TriMet Language Implementation Plan
As part of its application for a cooperative agreement under the FTA’s Transportation Equity Research Program (TERP), the Tri-County Metropolitan Transit District of Oregon (TriMet) developed the attached plan in 2006. The plan’s contents are consistent with the guidance on an effective language implementation plan expressed in Section VII of the the U.S. Department of Transportation’s Policy Guidance Concerning Recipients' Responsibilities to Limited English Proficient (LEP) Persons [Federal Register: December 14, 2005 (Volume 70, Number 239)]. The attached plan directs a cross-section of departments within the transit agency to undertake language assistance activities including the following activities that are recommended in the DOT LEP Guidance on an implementation plan:
1. Identifying LEP individuals who need language assistance.
2. Providing language assistance measures.
3. Training staff
4. Providing notice to LEP persons of the availability of language assistance
5. Monitoring and updating the LEP plan.
TriMet’s plan also takes into account the DOT LEP Guidance on oral language services (interpretation) and written language services (translation).
FTA will publish deliverables pursuant to TriMet’s activities as they become available. For more information, contact Yvonne Lyon, Manager of Marketing Analysis with TriMet at 503-962-6430 or the Title VI Coordinator, FTA Office of Civil Rights, 202-366-4018.
The FTA Office of Civil Rights is seeking additional examples of language implementation plans and products that have been developed by transit agencies, metropolitan planning organizations, or state departments of transportation. If your agency is interested in sharing examples of projects that have been developed or will be developed pursuant to the DOT LEP Guidance, please contact the Title VI Coordinator with the FTA Office of Civil Rights at 202-366-4018.
Capital Projects & Facilities
ITEM NOW FY07 FY08 FY09
Assess the LEP population in areas affected by construction.
• Code businesses and residents who are LEP along the project in TriMet’s database.
• Develop an outreach plan targeting LEP residents and businesses in construction areas. X
Use of in-person interpreter services upon request for public meetings and important events (community relations staff will provide notification to the community about availability of interpretive services). X
Translate vital documents. X
Provide notice of right to language assistance, at no cost, on non-vital yet important outreach documents. X
Legal/Human Resources
ITEM NOW FY07 FY08 FY09
Develop/review contract language to ensure all contractors providing goods and services for TriMet are in compliance with Title VI regulations (Title VI of the Civil Rights Act of 1964, “Nondiscrimination under Programs Receiving Federal Financial Assistance through the U.S. Department of Transportation”). X
Determine which TriMet documents meet the definition of “vital documents”; stay aware of new documents that may be considered “vital”. X
Develop curriculum and train frontline and other key staff in:
• awareness of type of language services available
• how staff and/or LEP customers can obtain these services
• how to respond to LEP callers
• how to respond to correspondence from LEPs
• how to respond to LEPs in person
• how to document LEP needs
• how to respond to civil rights complaints. X
Incorporate LEP plan information into the new employee orientation, handbook and TriNet. X
Marketing & Customer Services
ITEM NOW FY07 FY08 FY09
Provide telephone interpretation for basic transit questions and trip planning assistance in virtually any language. X
Establish competency standards for interpreters and translators. X
Draft a TriMet policy that states that all interpretation and written translation must be performed by approved vendors/individuals whose competency has been established. X
Add a question to the O&D Survey to assess respondents’ English proficiency and primary spoken language. X
Develop a process for determining:
• if a particular document needs to be translated
• into which languages it should be translated. X
Establish an agency-wide workflow whereby all written translation requests are routed through and managed by Marketing to ensure consistency. X
Translate vital documents identified by TriMet’s Legal Department, including:
• signage that communicates hazardous pedestrian access in areas of high LEP concentration
• signage that indicates prohibited behavior in areas of high LEP concentration X
Place a notice of right to language assistance, at no cost, on important outreach documents and on TriMet’s website. X
Develop formal procedures for documenting the number of requests by LEPs for ticket/pass purchases at CAO and from LIFT personnel; investigate whether it is possible to track TVM transactions that are completed in Spanish. X
Provide information in multiple languages about TriMet’s complaint process X
Create sign in multiple languages informing LEP clients about available language services at post at TTO. X
Identify routes serving areas with high concentrations of LEP individuals. X
Identify service disruptions in areas with high concentrations of LEP individuals and translate appropriate signage. X
Create protocol for responding to foreign language correspondence and communication. X
Day-to-day administration of LEP program, ensuring compliance and correct implementation. X
Operations
ITEM NOW FY07 FY08 FY09
Provide training to operators, fare inspectors and other frontline employees in LEP policies and procedures (see Legal/Human Resources section for details). X
Coordinate training with TriMet’s Human Resources and Diversity & Transit Equity departments. X
Diversity & Transit Equity
ITEM NOW FY07 FY08 FY09
Identify areas within the service district that have high concentrations of LEP individuals. X
Conduct an evaluation of TriMet’s LEP plan to gauge its effectiveness and determine if updates are needed every two years. Transit Equity staff will lead the evaluation with the help of staff familiar with Title VI language access requirements and the LEP plan. The evaluation will:
• determine the number of LEP individuals in TriMet’s service district
• assess whether existing language assistance services are meeting the needs of clients with LEP
• assess whether staff members understand TriMet’s LEP policies and procedures, how to carry them out, and whether language assistance resources and arrangements for those resources are still current and accessible
• seek feedback from LEP communities, including customers and community organizations, about the effectiveness of TriMet’s LEP plan
X
Additional Services
ITEM NOW FY07 FY08 FY09
Provide key transit information and online Trip Planner in Spanish on TriMet’s website. X
Provide Transit Tracker by Phone information in Spanish via 238-RIDE. X
Record MAX announcements in both Spanish and English. X
Place foreign-language ads in publications serving second language populations to demonstrate TriMet’s commitment to full information; to share current significant, service-related announcements; to increase comfort levels regarding access to information in a native language. X
Provide Spanish-language interface for TVM transactions. X
Provide one-on-one and group travel training to LEPs by working through an interpreter. X
Establish partnerships and work closely with community organizations that serve LEP populations. X
Design new pictograms with community input to replace text in signage when possible X
Offer Spanish classes through TriMet U for key personnel. X
Identify service changes affecting areas with high concentrations of LEP individuals and develop mitigation strategies. X
Create one-stop LEP info center for agency. X
Survey TriMet staff to determine existing bilingual resources. X
Develop standards to certify TriMet staff as qualified translators and/or interpreters. X
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