STA Limited English Proficiency (LEP) Four Factor Analysis. Produced concurrently with the 2014 STA Title VI Program Update.

Transcription

1 STA Limited English Proficiency (LEP) Four Factor Analysis Produced concurrently with the 2014 STA Title VI Program Update Attachment A January 30, 2014 Upon request, alternative formats of this document will be produced for people with disabilities. Please call or TTY WA Relay 711 or smillbank@spokanetransit.com

2 Table of Contents Introduction... 3 The Four Factor Analysis... 4 Factor 1 The number and proportion of LEP persons served or encountered in the eligible population Factor 2 The frequency with which LEP individuals come in contact with a Spokane Transit Authority program, activity, or service... 5 Factor 3 The nature and importance of the program, activity, or service provided by Spokane Transit Authority to the LEP Community... 6 Factor 4 The resources available to Spokane Transit Authority and overall costs... 7 Appendix Attachment 1 Demographic Data Attachment 2 LEP Distribution List Attachment 3 Cover Letter for Survey Attachment 4 LEP Survey Attachment 5 Survey Results Table 1 Language Spoken at Home Table 2 Language Spokane at Home by Ability to Speak English Table 3 Nativity by Language Spoken at Home Table 4 Spokane Transit Authority Public Transportation Benefit Area (PTBA) LEP Population by Census Tract Table 5 Survey Results for Question Table 6 Survey Results for Question Map 1 LEP Population by Census Tract Map 2 STA System Map Title VI Plan Attachment A LEP Plan

3 Introduction Spokane Transit Authority (STA) has conducted a Four Factor Analysis to meet the requirements under Title VI of the Civil Rights Act of The Four Factor Analysis provides a framework to conduct a needs assessment of people with Limited English Proficiency (LEP). Based on the needs assessment, a language assistance plan was developed that was consistent with the provisions of Section VII of the LEP guidance. Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq., and its implementing regulations provide that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied benefits of, or be otherwise subjected to discrimination under any program or activity that receives Federal financial assistance. The Supreme Court, in Lau v. Nichols, 414 U.S. 563 (1974), interpreted Title VI regulations prohibits conduct that has a disproportionate effect on persons with Limited English Proficiency (LEP) because such conduct constitutes national origin discrimination. According to the Federal Transit Administration Office of Civil Rights handbook dated April 13, 2007, Implementing the Department of Transportation s Policy Guidance Concerning Recipients Responsibilities to Limited English Proficient (LEP) Persons: A Handbook for Public Transportation Providers, Individuals, who have a limited ability to read, write, speak, or understand English are limited English proficient or LEP Title VI Plan Attachment A LEP Plan

4 The Four Factor Analysis Factor 1 The number and proportion of LEP persons served or encountered in the eligible population. The purpose of Factor 1 is to determine the number and proportion of LEP persons served or encountered within the service area. There are several suggested steps including: examine prior experiences, review U.S. Census data, identify the geographical boundary, consult other sources of data, and reach out to community organizations. Spokane Transit has broken Factor 1 into two phases: 1) Data and Information Gathering, 2) Review and Findings. Below are the actions taken by Spokane Transit for each phase. Data and Information Gathering: Interviewed STA staff (Community Ombudsman, Communications Manager, Paratransit Manager, etc.) to gather information related to contact with LEP persons. Collected 2010 U. S. Census and American Community Survey Data and displayed the data into a format that is included in this report (Attachment 1, Tables 1, 2, 3, and 4). Identified organizations that potentially have contact with LEP persons. The list (Attachment 2) was gathered through the web, STA staff, and follow-up from other organizations. Drafted and distributed an introductory letter (Attachment 3) and survey (Attachment 4) to the list of organizations that potentially have contact with LEP persons. Interviewed community organizations both on phone and in person. Refugees who are placed in the Spokane area are initially provided housing and basic needs by the local resettlement agency, World Relief, and post-resettlement needs are provided by smaller community organizations. Described Spokane Transit service area and concentrations of LEP populations (Attachments 6 and 7) in the service area. Based on the review of the information collected above (census data, returned surveys, interviews, and document review) the following characteristics of the LEP population in Spokane County are described below. Review There is a relatively low LEP population in Spokane County. The most common languages encountered by community organizations (based on surveys received) are Spanish, Russian, Arabic, and Burmese (including Chin and Karen). Other recurring languages include Chinese, French, Swahili, Ukrainian, and Vietnamese. Community organizations (based on surveys received) requested updates to service and fare changes. Several community organizations stated that transit was extremely important for LEP persons mobility Title VI Plan Attachment A LEP Plan

5 Several community organizations expressed that LEP people have difficulty using public transit or that current transit services were inadequate. Concentrations of LEP people are low and spread out throughout the service area. According to interviews with community organizations, areas of LEP concentrations include along the Division and Hamilton Street corridors, the Lower South Hill, and around the East Central Community Center, where there are reliable transit services with a mix of basic and frequent bus headways. Geographical Service Area The Spokane Transit service area includes the Spokane County cities of Airway Heights, Cheney, Liberty Lake, Medical Lake, Millwood, Spokane and Spokane Valley, as well as limited unincorporated areas of Spokane County that are within the Public Transportation Benefit Area (PTBA). Census Overview Individuals demonstrating a limited ability to read, write, speak, or understand English are considered to be of limited English proficiency. According to the American Community Survey year estimates, 23,502 of Spokane County s 431,952 residents reported speaking English less than very well. This equates to approximately 5% of the total population below the national average in The percentage of people with limited English proficiency is slightly higher when adjusted for just the population within the Public Transportation Benefit Area (PTBA) at 6% (22,906 out of 392,684). Although the percentage of persons with limited English proficiency is relatively small in Spokane Transit Authority s service area, it is essential that language does not prove a barrier to their access to transit service. The percentage of persons in Spokane County speaking a language other than English is proportionally low, with Spanish and Russian being the top two languages (Attachment 1, Tables 2 and 3). A small minority of the Spokane County population responded as speaking English not well (2.8%) or not at all (0.2%). Factor 2 The frequency with which LEP individuals come in contact with a Spokane Transit Authority program, activity, or service Description of Services Spokane Transit Authority is a regional public transportation agency, and as such, provides a variety of transportation services, including fixed route, Paratransit, and Vanpool service to the cities of Airway Heights, Cheney, Liberty Lake, Medical Lake, Millwood, Spokane, and Spokane Valley. These services include connections between downtown Spokane and Spokane Valley, Spokane International Airport, major shopping malls, area colleges and universities, major medical centers, Fairchild Air Force Base, and other cities within the PTBA. Spokane Transit operates within an area encompassing approximately 248 square miles of Spokane County, which includes approximately 405,302 residents or 84.4 percent (91.6%) of the county population (based on Washington State Office of Financial Management (OFM) 2013 Population Estimates) Title VI Plan Attachment A LEP Plan

6 Paratransit Service is operated by STA and its contractor for people who qualify under the eligibility requirements of the Americans with Disabilities Act (ADA). Paratransit service is provided within a defined service area, during the same hours and days as fixed route service and in compliance with applicable state and federal laws for service to people whose disability prevents them from using fixed route bus service. Vanpool (Rideshare) Service augments STA s public transportation system through the assignment of passenger vans to vanpool groups. Input from Community Organizations Spokane Transit conducted interviews and requested input from community groups serving LEP persons through a survey (Attachment 4). There were 19 surveys sent out of which 16 returned a completed survey. Of the surveys returned, 81% of respondents answered in the affirmative to the question of whether the LEP population served has inquired about how to access Spokane Transit s public transportation service or expressed a need for public transportation service. A summary of the returned surveys is provided (Attachment 5). Review Per the 2010 American Community Survey data, Spokane Transit service area does not have a large LEP population (Attachment 1 (Table 4) and Attachment 6). Community organizations have stated that LEP persons inquire about transit access; however, we do not have firm data on the number of riders or potential riders of public transit. Factor 3 The nature and importance of the program, activity, or service provided by Spokane Transit Authority to the LEP Community In 2013, Spokane Transit s 34 fixed routes provided 11,087,049 passenger trips, 383,356 revenue hours, and 5,334,753 revenue miles. Paratransit provided over 483,010 passenger trips, 163,220 revenue hours, and 2,517,922 revenue miles in Vanpool provided 241,257 passenger trips, 29,612 revenue hours, and 1,126,943 revenue miles in data has not been audited. Input from Community Organizations Spokane Transit conducted interviews and requested input from community groups serving LEP persons through a survey (Attachment 4). Below is a composite of the responses to the survey as relating to importance of service to the LEP population. 100% of respondents serve or have contact with persons with LEP. The number of LEP persons the agency provides services to ranges from one person per month to 400 individuals per day. 73% of survey respondents had an increase in LEP populations since 2011 (the year of the last Title VI LEP Plan Update) Title VI Plan Attachment A LEP Plan

7 81% of responders stated that LEP individuals inquired about how to access STA s public transit services or expressed a need for such services. 69% of responders stated that LEP individuals express difficulty in accessing current public transit services. According to the local refugee resettlement organization, housing for newly arrived refugees must be located within a few blocks of a transit stop. According to interviews with community organizations, areas of LEP concentrations include along the Division and Hamilton Street corridors, the Lower South Hill, and around the East Central Community Center, where there are reliable transit services with a mix of basic and frequent bus headways. 94% of respondents affirmed that they would like to receive notification related to major service and fare changes in order to communicate these changes to those with LEP. Review Spokane Transit provides an important service to the community, inclusive of the LEP population. The local resettlement agency is required to place newly arrived refugees in housing that is close to public transit services. Spokane Transit provides access throughout the community to major employment centers, social services, commercial and retail locations, and educational and health care facilities. As seen in Attachments 6, Spokane Transit serves the majority of areas where LEP populations reside. There is an interest or need from LEP populations to access public transit services, but many individuals express difficulty in accessing such services. There is interest from community organizations to receive updates from Spokane Transit. There were six requests for translation of STA materials received during the assessment period. Two were for Mobility Training and four were for assistance through the Paratransit in-person assessment for eligibility. There was a total of 17 hours for translation service. Website access by LEP persons is unknown. All translations were arranged through Spokane International Translation at a rate of $50 per hour ($2.50 less an hour than their current contract with Washington State). Factor 4 The resources available to Spokane Transit Authority and overall costs Input from Community Organizations There are organizations serving LEP populations in a variety of ways including: translation, ESL, networking, job training, and basic services. There are translation services readily available for use by Spokane Transit. STA contracts with Spokane International Translation to provide translation services. The cost of translation services is $50 per hour Title VI Plan Attachment A LEP Plan

8 A member of the STA Human Resources staff is fluent in Spanish and available to provide translation services. Review Based on the low LEP population in the service area and limited prior requests for translation services, the most fiscally responsible use of resources for Spokane Transit is to obtain translation services as requested. Plan for Assisting Persons of Limited English Proficiency. How to Identify an LEP Person who Needs Language Assistance. Below are tools to help identify persons who may need language assistance. Examine requests for language assistance for bus scheduling information. Examine records requests for language assistance from past public notice meetings and events to anticipate the possible need for assistance at upcoming public meetings. Though language needs may not be met at the current meeting, an inventory of those needs will help staff plan for language needs at a future meeting. Language Assistance Measures When an in-person interpreter is needed, it should be determined what language is required. This will be addressed by posting a notice of available language assistance in the Spokane Transit Authority Plaza, Boone Avenue Customer Service Center, and STA website. Notice of translation services will also be displayed in Spanish and Russian, the two most commonly spoken languages among area LEP populations. Once the LEP person s language is determined, STA staff will contact a translating service for assistance to understand the customer s needs. Spokane Transit Staff Training The LEP Plan will be available for all employees in electronic or hard copy format. This information will also be part of the Spokane Transit staff orientation process for new hires. Training topics include: Understanding the Title VI LEP program responsibilities; What language assistance Spokane Transit offers; How to access an interpreter; Documentation of language assistance requests; How to handle a complaint; The importance of educating Spokane Transit staff on its LEP program responsibilities and their obligation to provide language assistance. Providing Notice of Available Language Service to LEP Persons Safe Harbor Provision Title VI Plan Attachment A LEP Plan

9 According to the US Department of Justice s (DOJ) Safe Harbor Provision, adopted by US Department of Transportation (DOT), if a recipient of federal funds provides written translation of vital documents for each eligible LEP population that that constitutes five percent (5%) or 1,000 persons of the total population served by the agency, whichever is less, then such action will be considered strong evidence of compliance with the recipient s written translation obligation. As mentioned earlier, STA posts notices in Russian and Spanish, informing of available translation services. According to the 2010 American Community Survey 5-year estimates, these are the two LEP languages in the Spokane area that meet the criteria above. In addition to being posted on the STA website, this notice is posted on large, prominent signs within the downtown Transit Plaza and in the Boone Avenue Customer Service Center. These notices are considered vital documents because they inform these prominent language groups about translation services that are available to them. Through these services, other STA documents can be translated based on the need of individuals. By providing notice of translation services in these two LEP languages, STA complies with the DOJ Safe Harbor Provision. Outreach Techniques Send updated information concerning fare changes or major service changes to community organizations (as identified in the distribution list) that have contact with LEP persons. Update the distribution list as needed. Send surveys to community organizations inquiring about the demographics of and the services provided to LEP persons. Work with community organizations to distribute STA information in needed languages. Monitoring and Updating the LEP Plan This plan is designed to be flexible and is one that can be easily updated. At a minimum, Spokane Transit will follow the Title VI program update schedule for the LEP plan. Each update should examine all plan components such as: How many LEP persons were encountered? Were their needs met? What is the current LEP population in the service area? Has there been a change in the types of languages where translation services are needed? Is there still a need for continued language assistance for previously identified Spokane Transit programs? Are there other programs that should be included? Has Spokane Transit s available resources, such as technology, staff, and financial costs, changed? Has Spokane Transit fulfilled the goals of the LEP plan? Were there any complaints received? Dissemination of the Spokane Transit Limited English Proficiency Plan Spokane Transit will post the LEP plan on its website at Title VI Plan Attachment A LEP Plan

10 An LEP person may obtain copies of the plan upon request. Any questions or comments regarding this plan should be directed to: Susan Millbank, Community Ombudsman and Accessibility Officer 1229 W. Boone Avenue Spokane, WA (509) Title VI Plan Attachment A LEP Plan

11 Appendix Title VI Plan Attachment A LEP Plan

12 Attachment 1 Demographic Data Table 1 Language Spoken at Home S1601: Language Spoken at Home 2010 American Community Survey 5-Year Estimates Title VI Plan Attachment A LEP Plan

13 Table 2 Language Spokane at Home by Ability to Speak English B16001: Language Spoken at Home by Ability to Speak English for the Population 5 Years and Over 2010 American Community Survey 5-Year Estimates Title VI Plan Attachment A LEP Plan

14 Table 2 continued Title VI Plan Attachment A LEP Plan

15 Table 3 Nativity by Language Spoken at Home B16005: Nativity by Language Spoken at Home by Ability to Speak English for the Population 5 Years and Older 2010 American Community Survey 5-Year Estimates Title VI Plan Attachment A LEP Plan

16 Table 3 continued Title VI Plan Attachment A LEP Plan

17 Table 4 Spokane Transit Authority Public Transportation Benefit Area (PTBA) LEP Population by Census Tract 2010 American Community Survey 5-Year Estimates Census Tract Total Population 5 Years and Older Total ALL groups who speak English less than "very well" Percent Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Title VI Plan Attachment A LEP Plan

18 Census Tract Total Population 5 Years and Older Total ALL groups who speak English less than "very well" Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Percent Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Tract % Tract % Tract % Tract % Tract % Tract % Tract % Census Tract % Census Tract % Census Tract % Census Tract % Tract % Tract % Tract % Tract % Census Tract % Census Tract % Census Tract % Census Tract % Tract % Tract % Census Tract % Title VI Plan Attachment A LEP Plan

19 Census Tract Total Population 5 Years and Older Total ALL groups who speak English less than "very well" Percent Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Tract % Tract % Census Tract % Census Tract % Tract % Tract % Tract % Tract % Tract % Tract % Census Tract % Census Tract % Tract % Tract % Tract % Census Tract % Census Tract % Census Tract % Census Tract % Census Tract % Tract % Tract % Census Tract % Census Tract % Census Tract % Total 392,684 22,906 6% Title VI Plan Attachment A LEP Plan

20 Attachment 2 LEP Distribution List LEP Community Organizations Survey Distribution List Community Organization Contact Name Title AHANA/Community Minded Enterprises Ben Cabildo Director Hispanic Business Professional Association of Spokane Bernadette Pillar President Spokane School District 81 Program Taffy Carlisle English Language Dept Coordinator World Relief Spokane Mark Kadel Director Catholic Charities Spokane Refugee and Immigration Greg Cunningham Director Services Gonzaga University English Language Center Melissa Heid Program Manager Spokane Community Program College International Trina Allen Coordinator Students Program Global Neighborhood Spokane Jacob's Well Community Resource Center Country Homes Christian Church ESL Program Spokane College of English Language West Central Community Center Refugee Connections Northeast Community Center Aging and Long Term Care of Eastern Washington Amy Hendricks Sue Beck Calli Foxworth Jim Clark Kim Ferraro Susan Hales Tracy Swank Jamie McIntyre Director of Interns and Volunteers Director ESL Program Director President Executive Director Planner and Title V Coordinator Perciba Inc/Spokane International Translation Spokane Slavic Adventist Church Institute for Extended Learning ESL Program Spokane Regional Health District Marta C. Reyes Owner Gregory Arutyunyan Pastor Stoja Saric Barbara Lorang Master of ESL Classes Manager of Human Resources Title VI Plan Attachment A LEP Plan

21 Attachment 3 Cover Letter for Survey Title VI Plan Attachment A LEP Plan

22 Attachment 4 LEP Survey Community Groups Serving People with LEP Survey Agency Name Contact Name, Title Contact Phone Number Contact If you have any questions regarding this survey, please contact Gordon Howell, Spokane Transit Planner at (509) Please answer the following questions and return via or via the postage paid envelope provided by December 17, Thank you. If you require more time, please let us know. 1. Do you serve or have contact with persons with limited English proficiency that require translation assistance? If not, please complete question #2 and return the survey. Yes No 2. Are you aware of any other organizations that come into contact or have services for persons with limited English proficiency? If yes, please list the organization(s). Yes No Name of Organization(s): 3. What Geographic area does your agency service? 4. Approximately how many persons with limited English proficiency does your agency provide services to or come into contact with either on a daily or weekly basis? Please specify. 5. Has the size of this population increased, stayed the same, or decreased since 2011? 6. What are the nationalities of the population that you provide services to? Title VI Plan Attachment A LEP Plan

23 7. What are the languages spoken by the population you serve? 8. What is the approximate age range of your population? 9. What services do you provide to persons with limited English proficiency? 10. Has the population inquired about how to access Spokane Transit s public transportation service or expressed a need for public transportation services? 11. Do individuals express difficulty in accessing current public transportation services? If so, please let us know how we can assist. 12. What are the best ways to inform your population about Spokane Transit services and to receive their feedback in return? 13. Would you like to receive notification related to major service changes and fare changes at Spokane Transit in order to communicate these changes to those with limited English proficiency? Thank you again for your assistance Title VI Plan Attachment A LEP Plan

24 Attachment 5 Survey Results Questions 1, 2, 10, 11, and 13 are yes/no questions. The answers here are shown by the number of community organizations responding yes, no, or N/A per question. Question 1 asks whether an organization comes into contact with LEP persons and Question 2 asks whether it knows of any other organizations that serve LEP populations. All sixteen (16) survey responders said yes for Question 1 and 14 said yes for Question 2. Question 10 asks if an organization s LEP clients inquire or express interest in STA public transportation services. The majority or survey responders answered yes and that public transit is important to their LEP clients. Question 11 asks organizations whether their LEP clients express difficulty in accessing public transportation. Most said yes, and this is mostly due to the lack of translated materials on coaches or being unable to communicate with bus operators. Some survey responders answered that the bus does not run as frequently or run as late into the night to some areas of town, and this is a problem expressed by some of their clients. Question 13 asks whether the organization would like to receive notices of service or fare changes. Almost all said yes, except one health department at Spokane Regional Health District that encounters very few LEP people. Question Yes No N/A Question 3 asked organizations what geographic area they typically serve or work in. Six (6) answered Eastern Washington, four (4) answered the City of Spokane, and two (2) said Spokane County, and one (1) listed Washington State. One organization stated that it served a particular area of Spokane and one cited a university. One other one did not answer. Question 4 asked how many LEP persons each organization serves or comes into contact with. There was a wide range, from 400 a day to one (1) per month. Question 5 asked whether an organization s LEP population has grown or not. Eleven (11) answered that it has increased, one (1) said it decreased, and four (4) that it stayed the same Title VI Plan Attachment A LEP Plan

25 Number of LEP Organizations from Survey Question 6 asked what nationalities each organization encounters. Table 5.1 below helps to explain the results of this question and determine which nationalities are most common among the Spokane area LEP populations. Only nationalities that were specifically mentioned by three or more organizations were added to this dataset. Based on the information below, six (6) organizations reported that they encounter people from either China, Iraq, Mexico, and Myanmar and five (5) reported encountering people from Bhutan, Congo (either Congo Republic or Democratic Republic), Korea (either North or South), Russia, and Ukraine. The top nationalities in this table match closely with the top languages in the Table 5. Table 5 Survey Results for Question Most Common Nationalities Encountered by Area LEP Organizations (three or more) Nationalities Specifically Mentioned by LEP Organizations Question 7 asked what languages each organization encounters. Table 5.2 below helps to explain the results of this question and determine which languages are most commonly spoken among local LEP populations. Only languages that were specifically mentioned by three or more organizations were added to this dataset. Based on the data below, Spanish was the most prevalent language, with ten (10) organizations reporting that they encounter this language. This is closely followed by Arabic and Russian, with nine (9), and Burmese (including Chin and Karen dialects), with eight (8). The top languages in this table closely with the most top nationalities in the Table Title VI Plan Attachment A LEP Plan

26 Number of LEP Organizations from Survey Table 6 Survey Results for Question 7 12 Most Common Languages Encountered by Area LEP Organizations (three or more) Languages Specifically Mentioned by LEP Organizations Question 8: This question asks organizations what ages they serve. A few organizations, such as the Gonzaga English Language Center and Aging and Long Term Care of Eastern Washington, serve a specific age group, but the majority of community organizations from the survey serve all or a wide range of ages. Questions 9 and 12: The answers to questions are qualitative and difficult to summarize in table format. Question 9 asked community organizations about what services they provide to LEP populations. Most mentioned translation, and some of the other services mentioned by organizations included any one or more of the following: acquiring basic needs, housing, employment placement and job training, English language classes, legal assistance. Question 12 asked organizations about the best way to inform their LEP populations about transit service and fare changes. Most answered that they would inform their clients themselves, but many also suggested printing translated notices or schedules into multiple languages Title VI Plan Attachment A LEP Plan

27 Maps Title VI Plan Attachment A LEP Plan

28 Map 1 LEP Population by Census Tract Title VI Plan Attachment A LEP Plan

29 Map 2 STA System Map Title VI Plan Attachment A LEP Plan