This Limited English Proficiency (LEP) Plan has been prepared to address GTrans’ responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964 which prohibits discrimination on the basis of race, color or national origin in programs and activities receiving Federal financial assistance. Specifically, Title VI provides that “no person shall, on the grounds 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”.
GTrans is committed to ensuring that no person is excluded from participation in or denied the benefits of its transit services on the basis of race, color, or national origin.
This plan was developed to guide GTrans in its administration and management of Title VI related activities.
GTrans has developed this Limited English Proficiency Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency [LEP] who wish to access services provided. As defined in Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write or understand English. This plan outlines how to identify a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how to notify LEP persons that assistance is available. In order to prepare this plan, GTrans undertook the U.S. Department of Transportation’s four-factor LEP analysis which considers the following factors:
A summary of the results of the four-factor analysis is in the following section.
1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a GTrans program, activity or service.
GTrans reviewed 2010 U.S Census tract level data and the 2014 American Community Survey census update data. Those census tracts that were within 1/4 mile of a GTrans route were considered part of the GTrans service area. The review indicated that the total service area has a population of 498,085 that are five years of age or older. Of those persons, 129,599 (26.0%) speak English “not well” or “not at all”. Of those persons with limited English proficiency, 95,688 (73.8%) speak Spanish. The next languages listed with the highest number of persons that speak English “not well” or “not at all” is Korean at 6,731 persons (5.2%), Tagalog at 6,048 (4.7%), and Japanese at 4,729 persons (3.6%). A number of other language groups make up the remainder of limited English speaking persons in the service area.
As detailed in Figures 1 through 5, census tracts with the majority of limited English speaking persons were located primarily in the Downtown Los Angeles area and along Western and Normandie Avenues, with a fairly large number of limited English speaking persons of Korean, Tagalog and Japanese decent living in the Redondo Beach Blvd. corridor. These tracts had a population of limited English speaking persons ranging from a low of 2% to a high of 50% or more.
2. The frequency with which LEP persons come in contact with GTrans programs, activities or services.
GTrans reviewed the frequency with which staff and drivers have, or could have, contact with LEP persons. This includes reviewing phone inquiries and surveying bus operators. To date, GTrans staff has had infrequent requests for assistance in languages other than English. In an optional survey of bus operators, thirty-seven (37) bus operators indicated a fairly high level of interaction with LEP persons. Just over 60% of all bus operators surveyed indicated that they have daily interaction with LEP persons. Approximately 40% of bus operators surveyed interact with LEP persons 10 or more times a day. The predominate language encountered by bus operators is Spanish, with some interaction with Korean-speaking and Japanese-speaking passengers. There have been few requests made to bus operators for language translation of public information, with 68% of operators indicating that passengers do not request translated materials.
Figure 1: Percentage of English Language Spoken by Census Tract
Figure 2: Percentage of Spanish Speakers with Little or No English Proficiency
Figure 3: Percentage of Korean Speakers with Little or No English Proficiency
Figure 4: Percentage of Tagalog Speakers with Little or No English Proficiency
Figure 5: Percentage of Japanese Speakers with Little or No English Proficiency
3. The nature and importance of programs, activities or services provided by GTrans to the LEP population.
As detailed in Figures 1 through 4, census tracts with the majority of limited English speaking persons were located primarily in the Downtown Los Angeles area and along Western and Normandie Avenues, as well as the Redondo Beach Blvd. corridor. Because GTrans service to Downtown Los Angeles is express-oriented with few stops, the largest geographic concentration of LEP individuals in the GTrans service area that has access to local bus service live adjacent to Western and Normandie Avenues and in the Redondo Beach Blvd. corridor. Between 20% – 50% of Spanish-speaking persons in the Western and Normandie Avenue corridors have little or no English proficiency, and between 20%-40% of persons of Korean, Tagalog and Japanese decent in the Redondo Beach Blvd. corridor have little or no English proficiency. The Nakaoka Community Center, located near GTrans Lines 1, 2, 3 and 4, provides literacy programs and English as a Second Language (ESL) classes to community residents. In speaking with a customer service representative of the city-operated community center, they have contact everyday with persons who speak Spanish, Korean and Japanese as a first language. Many participants of the ESL program use transit to access the facility, as well as seniors who ride Gardena Special Transit to the community center, although it is unknown how much they use GTrans compared to other local transit providers (Metro, Torrance Transit). The customer service representative indicated that some comments regarding transit from persons attending the center focused on being unsure of bus stop locations or how to contact GTrans for transit information.
4. The resources available to GTrans and overall cost to provide LEP assistance.
GTrans reviewed its available resources that could be used for providing LEP assistance, which of its documents would be the most valuable to be translated if the need should arise, and evaluated resources that could be used for outreach and translation efforts. Based on the four-factor analysis, GTrans developed its LEP Plan as outlined in the following sections.
A person who does not speak English as their primary language and who has a limited ability to read, write, speak or understand English may be a Limited English Proficient person and may be entitled to language assistance with respect to GTrans’ programs and activities. Language assistance can include interpretation, which means oral or spoken transfer of a message from one language into another language and/or translation, which means the written transfer or a message from one language into another language. GTrans will determine when interpretation and/or translation are needed and are reasonable. How the GTrans staff may identify an LEP person who needs language assistance:
Language Assistance Measures – GTrans will strive to offer the following measures to LEP individuals, that is, persons who speak English “not well” or “not at all”,:
Federal law provides a “Safe Harbor” stipulation so that recipients can ensure with greater certainty that they comply with their obligations to provide written translations in languages other than English. A “safe harbor” means that if a recipient provides written translations under certain circumstances, such action will be considered strong evidence of compliance with the recipient’s written-translation obligations under Title VI.
The failure to provide written translations under the circumstances does not mean there is noncompliance, but rather provides a guide for recipients that would like greater certainty of compliance than can be provided by a fact-intensive, four-factor analysis. For example, even if a safe harbor is not used, if written translation of a certain document(s) would be so burdensome as to defeat the legitimate objectives of its program, it is not necessary. Other ways of providing meaningful access, such as effective oral interpretation of certain vital documents, might be acceptable under such circumstances.
Strong evidence of compliance with the recipient’s written-translation obligations under ‘safe harbor’ includes providing written translations of vital documents for each eligible LEP language group that constitutes 5% or 1,000, whichever is less, of the population of persons eligible to be served or likely to be affected or encountered. GTrans’ translation of other documents, if needed, can be provided orally.
This safe harbor provision applies to the translation of written documents only. It does not affect the requirement to provide meaningful access to LEP individuals through competent oral interpreters where oral language services are needed and are reasonable.
In the GTrans service area, the Spanish-speaking, Korean-speaking and Tagalog-speaking LEP language groups constitute the 5% or 1,000 persons of population threshold for which written translations of vital documents should be provided meet the safe harbor standard. Also, while the Japanese-speaking language group constitutes less than the 5% threshold (3.6%), the concentration of this language group in the service area and their history of participation in the civic and social affairs of the City of Gardena would suggest the inclusion of this language group for written translations of vital documents. To meet the safe harbor standard, GTrans will translate vital documents such as the Route & Schedule Guide, the Title VI Report, the LEP Plan and public notices of changes to transit service into the languages listed above through Google Translate on the GTrans website. GTrans staff will utilize features such as Google Translate and multi-lingual staff from the City of Gardena (Spanish, Korean, Tagalog and Japanese speakers) to translate for eligible LEP language groups. GTrans will also proceed with oral interpretation options for compliance with LEP regulations.
The following training will be provided to GTrans staff:
Information will be distributed to all GTrans staff.
Monitoring and Updating the LEP Plan – GTrans will update the LEP as required by U.S. DOT. At a minimum, the plan will be reviewed and updated when data from the 2020 U.S. Census is available, or when it is clear that higher concentrations of LEP individuals are present in the GTrans service area. Updates will include the following: