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language services are needed and are reasonable. When appropriate, translation of any document will be <br /> communicated orally in the appropriate language. <br /> In the event that the 5% trigger is reached for a LEP language group that is fewer than 50 persons, written <br /> notice will be provided in the primary language of that group of the right to receive competent oral <br /> interpretation of vital written materials, free of cost. The most effective method of notice, which could be an <br /> ad in the local newspaper or other publication, a radio commercial, or door hangers, will be determined in <br /> consideration of the circumstances on the ground and in coordination with LEP community contacts. <br /> • Agency staff (including call center staff) will be provided a list of referral resources that can assist LEP <br /> persons with written translation and oral interpretation, including the Title VI Officer and any outside <br /> consultant contracted to provide language services. This list will be updated as needed to remain current. <br /> • All main offices and vehicles will have on hand a supply of language assistance flashcards and materials <br /> translated into the languages of the largest LEP language groups. When encountered by an LEP person, staff <br /> (including drivers) should present the individual with an iSpeak flashcard and let them choose the language. <br /> Do not assume you know their preferred language. Drivers are permitted to seek volunteer assistance from <br /> other passengers before contacting a referral resource. Document the encounter and report it to the Title VI <br /> Coordinator. <br /> • Training: All employees will be instructed on our procedures for providing timely and reasonable <br /> assistance to LEP persons. New employee orientation will also explain these procedures to new hires. Staff <br /> routinely encountering LEP persons by telephone or in person will receive annual refresher training. All other <br /> employees will be reminded of LEP through annual Title VI program acknowledgements (Section 5.0) and basic <br /> Title VI trainings (Section 11.0). <br /> A project-specific four factor analysis will be conducted for any project or outreach event limited to a specific <br /> geographical area (i.e., the project study area or outreach area, respectively). Language assistance will be <br /> provided in accordance with the measures already outlined, including translating written materials for each <br /> LEP language group that is 5% or 1,000, whichever is less, of the project or outreach area population. <br /> monitoring anci Updating the LAB' <br /> Monitoring of daily interactions with LEP persons will be continuous, thus language assistance techniques may <br /> be refined at any time. This Plan will be periodically reviewed—at least annually—to determine if our <br /> assistance measures and staff training are working. Resource availability and feedback from agency staff and <br /> the general public will be factors in the evaluation and any proposed updates. Among other practices, this <br /> process will include working with LEP community contacts to determine if our employees are responding <br /> appropriately to requests made with limited English or in languages other than English, and observing how <br /> agency staff responds to requests, including observing drivers or surveying riders. To the best of our ability, we <br /> will attempt to never eliminate a successful existing LEP service. Significant LEP program revisions will be <br /> approved or adopted by our board or designated official and dated accordingly. LEP data and procedures will <br /> be reviewed and updated at least once every three years. <br />