Okaloosa County BOCC — March 4, 2014 — Title VI and Nondiscrimination Policy and Limited English Proficiency (LEP) Plan — reading text

County Commissioners interviewed the Okaloosa County Transit Program Manager, Operations Manager (supervisor to all field staff), and Administrative Assistant (supervisor to all administrative staff) regarding either their personal interactions with LEP Persons, or reports by their employees of daily interactions between LEPs and staff. The Administrative Assistant stated that she has worked with 2 LEPs in the last several years, one client was French who utilized her own resources to provide an interpreter and one client that spoke English, not very well, but enough to communicate. This client’s native language was Spanish. The Operations Manager acknowledged that during the summer, the local tourist area experiences an influx of foreign workers. These foreign workers use public transportation during their temporary stay in Okaloosa County. Their LEP does not emerge as a deterrent to accesses the public transit service available and many utilize the service with great ease. Okaloosa County also provides maps along with written information in their Ride Guide and OCT website. The maps can provide LEPs and individuals with limited reading capabilities where and when the routes operate (Fig. 1 and Fig. 2). Fig.1  Fig.2 Attendees of Okaloosa County Transit (OCT) affiliated community meetings and/or public hearings are requested to sign an attendance sheet. No attendees have displayed signs of LEP nor has any special accommodations been requested. OCT provides deviated fixed route service rather than ADA complementary paratransit service. Task 1, Step 2: Become familiar with the data from the U.S. Census Task 1, Step 2A: Identify the geographic boundaries of the area that your agency serves Okaloosa County provides demand response/paratransit door-to-door service to all of Okaloosa County. Fixed route service is provided in the most densely populated areas of Okaloosa County. Okaloosa County’s geography is divided by the largest Air Force Base in the world, Eglin AFB. Thus the service is divided in Northern and Southern regions with Eglin AFB in the center of the county. No fixed-route service is provided on Eglin AFB at this time. Task 1, Step 2B: Obtain Census data on the LEP population in your service area Okaloosa County, Florida Percent Subject Margin of Estimate Percent Margin of Error Error LANGUAGE SPOKEN AT HOME Population 5 years and over 171,333 +/-110 171,333 (X) English only 154,058 +/-951 89.90% +/-0.6 Language other than English 17,275 +/-953 10.10% +/-0.6 Speak English less than "very well" 6,078 +/-745 3.50% +/-0.4 Spanish 9,443 +/-598 5.50% +/-0.3 Speak English less than "very well" 3,013 +/-432 1.80% +/-0.3 Other Indo-European languages 3,694 +/-673 2.20% +/-0.4 Speak English less than "very well" 1,206 +/-373 0.70% +/-0.2 Asian and Pacific Islander 3,666 +/-451 2.10% +/-0.3 languages Speak English less than "very well" 1,672 +/-379 1.00% +/-0.2 Other languages 472 +/-196 0.30% +/-0.1 Speak English less than "very well" 187 +/-97 0.10% +/-0.1 Source: U.S. Census Bureau, 2008-2012 American Community Survey 2010 Census - Florida, Okaloosa County Population Total Population 180,822 Population by Ethnicity Hispanic or Latino 12,296 Non Hispanic or Latino 168,526 Population by Race White 146,582 African American 16,797 Asian 5,328 American Indian and Alaska Native 1,068 Native Hawaiian and Pacific Islander 354 Other 3,592 Identified by two or more 7,101 Source: Census.gov 2010 Census Data Task 1, Step 2C: Analyze the data you have collected Staff reviewed the 2010 U.S. Census Report and the U.S. Census Bureau 2008-2012 American Community Survey and determined that 17,275 persons in Okaloosa County (10 % of the population) speak a language other than English. In Okaloosa County, 6,078 persons have limited English proficiency; that is, they speak English “not well” or “not at all.” Of those persons with Limited English Proficiency, 3,013 speak Spanish, 1,206 speak one of the Indo-European languages, 1,672 speak one of the Asian and Pacific Island languages and 187 speak a language classified as other. Only the Spanish speaking LEP population reached the DOJ’s Safe Harbor Provision of 1,000 persons or 5%. Task 1, Step 2D: Identify any concentrations of LEP persons within your service area. The 2010 Census block group with the greatest concentration of LEPs is located on Eglin Air Force Base. This can be explained by the higher number of military spouses that are natives of the United States. OCT does not service Eglin Air Force Base at this time. The highest concentration area serviced is in the southern end of the county. This area, at most, has 8.5% recorded as LEPs. Task 1, Step 3: Consult state and local sources of data We consulted with the Okaloosa County School District which offers ESOL or “English for Speakers of Other Languages” programs. Total enrollment of all students in Okaloosa County in 2013-14 is 34,345. The predominant language spoken at home is English (96% of all students). 2.6% of the student population are enrolled in the ESOL program. There are 36 languages other than English reported as the predominant language spoken at home by ESOL students. Of the 2.6% ESOL students, the largest primary language reported is Spanish at 594 students or 1.9% of the total student population. Task 1, Step 4: Reach out to community organizations that serve LEP persons Task 1, Step 4A: Identify community organizations Northwest Florida State College (NWFSC) Workforce Development Board/Jobs Plus Task 1, Step 4B: Contact relevant community organizations Ms. Nancy Ordonia, Coordinator for the Adult Education Program for Northwest Florida State College was contacted Ms. Linda Sumblin, Executive Director of CareerSource Okaloosa Walton was contacted. Task 1, Step 4C: Obtain information Suggested that NWFSC utilize the OCT’s Ride Guide as part of the ESL (English as Second Language) curriculum. NWFSC, as part of their current instruction, provides lessons on public transit use. Our goal is to formulate a plan to work with NWFSC in partnership to provide classroom instruction on the local transit service. Ms. Linda Sumblin, Executive Director of CareerSource Okaloosa Walton was contacted. There is currently no demand for dual language services for clients. OCT and CareerSource (formerly JobsPlus) currently work in partnership to provide transportation to individuals who are unemployed and need transportation. There has never been a request for special accommodations from a CareerSource client. Factor 2: The Frequency with Which LEP Individuals Come into Contact with your programs, activities, and services Task 2, Step 1: Review the relevant programs, activities, and services you provide OCT provides demand response and fixed route transportation. Rarely do staff come in contact with LEP individuals, contact when made, will be made once to twice a year at which time staff is able to communicate with them by spending time and having patience to work with clients. We have not had to turn clients away due to language barriers. Should we come in contact with LEP individuals that staff cannot communicate with we will refer them to agency volunteers. If they speak an uncommon language a commercial telephonic interpretation service may be used. Task 2, Step 3: Consult directly with LEP persons The LEP persons that we are in contact with have not demonstrated a need for special accommodations. The LEPs that currently use the system are entirely self-sufficient and do not appear to have any problems with acquiring transit service. It is our goal to work with Northwest Florida State College’s ESL program to make contact with additional LEP persons regarding public transit in Okaloosa County. Factor 3: The Importance to LEP Persons of Your Program, Activities and Services Task 3, Step 1: Identify your agency’s most critical services Fixed Route service is the most critical service provided to persons with LEP. As stated earlier in this plan, Okaloosa County experiences an influx of Eastern European student workers during the summer season. These people live and work on the beach and they rely on fixed route service. We have interviewed several of them and their command of the English language is limited, but sufficient for them to be heavy users of public transportation. We do not see a need for special accommodations at this time. Task 3, Step 2: Review input from community organizations and LEP persons Over the years we have spoken with LEP persons that use our service. Though they are not native English speakers, their proficiency is enough to use public transportation in Okaloosa County. We have witnessed them at bus stops navigating the maps to determine how the system works independently. We do not see a need for special accommodations at this time. Factor 4: The Resources Available to the Recipient and Costs Task 4, Step 1: Inventory language assistance measures currently being provided, along with associated costs. Should the occasion arise that an interpreter is required agency volunteers will be utilized. There is no cost associated with this service Task 4, Step 2: Determine what, if any, additional services are needed to provide meaningful access Documents that are considered vital, such as the Title VI complaint form, notice of a person’s rights under Title VI, fare structure modifications and application forms will be printed in-house at minimal cost and made available to the LEP population. Okaloosa County BCC will also ensure the Title VI Coordinator and Chairman have reviewed the most up-to-date Title VI training available from the Federal Highway Administration and/or the Federal Transit Administration to ensure we are informed of our responsibilities. Task 4, Step 3: Analyze your budget Documents that are considered vital, such as the Title VI complaint form, notice of a person’s rights under Title VI, fare structure modifications and application forms will be printed in-house at minimal cost and made available to the LEP population. As additional funding currently is not