Appendix D
LEP Survey of Regional Transit Authority Employees
Appendix D
Communication with Limited English Proficient (LEP) Individuals:
MassDOT Survey of RTAs That Are Subrecipients of FTA Funds
Survey of: FRANKLIN REGIONAL TRANSIT AUTHORITY
Under Title VI, MassDOT, as a recipient of financial assistance from the Federal Transit Administration (FTA), is required to
“take responsible steps to ensure meaningful access to the benefits, services, information, and other important portions of
[its] programs and activities for individuals who are Limited English Proficient (LEP).” To do so, MassDOT must ensure that
written and oral translations of several types of communications are provided for LEP individuals (that is, people who do
not speak English well or at all). The determination of which written or spoken communications must be translated and the
languages into which they must be translated is based on a four-factor analysis that considers the:
• Number or proportion of the persons eligible to be served by or likely to encounter a program, activity, or service
who are LEP
• Frequency with which LEP individuals come into contact with the program, activity, or service
• Nature and importance of the program, activity, or service in people’s lives
• Resources available to the service provider and the costs of providing translations
In a recent Compliance Review of MassDOT’s Title VI program under FTA Circular 4702.1A, deficiencies were found regarding
MassDOT’s compliance with the LEP requirements. MassDOT must, therefore, complete the following corrective actions:
• Conduct a four-factor analysis of MassDOT
• Conduct a four-factor analysis of MassDOT subrecipients
• Develop Language Assistance Plans for MassDOT and its subrecipients that meet the Title VI requirements to
provide meaningful access to LEP persons
The MassDOT Office of Civil Rights requests that FRTA, as one of MassDOT’s subrecipients, answer the following
questions to assist in the completion of the subrecipient four-factor analysis:
1. Approximately how many employees who work for your RTA have direct contact with the public in some
capacity? Please specify how many of these employees are bus operators.
2. What are the job titles and/or functions of the employees from question #1 who are not bus operators?
3. What vital documents does your agency have that may need to be translated into other languages? When
making this inventory of vital documents, please consider the following:
USDOT guidance states that a document should be considered vital if it contains information that is critical for
obtaining services and/or benefits, or if it is required by law. Vital documents include (but are not limited to), for
example, notices of rights, notices advising LEP persons of the availability of free language assistance, letters or
notices that require a response from the beneficiary or client, and consent and complaint forms. For instance, if a
complaint form is necessary in order to file a claim with an agency, that complaint form would be vital. Non-vital
documents are those that are not critical to access benefits or services.
It may sometimes be difficult to draw a distinction between vital and non-vital documents, particularly when
considering outreach documents and other documents designed to raise awareness of rights or services. It should
be noted, however, that in some circumstances lack of awareness of the existence of a particular program may
effectively deny LEP individuals meaningful access: for example, lack of awareness of the availability of language
interpretation services at public meetings. In such cases, the outreach materials would be considered vital.
Please return your completed survey to Elizabeth Moore (emoore@ctps.org) at the Central Transportation Planning Staff. CTPS
will compile and analyze the results from all of the returned RTA subrecipient surveys. If you have any questions regarding this
Jan. 2012
survey, please contact Elizabeth at 617-973-8495. THANK YOU.
Appendix D
SURVEY OF FRANKLIN REGIONAL TRANSIT AUTHORITY BUS OPERATORS
Interacting with Customers Who Cannot Speak English Well
The purpose of this survey is to gain information from bus operators about their interactions with
customers who cannot speak English well or at all. The results of the survey will help FRTA determine the
needs of its passengers who have limited English proficiency.
Please answer the four questions below and return the form to:
Survey Questions
1) Please indicate how often you come into contact with customers who cannot speak English
well. For summer, place an “x” in one of the boxes in that row, and for the other seasons,
place an “x” in one of the boxes in that row.
Most Days
At Least
Once/ Week
At Least
Once/ Month
At Least
Once/ Year
Never
2) How do you communicate with a customer who cannot speak English well?
3) In what ways could FRTA help you and other staff to communicate better with customers who
cannot speak English well?
4) If you can recognize any of the languages spoken by customers who cannot speak English well,
please list the languages you hear most often.
Appendix D
Summary of the FRTA and VTA Responses to RTA Bus Operator Survey, Questions 4 and 5
How do you communicate when you come into contact with members of the public who do
not speak English well or at all?
0
2
4
6
8
10
12
14
Use gestures
I try my best
I speak more slowly/more clearly
Use a map
I speak their language
No response
Repeat sentences
Simplify sentences
Ask someone else on the bus
Not a problem
Have client/public ask a friend/family member
Has not come up
In what ways could the RTA help you and other staff to communicate better with customers
who cannot speak English well?
0
No response
Provide signage in other languages
Translate schedules/maps
Offer language courses for employees
Provide employees with translated material
I have no recommendations
Provide staff with electronic translators
It's not a problem
Ask clients/public to learn English
Provide employees with interpreters
"I speak" cards
Use automated website translation
Provide symbol signs
1
2
3
4
5
6
7
8
9