or literature. • Provide language identification forms which invite LEP persons to identify their language needs to our staff members. Records will be maintained for a 3 -year period. Safe Harbor Provision. DOT has adopted DOJ's Safe Harbor Provision, which outlines circumstances that can provide a "safer harbor' for recipients regarding translation of written materials for LEP populations. The Safe Harbor Provision stipulates that, if a recipient provides written translation of vital documents for each eligible LEP language group that constitutes five percent (5%) or 1,000 persons, whichever is less, of the total population of persons eligible to be served or likely to be affected or encountered, then such action will be considered strong evidence of compliance with the recipient's written translation obligations. Translation of noh-vital documents, if needed, can be provided orally. If there are fewer than 50 persons in a language group that reaches the five percent (5%) trigger, the recipient is not required to translate vital written materials but should provide written notice in the primary language of the LEP language group of the right to receive competent oral interpretation of those written materials, free of cost. These safe harbor provisions apply to the translation of written documents only. They do not affect the requirement to provide meaningful access to the LEP individuals though competent oral interpreters where oral language services are needed and are reasonable. A recipient may determine, based on the Four Factor Analysis, that even though a language group meets the threshold specified by the Safe Harbor Provision, written translation may not be an effective means to provide language assistance measures. For example, a recipient may determine that a large number of persons in that language group have low literacy skills in their native language and therefore require oral interpretation. In such cases, a background documentation regarding the determination shall be 17