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01-14-2026 Council Packet
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01-14-2026 Council Packet
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Safe Harbor Provision (Written Documents) <br /> <br />U.S. DOT LEP Guidance provides a “safe harbor” to help ensure greater clarity regarding <br />whether City of Little Canada is meeting its obligation to provide written translations. These safe <br />harbor provisions only apply to the translation of written documents and do not affect the <br />requirement to provide meaningful access to LEP individuals through competent oral <br />interpreters where oral language assistance services are needed and reasonable. <br /> <br />The following actions are considered strong evidence of compliance with the Department’s <br />written-translation obligations: <br /> <br />(a) Providing written translations of vital documents for each eligible LEP language group that <br />constitutes 5% or 1,000 people of the population of individuals eligible to be served or likely to <br />be affected or encountered. Translation of non-vital documents, if needed, can be provided <br />orally; or <br /> <br />(b) If there are fewer than 50 individuals in a language group that reaches the 5% trigger in (a), <br />the vital written materials are not translated, but written notice of the right to receive free, <br />competent oral interpretation of those vital written materials in the primary language of the LEP <br />language group of is provided. <br /> <br />The above findings from the graphs on the preceding pages did not indicate any LEP <br />language groups meet the safe harbor threshold. Therefore, City of Little Canada will not <br />proactively translate written documents at this time. However, efforts will be made to reasonably <br />accommodate any language access requests that arise. <br /> <br />FACTOR #2: THE FREQUENCY WITH WHICH LEP INDIVIDUALS COME IN CONTACT <br />WITH THE PROGRAM, ACTIVITY, OR SERVICE <br /> <br />City of Little Canada should assess, as accurately as possible, the frequency with which they <br />have or should have contact with LEP individuals from different language groups seeking <br />assistance. If LEP individuals access a program or service on a regular, consistent basis, then <br />that program or service provider has greater language access duties than a program or service <br />whose contact with LEP individuals is unpredictable or infrequent. <br /> <br />However, even if there are infrequent or unpredictable interactions with LEP individuals, City of <br />Little Canada must be prepared to provide language assistance services to LEP individuals. <br /> <br />In applying this factor City of Little Canada should also consider whether outreach to LEP <br />individuals could increase the frequency of contact with LEP language groups and remain <br />mindful of the data analysis conducted under Factor #1 to identify the proportion of LEP <br />population present in the service area. <br /> <br />LEP persons may interact in several ways with City of Little Canada, including but not limited to:
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