Language Access Plan City of Camilla, Georgia Community Improvement Department November 2022 ADOPTED: NOVEMBER 14 a0a3 30 East Broad Street P.O. BOX328 Camilla, GA31730 (229)336-2220 1 Table of Contents .General Information. .Page 3 Page 5 .Page 7 Page 8 Page 8 Page 9 Page 9 Page 9 Page 9 Page 10 II. Meaningful Access: Four Factor Analysis III. Language Assistance. IV. Staff Training. V. Translation of Documents. VI. Monitoring and Updating the LAP Plan... VII. Dissemination of the City of Camilla's LAP Plan... VIII. Records. IX. Complaints/Findings X. Available Federal LEP Resources. 2 LANGUAGE ACCESS PLAN LGENERALINFORMATION Prepared By: Phillip L. Davis Associates In Local Government Assistance, Inc. P.O. Box 2025 1007 West 12th Street Alma, GA 31510 (912)632-7839 gainc@arcessatc.net List of Current Applicable Funded Grants/Programs (to be automatically amended as projects are funded): 1. Grantee: City of Camilla, GA CDBG Grant Number: 22p-x-101-2-6270 Target Area: Palmer Street, N. Butler Street, Inman Street. Camilla, Georgia (Census Tract for the City of Camilla: 0% LEP: Spanish 0%, Asian and Pacific Island 0%, and 0% Other) This Language Access Plan has been prepared to address the City of Camilla's responsibilities as a recipient of federal financial assistance from Georgia Department of Community Affairs programs & grants funded by HUD as they relate to the needs ofindividuals with limited English The plan has been prepared to ensure compliance with HUD's guidance and Title VI of the Civil Rights Acto of1964, and its implementing regulations. Under HUD'sg guidance, the City ofC Camilla must take reasonable steps to ensure meaningful access to their programs and activities by persons Executive Order 13166, titled Improving Access to Services for Persons with Limited English Proficiency, indicates that differing treatment based upon aj person'si inability to speak, read, write or understands English is a type of national origin discrimination. It directs each agency toj publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to all state and local agencies which receive federal funds, language skills. with Limited English Proficiency (LEP). including the City of Camilla. 3 The City of Camilla has developed this Language Access Plan to help identify reasonable steps for providing language assistance to persons with Limited English Proficiency (LEP) who wish to access services provided through programs funded by the Georgia Department of Community Affairs/HUD. As defined by Executive Order 13166, LEP persons aret those who do not speak English as their primary language and have limited ability to read, speak, write or understand English. This plan outlines how to identify a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how to notify LEP persons that assistance is In order to prepare this plan, the City of Camilla used HUD's four-factor LEP analysis which considers 1. The number or proportion of LEP persons eligible to be served or likely to be encountered by the 2. The frequency with which LEP persons come in contact with Community Improvement programs; 3. The nature and importance of the Community Improvement programs and services provided by 4. The resources available to the City of Camilla and overall cost to provide LEP assistance. available. the following factors: Community Improvement programs; City of Camilla to the LEP population; SAFE HARBORS In accordance with HUD Safe Harbors for LEP, the City of Camilla will translate written Community Improvement documents for groups that are at least 5% ofthe population eligible (and more than 50 persons) or 1,000 persons, whichever is less. Ift there are fewer than 50 persons in a language group that reaches the 5% trigger above, the City of Camilla will not translate the vital Community Improvement written materials, but provides written notice in the primary language oft the LEP group of the right to receive competent oral interpretation of those written materials, The size of the language group determines the recommended provision for written language free ofcost. assistance. Size ofl Language Group Recommended Provision of Written Language Assistance Translated vital documents Translated vital documents 1,000 or more in the eligible population More than 5% oft the eligible population or beneficiaries and more than 50 in number More than 5% oft the eligible population or beneficiaries and 50 or less in number 5% or less of the eligible population or beneficiaries and less than 1,000 in number Translated written notice of right to receive free oral interpretation of documents. No written translation is required. 4 LMEANINCFULACCESS: FOUR-FACTOR ANALYSIS 1.The number or proportion ofLEP persons eligible to be served or likely to The City of Camilla Community Improvement staff reviewed the Georgia Department of Community Affairs mapping tool and determined that of the population of 4,858 persons over 5 years of age, 63 persons in Camilla (0% of the total population) speak a language other than English. Ofthose 63 persons, 0(0% ofthet total population speaking al language other than English) have limited English proficiency; that is, they speak English less than "very well". In Camilla, of those persons with limited English proficiency, 0 speak Spanish and 0 speak Asian and Pacific Ar review of the residents that were in our FY 2022 22p-x-101-2-6270) CDBG Target Area revealed (other than White or African-American) 2 Hispanic Individuals (1% of the area population, all able to understand English very well) 0 Multi-Racial, 0 Native American and 0 Unknown (survey information not available). Housing applicants for our FY 2022 CDBG Neighborhood Revitalization Application (Proposed) showed zero (1) Hispanic households or other households. 98% were African-American and 2% were Asian. This does not meet the threshold described above for translating vital documents or translated written notice of right to receive free oral interpretation of documents. Oral Interpretation Services are available for clients upon request. However, in the past, all of our clients have provided their own translator with be encountered by the programs. Island languages. whom they are comfortable sharing personal information. Language Spoken* # of Residents Over Speaks English Less 5Years of Age* 4,795 51 12 Than "Very Well"* (0%) (0%) (0%) English Spanish Asian & Pacific Island Total (98.7%) N/A (1.1%) 0 (0.2%) 0 4,858 (100.0%) 0 CDBG Grant Number: 22p-x-101-2-6270 Target Area: Palmer Street, N. Butler Street, Inman Street. Camilla, Georgia (Census Tract for the City of Camilla: 0% LEP: Spanish 0%, Asian and Pacific Island 0%, and 0% Other) At the present time, GA DCA has identified No Census Tract in the City of Camilla that meets LEP criteria: 2. The frequency with which LEP persons come in contact with Community The City of Camilla Community Improvement Department staff reviewed the frequency with which staff have, or could have, contact with LEP persons. This includes documenting phone inquiries or office visits, as well as public hearings and interactions during surveys. Over the past two years, Community Improvement has had no requests for interpreters and no requests for Improvement Department services. translated program documents. 5 A review of the residents that were in our FY 2022 (22p-x-101-2-6270) CDBG Target Area revealed (other than White or African-American) 2 Hispanic Individuals (1% of the area population, all able to understand English very well) 0 Multi-Racial, 0 Native American and 0 Unknown (survey information not available). Housing applicants for our FY 2022 CDBG Neighborhood Revitalization Application (Proposed) showed zero (1) Hispanic households or other households. 98% were African-American and 2% were Asian. This does not meet the threshold described above for translating vital documents or translated written notice of right to receive free oral interpretation of documents. Oral Interpretation Services are available for clients upon request. However, in the past, all of our clients have provided their own translator with whom they are comfortable sharing personal information. Frequency of Interaction: Annually For Project Applications: a. When notifying the public about grant award application and its proposed activities b. When notifying the public about grant award and its funded activities When seeking applicants toj participate in the program (e.g., when seeking homeowners for rehabilitation assistance) d. When seeking qualified contractors . When working with homeowners selected for assistance When seeking bids from builders to construct the homes When notifying the public about the grant award closeout andi its accomplishments 3. The nature and importance of programs, activities or services provided by Housing plays a critical role in maintaining quality oflife. Community Improvement is committed toe ensure access to safe, sanitary and affordable housing for our eligible clients. Outreach throughout the community helps to ensure: a Warmness ofour programs. Thei majority ofthe City's population- 98.7% speaks English. Other than English speaking individuals, Community Improvement staff are most likely to encounter Spanish speaking LEP individuals through office visits, phone conversations and during surveys. Upon client request, the City of Camilla will provide oral interpreters using bi-lingual employees or qualified contract interpreters. To date, all Community Improvement to the LEP population. LEP individuals have provided their own interpreter-a child or friend. Nature oft the Program(s): CDBG Sewer Improvements. serious or life-threatening implications for the LEP individual. Importance oft the Program(s): Denial or delay ofa access to services orinformation would not have 4. The resources available to the City of Camilla, and overall cost to provide LEP assistance. The City of Camilla reviewed its available resources that could be used for providing LEP assistance, including which of its documents would be most valuable to be translated if the need 6 should arise. An "I Speak" card/poster will be made available to determine needed language translations. Anotice (see below) will bej posted in all ads for GA DCA/HUD programs regarding who to contact should language assistance be needed. Language translation, ifneeded, would be provided through the available bi-lingual staffand/ort thel Language Line (770-455-7141): for which the City of Camilla would pay a fee. IILLANGUAGE ASSISTANCE Aj person who does not speak English as their primary language and who has a limited ability to read, write, speak or understand English may be a Limited English Proficient person and may be entitled to language assistance with respect to Community Improvement services. Language assistance can include interpretation, which means oral or spoken transfer ofa a message from one language into another language and/or translation, which means the written transfer of a message The Name oft the individual at the City ofCamilla responsible for coordination ofLEP Compliance from one language into another language. is: Santos Gonzales, City Firefighter City of Camilla (229) 330-2325 cford@etyolcamila.com P.O. Box 328-Camilla, Georgia 31730 How the Community Improvement staff may identify an LEP person who needs language assistance: Post notice ofLEP Plan and the availability ofinterpretation: services free ofc charge Add statement (see below) to public meeting and event notices concerning GA All Community Improvement staff will be informally surveyed periodically on their experience concerning any contacts with LEP persons during the previous When Community Improvement conducts a Public Hearing, an informational meeting or event, as staff person may greet participants as they arrive. Byi informally engaging participants in conversation it is possible to gauge each attendee'sal ability to speak and understand English. Although translation may not be able to be provided at the event (unless previously requested) it will helpi identify the need for Language Identification Cards/Posters will be used as necessary to determine a inl languages LEP persons would understand; DCA/HUD programs; year; and future events; and client's language needs. 7 Language Assistance Measures-Altough there is a small percentage in Camilla of eligible LEP households, that is, persons who speak English "not well" or "not at all", it will strive to offer the 1.The Community Improvement staff will take reasonable steps to provide the opportunity for meaningful access to LEP clients who have difficulty communicating English. 2. The following resources will be available to accommodate LEP persons: following measures: Interpreters for the Spanish language ifavailable will bej provided within a reasonable time Language interpretation will be accessed through Language Line Solutions. period; or 3. Language Identification Cards/Posters will be used as necessary to determine a client'sl language 4. The following statements will be added to public meeting and event notices concerning GA "Persons with special needs relating to handicapped accessibility or foreign language shall contact Cheryl Ford, City Clerk at (229)330-2325. This person can be located at the Camilla City Hall 30 East Broad Street, Camilla, Ga. 31730 between the hours of 8:00 to 5:00 Monday through Friday, except holidays. Individuals who are hearing impaired can contact the Georgia Relay Services, needs. DCA/HUD programs: telephone number (TDD)1-800-255-0056,Voice)1-800-255-0135." IV.STAFF TRAINING The following training will be provided to all Community Improvement staff: Information on the Title VIPolicy and LEP responsibilities; Description ofl language assistance services offered to the public; Documentation ofl language assistance requests; and How to handle aj potential Title VI/LEP complaint. All contractors, subcontractors and sub-recipients performing work for or receiving federal funds for Community Development projects will be required to follow the Title VI/LEP guidelines. V.TRANSLATION OF DOCUMENTS The City of Camilla weighed the cost and benefits of translating documents for potential LEP groups. Considering the expense oftranslating the documents, the likelihood of frequent changes in documents and other relevant factors, at this time no documents require translation. 8 e Due to the relatively small eligible local LEP population, the City of Camilla does not have a formal outreach procedure inj place at this time. Translation resources have been identified. When and ift the need arises for LEP outreach, the City of Camilla will consider the following option: -When staff prepares a document, or schedules a meeting, for which the target audience is expected to include LEP individuals, then relevant documents, meeting notices, flyers, and agendas will be printed in an alternative language based on the known LEP population, if requested. VI. MONITORING AND UPDATING THE LAP PLAN The City ofCamilla will update the LAP Plan as required.. Atam minimum, the plan will ber reviewed and updated every five years using the United States Census Bureau for census information, or when it is clear that higher concentrations OfLEP individuals are present in the City of Camilla. Updates will include the following: The number of documented LEP person contacts encountered annually; How the needs ofLEP persons have been addressed; Determination of the current LEP population in the service area; Determination as to whether the need for translation services has changed; Determine whether local language assistance programs have been effective and sufficient Determine whether the CityofCamilla'sf financial resources are: sufficient to fund language Determine whether the City of Camilla fully complies with the goals oft this LAPI Plan; and Determine whether complaints have been received concerning the agency's failure to meet tor meet the need; assistance resources needed; the needs OfLEP individuals. VII. DISSEMINATION OF THE CITY OF CAMILLA'S LAP PLAN The LAP Plan will be on the City of Camilla's website page and provided to anyone requesting the information. VIII. RECORDS The City of Camilla will maintain records int the City Clerk's officei regarding its efforts to comply with Title VILEP obligations. These records will be reviewed periodically and open to the public in an effort to improve service. IX. COMPLAINTS/FINDINGS Any person who believes they have been denied the benefits ofthis] LAP or that the City ofCamilla has not complied with Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000(d) and Executive Order 13166 regulations may file a complaint with the City LAP Coordinator. The City LAP Coordinator may be the first point of contact for any complaints or appeals, but the DCA LAP Coordinator must be informed of all complaints and appeals. The LAP Coordinator will provide oversight of the complaint/appeal resolution process. To file a complaint, submit the written complaint to: 9 Santos Gonzales, City Firefighter City of Camilla (229).330-2325 torl@etyolcamila.com DCA 504 Coordinator 60 Executive Park South, N.E. Atlanta, Georgia 30329-2231 Armousing@deagasov P.O. Box 328-Camilla, Georgia 31730 Or X.AVAILABLE FEDERALLEP RESOURCES HUD'sI LEP Website: tp/wpw.hudpovotice/heo/epam. Federal LEP Website: htp/www.lep.gov, LEP and Title VI Videos: itp/www.ep.govwvideo/video.htm "I Speak" Card: ntp.www.lepgovi5peakCarti200pdr 10