Limited English Proficiency Plan

 

The Centre County Metropolitan Planning Organization (CCMPO) is responsible for transportation planning and programming in Centre County, Pennsylvania.  The Centre Regional Planning Agency (CRPA) and the Centre County Planning and Community Development Office (CCPCDO) provide staff support to the CCMPO.  As a recipient of federal funding, the MPO must take reasonable steps to ensure meaningful access to the information and services it provides.

 

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 the benefits of, or be otherwise subjected to discrimination under any program or activity that receives federal financial assistance.

 

Executive Order 13166 “Improving Access to Service for Persons with Limited English Proficiency,” signed into law on August 11, 2000, further clarified Title VI of the Civil Rights Act of 1964 to improve access to federally conducted and federally assisted programs and activities for persons who, as a result of national origin, are limited in their English proficiency.

 

The executive order requires each federal agency to examine the services it provides and to develop and implement a system by which Limited English Proficiency (LEP) persons can meaningfully access those services.  Each federal agency is required to work to ensure that recipients of federal financial assistance also provide meaningful access to their services.  The order states that,

 

 

As a condition of receiving federal financial assistance, recipients are required to comply with Title VI and LEP guidelines of the federal agency from which funds are provided.  The U.S. Department of Transportation (DOT) published “Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient Person” in the December 14, 2005, Federal Register.  This document indicates that organizations receiving DOT funds are required to follow this guidance as well:

 

The purpose of this Limited English Proficiency (LEP) Plan is to develop procedures to ensure meaningful access for LEP persons to information and services provided by the CCMPO.  The plan includes a needs assessment, identifies individuals who may need language assistance, identifies available resources, and outlines language assistance measures.

 

Individuals who do not speak English as their primary language and who have a limited ability to read, write, speak, or understand English are Limited English Proficient (LEP), and therefore, are entitled to language assistance under Title VI of the Civil Rights Act of 1964 with respect to a particular type of service, benefit, or encounter.

 

For the purposes of this plan, a LEP person is defined as any individual who speaks a language at home other than English as his or her primary language, and who speaks or understands English “less than very well.”

 

Section V of the U.S. DOT “Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient Person” outlines a four-factor analysis for agencies to use in determining a cost-effective mix of language assistance measures and targeting resources appropriately.  The guidance allows local agencies the flexibility to perform their own assessment of the factors and determine reasonable means to accommodate LEP individuals.  The following is a LEP needs assessment for the CCMPO in relation to the transportation planning process.

 

 

 

Table 1:  Number of LEP persons in Centre County for the population 5 years and older

	Number of Individuals	% of Total Population
Total population 5 years and older	155,581	100.00%
Speak only English	136,719	87.88%
Speak a language other than English and understand English "very well"	13,071	8.40%
Speak a language other than English and understand English "less than very well"	5,791	3.72%

According to ACS estimates, most of the population in Centre County is proficient in English.  As shown in Table 1 above, only 3.72% of the total county population (5,791 individuals) understand English “less than very well” and would therefore be identified as LEP individuals. 

 

Table 2:  Language spoken at home in Centre County for the population 5 years and older

	Number of Individuals	% of Total Population
Total population 5 years and older	155,584	100.00%
Speak only English	136,719	87.88%
Speak Chinese	4,420	2.84%
Speak Spanish	3,178	2.04%
Speak Yiddish, Pennsylvania Dutch, or other West Germanic languages	2,144	1.38%
Speak Korean	1,245	0.80%
Speak Russian	813	0.52%

Table 2 above shows the languages most commonly spoken at home by the Centre County population, according to 2015-19 ACS data. Within Centre County, other than English, Chinese is the most prevalent language spoken at home, followed by Spanish; Yiddish, Pennsylvania Dutch, and other West Germanic languages; Korean; and Russian.

 

Table 3:  Language spoken at home by LEP persons in Centre County for the population 5 years and older

	Number of Individuals	% of Total Population
Total population 5 years and older	155,581	100.00%
Speak only English	136,719	87.88%
Speak Chinese and understand English "less than very well"	2,231	1.43%
Speak Spanish and understand English "less than very well"	636	0.41%
Speak Yiddish, Pennsylvania Dutch, or other West Germanic languages and understand English "less than very well"	507	0.33%
Speak Korean and understand English "less than very well"	425	0.27%
Speak Russian and understand English "less than very well"	333	0.21%

Table 3 above shows the languages most commonly spoken at home by LEP individuals (those who understand English “less than very well”) for the Centre County population, according to 2015-19 ACS data. Among LEP individuals in Centre County, the most commonly spoken language is Chinese, followed again by Spanish; Yiddish, Pennsylvania Dutch, and other West Germanic languages; Korean; and Russian.

This analysis shows that at the Centre County level, the only LEP group exceeding Safe Harbor Provisions (5% of the total population, or 1,000 individuals, whichever is less) are those individuals who speak Chinese.  Within Centre County, there are 2,231 individuals (1.43% of the total population) who speak Chinese within the home and understand English “less than very well”.

A subsequent analysis of LEP individuals by census tract within Centre County suggests that proportions of individuals who speak Chinese within the home and understand English “less than very well” greater than the countywide average of 1.43% of the total population are located in the following areas:

• Census Tract 115.02 (Ferguson Northwest) – 8.23% of total population
• Census Tract 128 (State College Southwest – Greentree) – 7.81% of total population
• Census Tract 114 (Patton East) – 3.52% of total population
• Census Tract 115.01 (Ferguson Northeast) – 2.90% of total population
• Census Tract 121 (University Park East) – 2.64% of total population
• Census Tract 122 (University Park West) – 1.78% of total population
• Census Tract 113 (Patton West) – 1.77% of total population
• Census Tract 124 (State College Urban Village – Holmes Foster) – 1.69% of total population
• Census Tract 123 (State College – College Heights) – 1.44% of total population

Based upon the above analysis, the most significant proportions of individuals who speak Chinese within the home and understand English “less than very well” reside on the main campus of Penn State University, and in portions of surrounding State College Borough, Ferguson Township, and Patton Township.

LEP individuals interact with the CCMPO in five primary ways: The CCMPO website, written materials and documents, telephone contact, public meetings, and other in-person encounters.  Based on historical experience, such interactions are limited in both number and scope.

Further, LEP individuals are not believed to be underserved by the CCMPO based upon language barriers. Historical and current levels of communication with these individuals are proportionate to the public as a whole, as are impacts resulting from transportation projects on the current TIP and LRTP. Nevertheless, this document specifies actions to improve interactions with LEP individuals, including further data collection and analysis, pre-emptive translation of certain documents, and additional outreach – including on a project-specific basis.

For example, it is recognized that “Chinese” does not merely represent one language, but a language group. Though ACS data does not provide information specific to Chinese dialects, going forward, the CCMPO will utilize information collected regarding requests for language accommodation and work closely with other regional stakeholders – such as the Centre Area Transportation Authority (CATA), Penn State University, and other local Chinese organizations such as churches and student organizations – to more appropriately tailor necessary language assistance efforts according to dialect (Mandarin, Cantonese, etc.).

 

 

LEP individuals could potentially encounter CCMPO services – at a very minimum, on an indirect basis – as the agency’s transportation planning process results in discussions, decisions, and policy actions that affect all Centre County users of road, bridge, transit, bicycle, and pedestrian networks. Such individuals could also encounter CCMPO services on a project-specific basis, as improvements are planned, programmed, constructed, and/or implemented near a residence or place of work.

As with the broader public, interests with respect to language assistance for LEP individuals would chiefly involve in-person, web-based, and printed information. Moreover, the CCMPO would likely be expected to meet such needs through the translation and distribution of pieces of information such as required transportation planning documents; public meeting notices; surveys; solicitations; and meeting agendas, minutes, and other materials in both print and electronic form.

It should also be noted that CCMPO discussion, decisions, and policy actions impact transportation projects for which the lead agency may be an external entity such as PennDOT or CATA. Accordingly, strong partnerships that exists between the CCMPO and outside entities can help to enhance both the extent and the effectiveness of outreach to LEP individuals.  Both above-referenced entities have representation on the CCMPO Technical and Coordinating Committees.

To date, no direct requests have been made to CCMPO staff by individuals or groups seeking language assistance in the form of interpretation or the translation of written documents into other languages. This, however, does not suggest that all potential needs are being met, or that needs are not being met indirectly; nor does it absolve the CCMPO of its responsibility to fill requests for language assistance that are required by law and regulation, or otherwise appropriate and reasonable.  These requests may come from system users, those in the professional or academic realm, or any interested member of the public.

The most frequent interaction between CATA and local LEP populations is believed to be through printed and electronic service information for which translations are available either directly and/or through Google Translate, as appropriate. CATA and the CCMPO consistently promote important messages on the other agency’s behalf, and this is a partnership that could be further strengthened to mutual benefit.

In a similar manner, a cooperative relationship with Penn State University provides the potential for further outreach via a wide range of campus-based equity and diversity groups and other resources.

As part of the adopted PPP – as well as the PPP to be adopted in fall 2022 – the solicitation of public input for transportation projects on the Centre County Transportation Improvement Program (TIP) and Long Range Transportation Plan (LRTP) includes written correspondence to human service agencies and organizations that may work with LEP populations, and representatives of these agencies and organizations are encouraged to provide questions, comments, and recommendations.

The CCMPO is committed to gathering further information with respect to how its programs could even better involve local LEP populations on their own, and in partnership with the aforementioned community and campus organizations.  The first step in this effort will involve identification of appropriate organizations, establishing contact(s) within each, and surveying to develop a better sense of need for language assistance, as well as type of assistance.

 

 

Moreover, Centre County’s transportation systems provide access to employment, medical offices, schools, grocery stores, and other retail shopping locations, as well as other locations that meet personal needs. 

As such, the CCMPO’s programs, activities, and services are highly important to Centre County and its people. This includes LEP individuals.

The transient nature of Centre County’s significant University-related population suggests an even higher level of importance, as population turnover steadily brings new users of transportation networks into the community – although this suggests outreach challenges as well.

The nature of impacts across all segments of the Centre County population make clear that the CCMPO must ensure that each of these segments – including LEP individuals – can participate in the full scope of the transportation planning process and related activities. 

In many cases, public transit may be the only transportation option available to individuals, including LEP individuals.  CATA is represented on the CCMPO Technical and Coordinating Committees, and – as described in the preceding section – both entities cooperate with respect to promotion and outreach activities.  Moreover, staff from both agencies cooperatively lead efforts to develop a coordinated plan for human service transportation within Centre County. This plan has guided the allocation of Jobs Access and Reverse Commute (JARC) and New Freedom funding in previous years.

The CCMPO also utilizes its adopted PPP to facilitate the participation of LEP individuals in the transportation planning process.

Based on our evaluation of translated information currently available and provided, further action as outlined in the subsequent language assistance plan, location and size of LEP populations exceeding the Safe Harbor threshold, the transient nature of these populations, relative location of currently planned and programmed transportation projects, and the scarcity of requests for CCMPO language assistance, we believe that meaningful access and opportunity is being provided to LEP populations.  As discussed elsewhere in this document, we intend to verify this finding through outreach to appropriate groups representing the Chinese-speaking population.

Given the importance of its programs, activities, and services, the CCMPO is committed to taking all required, appropriate, and reasonable steps to further provide meaningful access to transportation programs and activities, and make every effort to further involve interested parties in the transportation planning process.

 

 

The agency has access to services provided through the Pennsylvania State University, specifically through university offices designed for such, advisors of appropriate student organizations, professors willing to perform community service, and students who need such opportunities for class projects; better coordination with these other community stakeholders will be critical to providing a higher level of outreach going forward.  Moreover, the CCMPO is able to access to paid translation services, community organizations, and individual community volunteers who can provide similar services as appropriate.  Further, free internet-based translation services, such as Google Translate, are available to the CCMPO to utilize.  Last, PennDOT has provided native language taglines for use in CCMPO documents; however, the CCMPO has elected to utilize the Notice of Language Assistance Services contained in Appendix G, as it is more uniquely tailored to our service area. 

None of these available interpretation or translation services – when balanced against frequency and importance of need – are known or perceived to create any kind of undue financial burden for the CCMPO.

The CCMPO does not currently have contracts for over-the-phone or in-person translation services, given the scarcity of requests for CCMPO language assistance.  We will consider this solution going forward, should the need present itself and should it be cost-effective when measured against other solutions.

Moreover, the CCMPO does not currently have a specific budget line item for LEP or other accommodations required by Title VI and other non-discrimination policies.  Any such activities are provided for by the MPO meeting budget, or project-specific budgets.  As the CCMPO further advances its Title VI program and related accommodations, and receives more requests for assistance to which it must respond, we believe we will accrue better time- and project-based data upon which to base such a budget line item.

While LEP individuals exceeding Safe Harbor Provisions currently account for a relatively small percentage of the Centre County population, the CCMPO will monitor resident population profiles and trends for increases in the LEP population and periodically reevaluate the available resources and the translation services it chooses to provide.

 

• Description of the vital documents that are translated into the language(s) of frequently encountered LEP groups, consistent with the Safe Harbor Provision: The CCMPO’s Four Factor Analysis shows that the only LEP population in Centre County that exceeds the Safe Harbor Provision threshold is the Chinese-speaking population.  The CCMPO has identified the following documents as vital written materials subject to translation into Chinese on demand:
• Unified Planning Work Program (UPWP)
• Long Range Transportation Plan (LRTP)
• Transportation Improvement Program (TIP)
• Technical and Coordinating Committee Meeting Agendas and Minutes
• Public Meeting Notices
• Title VI Program
• Title VI / Non-Discrimination Statement of Policy and Notice to the Public
• Title VI / Non-Discrimination Complaint Procedures
• Title VI / Non-Discrimination Complaint Form
• Notice of Language Assistance Services
• Description of how the recipient provides language assistance services by language:  The CCMPO’s current and planned efforts – which respond to the findings of the Four Factor Analysis – are comprised of actions to make information resources available in Chinese and other languages prevalent in Centre County, and include the following:
• All vital documents, as defined by the CCMPO in subsection (a) of the Language Assistance Plan, are made available in Chinese on demand.  These documents can be translated by the interested party using the Google Translate or Microsoft Word translation function of the CCMPO website, or will be made available to the interested party directly by CCMPO staff;

• Going forward, the CCMPO will utilize information collected regarding requests for language accommodation and work closely with other regional stakeholders – such as the Centre Area Transportation Authority (CATA) and Penn State University – to more appropriately tailor necessary language assistance efforts to relevant populations according to dialect (Mandarin, Cantonese, etc.);

• The Google Translate and Microsoft Word functionality of the CCMPO website makes information available in Chinese or a number of other languages; CCMPO staff will ensure that all web-based materials are in translatable format to make use of this functionality;

• In requests for language assistance where more personalized responses are necessary and appropriate – such as requests for documents not defined as vital by the CCMPO (meeting presentation materials, etc.) or requests for oral translation – accommodations can be made in Chinese if requested with at least five business days’ notice; and

• The CCMPO commits to required, appropriate, and reasonable targeting of concentrated LEP individuals to disseminate information on localized projects.
• Description of how the recipient provides notice to LEP individuals about the availability of language assistance: The CCMPO shall provide notice to LEP individuals and populations that language services are available at no cost to the requester using the following methods:

• A notice of available language assistance services for LEP individuals can be found on the CCMPO website in the “Notice of Language Assistance” section (https://www.crcog.net/index.asp?SEC=D4352CB9-0D18-4CBD-97D0-AF3CC006148E&DE=0246461A-07D7-4732-B33C-5E8414CC57B5) and is posted at the primary physical business location of the CCMPO (2643 Gateway Drive, Suite 4, State College, PA  16801).  The full text of the notice is also included as Appendix G.  All such notices are posted in English, Simplified Chinese, Spanish, Russian, and Korean;

• The CCMPO also utilizes this translated notice of available language assistance in its vital documents, as well as other documents as appropriate;

• CCMPO staff works cooperatively with PennDOT, CATA, Penn State University, community‐based organizations, and other stakeholders during development of the TIP, LRTP, and otherwise within the guidelines of the adopted PPP to inform LEP individuals of CCMPO programs and the availability of language assistance; and

• CCMPO staff will identify concentrations of LEP populations using US Census and ACS data, work with the aforementioned community-based organizations, identification of the frequency and type of encounters between LEP individuals and staff, and its log of requests for translated information.  We will further identify and implement targeted outreach for specific projects where required, appropriate, or reasonable to do so.
• Description of how the recipient monitors, evaluates, and updates the Language Assistance Plan:  The CCMPO’s Four Factor Analysis shows that the only LEP population in Centre County that exceeds the Safe Harbor Provision threshold is the Chinese-speaking population. The subsection of the Language Assistance Plan above addresses how written, electronic, and spoken information will be made available in Chinese.

The CCMPO will monitor language data for Centre County, and analyze any major changes in the number, proportion, or type of LEP individuals when updated 5-year ACS data or decennial census data becomes available.  The CCMPO will also monitor the frequency of encounters between LEP individuals and staff, as well as translated documents requested and provided.

If significant changes are noted in the concentration or type of LEP individuals, or if there is a significant increase in encounters with LEP individuals, an update to the language assistance plan will be conducted. If no significant changes are noted, the language assistance plan will be updated in conjunction with the next major update of the CCMPO’s larger Title VI Program.

• Description of how the recipient trains employees to provide timely and reasonable language assistance to LEP populations:  The CCMPO has a small staff, so training is largely informal.  All staff members assist with operations and customer service functions, so all are provided a copy of the language assistance plan, and informed of the interpretation and translation services offered to LEP individuals.  All staff members likewise have a familiarity with the CCMPO’s vital documents, as well as with Google Translate and the translate function of Microsoft Word.

When requests for language assistance are made of staff members, those staff members work with the CCMPO Principal Transportation Planner / Compliance Officer to accommodate the request.

As more information is collected regarding requests for language assistance, additional training can be identified and carried out, as appropriate.

• Minority representation on planning and advisory bodies: This section is not currently applicable to the CCMPO.  The CCMPO currently has no planning boards, advisory councils, or committees, the membership of which is selected by the CCMPO.  Should this change in the future, the CCMPO fully commits to non-discrimination, and will provide the required information.
• Providing assistance to sub-recipients: This section is not currently applicable to the CCMPO.  The CCMPO does not currently pass any federal funding assistance through to sub-recipients.  Should this change in the future, the CCMPO fully commits to providing all required assistance.
• Monitoring sub-recipients: This section is not currently applicable to the CCMPO.  The CCMPO does not currently pass any federal funding assistance through to sub-recipients. Should this change in the future, the CCMPO fully commits to conducting all required monitoring to ensure compliance of the sub-recipient with Title VI requirements, and therefore its own compliance with Title VI requirements.
• Determination of site or location of facilities: This section is not currently applicable to the CCMPO. The CCMPO is not currently, nor has it been recently,  involved in determining the site or location of facilities, land acquisition, or the displacement of persons from their residences and businesses. Should this change in the future, the CCMPO fully commits to non-discrimination on the basis of protected class, and will provide the required information.
• Determining the site or location of facilities, land acquisition, or the displacement of persons from their residences and business as part of projects for which funds are allocated by the CCMPO – but undertaken by an outside lead agency – are discussed in subsequent sections of this document.
• Requirement to provide additional information upon request: As it has in the past, the CCMPO fully commits to providing any additional information requested by federal, state, or local authorities to further assess its compliance with Title VI and other non-discrimination requirements.

NOTICE OF LANGUAGE ASSISTANCE SERVICES

Appendix G

The Centre County Metropolitan Planning Organization (CCMPO) provides language assistance services to individuals of limited English proficiency at no cost to the requester. 

Documents, notices, surveys, agendas, minutes, and other information can be translated directly using the Google Translate function of our website, or written materials will be made available by CCMPO staff via the same method at the primary physical business location of the CCMPO (2643 Gateway Drive, Suite 4, State College, PA  16801).

In requests for language assistance where more personalized responses are necessary and appropriate – such as requests for documents not defined as vital by the CCMPO (meeting presentation materials, etc.) or requests for oral translation – accommodations can be made in Chinese if requested with at least five business days’ notice.

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中心县大都会规划组织（CCMPO）为英语水平有限的个人提供语言援助服务，免费向请求者收取费用。

文件，通知，调查，议程，会议记录和其他信息可以使用我们网站的Google翻译功能直接翻译，或者 CCMPO 工作人员将通过相同的方法在 CCMPO 的主要实体业务地点（2643 Gateway Drive Suite 4, State College PA 16801）提供书面材料。

在语言协助请求中，如果更个性化的回答是必要的和适当的 - 例如要求 CCMPO 未定义为重要的文件（会议演示材料等）或口头翻译请求 - 如果要求至少提前五个工作日通知，可以用中文进行住宿。

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La Organización de Planificación Metropolitana del Condado Central (CCMPO, por sus siglas en inglés) brinda servicios de asistencia lingüística a personas con dominio limitado del inglés sin costo alguno para el solicitante.

Los documentos, avisos, encuestas, agendas, actas y otra información se pueden traducir directamente usando la función Google Translate de nuestro sitio web, o el personal de CCMPO pondrá a disposición los materiales escritos a través del mismo método en la ubicación comercial física principal de CCMPO ( 2643 Gateway Drive, Suite 4, State College, PA 16801).

En las solicitudes de asistencia lingüística en las que se necesiten y correspondan respuestas más personalizadas, como solicitudes de documentos no definidos como vitales por el CCMPO (materiales de presentación de reuniones, etc.) o solicitudes de traducción oral, se pueden hacer adaptaciones en chino si se solicitan con al menos aviso mínimo de cinco días hábiles.

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Организация городского планирования округа Центр (CCMPO) бесплатно предоставляет услуги языковой помощи лицам с ограниченным знанием английского языка.

Документы, уведомления, опросы, повестки дня, протоколы и другая информация могут быть переведены непосредственно с помощью функции Google Translate на нашем веб-сайте, или письменные материалы будут доступны сотрудникам CCMPO тем же способом в основном физическом офисе CCMPO ( 2643 Gateway Drive, Suite 4, State College, PA 16801).

В запросах на языковую помощь, когда необходимы и уместны более персонализированные ответы, например, запросы на документы, которые не определены CCMPO как жизненно важные (материалы для презентаций на собрании и т. д.), или запросы на устный перевод, можно сделать согласование на китайском языке, если это необходимо по адресу: уведомление не менее чем за пять рабочих дней.

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 Centre County Metropolitan Planning Organization(CCMPO)은요청자에게무료로영어구사능력이부족한개인에게언어지원서비스를제공합니다.

문서, 공지, 설문조사, 의제, 회의록및기타정보는당사웹사이트의 Google 번역기능을사용하여직접번역할수있습니다. 또는서면자료는 CCMPO의주요물리적비즈니스위치에서동일한방법을통해 CCMPO 직원이제공합니다( 2643 Gateway Drive, Suite 4, State College, PA 16801).

CCMPO에서중요하다고정의하지않은문서(회의프레젠테이션자료등) 또는구두번역요청과같이보다개인화된응답이필요하고적절한언어지원요청에서최소 5 영업일통지.