Title VI (Civil Rights) – Language Assistance Plan

Language Assistance Plan for Ability Building Center
Effective: June 23, 2015


The purpose of this Language Assistance Implementation Plan (hereinafter ”plan”) is to meet Federal Transit Administration’s (FTA’s) requirements to comply with Title VI of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, or national origin. As a subrecipient of FTA funds, this transit system is pledged to take reasonable steps to provide meaningful access to its transit services for persons who do not speak English as their primary language and who have a limited ability to read, speak, write, or understand English. The FTA refers to these persons as Limited English Proficient (LEP) persons.

The U.S. DOT’s FTA Office of Civil Rights’ publication “Implementing the Department of Transportation’s Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient Persons – A Handbook for Public Transportation Providers” was used in the preparation of this plan.

A. LEP Needs Assessment – the Four-Factor Analysis

Factor 1.  The number or proportion of LEP persons in our service area who may be served or are likely to encounter a transit program, activity, or service.

We assessed the following information (as checked) about LEP persons to determine the number or proportion of LEP persons who might use or want to use our transit services:

_____ GIS map showing transit service area and concentrations of LEP persons (Attachment A)
_X___ 2000 & 2010 US Census data
_____ Survey results
_X___ Reports from drivers, dispatchers, others about contact with LEP persons
_X___ Local school district data
_____ Human Services Dept. data
_____ Information from local organizations (religious, legal, social service, etc.) about LEP persons in our service area
_____ Other information. Describe: _____________________

Ability Building Center reviewed data from both the US Census Bureau and the Olmsted County School Districts.

According to the US Census 2011-2013 American Community Survey 3-Year Estimates, only 3.1% of all households in Olmsted County indicated that “no one age 14 and over speaks English only or speaks English very well.”  Concurrently, only .1% of all households in Houston County indicated that “no one age 14 and over speaks English only or speaks English very well.”

The data for the School Districts headquartered in Olmsted County indicated that there were 79 different languages reported as being the primary language in the households of children enrolled in 2011-12.  English was the primary language for 83% of students. Other predominant languages in the region included: Somali (4.3%), Spanish (4.3%), Khmer/Cambodian (1.6%), Arabic (1.3%), Vietnamese (0.9%), and Chinese Mandarin (0.9%).

Factor 2.  The frequency with which LEP persons come in contact with our transit programs, activities, or services. 
Ability Building Center provides services to persons with disabilities and other special needs.  As of October of 2014, ABC was serving 766 program participants of which 12 had LEP (1.567%).  Of these 12, English proficiency was indicated as follows:

  • 12 = Speak English “not well” (10 indicated Vietnamese as their primary language and 2 indicated Spanish as their primary language)
  • 0 = Speak English “not at all”

Factor 3.  The nature and importance of programs, activities, or services provided to the LEP population.

Ability Building Center considers transit to be an important and essential service for its program participants.  Our LEP program participants benefit from this service by being transported to places of employment and non-vocational community integration opportunities such as recreational, volunteer, and social activities.

Factor 4. The resources available to our transit system and the overall cost to provide language assistance.

Our current budget for marketing to or communicating with LEP persons in their language about transit services that are available to them is $_763.50___.  This would include funding for translation services, brochures, posters, website, etc.

B. Language Assistance Measures

Language measures currently used and planned to be used by our transit system to address the needs of LEP persons include the following:

_____Translating key documents in the following language(s): __________
__X__Arranging for availability of oral translators
_____Communicating with LEP persons’ groups about transit services
_____Posting notices in appropriate languages informing LEP persons of available services
__X__Other:  _Assistive Technology_

Ability Building Center works closely with stakeholders (i.e. social workers, family members) of persons served to address any language barriers its LEP program participants may have.  When necessary, formal interpretive services are obtained locally through agencies such as the Intercultural Mutual Assistance Association(IMAA) http://imaa.net/.

C. Staff Training

To ensure effective implementation of this plan, the transit system will schedule training at orientations for new staff and annually thereafter for all employees who may have direct contact with the public.  This review shall include:

  • the transit system’s Language Assistance Implementation Plan
  • how to handle verbal requests for transit service in a foreign language
  • responsibility to notify the Transportation Coordinator about any LEP persons’ unmet needs.

D. Notice to LEP Persons about Available Language Assistance

Our transit system plans to notify LEP persons in their own language about the language assistance available to them without cost by using the following methods:
_____signs on buses or at bus stops
__X__sending information to local organizations that work with LEP persons
_____telephone messages
_____local ads (newspaper, radio, TV)
__X__website notices
_____information tables at local events, grocery stores, pharmacies, and churches
_____Other, describe _____________________________

E. Monitoring, Evaluating and Updating Plan

The transit system will review this plan during its annual review with its Mn/DOT transit project manager by:

  • assessing its effectiveness (e.g., comparing numbers of LEP persons served by year, number of requests for language assistance received during the year),
  • assessing the sufficiency of staff training and budget for language assistance,
  • reviewing current sources for assistance to ensure continuing availability, and
  • reviewing any complaints from LEP persons or about their needs that were received during the past year.

This plan will be reviewed by our transit system annually. Revisions of this plan will be approved or adopted by the transit system (transit manager or board) and dated accordingly.

F. Dissemination of Plan

This Language Assistance Plan is available on our website at www.abcinc.org

This plan is also available at no cost in English upon request by telephone, fax, and mail or in person.  If requested to be provided in another language and it is feasible to have it translated, it shall be provided at no cost to the requester.

G. Contact Information

Questions or comments about this plan may be submitted to:

Katie Gifford, Transportation Manager
PO Box 6938, Rochester, MN 55903
507-281-6270 (fax)

Date approved by Ability Building Center Board of Directors:  June 23, 2015