LANGUAGE
ASSISTANCE PLAN
AUGUST 2022
Free Language Assistance | Ayuda gratuita con el idioma | Libreng Tulong sa Wika | Hỗ trợ ngôn ngữ miễn phí
免費語言協助 | 免费语言协助 |  | 무료 언어 지원 |  | 無料の言語支援 | 
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ఉత  సం | ການ່ວຍເືອ້ານພາສາຟີ | Kaalmada Luqadda ee Bilaashka ah | Безкоштовна мовна допомога
sandag.org/LanguageAssistance | (619) 699-1900
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Table of Contents
List of Figures ................................................................................................................................................. 4
Definitions ........................................................................................................................................................ 5
Executive Summary....................................................................................................................................... 7
1. Background and Introduction .............................................................................................................................. 7
2. Four Factor Analysis ..................................................................................................................................................... 7
3. Language Assistance Measures .......................................................................................................................... 9
4. Monitoring and Updating ...................................................................................................................................... 10
1. Introduction ............................................................................................................................................. 11
About SANDAG ........................................................................................................................................................................ 11
SANDAG Commitment to Equity Statement ..................................................................................................... 11
Background .............................................................................................................................................................................. 12
The Four Factor Analysis and Language Assistance Plan ....................................................................... 13
2. Factor 1: Identifying Individuals with Limited English Proficiency Who Need
Language Assistance ........................................................................................................................... 14
Data Sources and Findings ........................................................................................................................................... 14
Location of Populations with Limited English Proficiency ....................................................................... 17
SANDAG Safe Harbor Languages ............................................................................................................................ 23
3. Factor 2: Frequency that Persons with Limited English Proficiency Come in Contact
with SANDAG .......................................................................................................................................... 25
Staff Survey and Interviews .......................................................................................................................................... 25
Focus Groups .......................................................................................................................................................................... 35
SANDAG Data on Contact with Limited English Proficiency Populations ................................... 36
Factor 2 Conclusions ......................................................................................................................................................... 37
4. Factor 3: Nature and Importance of Contact with SANDAG to Persons with
Limited English Proficiency .............................................................................................................. 39
Focus Groups .......................................................................................................................................................................... 39
Factor 3 Conclusions ......................................................................................................................................................... 43
5. Factor 4: Resources Available to SANDAG and Estimated Costs ........................................ 44
Resources for Language Assistance at SANDAG.......................................................................................... 44
Identifying Language Assistance Expenditures ............................................................................................. 45
Assessing Language Assistance Expenditures ............................................................................................... 46
Factor 4 Conclusions ......................................................................................................................................................... 46
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6. Language Assistance Plan ................................................................................................................ 48
Introduction .............................................................................................................................................................................48
Safe Harbor Languages and Language Priority Groups .........................................................................48
Departments and Staff Responsibilities .............................................................................................................. 49
Vital Documents .................................................................................................................................................................. 50
Language Assistance Measures ............................................................................................................................... 52
Bilingual Employees and Pay Policy ....................................................................................................................... 61
Training on Limited English Proficiency Requirements ............................................................................ 62
Advocate for Measures to Advance Access for Persons with
Limited English Proficiency .................................................................................................................................. 62
7. Monitoring and Updating .................................................................................................................. 64
Introduction ............................................................................................................................................................................. 64
Quantitative Data ............................................................................................................................................................... 64
Qualitative Data ................................................................................................................................................................... 65
8. Summary of Conclusions and Recommendations .................................................................... 67
9. Appendix 1: Employee Survey Form ............................................................................................... 70
10. Appendix 2: Community-Based Organization Focus Group Moderator Guide and
Consent Form ........................................................................................................................................ 76
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List of Figures
Figure Ex-1: Safe Harbor Languages.................................................................................................................................. 7
Figure Ex-2: Language Priority Groups .......................................................................................................................... 10
Figure 2-1: Limited English Proficiency Speakers in San Diego County by Language and
Data Source ............................................................................................................................................................................... 15
Figure 2-2: Foreign-Born Population in San Diego County .............................................................................. 19
Figure 2-3: Speaks a Language Other Than English at Home in San Diego County .................... 20
Figure 2-4: Limited English Proficient Population in San Diego County ................................................. 21
Figure 2-5: Spanish Speaking Population with Limited English Proficiency in
San Diego County ............................................................................................................................................................... 22
Figure 2-6: Safe Harbor Languages ................................................................................................................................ 23
Figure 3-1: In which areas/programs do you have contact with the public?
(Check all that apply) ........................................................................................................................................................ 25
Figure 3-2: How important is it for limited English speakers to have information
regarding your area/program to access the programs, projects, and services
funded by SANDAG? .......................................................................................................................................................... 26
Figure 3-3: How often do you interact with individuals with Limited English Proficiency? ....... 26
Figure 3-4: How do you interact with individuals with Limited English Proficiency? .................... 27
Figure 3-5: What methods do you use to communicate with limited English proficient
individuals? .............................................................................................................................................................................. 27
Figure 3-6: What are some of the challenges you face when communicating with
individuals who do not speak English very well or not at all? ............................................................... 28
Figure 3-7: What tools do you have available to provide assistance to people with limited
English capabilities? (Multiple answers acceptable) .................................................................................. 30
Figure 3-8: What is your level of satisfaction with existing tools for providing assistance to
individuals with Limited English Proficiency on a scale of 1 to 5, with 5 being highest
satisfaction? ............................................................................................................................................................................. 31
Figure 3-9: What other tools would help you to assist customers who speak
limited English? .................................................................................................................................................................... 32
Figure 3-10: Do you speak any of these languages fluently? ......................................................................... 34
Figure 3-11: Which SANDAG department do you work for? ............................................................................. 34
Figure 3-12: Community-Based Organizations and Focus Group Languages .................................. 35
Figure 3-13: Translation Requests by Language ..................................................................................................... 37
Figure 4-1: Freeway Sign for Motor Assistance and Tow Truck Logo ......................................................... 41
Figure 4-2: San Diego Call Box Sign and Example of European Call Box Sign .................................. 41
Figure 4-3: South Bay Expressway FasTrak Signage........................................................................................... 42
Figure 4-4: Examples of European Signs for Electronic Tolling .................................................................... 42
Figure 6-1: Language Priority Groups ............................................................................................................................. 49
Figure 6-2: SANDAG Free Language Assistance Notice .................................................................................... 54
Figure 6-3: SANDAG Web Pages ........................................................................................................................................ 56
Figure 6-4: Metropolitan Transit System Website Home Page .................................................................... 58
Figure 6-5: Examples of Bilingual U.S. Highway Signs Near Canadian Border ................................. 63
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Definitions
• Bilingual: Ability to speak two languages fluently and without effort; fluency and bilingual
skills may be measured and certified.
• Community-Based Organization (CBO): A local, non-profit, non-governmental
organization that represents the interests of a community or particular population within
the community.
• Cultural Competency: Programs or content that understand and effectively respond to
cultural diversity.
• English Learner: Students learning English as a second language as identified by the
California Department of Education (DOE).
• Equity and Equality: Equity ensures access, opportunity, and advancement for all people,
and strives to identify and eliminate barriers that prevent the full participation of some
groups. Equality ensures the same access, opportunity, and advancement for all people; it
aims to promote fairness but can only work if everyone starts from the same place.
• Executive Order: Rule or order issued by the U.S. President to an executive branch of the
government and having the force of law.
• Federal Transit Administration (FTA): Operating administration of the U.S. Department
of Transportation (U.S. DOT); it provides financial and technical assistance to the San
Diego Association of Governments (SANDAG) (and SANDAG passes such funding through
to local public transit systems).
• Four Factor Analysis: Framework developed by the U.S. DOT to help agencies determine
the number of persons in their community that do not speak English very well and
develop programs to assist Limited English Proficiency (LEP) persons in interacting with
government agencies such as SANDAG.
• Interactive Voice Recognition (IVR) phone system: Automated phone system that
callers interact with, and which gathers information from callers via a menu, without
contact with a live person.
• Interpretation: Oral, real-time translation from one language into another.
• Interpretation (simultaneous versus consecutive): Through simultaneous
interpretation, the interpreter speaks at the same time as the speaker and voices may
overlap; through consecutive interpretation, the person with LEP speaks, followed by the
interpreter, and there are pauses or breaks between sentences when each is speaking.
• “I Speak” cards: Tool which allows a person to identify what language they speak.
• Limited English Proficiency (LEP): Persons with LEP are those for whom English is not
their primary language and who have a limited ability to read, write, speak, or understand
English; LEP designation includes people who reported to the U.S. Census that they
speak English less than very well, not well, or not at all.
• National Origin Discrimination: Treating people unfavorably because they are from a
particular country or part of the world, including because of ethnicity, because they speak
a foreign language, or because they speak English with an accent.
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• Over the Phone Interpretation: Three-way call interpreting service, where the
interpreter works during the conversation between two parties who speak different
languages; this service is typically provided remotely.
• Safe Harbor Language: Language spoken by at least 1,000 persons with LEP in the
SANDAG region, as defined by the FTA.
• Title VI: Title VI of the Civil Rights Act of 1964, which prohibits recipients of federal funding
from discriminating on the basis of race, color, or national origin.
• Translation: Written rendering of text from one language into another while preserving
meaning.
• Vital Document: A document that contains information that is critical for obtaining
federal services and/or benefits, or is required by law.
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Executive Summary
1. Background and Introduction
Agencies that receive funds from the U.S. Department of Transportation (U.S. DOT) are
responsible for providing language assistance measures to persons with Limited English
Proficiency (LEP). To ensure compliance, the U.S. DOT developed a four-factor framework and
guidance to help agencies determine the number of persons in their community that do not
speak English very well and develop programs to assist them in interacting with government
agencies such as the San Diego Association of Governments (SANDAG). The U.S. DOT
guidance also requires agencies to prepare Language Assistance Plans to outline the
measures that an agency will take to assist persons who do not speak English very well. This
document summarizes the Four Factor Analysis conducted by SANDAG and identifies the
language assistance measures provided by SANDAG. It also identifies how the agency trains
employees and provides notice to people with LEP and details how the plan will be
monitored. Providing language assistance is deeply connected with SANDAG’s Commitment
to Equity and to creating a San Diego region where every person who visits, works, and lives
can thrive.
2. Four Factor Analysis
Figure Ex-1: Safe Harbor Languages
Factor 1: The number or proportion of LEP
persons eligible to be served or likely to be
encountered by a program, activity, or service of
the recipient or grantee.
Following Factor 1 U.S. DOT Guidance, multiple
sources—including the U.S. Census American
Community Survey (ACS), California Department
of Education (DOE), County of San Diego
Department of Behavioral Health Services, and
San Diego Superior Court—were used to
determine the number of people with LEP in
San Diego County. According to these findings,
about 400,000 people five years or older speak
English less than very well. This accounts for 13%
of the county’s population. There are more than
245,000 Spanish speakers who speak English
less than very well, and this is about 64% of the
LEP population in San Diego County. Tagalog
and Filipino, Vietnamese, Chinese (all dialects),
and Arabic have between 15,000 and 30,000
speakers who don’t speak English very well.
Twelve other languages or language groups
were identified as having more than 1,000
speakers who do not speak English very well.
One thousand speakers is the minimum
threshold for safe harbor protection established by the federal government.
Safe Harbor Languages
1 Spanish
2 Tagalog (incl. Filipino)
3 Vietnamese
4 Chinese (Mandarin and Cantonese)
5 Arabic
6 Korean
7 Persian (incl. Farsi, Dari)
8 Japanese
9 Russian
10 Portuguese
11 Hindi
12 French (incl. Cajun)
13 Khmer
14 Telugu
15 Lao
16 Somali
17 Ukrainian
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Based on data in Factor 1, it is recommended that SANDAG provide safe harbor protections
to speakers of the 17 languages shown in Figure Ex-1. Each of these languages is estimated to
have at least 1,000 speakers who reside in San Diego County and who do not speak English
very well.
Factor 2: The frequency with which LEP individuals come in contact with the program,
activity, or service.
Information on the frequency that persons with LEP come in contact with SANDAG was
assessed based on a survey of employees, follow-up interviews, focus groups made up of
individuals with LEP from five language groups, and a review of available data collected by
SANDAG on LEP contacts.
All SANDAG employees were sent an email with a link to an online survey regarding their
interactions with individuals with LEP and the resources available for communication. About
one fourth, or 103 employees, provided complete responses.
The focus groups were held to help understand, from the perspective of people with LEP,
how frequently individuals with LEP come in contact with SANDAG programs, services, and
staff. The language groups were selected based on the prevalence of speakers from the 2019
Factor 1 results and the availability of community-based organization (CBO) partners that
could hold focus groups in those languages.
The greatest number of contacts with individuals who have LEP are in Spanish, which is
consistent with the findings of Factor 1 and reflective of the cross-border planning
relationship with and geographic proximity to Mexico. The absence of data showing contact
with other language groups appears largely due to people not being aware of SANDAG, its
role, and the services it provides. Part of this issue is that many recent immigrants and non-
English speakers come from nations that do not have organizations like SANDAG that
provide services such as FasTrak, or no-cost services such as 511, the Freeway Service Patrol, or
highway call boxes. Greater awareness of SANDAG’s role and services in the LEP community
will increase contacts.
Factor 3: The nature and importance of the program, activity, or service provided by the
recipient to people’s lives.
SANDAG is a multifaceted organization that carries out planning activities which rely on
significant public input, and also provides services for the public. Many of the programs
SANDAG administers and projects the agency builds have a direct impact on the public,
including individuals with LEP.
Focus groups for individuals with LEP sought to identify the importance of SANDAG in their
lives. The results from the focus groups generally found a low level of awareness of SANDAG
programs and little contact with the agency. Most people were unaware they have a right to
communicate with SANDAG in their native languages, and many stated they felt intimidated
to communicate with a government agency because of their poor English. Spanish speakers
seemed to be more aware of SANDAG programs and were more willing to communicate
with the agency than members of other language groups.
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The individuals who participated in the focus groups placed a high level of importance on
being able to communicate with elected representatives though the Board of Directors and
Policy Advisory Committees (PACs). Transit riders also felt it was important to be able to
comment on fare changes. Even though few had used Motorist Aid, or even knew of its
existence, the individuals participating in the focus groups found the Motorist Aid Services,
including the Freeway Service Patrol and call boxes, to be particularly important. The 511
system, except for requesting Motorist Aid, was not seen as particularly important because
more easily accessible traffic/transit information alternatives exist. iCommute was not viewed
as important because none of the participants had a need for the services provided.
Factor 4: The resources available to the recipient and costs.
The U.S. DOT LEP guidance recognizes the level of language assistance provided by agencies
will differ based on the size of the establishment and the resources or budget available. The
guidance directs agencies to take reasonable steps to provide language access; if the costs
substantially exceed the benefits, additional actions may not be necessary.
The total resources dedicated to supporting individuals with LEP is not available in a single,
centralized location, making the estimation of total resources very difficult. Individuals with
LEP constitute about 13% of the total population of San Diego County. As a rough measure,
one would expect at least 13% of the total communications budget to be spent on
communicating with individuals with LEP. With direct LEP costs estimated to be about
$282,000, the expenditure is equivalent to about 27% of the direct communications costs,
excluding project communications costs, which are budgeted separately. Therefore, it
appears that percentage of costs associated with providing service to individuals with LEP
exceeds the percentage of LEP population in San Diego County. This is a rough indication
that SANDAG resources are reasonable.
3. Language Assistance Measures
It is SANDAG’s policy to provide timely, meaningful access for persons with LEP to its services
and decision-making processes. SANDAG communicates with individuals with LEP in person
and through virtual platforms, over the phone, in writing, and through digital media as
provided in this Language Assistance Plan (LAP). The LAP is an important component of
SANDAG’s Commitment to Equity. An effective LAP will help ensure historically underserved,
systemically marginalized, and otherwise linguistically isolated groups can receive the full
benefit of SANDAG programs, services, and facilities, and can participate in public
engagement opportunities conducted by SANDAG. SANDAG is committed to creating a
region where every person, regardless of the language they speak, has a bright future.
This LAP for SANDAG has seven elements:
1. Identify a person, department, and staff advisory group responsible for ensuring LEP
compliance
2. Identify existing language assistance measures
3. Identify vital documents
4. Provide training for staff on LEP requirements
5. Identify new services and resources to be made available for language services by
functional area
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6. Recommend an agency compliance monitoring process to ensure language access
services are being made available and monitor encounters with individuals with LEP
7. Advocate internally and externally to enable SANDAG to better serve individuals with LEP
The plan also contains recommendations for updating the LAP and for monitoring language
assistance efforts to ensure language access services are being made available.
The Four Factor Analysis identified 17 languages that meet the safe harbor threshold. The
number of persons ranged from in excess of 245,000 Spanish speakers to more than 1,000
estimated Ukrainian speakers. Spanish is the language most spoken by persons with LEP
and—given factors such as the historical role of Spanish in the region, the close relationship
with Tijuana, and crossborder flows of people—Spanish has a unique importance for
SANDAG. Four languages—Chinese, Tagalog/Filipino, Vietnamese, and Arabic—have
significant populations of people with LEP, and those groups are substantially smaller than
the Spanish-speaking LEP population. There are 12 additional language groups consisting of
between 1,000 and 7,500 individuals that meet the threshold for safe harbor designation. The
wide range in the sizes of the language group populations and the historical and geographic
proximity issues support the use of a priority designation for the languages which were used
to develop language assistance measures. The Language Priority Groups are shown in
Figure Ex-2. (Language designations in this table are as provided in U.S. Census Bureau data.)
Figure Ex-2: Language Priority Groups
Priority 1 Priority 2 Priority 3
Spanish
Tagalog/Filipino
Vietnamese
Chinese: Mandarin (oral);
Simplified (written)
Arabic
Chinese: Cantonese (oral);
Traditional (written)
Korean
Persian
Japanese
Russian
Portuguese
Hindi
French
Khmer
Telugu
Lao
Somali
Ukrainian
4. Monitoring and Updating
The Four Factor Analysis and LAP will be reviewed and updated, if necessary, every three to
five years to ensure alignment with the most recent available data, the SANDAG Equity
Action Plan, and any significant changes in the SANDAG Title VI Program. The Director of
Diversity and Equity is responsible for the review and update of the document and for
monitoring the implementation of the plan, which falls under the Department of
Organization Effectiveness.
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1. Introduction
About SANDAG
SANDAG is the regional planning agency as well as the technical and informational resource
for the San Diego, California area’s 18 incorporated cities and the county government, which
collectively make up the association of governments. A Board of Directors comprising
elected officials from each of the 19 member agencies governs SANDAG. Advisory
representatives from Imperial County, the U.S. Department of Defense, California
Department of Transportation (Caltrans), Port of San Diego, San Diego County Water
Authority, Metropolitan Transit System (MTS), North County Transit District (NCTD), Southern
California Tribal Chairmen’s Association, San Diego Regional Airport Authority, and Mexico
supplement the voting members. The agency’s planning boundary is the jurisdictional limits
of the County of San Diego; in addition, SANDAG partners with agencies in Mexico and
throughout Southern California. In 2020, the county population was estimated at 3,351,737.
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SANDAG was created in 1966 as a comprehensive planning organization (CPO) under a state-
authorized joint powers agreement. The governor of California designated the CPO as the
metropolitan planning organization for the region in 1970. In 1972, the CPO was established
as a joint powers authority. It adopted its current name in 1980 to better reflect its purpose. In
1987, SANDAG added the responsibilities of administering the region’s voter-approved half-
cent sales tax for regional transportation projects—TransNet.
On January 1, 2003, Senate Bill 1703 (Peace, 2002) (SB 1703) was enacted and changed
SANDAG’s structure from a joint powers authority to a state-created regional governmental
agency, which made it a permanent (rather than voluntary) association of local governments
with increased responsibilities and powers. SB 1703 consolidated MTS’s and NCTD’s
transportation planning and development functions into SANDAG so those activities would
occur multimodally.
The roles and responsibilities of SANDAG, MTS, and NCTD are outlined in a master
memorandum of understanding executed on April 23, 2004. SANDAG is responsible for
transit planning, development, and construction, whereas MTS and NCTD are responsible for
transit operations. MTS and NCTD also manage small construction projects with SANDAG’s
assistance, and SANDAG is responsible for establishing the regional fare policy.
SANDAG Commitment to Equity Statement
In February 2021, the SANDAG Board of Directors adopted the following Commitment to
Equity statement:
We hold ourselves accountable to the communities we serve. We
acknowledge we have much to learn and much to change; and we firmly
uphold equity and inclusion for every person in the San Diego region. This
includes historically underserved, systemically marginalized groups affected
by actions and inactions at all levels of our government and society. We have
an obligation to end disparities and ensure that safe, healthy, accessible, and
inclusive opportunities are available to everyone.
1
Source: U.S. Census Bureau 2020 Census.
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We have an obligation to eliminate disparities and ensure that safe, healthy,
accessible, and inclusive opportunities are available to everyone. The SANDAG
equity action plan will inform how we plan, prioritize, fund, and build projects
and programs; frame how we work with our communities; define how we
recruit and develop our employees; guide our efforts to conduct unbiased
research and interpret data; and set expectations for companies and
stakeholders that work with us.
We are committed to creating a San Diego region where every person who
visits, works, and lives can thrive.
Background
Title VI of the Civil Rights Act of 1964 (Title VI) states, “No person in the United States shall, on
the grounds of race, color, or national origin, be excluded from participation in, be denied the
benefits of, or be otherwise subjected to discrimination under any program or activity that
receives Federal financial assistance.” In the 1974 case of Lau v. Nichols (414 U.S. 563), the
Supreme Court interpreted the Title VI ban on national origin discrimination to hold that Title
VI prohibits conduct that has a discriminatory impact on individuals with LEP.
On August 11, 2000, President Bill Clinton signed Executive Order 13166, Improving Access to
Services for Persons with Limited English Proficiency. This executive order directs federal
agencies to examine the services they provide and to develop and implement a system by
which persons with LEP can access those services meaningfully. Federal agencies were
instructed to publish guidance for their respective recipients to assist them with their
obligations to persons with LEP under Title VI.
The U.S. DOT published guidance for its recipients in 2005, the Policy Guidance Concerning
Recipients’ Responsibilities to Limited English Proficient (LEP) Persons (Volume 70,
Number 239). The guidance states that Title VI and its implementing regulations require that
U.S. DOT recipients take responsible steps to ensure meaningful access to the benefits,
services, information, and other important portions of their programs and activities for
individuals with LEP. The guidance also suggests recipients use the U.S. DOT LEP policy
guidance to determine how best to comply with statutory and regulatory obligations to
provide meaningful access to the benefits, services, information, and other important
portions of their programs and activities for individuals with LEP. The guidance proposes a
structure—the Four Factor Analysis—for determining the best approach to provide language
assistance.
The Federal Transit Administration (FTA) Title VI circular 4702.1B provides the definition of
LEP used in this report. It states persons with LEP are those “for whom English is not their
primary language and who have a limited ability to read, write, speak, or understand English.
It includes people who reported to the U.S. Census that they speak English less than very
well, not well, or not at all.”
SANDAG used these resources to guide development of this LAP. SANDAG intends this plan
will address the needs of and provide meaningful assistance to individuals with LEP in
San Diego County. The LAP summarizes findings of the Four Factor Analysis, identifies
persons who need language assistance and how they will be notified about the availability of
such assistance, details what language assistance measures SANDAG will take and how
employees will be trained to carry them out, and specifies how the plan will be monitored
and updated.
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California law also provides protections for individuals with LEP, found in the California Civil
Rights Act (Unruh Act; California Code 11135) and the Bilingual Services Act (California Code
7290). Unlike federal protections, these statutes do not have regulations that require
proactive measures to identify LEP populations and develop programs to ensure their
language needs are meet. Agencies have local discretion to determine how large the LEP
population must be before providing services in another language. The best practice for local
agencies is to adopt the state standard to provide services if any language group constitutes
5% of the population being served. As a result, compliance with California law will be attained
if the federal requirements are met and implemented.
The Four Factor Analysis and Language Assistance Plan
Guidance issued by the U.S. DOT and the FTA requires each agency that receives federal
funding to prepare a Four Factor Analysis. The Four Factor Analysis must address the
following four topics:
• Factor 1: The number or proportion of persons with LEP eligible to be served or likely to
be encountered by a program, activity, or service of the recipient or grantee
• Factor 2: The frequency with which individuals with LEP come in contact with the
program, activity, or service
• Factor 3: The nature and importance of the program, activity, or service provided by the
recipient to people’s lives
• Factor 4: The resources available to the recipient and costs
The Four Factor Analysis provides the groundwork for developing this LAP which addresses
how SANDAG will communicate with and provide services to persons with LEP.
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2. Factor 1: Identifying Individuals with
Limited English Proficiency Who
Need Language Assistance
Federal guidance from the U.S. DOT requires federal funding recipients to identify the
number or proportion of individuals who have LEP and are likely to come in contact with
federally funded services and programs. Any individual older than five years of age who does
not speak English very well is considered to have LEP, and every program at an agency that
receives any federal funding must comply with the requirement, regardless of whether
federal money funds the specific program.
The U.S. DOT and FTA guidance also address how to determine whether the population of
speakers of a particular language reaches a minimum that would trigger a requirement to
provide translated vital documents—the safe harbor requirement. The presence of at least
1,000 individuals or 5% of the population (whichever is less) who speak a language other than
English and do not speak English very well triggers the safe harbor requirement.
The goal of Factor 1 is to determine which San Diego County populations meet the safe
harbor threshold. The goal of the federal and state legislation, regulations, and guidance is to
encourage government agencies to provide additional services in alternative languages to
ensure individuals with LEP are not subject to discrimination.
Data Sources and Findings
Determining the precise number of persons with LEP is more nuanced than simply
consulting the U.S. Census Bureau because it’s possible that not all limited English speakers
are included in Census statistics, and the Census may inadequately stratify the languages
found in all communities. In preparing Factor 1, other state and local data on language use
and predominance supplemented Census data.
U.S. Census Bureau American Community Survey
The U.S. Census Bureau ACS replaced the long form of the decennial Census and is
conducted continuously throughout the year. Nationally, about 250,000 households are
surveyed monthly, and the survey includes questions about English language proficiency
(unlike the decennial Census). Based on the survey results, estimates are prepared based on
one year and five years of data (Figure 2-1). There can be differences between the one-year
and five-year estimates, and by using both sets of data, a valid picture of a particular data set
can be achieved. The most recent year of available ACS data is 2019. The one-year estimate
shows almost 400,000 individuals with LEP in San Diego County (393,293), and the five-year
estimate shows more than 425,000 individuals with LEP (426,297). Figure 2-1, Column 1 shows
the one-year estimate for each language group at the county level, and Column 3 shows the
five-year estimate based on the San Diego Public Use Microdata Areas (PUMAs). PUMAs are
nonoverlapping, statistical geographic areas that partition each state or equivalent entity
into geographic areas.
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Figure 2-1: Limited English Proficiency Speakers in San Diego County by Language and Data Source
1 2 3 4 5 6 7 8
Language
LEP
Individuals;
ACS
B16001;
2019 1YR
County
% of
LEP
Individ-
uals
LEP
Individuals;
ACS B16001;
2019 5YR
PUMA
% of
LEP
Individ-
uals
English
Learner
Data;
SD County;
2020–2021
SD Superior
Court
Interpretation
Requests
2019–2020
County of
San Diego
Behavioral
Health
Services
FY 2021–22
MTS
Languages
for Vital
Documents
2019
Spanish
245,246
63.63%
65.08%
67,546
3,609
114,295
Tagalog
(incl.
Filipino)
29,583 7.68% 32,705 7.92% 1,702 207 44 7,988
Vietnamese
24,601
6.38%
6.16%
1,562
245
12,276
Chinese
(incl.
Mandarin,
Cantonese)
22,033 5.72% 23,858 5.78% 1,007 243 42 7,161
Arabic
15,274
3.96%
3.21%
2,668
330
5,091
Korean 7,824 2.03% 7,620 1.85% 574 40 39 2,855
Persian (incl.
Farsi, Dari)
7,501 1.95% 6,499 1.57% 905 240 42 1,301
Japanese
4,511
1.17%
1.28%
510
3
1,181
Russian 4,262 1.11% 4,176 1.01% 537 78 33
Portuguese
3,084
0.80%
0.56%
265
5
Hindi
2,086
0.54%
0.42%
147
French (incl.
Cajun)
1,110 0.29% 1,526 0.37% 203 8
Khmer
1,017
0.26%
0.40%
131
120
Italian
908
0.24%
0.32%
65
1
German
650
0.17%
0.30%
89
3
Telugu 1,119 0.29% 879 0.21% 175
Pashto
310
Kurdish
(Kurdi,
Kurmanji)
220
Armenian
14
6
Turkish
84
2
Polish
38
2
Thai, Lao, or
other Tai-
Kadai
languages
3,221 4,087
Lao 178 44 23 1,347
Thai
65
6
Amharic,
Somali, or
other Afro-
Asiatic
languages
9,938 8,405
Chaldean
1,718
1,989
Somali 796
Assyrian 54 1,591
Amharic
85
Ukrainian or
other Slavic
languages
1,466 1,175
Ukrainian
17
16
The U.S. Census Bureau clusters some languages into families, which means it is impossible
to determine whether some specific languages meet the safe harbor threshold requirement
contained in the U.S. DOT guidance based on the ACS alone. Other data sources must be
consulted to fully understand the San Diego region’s limited English population.
California Department of Education English Learner Data
The California DOE collects data from every kindergarten to grade 12 school in the state on
the number of students learning English as a second language. The DOE data do not
combine data into language families; therefore, the data sometimes can provide more detail
about individual languages within the language families reported in the ACS. For example,
the ACS lumps together Thai, Lao, and other Tai Kadai languages, while the DOE English
Learner data show that this group is predominately Lao in San Diego County. Similarly, the
ACS data do not specifically list Chaldean or Somali as separate languages—the ACS
combines them in a language group with Amharic and other Afroasiatic languages. There is,
however, an active Chaldean community in El Cajon, and CBOs report a recent influx of
Somali-speaking immigrants. DOE English Learner data shows that Chaldean and Somali
speakers account for most of the individuals in this ACS grouping.
The ACS data do not distinguish among Chinese dialects; this is a significant issue because
someone who speaks one dialect may not understand someone who speaks a different
dialect. A further complication arises in relation to written language, because immigrants
from Taiwan, Hong Kong, and Macau—who speak different Chinese dialects—use the
Traditional Chinese writing system rather than the Simplified system used in China and
elsewhere. The DOE English Learner data show that of 1,019 Chinese-speaking English
learners, about 84% are Mandarin speakers, and 15% are Cantonese speakers. Other dialects
make up less than 1% of Chinese-speaking English learners.
The ACS one-year data show more than 1,400 individuals in San Diego County speak one of
the languages in the “Ukrainian or other Slavic Languages” group, which includes Bulgarian
and Czech in addition to Ukrainian. The DOE English Learner data list only Ukrainian
students; none are shown for Bulgarian or Czech. In addition, recent news articles indicate
that the war in Ukraine has increased refugee resettlement in San Diego County. For these
reasons, the analysis suggests that it is appropriate to include Ukrainian in the list of
languages which may exceed the 1,000-person safe harbor threshold.
The DOE English Learner data for San Diego County schools are shown in Figure 2-1,
Column 5.
San Diego Superior Court Interpretation Request Data
The San Diego Superior Court tracks interpretation requests for all nonfederal courts in
San Diego County. These data reflect the language needs of participants in court
proceedings, so they also may reflect the number of individuals involved in court
proceedings by national origin. The data also show far greater demand for Lao interpretation
(44 requests) than Thai (no requests). The San Diego Superior Court interpretation request
data for 2019–2020 are shown in Figure 2-1, Column 6.
County of San Diego Department of Behavioral Health Interpretation Services
The County of San Diego Department of Behavioral Health Services also tracks interpretation
requests. The data appear to confirm Lao is the predominant Tai Kadai language in
San Diego County. The Behavioral Health Services interpreter data for fiscal year 2021 are
shown in Figure 2-1, Column 7.
17
Metropolitan Transit System Four Factor Analysis
As a direct recipient of federal funding, MTS also must prepare a Four Factor Analysis and
LAP based on the U.S. DOT regulations and FTA guidance. The area MTS serves is less than
the entire county; however, any language that meets the safe harbor requirement in the
portion of the county MTS serves also would meet the safe harbor requirement for SANDAG
and the entire county. MTS prepared its most recent Four Factor Analysis in 2019, and it uses
ACS data as well as an onboard survey and records from frontline staff to develop its estimate
of LEP populations in San Diego. MTS defines a person with LEP as someone whose primary
language is not English and who has a limited ability to read, write, speak, or understand
English. This is slightly different from the definition used by SANDAG, which is anyone who
speaks English less than very well.
As shown in Figure 2-1, Column 8, MTS concluded the counts of Lao, Chaldean, and Assyrian
speakers with LEP exceed the 1,000-person safe harbor threshold.
County of San Diego Registrar of Voters
The County of San Diego Registrar of Voters also must comply with both federal and state
language assistance regulations. Although data are unavailable to support its decision on
which language services are provided, translations are provided in Spanish, Filipino, Chinese,
and Vietnamese, and machine translation is provided for other languages via Google
Translate. Translated materials include the entire web page, voter pamphlets, and polling
place signage and information.
Location of Populations with Limited English Proficiency
Title VI of the Civil Rights Act of 1964 prohibits discrimination based on national origin.
National origin discrimination involves treating people unfavorably because they are from a
particular country or part of the world, because of ethnicity, because they speak a foreign
language, or because they speak English with an accent. All those factors can be taken as
indicators of a person’s national origin.
The map in Figure 2-2 shows the distribution of foreign-born persons in San Diego County.
These are persons who are protected by the national origin clause of Title VI, even though
they may speak English very well. There are large areas of the densely populated western
portion of the county where between 25% and 50% of the population are foreign born. There
are three principal areas—south of I-8, along the SR 56 corridor, and along the SR 78
corridor—with significant communities of foreign-born persons.
The map in Figure 2-3 shows the distribution of residents that speak a language other than
English at home. The map in Figure 2-3 closely resembles the general patterns shown in
Figure 2-2 with the addition of some large, low-density areas in east county where residents
speak a foreign language at home. In a number of geographies, including several which
share a border with Mexico, more than 50% of residents speak a language other than English
at home.
18
Figure 2-4 identifies the areas of the county where there are concentrations of population
that do not speak English very well. As previously stated, this is the definition of limited
English proficiency as identified for protection by the U.S. DOT LEP regulations and FTA
guidance. The purpose of this Four Factor Analysis is to identify the people and the
languages they speak, regardless of where they were born. In western San Diego County, the
areas with individuals with LEP follow the same patterns as in the previous maps, focused
south of I-8 and along SR 56 and SR 78, with some additional pockets in the rural portions of
the county. In general, these areas are smaller than the areas shown for foreign born or
speaking a foreign language at home except in the rural part of the county.
Spanish speakers make up the largest percentage of individuals with LEP. Their distribution
in San Diego County is shown in Figure 2-5. There are large concentrations south of I-8 and
along SR 78 in western San Diego, as well as large parts of the rural areas in eastern
San Diego. The corridor along SR 56—which showed large concentrations of foreign-born
residents who speak a language other than English at home or residents with LEP—is not
home to a concentration of Spanish speakers.
The four maps show that SANDAG should expect to encounter persons with LEP in most
areas of the county, especially in the western and southwestern areas of the county.
19
Figure 2-2: Foreign-Born Population in San Diego County
20
Figure 2-3: Speaks a Language Other Than English at Home in San Diego County
21
Figure 2-4: Limited English Proficient Population in San Diego County
22
Figure 2-5: Spanish Speaking Population with Limited English Proficiency in San Diego County
23
SANDAG Safe Harbor Languages
Figure 2-6: Safe Harbor Languages
Based on data from multiple federal, state, and
local sources, it is recommended that SANDAG
provide safe harbor protections to speakers of
the 17 languages shown in Figure 2-6. Each of
these languages is estimated to have at least
1,000 speakers who reside in San Diego County
and who do not speak English very well.
Several of the languages have special
considerations that are important to
understand when providing language
assistance.
Chinese
There are eight major Chinese dialects:
Mandarin (Putonghua), Cantonese (Yue),
Shanghainese (Wu), Fuzhou (Minbei),
Taiwanese (Minnan), Hakka, Xiang, and Gan.
Mandarin (or Putonghua, which means
“common language”) is China’s predominant
language; more than 80% of the population
uses it widely. Cantonese is spoken by many
who live in southern China and Hong Kong,
which is from where most of the early
immigrants to the United States originated. In
addition to the spoken dialects, there are two
forms of written Chinese. China, Malaysia, and Singapore use the fairly modern Simplified
character system, while the Traditional character system continues to be used in Taiwan,
Hong Kong, and Macau.
The DOE English Learner data suggest Cantonese speakers are about 15% of the total
Chinese speakers, or about 3,400 individuals, which meets the safe harbor threshold. There is
no information to determine what percentage of the Mandarin and Cantonese speakers use
Traditional characters; however, it appears likely that a high percentage of Cantonese (from
Hong Kong or Macau) and some Mandarin speakers (from Taiwan) use Traditional characters.
Tagalog/Filipino
More than 180 languages and dialects are spoken in the Philippines, and Filipino, a
standardized version of Tagalog, is the national language. Prior to 1987, because of the
country’s relationship with the United States, English was the sole language of instruction,
and many immigrants from the Philippines spoke English very well. While English remains
an official language, more people speak Filipino than English, and this is reflected in a shift of
English language proficiency among immigrants to the United States. Data show that many
Filipino immigrants today are likely to have LEP.
Safe Harbor Languages
1 Spanish
2 Tagalog (incl. Filipino)
3 Vietnamese
4 Chinese (Mandarin and Cantonese)
5 Arabic
6 Korean
7 Persian (incl. Farsi, Dari)
8 Japanese
9 Russian
10 Portuguese
11 Hindi
12 French (incl. Cajun)
13 Khmer
14 Telugu
15 Lao
16 Somali
17 Ukrainian
24
French/Cajun
French is spoken in Canada; France; and former French colonies in Africa, the Caribbean, and
Asia. Cajun is a version of French spoken in Louisiana that has evolved from the French
spoken by the state’s original settlers, who came from Nova Scotia, Canada. French is the
standard written language in Haiti, used in official documents and the education system, and
many Haitian refugees have found shelter in the San Diego region.
Persian, Farsi, and Dari
Persian is the name of the language known to English speakers. Farsi and Dari are the names
of two distinct accents that Persian speakers use. Generally, Farsi is the name applied to the
language spoken in Iran, and Dari is the name applied to the language spoken in
Afghanistan. Dari and Farsi speakers can understand each other, and the accents’ syntax and
sentence structure are the same.
Ukrainian
As described above, many Ukrainians escaping war in spring 2022 have recently arrived in
San Diego. Jewish Family Services, a refugee resettlement agency in the county, reported
that 400 Ukrainians have resettled in San Diego in the past 12 months, and more are
expected. The federal government has agreed to accept up to 100,000 refugees this year and
many who cross the border from Mexico will land in San Diego. As of April 1, 2022, an
estimated 1,500 Ukrainian speakers were waiting in Tijuana to enter the United States as
refugees; although many will settle elsewhere in the country, some are likely to settle in
San Diego County.
Other Languages/Not Included—Chaldean
As noted above, the ACS combines Chaldean, Somali, Assyrian, Amharic, and other Afroasiatic
languages together into one language “group” containing almost 10,000 individuals with
LEP.
Unfortunately, the data specifically related to Chaldean is not very clear. While the DOE
dataset shows approximately 1,700 Chaldean-speaking English learners in San Diego County,
SANDAG’s CBO partner working in the Chaldean community has suggested that there are an
extremely small number of people with LEP. Chaldean is sometimes referred to as a
language and sometimes as an ethnic, religious, or cultural group, and the language spoken
by members of that community is sometimes also referred to as Suret, Neo-Aramaic, or Neo-
Assyrian, making data collection and identification of translation and interpretation needs
difficult (in fact, the translation/interpretation firm currently used by SANDAG does not have
capacity to provide services in these languages).
Given these challenges, Chaldean is not included in the list of SANDAG safe harbor languages
at the present time. We will continue to investigate this issue going forward, and—as with all
other languages spoken by people with LEP—SANDAG will consider providing language
assistance based on demand or if it is warranted by the location or specifics of a project or
program.
25
3. Factor 2: Frequency that Persons
with Limited English Proficiency
Come in Contact with SANDAG
Information on the frequency that persons with LEP come in contact with SANDAG was
assessed based on a survey of employees, follow-up interviews, focus groups made up of
individuals with LEP from five language groups, and a review of available data collected by
SANDAG on LEP contacts.
Staff Survey and Interviews
There are approximately 400 employees at SANDAG, and all employees were sent an email
with a link to an online survey regarding their interactions with individuals with LEP and the
resources available for communication. About one fourth, or 103 employees, provided
complete responses. The complete survey form is provided in Appendix 1. Among the
respondents, about 37% have contact with the public at SANDAG Board of Directors and PAC
meetings and 34% at general SANDAG meetings and outreach events. The complete
responses are shown in Figure 3-1.
Figure 3-1: In which areas/programs do you have contact with the public? (Check all that apply)
Most of the contacts are in areas that generally receive input or comments on SANDAG plans
and proposals. In areas where SANDAG is providing a service—such as 511, toll roads, or
Motorist Aid—fewer responses reported contact with the public.
21%
14%
3%
5%
6%
8%
11%
11%
12%
17%
19%
25%
28%
30%
34%
37%
0% 5% 10% 15% 20% 25% 30% 35% 40%
None
Other
511, Motorist Aid Services
1-15 Express Lanes
Transit Fare Setting
South Bay Expressway
Transit Planning
Human Resources Recruitment & Selection
Purchasing & Procurement
RTP Planning Efforts
Corridor Planning/Active Transportation…
General SANDAG Information
Regional Planning Efforts
Capital Project Engineering, Design &...
General SANDAG Meetings/Public Outreach
SANDAG Board & Policy Committee Mtgs
26
Figure 3-2: How important is it for limited English speakers to have information regarding
your area/program to access the programs, projects, and services funded by SANDAG?
Figure 3-2 shows that most employees believe that providing individuals with LEP
information about SANDAG programs, projects, and services is important. Only 5% of
respondents believe it is not important for persons with LEP to have information in order to
access programs and services.
However, when asked how often they interact with persons who have LEP, a majority (52%)
say they rarely or never interact with persons with LEP (Figure 3-3). Further, 23% say they
interact only a few times a year. This leaves 32% who interact with individuals with LEP at
least monthly.
Figure 3-3: How often do you interact with individuals with Limited English Proficiency?
Employees were asked how they usually interact with individuals with LEP (Figure 3-4). The
largest percentage report in-person contact as the way they typically interact with
individuals with LEP. Virtual platforms, email, and social media are used by 29% to
communicate with individuals with LEP, and 21% use a telephone for this purpose.
5%
14%
24%
59%
0% 10% 20% 30% 40% 50% 60% 70%
Not at All Important
Somewhat Important
Important
Extremely Important
14%
38%
23%
15%
10%
7%
0% 5% 10% 15% 20% 25% 30% 35% 40%
Never
Rarely
A Few Times per Year
Monthly
Weekly
Daily
27
Figure 3-4: How do you interact with individuals with Limited English Proficiency?
Figure 3-5: What methods do you use to communicate with limited English proficient
individuals?
Figure 3-5 shows the most popular method to communicate with persons with LEP is to find
a bilingual staff member to assist. A later question shows that there are few bilingual staff
members who speak a second language other than Spanish, so this answer is only pertinent
for Spanish language assistance. Six percent of respondents say they use the “I Speak” cards
available at SANDAG, and only 4% use the over the phone interpretation service available at
SANDAG. Twenty-one percent respond to a request by a person with LEP by providing
written information in English rather than having materials translated or seeking
interpretation assistance.
Employees were then asked about challenges when communicating with individuals who do
not speak English very well. The comments are listed in Figure 3-6.
7%
3%
8%
9%
23%
24%
45%
64%
0% 10% 20% 30% 40% 50% 60% 70%
Other
Text
Written Correspondence
Through Social Media (Twitter, Facebook, etc.)
Phone
Email
Virtual Platform (Zoom, Teams, Facetime, etc.)
In Person
15%
4%
6%
12%
20%
21%
27%
33%
51%
0% 10% 20% 30% 40% 50% 60%
Other
Use an Over-the-Pohone interpretation on a…
Use I Speak Card to Identify Language First
Use Sign Language, Hand Signals or Body…
Use Online Translation Tools such as Google…
Provide Written Information in English
Provide Written Information in Their Language
Respond in their Language
Find a Bilingual Staff Member to Assist
28
Figure 3-6: What are some of the challenges you face when communicating with individuals
who do not speak English very well or not at all?
Ability to translate technical terms to similar meaning in their language
Accessing staff who speak their language
Availability of interpreters
Being able to communicate correct program information in their preferred language
Cannot understand what they are trying to say and cannot speak in their language
Determining which language they speak initially
Each member of public has varying levels of familiarity with planning concepts/vocabulary
Ensuring full understanding of the information I am providing
Ensuring proper translation is ready and available
Ensuring that the information that am providing them is clearly understood
Explain in mannerisms that are universal like a thumbs up or point to objects and
directions.
Feeling unable to assist and/or unprepared to assist.
Finding support for a language I may not speak.
Having them understand how to get info on upcoming construction projects.
I am bilingual in Spanish, but one of my coworkers has very limited English conversation
skills.
I depend on the translator.
I do not interact with individuals from the public very often, so this isn’t a common issue for
me.
I don’t know how to find tools that SANDAG already has available for translation and
interpretation.
I don’t speak another language, so it is hard to translate on my own.
I find it challenging to get on the same page efficiently.
I have concerns about the ease of vendors to understand and respond to solicitations
I haven’t faced this, but a challenge can be identifying the language being spoken.
I speak Spanish. I can communicate fluently with Spanish speakers.
I want to be able to help them and wish I could refer them to a help line with translation
I worry that I am being disrespectful when using hand signals, basic words, etc.
Identifying when this service is needed.
Inability to communicate decisively and concisely
It can be difficult to clearly convey planning/technical language.
It’s difficult when translations are not accurate/fitting
Knowing about SANDAG resources to provide live interpreting services.
Knowing when to plan for interpretation services to be present (always?).
Knowing which meetings and documents to prepare in Spanish. Being sure I understand
questions and can follow up.
Learning how to be patient and repeating what they say to confirm what they are saying.
Making sure I have someone who speaks their language and communicate our message.
29
Making sure nothing gets lost in translation and that the outcome for both parties is
understood
Making sure they get the best support/service the need.
My failure to understand Spanish. I have mostly forgotten how to converse
Need more SANDAG staff who speak and resemble the communities we serve.
Not being able to understand questions/requests/input, therefore being able to respond
effectively
Not having translation services readily available, not having text/docs in different
languages
Not knowing what level of proficiency they’re at.
Often individuals use improper terms or slang, so it’s important to ID exactly what info they
seek.
Overcoming frustration
Technical or jargon terms do not translate well into other languages. You need to explain
the terms
The inability to communicate about projects and to understand their questions/input.
The most difficult issue is understanding their question or conversation.
They are shy to ask questions
Translating technical/programmatic information into colloquial Spanish.
Trying to get the information to someone, so they are informed correctly and can get the
best use
Trying to help them without giving them any type of misleading information by accident
Trying to understand each other
Understanding and answering questions
Employees were asked to identify what tools they knew were available at SANDAG to assist
individuals with LEP. Almost one third (29%) are not aware of any tools at SANDAG. The most
frequently cited tool in Figure 3-7 is Google Translate or other web-based translation apps. It
is worth noting that in the focus groups with individuals with LEP, use of Google Translate
and other web-based translation apps is not well received. Only 10% of respondents are
familiar with the over the phone interpretation service available at SANDAG, while a quarter
are aware of the availability of bilingual employees.
30
Figure 3-7: What tools do you have available to provide assistance to people with limited
English capabilities? (Multiple answers acceptable)
The previous LAP prepared by SANDAG in 2019 offered several possible improvements for
communicating with individuals with LEP. For this update, employees were asked if any
improvements had been made in the past three years to enable their department to
communicate more effectively with individuals with LEP. About one quarter (23%) said that
no new initiatives had been taken since 2019, 6% say they sought training in using the over
the phone interpretation service, and 4% requested “I Speak” Cards. The most popular
responses were to use ethnic media to provide information or to purchase advertising in
ethnic or non-English media (14% and 17%, respectively). Eighteen percent of respondents
state that other unspecified programs were added to improve effectiveness.
Employees were asked to rank their satisfaction with the existing tools for assisting
individuals with LEP. The results, shown in Figure 3-8, show that 30% of respondents rank
their satisfaction with a 4 or 5, 47% rank their satisfaction in the middle (level 3), and 24% are
dissatisfied with the existing tools for communicating with individuals with LEP.
29%
14%
7%
10%
14%
25%
26%
38%
0% 5% 10% 15% 20% 25% 30% 35% 40%
None
Other
Dedicated Phone Number in That Language
Access to an Over-the-Phone Interpretation Service
Dedicated Web Content in That Language
A List of Bilingual Employees to Call for Assistance
Brochure or Instructions Card in Their Language
Google Translate or Other App on Mobile Phone or
Computer
31
Figure 3-8: What is your level of satisfaction with existing tools for providing assistance to
individuals with Limited English Proficiency on a scale of 1 to 5, with 5 being highest
satisfaction?
Staff also were asked to identify other tools that could be used to improve communication
with individuals with LEP. Figure 3-9 lists the many suggestions that were received. The
suggestions marked with an asterisk (*) exist and were not known to the person responding.
Better awareness of existing and available tools would be a significant improvement to the
language assistance program.
SANDAG created a list of bilingual or multilingual employees, however the list has not been
kept up to date and has not been widely circulated. The table in Figure 3-10 shows that
although many languages are spoken by employees who responded to the survey, few have
more than one or two speakers, and many of the languages identified in Factor 1 (Arabic,
Korean, Khmer, and Lao) have no speakers. Even if a list were widely circulated, it would be
difficult to keep up to date with staff turnover, and people can be difficult to find because of
meetings, vacations, illnesses, lunch breaks, and other reasons. Further, a person’s own
language skills do not necessarily reflect their ability to provide accurate interpretation.
The distribution of responses by SANDAG departments is shown in Figure 3-11. The data show
that 23% of respondents work in the Regional Planning department, and 12% of employees
are in that department. The Regional Transportation Services department, which includes
Motorist Aid and other services, accounted for just 5% of the survey responses. Some frontline
staff, such as tow truck drivers for the Freeway Service Patrol, are not SANDAG employees
and were not surveyed. Public Affairs (comprising Government Relations and
Communications) is a key department for provision of services for individuals with LEP, and
12% of the responses were from this group. Generally, the responses were proportional to the
departments at SANDAG.
10%
14%
47%
25%
5%
0% 5% 10% 15% 20% 25% 30% 35% 40% 45% 50%
1
2
3
4
5
32
Figure 3-9: What other tools would help you to assist customers who speak limited English?
A better sandag.org website with enhanced “page translation” capabilities
A bilingual phone number or website*
A liaison between SANDAG and limited speaking English communities.
A list of colleagues who are bilingual.*
A list of employees who can translate.*
A list of languages and types of availability and willingness to translate for staff members.*
A list of SANDAG employees and the languages they speak*.
A list of SANDAG staff who speak various languages*. Materials in languages common to
that area.
A list of what SANDAG/my department already has available would be a good start.
access to advertisement and communication sites where we can post notices in multiple
languages*
Access to language tools in languages other than Spanish.
An understanding of the tools not only for Spanish, but other languages.*
Available materials or a list of bilingual staff to contact*
Bi/multilingual individuals, translation guides, knowledge of basic SANDAG related terms
Budget for brochure and marketing materials to be translated and targeted to key
populations*
Creating visualizations with high level information
Google translate “stations” in meeting rooms or ability to take them to meetings
Google translate Podium Pc or pc devices to assist, technology
have other materials translated in other languages outside of English and Spanish*
Have translators translate documents to Spanish or other languages*
Having a SANDAG list where staff can identify other staff who are fluent in another
language.*
help cards or hiring people who speak in other languages besides English and Spanish*
Hire more diverse, multilingual staff to be present at events.
I do not deal with customers face to face. It would be cool though to have a Spanish class
offered
I personally think Google Translate helps enough.
I rarely speak to the general public but I have only had staff help to translate
I think we do a good job with Spanish-speakers at public meetings, but SANDAG staff also
need help.
I think we do pretty well with what we have, but more funding earmarked for this effort
would help.
I would like a better understanding of what tools are available and when they are
appropriate
I would like more direction and consistency on when to include interpretation services at
events.
increased pay for bilingual employees who interact with the public in multiple languages
Knowing what tools SANDAG offers free or for cost, verbal and written, how to access them.*
33
Learn their language
Make it easier to obtain translation services over the phone*.
Maybe have frequently asked questions translated so staff can try if tools aren’t there
Maybe our business cards can have a phone number or a link to a site that could assist.
More awareness and information about the tools that are available.*
More bilingual staff
More bilingual staff
more constantly having the tools and translators available or budget for them to be more
inclusive
More materials available in languages other than Spanish.
More readily available info on SANDAG’s LEP procedures and more access to translation
services.*
More translated we content, real-time interpretation of speakers at Board meetings.
More translations for specific program information
My position doesn’t interact or communicate with the public.
Not sure beyond making sure that all documents and presentations have translations
available.
Recruiting content in different languages specific to the San Diego region.
Something such as google translate that is simple to use.
Standardize all materials to be made available in at least English and Spanish.
The SANDAG tools are good. I do not have any specific suggestions.
Translator*
Updated “I Speak” cards; interpretation resources for LEP callers*
webpages, flyers, on demand SANDAG resources for translation services
Written materials are helpful.
Written materials*
34
Figure 3-10: Do you speak any of these languages fluently?
Figure 3-11: Which SANDAG department do you work for?
4%
0%
0%
0%
0%
0%
0%
0%
0%
1%
1%
1%
1%
2%
2%
2%
4%
26%
61%
0% 10% 20% 30% 40% 50% 60% 70%
Other Dialects or Languages not Listed…
Chaldean
Somali
Lao
Telugu
Khmer
Portuguese
Korean
Arabic
Russian
Japanese
Persian (Including Dari and Farsi)
Cantonese
Hindi
Mandarin
Tagalog or other Filipino Dialects
French (Including Cajun)
Spanish
None
5%
23%
19%
1%
1%
12%
5%
1%
16%
9%
3%
7%
0% 5% 10% 15% 20% 25%
Regional Transportation Services
Regional Planning
Organizational Effectiveness
Office of Independent Auditor
Office of General Counsel
Government Relations and Communications
Financial Programming, Budgets and Grants
Executive
Data Science
Capital Projects and Programs
Business Information and Technology
Accounting and Finance
35
Focus Groups
SANDAG arranged for focus groups to be convened by the CBOs that have a partnership
contract with SANDAG. The CBOs were expected to hold six focus groups with individuals
with LEP with Spanish as a first language; two in Arabic; and one each in Vietnamese,
Tagalog, and Chinese (Mandarin). One CBO was unable to convene their Spanish language
focus group, and as a result, only five Spanish focus groups were held. A $20 gift card
incentive was provided to each participant. The focus groups were held in-person or virtually
using platforms such as Teams or Zoom. Figure 3-12 shows the name of the CBOs that hosted
a focus group and the language of their group.
Figure 3-12: Community-Based Organizations and Focus Group Languages
Community-Based Organization Focus Group Language
Alliance for Regional Solutions Spanish
Bayside Community Center Vietnamese
Casa Familiar Spanish
City Heights Community Development Corporation Arabic
Chula Vista Community Collaborative Spanish
Environmental Health Coalition
Arabic
CSUSM National Latino Research Center Spanish
Nile Sisters Development Initiative Arabic
Olivewood Gardens Learning Center Spanish
Samahan Health Centers Chinese (Mandarin)
Urban Collaborative Project
Tagalog
Vista Community Clinic Spanish
The focus groups were held to help understand, from the perspective of individuals with LEP,
how frequently individuals with LEP come in contact with SANDAG programs, services, and
staff. The language groups were selected based on the prevalence of speakers from the 2019
Factor 1 results and the availability of CBOs that could hold focus groups in those languages.
The questions for the focus groups were specifically targeted to understanding how well
individuals with LEP are able to communicate with SANDAG and to highlight any
communication issues. Training was provided by GCAP, the consultant SANDAG procured for
the LAP update, for the CBO moderators and notetakers. The CBOs were instructed to select
participants who have used a SANDAG service, had some contact with SANDAG in the past,
or wanted to use a SANDAG service or contact SANDAG in the future.
The results of the focus groups generally showed that, in areas where SANDAG provides a
direct service to the public—such as 511, Motorist Aid, or FasTrak—in all language groups,
people were not extremely familiar with the services provided and rarely, if ever, used them.
However, generally, all were interested in beginning to use these services upon
understanding how they work and if the service was available in their language. Many
participants were recent immigrants and appeared to have come from countries where
government assistance was rare, and they were pleasantly surprised to find that assistance
exists here and, in some cases, at no cost to the user.
The features of the 511 system generated some interest as it was explained to the groups,
although it seemed like most people found workarounds or by using other sources (such as
Google Maps and Google Translate) without actually having to use the service.
36
One of the areas with direct impact on recent immigrants with limited English is transit fare
setting since many new arrivals depend on transit as they are getting established. Again, few
participants were aware that SANDAG sets transit fares for the region, and almost none had
participated in the outreach for the fare changes. Most seemed unaware that information is
provided in multiple languages, and most had never seen notices or heard about changes
until implemented.
Few have actually tried to contact SANDAG—partly because they had no need and partly
because they are intimidated by contacting a government agency and are unaware that
they have the right to receive assistance in their language.
Focus group participants from several of the groups had some contact with SANDAG for the
regional planning process. In some cases, the outreach itself was handled by a CBO. Some
provided input with the help of interpreters from the CBOs or family members; however,
many were intimidated by the language barrier. Few had seen translated documents.
No one in any of the groups had ever used iCommute, and all were unaware of the services
available.
SANDAG Data on Contact with Limited English Proficiency
Populations
The U.S. DOT and FTA guidance documents suggest that maintaining accurate information
about the number and nature of contacts with LEP populations is important. SANDAG has not
been consistent in recording LEP contacts in all departments. Records are available for the
number of translation and interpretation requests made to the Public Affairs (previously
Strategic Communications) department. The Toll Operations Center has data on the number of
calls handled by English and Spanish telephone queues. In 2021, almost 10,700 calls (12% of all
calls) to the call center were handled in Spanish. Data also are available for the number of
minutes of interpretation requested, by language, for the over the phone interpretation service.
The Public Affairs department received about 200 requests for translation/interpretation in
the most recent one-year period. The breakdown by language is shown in Figure 3-13. In
addition, consultants working on projects for SANDAG also did translations.
37
Figure 3-13: Translation Requests by Language
Language
% of
Translation
Requests
Spanish
75.2%
Arabic
5.8%
Tagalog
5.8%
Farsi
3.6%
Chinese
2.2%
Korean
2.2%
Vietnamese
2.2%
Somali
1.5%
Pashtu
0.7%
English
0.7%
Simultaneous Spanish interpretation has been available at Board of Directors, PAC, and
several other standing committees since May 2021. A record is not kept regarding the
number of times members of the public speak in Spanish. The Clerk of the Board does not
report any instances of requests for interpretation into languages other than Spanish. As of
May 2022, no mention is being made in the agendas about the availability of simultaneous
translation services.
Meeting agendas state that agenda materials can be made available in alternative languages
with advance notice. The same notice is repeated in Spanish and Chinese but has not been
provided in other languages such as Arabic, Vietnamese, or Tagalog.
Counts are not available for the number of documents printed in alternative languages or
the number of pages added to documents for translated pages, and it is not known how
much resources were spent on this effort.
Front-desk reception at 401 B Street does not keep a tally of calls received or persons arriving
unannounced who require language assistance. Anecdotal information provided by
reception indicates that fewer than 10 contacts per year are made, all in Spanish, with none in
any other language. It is not known if friends or family provided interpretation assistance for
any person contacting SANDAG. The Toll Operations Center has a separate telephone queue
for Spanish customers staffed by bilingual operators.
There has been no recent tracking of the number of individuals with LEP who attend public
outreach events. There also is no estimate of the reach of publications or electronic media in
alternative languages. Based on the anecdotal information received from the focus groups,
SANDAG communications are not being heard or seen widely in LEP communities.
Going forward, tracking should be implemented for the efforts mentioned above for which
no data are available.
Factor 2 Conclusions
The greatest number of contacts with individuals with LEP are in Spanish, which is consistent
with the findings of Factor 1 and reflective of the cross-border planning relationship with and
38
geographic proximity to Mexico. The absence of data showing contact with other language
groups appears largely due to people not being aware of SANDAG, its role, and the services it
provides. Part of this issue is that many recent immigrants and non-English speakers come
from nations that do not have organizations like SANDAG that provide services such as
FasTrak, or no-cost services such as 511, the Freeway Service Patrol, or highway call boxes.
Greater awareness of SANDAG’s role and services in the LEP community will increase
contacts.
39
4. Factor 3: Nature and Importance of
Contact with SANDAG to Persons
with Limited English Proficiency
As already noted, SANDAG provides services, administers programs, and builds projects
which have a direct impact on the public, including individuals with LEP. Accordingly,
SANDAG’s planning activities rely on significant public input.
Examples of such programs include setting fares for public transit and setting toll rates and
rules for FasTrak facilities. Major transportation decisions can have a significant impact on
individuals with LEP, although the impact of decisions made today on future corridors,
modes, or terminals, and hubs may not be felt in the community for many years after being
discussed and decided by the Board of Directors. SANDAG’s regional planning efforts are
critical to the livability of the region, and input from the public is needed, however the impact
of the input received may not be immediately seen.
The 511 system provides information to the public that supplements the data available from
other sources (e.g., traffic and transit information) and emergency response services through
the call box program and Freeway Service Patrol that is not available from any other source.
SANDAG designs and builds active transportation projects, major transit infrastructure, and
highway projects. Those projects require public input during the environmental and
planning stages and involve the posting of safety warnings and construction notices, all of
which should be communicated to LEP populations.
Some specialized programs within SANDAG have limited contact with individuals with LEP
because they are designed primarily to work with businesses or other government agencies.
Examples of such programs could include some aspects of iCommute, the Service Bureau,
ARJIS and the criminal justice program. Nonetheless, even though these functions may not
serve individuals with LEP directly, the products they produce or provide may be of interest
to individuals with LEP.
Focus Groups
Focus groups for individuals with LEP sought to identify the importance of SANDAG in their
lives. There were no control groups of non-LEP speakers with which to compare the results of
the LEP focus groups; having such a control group would have made it easier to determine
whether SANDAG was more or less important to individuals with LEP than to persons who
speak English very well.
The results from the focus groups generally found a poor level of awareness of SANDAG
programs and little contact with the agency. Most people were unaware they have a right to
communicate with SANDAG in their native languages, and many stated they felt intimidated
to communicate with a government agency because of their poor English. Spanish speakers
seemed to be more aware of SANDAG programs and were more willing to communicate
with the agency than members of other language groups.
The focus groups were asked to discuss seven specific areas:
• SANDAG meetings; transportation and regional planning
• Public transit fare setting
40
• 511 website and phone system
• Motorist Aid program
• iCommute
• FasTrak
• General SANDAG communications
A synopsis of the discussion by topic is provided in the following sections. The focus group
moderator’s guide and consent form are provided in Appendix 2.
SANDAG Meetings; Transportation and Regional Planning
Through the regional planning outreach process, SANDAG was able to connect with people
in the major language groups, although not everyone who participated in the focus groups
took part in or was aware of that activity. CBOs were able to generate interest in the process,
and that supported SANDAG’s efforts to reach disadvantaged populations. Many focus group
participants noted the lack of translated written materials, however, and some said they were
too intimidated by the language barrier to participate.
On the one hand, the level of participation indicated the LEP population seemed to find the
regional planning process outreach effort to be important. On the other hand, few
participants attended or took part in regular SANDAG Board or PAC meetings. Generally,
participants believed SANDAG was not providing enough resources in their native languages.
Public Transit Fare Setting
Few participants in the focus groups were aware SANDAG sets the fares for all public transit
in the region, and fewer actually participated in the outreach programs for fare changes,
despite the importance of transit fare changes to many individuals with LEP. Many recent
immigrants may have come from countries where outreach is not conducted for transit fare
changes (or other government programs) and may not be aware they can provide input or
comment on proposals. They may not have recognized the request for input or seen notices
in their native languages. The Spanish language participants who were unaware of the
SANDAG role expressed a strong interest in participating in the future.
511 Website and Phone System
There was little knowledge about the 511 system. Usage seemed to be limited to emergencies
(for Freeway Service Patrol and highway call boxes). It was reported that there were long waits
for a Spanish-speaking telephone operator. When the system was explained, there was
interest, however, the lack of other languages on the phone system would make it almost
impossible for people who do not speak English or Spanish to use. Alternatives such as Google
Maps and content provided by the local transit agencies (MTS and NCTD) offer comparable
transit and traffic information with similar levels of language support. Access to the Motorist
Aid Services appears to be the most important and unique aspect of the 511 San Diego system.
Motorist Aid Services Program
Few participants knew about the Freeway Service Patrol or highway call boxes. However,
when the service was explained, the participants felt it was an important service that should
be more widely advertised to individuals with LEP. There were some who had limited
experience with using the service, and participants noted they encountered long wait times
for assistance in Spanish. Some recent immigrants thought the Freeway Service Patrol was a
form of police and something to avoid, rather than for a service they may turn to for help.
41
It was confirmed that the signs along freeways in San Diego County advising motorists of
roadside assistance are in unilingual English (see Figure 4-1, left photo) and do not use
pictograms, which may help explain the lack of familiarity with the service. This contrasts
with the logo on the vehicles (see Figure 4-1, right photo), which is more self-explanatory.
Figure 4-1: Freeway Sign for Motor Assistance and Tow Truck Logo
Figure 4-2 shows that while signs for the call boxes (on the left) include a pictogram for a
phone, they provide no information on the purpose of the call box, either in English or with a
pictogram.
The unilingual call box sign in San Diego County is contrasted with a typical European sign
(Figure 4-2, right), which uses the universal phrase, SOS, to identify that call boxes provide help.
Figure 4-2: San Diego Call Box Sign and Example of European Call Box Sign
42
iCommute
None of the participants were aware of the iCommute program. This lack of awareness was
uniform across all languages. When the program was explained, there was some interest, but
overall, it did not seem to be an important service for the participants in the focus groups.
The impressions may have been quite different if any of the participants were specifically
interested in joining a vanpool or participating in another commuter-related service.
FasTrak
There was limited familiarity with FasTrak (I-15 Express Lanes and South Bay Expressway/SR
125). Users of I-15 had heard of FasTrak but did not know what it was about or how to acquire
a transponder. Several participants said they would be interested in getting a transponder if
the information was available in their language. Some thought the signs (see Figure 4-3) on
the freeway itself were for trucks because they were not highly informative and did not use
pictograms or other languages. In Figure 4-4, examples are provided of European signs for
electronic tolling, incorporating pictograms that are somewhat more self-explanatory
without using a written language.
Figure 4-3: South Bay Expressway FasTrak Signage
Figure 4-4: Examples of European Signs for Electronic Tolling
43
General SANDAG Communications
Only a few of the participants ever tried to call or visit the SANDAG offices. When they
attended a Board meeting, they used the interpretation service (Spanish). A Filipino
participant attended a Board meeting and understood English enough not to need any
interpretation, and noted only a Spanish interpreter was on site. Participants were not aware
an interpreter for Tagalog could be provided upon advance request, likely because there was
no notice of such availability on the agenda.
Note on Focus Groups
The input from the focus groups indicated that being able to participate in Board activities
and public meetings and to request motorist aid were the most important points of
communications with SANDAG. The focus group process could be improved in the future by
having the groups facilitated by consultants preparing the study or including professional
facilitators who can draw out more information. The selection of respondents should also be
drawn from persons who have had contact with SANDAG. The CBOs were asked to engage
people who were familiar or had contact with SANDAG, however, upon reviewing the results,
it appears few had any contact with SANDAG or experience with SANDAG programs. If the
same process is used in the future, then a control focus group of English speakers might also
be included to determine whether the responses and level of contact of the individuals with
LEP are different from those of non-LEP individuals.
Factor 3 Conclusions
The individuals who participated in the focus groups placed a high level of importance on
being able to communicate with elected representatives though the Board and policy
committees. Transit riders also felt it was important to be able to comment on fare changes.
Even though few had used Motorist Aid, or even knew of its existence, the individuals
participating in the focus groups found the Motorist Aid Services, including the Freeway
Service Patrol and call boxes, to be particularly important. The 511 system, except for
requesting Motorist Aid, was not seen as particularly important because more easily
accessible traffic and transit information alternatives exist. iCommute was not viewed as
important because none of the participants had a need for the services provided.
44
5. Factor 4: Resources Available to
SANDAG and Estimated Costs
The U.S. DOT Guidance on LEP recognizes the level of language assistance provided by
agencies will differ based on the size of the establishment and the resources or budget
available. The guidance directs agencies to take reasonable steps to provide language access,
but if the costs substantially exceed the benefits, additional actions may not be necessary.
The guidance points out costs can be minimized through technology, reasonable business
practices, sharing of language assistance materials, and partnering with advocacy or
community groups. SANDAG has embraced new technology (e.g., Google Translate), adopted
reasonable business practices (e.g., Toll Operations Customer Service Center bilingual
resources), and incorporated partnering with community groups (e.g., Regional Plan Social
Equity Working Group and CBO partners).
Resources for Language Assistance at SANDAG
The total resources dedicated to supporting individuals with LEP is not available in a single,
dedicated location. Typical language assistance costs include the items listed below; actual
costs are only available for the items marked with an asterisk (*):
• One full-time, Spanish-speaking, translation/interpretation coordinator*
• Translations sent to outside translator by SANDAG translation/interpretation coordinator*
• Time spent by bilingual employees providing on-the-spot interpretation or reviewing
translated documents
• Printing of separate or additional documents/items in Spanish and other languages
• Over the phone interpretation services*
• Total advertising in foreign languages in print and electronic media
• Translation/interpretation costs by consultants working on SANDAG projects*
• Interpretation at public outreach events and other public meetings*
• Interpretation at Board and PAC meetings*
• CBO partner relationships, which provide more engagement with LEP populations
Providing services for individuals with LEP is not a single-cost item in the budget, and the
costs are not in a single department. Some costs (e.g., printing of multilingual documents)
are not separately tracked. Specific projects, including planning and capital projects, may
also spend resources to provide communications in other languages, but there is no tally of
the costs.
45
Identifying Language Assistance Expenditures
A number of resources point to where else SANDAG might have assigned or spent funds for
language assistance.
The SANDAG Overall Work Program (OWP) for FY 2022 includes a total of $12.375 million for
contracted services, of which $1.682 million was allocated to support public engagement and
communications. In the actual budget document, one contract had a specific line item for
Spanish interpretation services ($6,000), and many of the contracts also contained
translation and interpretation services requirements for Spanish and other languages. In
addition to translation and interpretation, there are costs for printing separate or additional
pages for additional languages in reports and plans.
Chapter 1 of the FY 2022 OWP includes a statement on public involvement, and refers to the
Commitment to Equity statement and the need to eliminate disparities and include
opportunities for everyone. There is, however, no mention of any support for providing
language assistance in social media, print and electronic media, or websites.
Board Policy No. 25, Public Participation Plan policy, includes specific requirements for
ensuring public participation, such as measures that reach out to individuals who have LEP.
Public involvement program strategies are found in several specific OWP task descriptions,
and the need for providing language assistance activities is identified in one, Public
Involvement. In this category, about 15% of $610,000 is dedicated to communications for
underrepresented communities, including low-income communities, people of color,
persons with disabilities, older adults, tribal nations, and individuals with LEP. That includes
production of materials in various other languages.
Content in other languages is produced for many projects, however, there is no
acknowledgement of such tasks in the budget or specific budget allocation. Other budget
elements also make no mention of the use of additional languages for any print, digital, and
broadcast advertising copy, videos, public-facing websites, social media content, email blasts,
or other forms of engagement.
The OWP for Government Relations likely includes some costs for language-related activities
because it includes a cross-border working group and relations with agencies in Mexico.
Major projects such as Otay Mesa East Crossing and Central Mobility Hub also include
translation, interpretation, and media costs for other languages. iCommute has a contract
with an external consultant for outreach, and the contact may include expenses directly
related to individuals with LEP. The Office of Diversity and Equity has two OWPs which may
include costs associated with language assistance initiatives.
A new cost code for translation and interpretation expenditures was created in the budget
tracking system, and took effect on July 1, 2022; it is anticipated that this will streamline
tracking of these expenses.
46
Assessing Language Assistance Expenditures
One possible means of measuring the reasonableness of expenditures on language
assistance is to compare the percentage of funds expended with the percentage of LEP
population in the SANDAG service area.
Individuals with LEP constitute about 13% of the total population of San Diego County. As a
rough measure, one would expect at least 13% of the total communications budget to be spent
on communicating with individuals with LEP. Because costs such as translation and
interpretation increase the costs for communications to individuals with LEP, it would be
reasonable to assume costs could be greater than just 13% of the total communications budget.
In the 2021 OWP, the total budget for external support and communications is $6.76 million,
of which $1.06 million is directly allocated to public involvement and marketing. Known costs
associated with meeting the requirement to serve LEP individuals are limited; they include,
at a minimum:
Estimated annual cost for on-call contract for translation and
interpretation
$117,000
Annual fully burdened cost for in-house translator and language
coordinator
$115,000
Estimated cost: advertisements in foreign language media, printing,
and miscellaneous*
$50,000
Total estimated annual costs for providing service for individuals with
LEP
$282,000
*Exact figures are not available; this is a rough estimate of costs.
With direct language assistance costs estimated to be about $282,000, the expenditure is
equivalent to about 27% of the direct communications costs, excluding project
communications costs, which are budgeted separately. If more project communications
costs are known and included the percentage for LEP communications would increase.
Using this method, it appears that percentage of costs associated with providing service to
individuals with LEP exceeds the percentage of LEP population in San Diego County. This is a
rough indication that SANDAG resources are reasonable.
Factor 4 Conclusions
The federal guidance on providing service to individuals with LEP encourages agencies to
provide as many services as reasonable to as many language groups as possible who meet the
safe harbor threshold. The guidance leaves it to local decision makers to determine the
appropriate level of service and determine whether the costs are reasonable and sustainable.
To assess whether the costs and resources are reasonable, the expenses for communications
with persons with LEP should be tracked, which is not currently happening at SANDAG.
Without those records, it is impossible to positively determine whether the resources and level
of effort for meeting the challenge of providing services to populations LEP are reasonable.
It is recommended that the financial record-keeping system be modified to capture costs
associated with actual (and future) expenses in categories such as:
• Translation and interpretation services
• In-house translators and language coordination
• Advertising in foreign language media
47
• Over the phone interpretation service
• Printing documents in other languages
• Pay differential for bilingual employees (under consideration)
• Capital/leasing costs associated with multilingual Interactive Voice Recognition (IVR)
systems
• Capital/leasing costs for interpretation hardware
Keeping good records of resources allocated to communicating with individuals with LEP is a
best practice that will ensure the agency has documentation of expenditures which support
SANDAG’s commitment to providing language assistance.
As noted above, using a simple comparison between the percentage of the LEP population
in San Diego County and the percentage of known budget committed to language
assistance activities, SANDAG is meeting the standard suggested in the U.S. DOT guidance.
The next section, the LAP, will review measures being taken and determine whether
alternative or additional actions are needed.
48
6. Language Assistance Plan
Introduction
It is SANDAG’s policy to provide timely, meaningful access for persons with LEP to its services
and decision-making processes. SANDAG communicates with individuals with LEP in person
and over virtual platforms, over the phone, in writing, and through digital media as provided
in this LAP. The LAP will be updated every three to five years to ensure alignment with the
most recent Four Factor Analysis, the SANDAG Equity Action Plan, and any significant
changes in the SANDAG Title VI Program.
The LAP is an important component of SANDAG’s Commitment to Equity. An effective LAP will
help ensure historically underserved, systemically marginalized, linguistically isolated groups
can receive the full benefit of SANDAG programs, services, and facilities, and can participate in
public engagement opportunities conducted by SANDAG. SANDAG is committed to creating a
region where every person, regardless of the language they speak, can thrive.
This LAP for SANDAG has seven elements:
1. Prioritize safe harbor languages to provide appropriate language assistance
2. Identify persons, departments, and staff advisory group language assistance
responsibilities
3. Identify vital documents
4. Determine high-level and program-specific language assistance measures, including
existing and proposed
5. Consider efforts to increase availability of bilingual employees
6. Provide training for staff on language assistance requirements
7. Advocate internally and externally to enable SANDAG to better serve individuals with LEP
Each of these elements is described in the following sections.
Safe Harbor Languages and Language Priority Groups
The Four Factor Analysis identified 17 languages (including two dialects of Chinese) that
meet the safe harbor threshold. The number of persons ranged from more than 245,000
Spanish speakers to an estimated 1,000 Ukrainian speakers. Spanish is the language most
spoken by persons with LEP and—given factors such as the historical role of Spanish in the
region, the close relationship with Mexico, and cross border flows of people—Spanish has a
unique importance for SANDAG. Four more languages—Chinese, Tagalog, Vietnamese, and
Arabic—have significant populations of LEP persons (15,000–30,000 individuals). There are
12 additional language groups consisting of between 1,000 and 7,500 individuals that meet
the threshold for safe harbor designation. Language groups with fewer than 1,000 LEP
individuals in San Diego County do not meet the requirement for safe harbor designation.
49
The wide range in the sizes of the language group populations and the historical and
geographic proximity issues support the use of priority designations to develop language
assistance measures. (Note that while Chinese is listed as one language in the safe harbor
languages list, Mandarin (for oral communication) and Simplified (for written) are designated in
Language Priority Group 2 and Cantonese and Traditional are designated in Language Priority
Group 3.)
Figure 6-1: Language Priority Groups
Priority 1 Priority 2 Priority 3
Spanish
Tagalog/Filipino
Vietnamese
Chinese: Mandarin (oral);
Simplified (written)
Arabic
Chinese: Cantonese (oral);
Traditional (written)
Korean
Persian
Japanese
Russian
Portuguese
Hindi
French (incl. Cajun)
Khmer
Telugu
Lao
Somali
Ukrainian
Departments and Staff Responsibilities
Implementation and monitoring of this plan is the responsibility of the Organization
Effectiveness (OE) Department. The Office of Diversity and Equity, within OE, is responsible
for compliance activities related to providing language assistance under the Title VI
mandate, including updating the Four Factor Analysis and LAP, and developing and
delivering Social Equity training. Other staff in OE have important responsibilities for
implementing the LAP, including providing language assistance resources to project
managers and coordinating translation and interpretation requests. OE staff partner closely
with the Public Affairs Department responsible for developing outreach and public
information and materials.
An interdepartmental working group was created to provide input to this LAP update. It is
recommended that, going forward, the knowledge and experiences of that group be tapped
to provide employee input on language assistance issues.
50
Vital Documents
The U.S. DOT LEP Guidance requires each agency to identify a list of vital documents that
must be translated into the languages identified in the Four Factor Analysis. The U.S. DOT
guidance states recipients are not required to provide written translations of vital documents
for all safe harbor languages, however, if they do so, the FTA will consider it to be strong
evidence of compliance with the recipient’s written translation obligations. SANDAG has
divided the 17 languages into three priority groups, as described above, and identified how
the language groups prioritization shall be applied to the translation of vital documents.
Language groups will be reevaluated when the LAP is updated.
Vital Document Identification
The determination of the vital status of a document is an ongoing process. Documents will
evolve, and so will their importance. Thus, document classification is divided into the three
tiers, as follows:
Tier 1 Documents
Tier 1 documents are the highest priority. They are considered vital documents and include
documents and media that:
• Provide notice of a person’s rights under Title VI of the Civil Rights Act and the processes
by which complaints can be filed
• Allow persons with LEP to participate in the core functions of SANDAG, including
providing public comment and accessing services
• Provide executive summaries of the Regional Plan and Title VI Program updates
• Provide notices on public safety or construction closures
All Tier 1 documents will be translated manually for Spanish (Priority Group 1) and Priority
Group 2 languages. Translations for Tier 1 documents for languages in Priority Group 3 will be
available on demand. Care should be taken to ensure the format of documents can facilitate
machine translation, if that is the method provided for translations; upon special request, and
depending on available resources, a decision may be made to provide manual translation of
specific documents in this tier for language Priority Group 3.
Examples of Tier 1 documents include:
• Board Policies No. 07 (Equal Employment Opportunity (EEO) and Disadvantaged
Business Enterprise (DBE) Programs) and No. 09 (Discrimination Complaint Procedures),
and associated brochures, notices, and forms
• Fare change proposals and notices
• FasTrak user information including customer applications, agreements, terms and
conditions, and instructions for how to access services
• Freeway Service Patrol user information, including how to access services
• Public safety and access information triggered by major regional planning efforts such as
GO by BIKE and the Regional Plan
• Information about ballot measures that concern funding for transportation and mobility
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Tier 2 Documents
Tier 2 documents include documents and media that enhance a customer’s experience or
encourage involvement in the planning process. Tier 2 documents would be manually
translated at all times for language Priority Group 1 and be available by machine translation
for Priority Groups 2 and 3. Care should be taken to ensure the format of PDFs can facilitate
machine translation. Upon request, and depending on available resources, a decision may be
made to provide manual translation of specific documents in this tier for language Priority
Groups 2 and 3.
Examples of Tier 2 documents include:
• Project fact sheets and other collateral pieces that are not deemed instructions for use;
including maps and copy on images
• General Freeway Service Patrol, South Bay Expressway, and FasTrak information that is
not deemed to be critical user information, including marketing materials and additional
collateral and complete promotion terms and conditions
• 511 user information including how to access services
• Other civil rights policies such as the American with Disabilities Act policies
Tier 3 Documents
Tier 3 includes information that will enhance the role that all individuals, regardless of
language ability, might have in SANDAG planning efforts, services, and operations. For Tier 3,
machine translations should be available for all three priority groups. Upon request, and
depending on available resources, a decision may be made to provide manual translation of
specific documents in this tier for any of the language priority groups. Examples of Tier 3
documents include:
• Information regarding SANDAG Board of Directors, PAC, SSTAC and any other meetings
subject to the Brown Act, including agendas and minutes
• Information regarding regional, corridor, and transit fare efforts, including study
documents and reports
• General SANDAG information, including marketing materials and collateral
• General information regarding major regional planning efforts such as GO by BIKE and
the Regional Plan
• General project and program information, including about 511, iCommute, Freeway
Service Patrol, South Bay Expressway, and FasTrak, including marketing materials,
additional collateral outside of instructions for use, and complete promotion terms and
conditions
The form these translations will take should be determined on a case-by-case basis as the
documents are published. In many cases, translation of an abbreviated summary document
might be most appropriate. In some cases, notice of language assistance might be sufficient.
Machine translation should always be available, and care should be taken to ensure the
format of provided documents can facilitate machine translation. Upon request, and
depending on available resources, a decision may be made to provide manual translation of
specific documents in this tier for language Priority Groups 1, 2, and 3.
For each tier, SANDAG will assess documents against available resources or alternatives.
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Language Assistance Measures
Existing and proposed language assistance measures at SANDAG are listed below. High level
initiatives are followed by program-specific initiatives. In some cases, initiatives are shown
which have been previously recommended and are not yet implemented (or fully
implemented); in these cases, efforts are underway to implement promptly.
General SANDAG Communications
• Bilingual English/Spanish employees provide assistance on the phone and in person
• All staff have access to over the phone interpretation service
• “I Speak” cards for staff having public or customer contact
• In-house certified English/Spanish translator, and internal translation review by native
Spanish speakers
• SANDAG webpages for many programs fully translated into Spanish; work toward
ensuring that clicking on links within Spanish-language content does not lead to English-
only content
• Google Translate toolbar on each webpage; work toward standardization of location and
functionality
• Non-discrimination notice, including notice of Title VI rights and complaint procedures,
and notice of availability of language assistance included in Board policies and on
website
• Grant agreements contain language to ensure language assistance requirements are
met by grantees
• On-call contracts for document translation and interpretation services
• Translation and interpretation tracking system
• Dedicated cost code streamlines tracking interpretation and translation expenditures in
the budget system
• Spanish translation style guide and Spanish language glossary
• Internal intranet provides information about translation and interpretation services,
including procedures, language assistance resources, vital documents guidelines, and
more to all employees
Oral Interpretation
Oral interpretation services are an important element of language assistance. This effort can
be improved by:
• Providing instructions and training on the use of over the phone interpretation service to
all employees, including information about how to get interpretation during a public
outreach event
• Ensuring front-line positions such as reception, tow truck drivers, and call centers are
staffed with fluent bilingual English/Spanish employees
• Evaluating delays in responding to requests for service (general reception, motorist aid,
511, operations call center, iCommute) in languages other than English
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• Providing notices on Board, policy committee, SSTAC, and other relevant agendas about
the availability of Spanish simultaneous interpretation and means to request in other
languages
• Developing protocols to ensure that bilingual employees are available at external events
Written Translation
The written translation services provided by SANDAG include:
• The SANDAG non-discrimination notice, including notice of Title VI rights and complaint
procedure, is translated into Language Priority Groups 1 and 2 and available for use in a
variety of written and digital materials
• Notice of the availability of language assistance is translated into all Language Priority
Groups; in conjunction with the Free Language Assistance Notice (see below), it provides
the means for persons with LEP to easily identify the availability of language assistance
• An icon which identifies toolbars, QR codes, links, or statements on language access has
been developed and should be implemented wherever possible
• Manually translating documents and materials into languages other than those identified
in the Tiers (above) when a project is located in a community with a large number of
persons with LEP
Language Assistance Toolkit
SANDAG language assistance materials are collected and made available to all employees in
one centralized location. This Language Assistance Toolkit contains the resources staff,
especially project managers, are likely to need, including existing internal document
translation and interpretation procedures (the Language Assistance Guidelines, SANDAG
Translation Procedures, and Translation and Interpretation Request Form). The Toolkit should
be reviewed, updated, and expanded regularly, distributed to project managers and other staff,
and located in an easy to find section of the SANDAG intranet (SharePoint). Additional
materials, such as training materials and videos, language glossaries, instructions for using the
over the phone interpretation service, should be added to the Toolkit as they are developed.
Free Language Assistance Notice
SANDAG has made significant strides to provide language access through use of bilingual
employees, over the phone interpretation services, and translated documents. To ensure all
those with LEP understand the availability of these various efforts, the LAP proposes to
implement a Free Language Assistance text block and image. This notice will be added to
written content—both printed and digital—to notify the public that language assistance is
available in all the safe harbor languages. The notice will contain a phone number for
contacting SANDAG, and staff answering this number will use the over the phone
interpretation service, if needed, to communicate with the caller. The notice will also direct
an interested person to a dedicated webpage containing details about SANDAG’s
commitment to provide language assistance, translated content, and information about how
to use available translation tools. Going forward, a QR code could be added to the Free
Language Assistance notice to streamline access to this website.
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Figure 6-2: SANDAG Free Language Assistance Notice
Digital Information
Digital media is an increasingly important means of communicating with persons with LEP.
Widespread access to smart phones and computers has made it easier and faster to get
information into the hands of the public. Machine translation and interpretation is becoming
more accurate every year and has significantly improved the ability of SANDAG to make
information available to individuals with LEP.
LEP access to SANDAG digital media resources has not grown as quickly as access to
information for persons who can speak English. Examples of areas with opportunities for
improvement are web pages and social media, especially given tools on many digital
platforms which provide users with the opportunity to set their own language preferences
(triggering automatic translations).
Social Media Strategic Plan
Under development at the time of the preparation of this LAP, the Plan will address how
SANDAG uses social media, including for communication with individuals with LEP. It is
recommended that staff from appropriate departments (including OE, Office of Diversity and
Equity, and Public Affairs) work together to ensure guidelines in the Social Media Strategic
Plan align with the recommendations included in this LAP, and should include:
• Recommendations about when to translate content for social media
• Guidance about providing same information to speakers of different using culturally
appropriate language
• A list of the top languages expected to be encountered in the social media realm, and
recommendations for translating content, following requirements and recommendations
in this LAP
Websites
Websites are an important method for communicating with the public, including persons
with LEP. A redesign of the SANDAG.org website is in progress, including improvements for
language access and ADA accessibility. SANDAG already provides much content in Spanish
along with the Google Translate toolbar for other languages, and SANDAG will continue to
create dedicated Spanish language websites for certain projects.
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A new SANDAG webpage (sandag.org/LanguageAssistance) was recently created. It is
envisioned to be a centralized source of translated materials, information about SANDAG’s
language assistance efforts, and guidance about using translation tools and/or requesting
translation or interpretation assistance. Links to this site will be located on other webpages
throughout the SANDAG website. In conjunction with the Free Language Assistance Notice
(above), it can provide a streamlined way for persons with LEP to use the SANDAG website.
A review of several SANDAG webpages revealed some inconsistencies with the Google
Translate toolbar (see screenshots in Figure 6-3). On three pages, the toolbar was located at
the bottom of the page and only labeled in English without any icon or pictogram. On one,
the bottom of the page was more than a full page beyond the initial splash screen, although
a link for Spanish content was found near the top. A fourth site, for the South Bay
Expressway, which serves the Mexican border and covers an area with many Spanish
speakers, did not have the translation toolbar.
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Figure 6-3: SANDAG Web Pages
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Figure 6-3: SANDAG Web Pages (Continued)
58
On the SANDAG pages with Google Translate where the viewer clicks on a link to a PDF, the
PDF usually comes up in its original English form; no tools or instructions are provided for
obtaining the information in alternate languages.
To enhance the experience of individuals with LEP, improvements to SANDAG’s web
presence through the website redesign should include:
• Improving usability of the translation toolbar by locating it at the top of each page, in a
contrasting color, and including a special icon, such as shown on the MTS website
(Figure 6-4)
• Ensuring that documents available on the website are either able to be translated in the
browser or downloaded and easily translated to the greatest extent possible
• Ensuring information about requesting translation of documents found on SANDAG sites
is easy to find and easily understood
• Eliminating the use of images containing text (which cannot be translated)
• Translating the South Bay Expressway website into Spanish, similar to the San Diego
Forward web content
Figure 6-4: Metropolitan Transit System Website Home Page
In addition to high-level language assistance measures, program-specific language
assistance measures at SANDAG include the following:
SANDAG Board, Policy Advisory Committees, Social Services Advisory Committee
• Simultaneous interpretation available in English/Spanish at every meeting, including
virtual/hybrid meetings
• Notification of non-discrimination, Title VI rights, and complaint procedures provided on
agendas
• Agenda notice that materials can be made available in alternate languages
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Regional Planning, Transportation Planning, Corridor Planning
• Interpretation provided at public meetings/workshops based on invited or expected LEP
audience
• Bilingual English/Spanish staff attend public meetings and workshops in areas with high
concentrations of Spanish-speaking LEP populations
• Bilingual English/Spanish court reporter present at meetings where public comment is
requested
• Notifications for document review and comment periods and for planned environmental
analysis provided in English/Spanish
• Fact sheets, fliers, brochures, and comment cards; surveys for workshop/community
meetings; and some web content produced in English/Spanish; some content in other
languages produced as appropriate
• Informational videos and webinars in English/Spanish (voiceover or subtitles)
• Partnerships with Social Equity Working Group and other CBOs to encourage
participation from and ongoing engagement with underrepresented groups including
those with concentrations of LEP populations
• Periodic, region-wide public opinion surveys in English/Spanish
• Surveys translated to other languages depending on LEP populations in project areas
• Use of CBO database to provide information to organizations that serve LEP communities
511 Website and Phone System
• Bilingual English/Spanish IVR phone system; work toward improving/streamlining
Spanish voice recognition
• Bilingual English/Spanish operators at roadside assistance service centers
Transit Fare Changes
• Public comment information printed in English/Spanish in regional and local newspapers
• Bilingual English/Spanish staff attend public meetings and workshops in areas with high
concentrations of LEP populations
• Public notices provided in English/Spanish when fare changes are being considered
• Community outreach materials provided in English/Spanish when fare changes take
place
• Fact sheets and comment cards produced in English/Spanish in areas with high
concentrations of LEP populations
• Onboard transit rider survey conducted in English/Spanish, and additional languages
through digital format as needed
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Motorist Aid
• Written and online customer survey produced in English/Spanish
• Web content provided in Spanish
• Bilingual English/Spanish Freeway Service Patrol drivers with one driver currently fluent
in Chaldean (as available—bilingual skills not required by contract)
• Laminated information cards in Tier 1 and Tier 2 languages, with photo depictions of
services offered; include notification of this feature on website
• Spanish language media purchased for marketing campaigns
• Informational rack card in English/Spanish
• English/Spanish informational insert in registration wallet that is handed to all motorists
after receiving service
• English/Spanish card inviting motorists to share their experience by taking the survey or
writing a review on Yelp
I-15 Express Lanes, South Bay Expressway, and FasTrak
• Bilingual English/Spanish IVR phone system; work toward improving/streamlining
Spanish voice recognition
• 88% bilingual English/Spanish customer service representatives; additional
representatives fluent in other safe harbor languages; Bilingual skills shown as preferred
in job description
• Bilingual staff participate in outreach events in areas with high concentrations of LEP
populations
• Printed and digital materials (brochures, application forms, marketing material) in
English/Spanish
• English/Spanish automated cash machines at toll road on/off ramps
• FasTrak customer surveys translated into Spanish
• Spanish language media purchased for marketing campaigns
iCommute
• Bilingual English/Spanish operator
• Bilingual staff sent to employer and community meetings as needed
• Spanish language media purchased for marketing campaigns
• Program applications and rules/agreements, and Vanpool program webpage, provided in
Spanish
• Collateral, including employee surveys, translated into Spanish and other languages as
needed
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Bilingual Employees and Pay Policy
Spanish is the only language in Language Priority Group 1. More than 240,000 Spanish-
speaking residents in San Diego County do not speak English very well. As a border
community, the region witnesses a large daily influx of Spanish-speaking individuals with
LEP who may need to access services such as 511, Motorist Aid, or the South Bay Expressway.
There is a demonstrable need for public offices in San Diego County to provide services to the
Spanish-speaking population. Bilingual employees are the key to meeting that need.
Currently, SANDAG has a number of bilingual employees in positions at the Toll Operations
Center and other locations and on contracted service such as the Freeway Service Patrol.
However, neither the positions not the contract are classified as requiring written or verbal
communication skills in languages other than English.
Many California government departments and local governments across southern California
have certain positions that require employees to be fluent in Spanish. In conjunction with
this requirement, the agencies have implemented standards for demonstrating language
abilities, and provide eligible employees a bilingual pay differential. Within San Diego County,
the County and many cities (e.g., San Diego, Chula Vista, Carlsbad, Encinitas, Escondido,
National City, Oceanside, etc.) have policies that provide bilingual pay, including processes for
identifying and approving positions, testing procedures, and setting the additional amount
of a pay an employee may receive. (It should be noted that State law provides that an
employee in a position newly categorized as bilingual may not be terminated because of
their inability to meet such a new requirement.)
This LAP proposes to increase the availability of bilingual employees at SANDAG though
research and possible implementation of a new Bilingual Pay policy and related
administrative procedures. Creation of a Bilingual Pay policy would provide an opportunity to
test or certify employees to ensure those representing SANDAG have a sufficient grasp of the
required language to represent the agency. The annual cost of providing a bilingual pay
differential would be estimated as part of the initial research and development of the new
policy; this estimate would include the identification of positions that might be designated as
requiring bilingual staff and the costs for language testing to confirm the fluency of existing
and potential new employees.
If a bilingual pay policy is implemented, it should include a procedure whereby Human
Resources, program managers, and Directors would periodically evaluate job responsibilities
to identify the employees who use bilingual (English/Spanish) skills on a regular basis.
Further, as part of establishing eligibility for bilingual pay, the employee would be required to
demonstrate proficiency through a standardized testing process offered by a third-party.
Areas that may be reviewed in the development of the bilingual pay policy might include Toll
Plaza attendants, Customer Service representatives, receptionists, those involved in Borders
Programs, and Planners and Communications staff, to name a few examples.
Only 21 employees have currently agreed to be on the list of employees willing to use their
second language abilities. In the survey conducted for this LAP update, 28 employees said
they would be willing to use their second language skills. Putting extra attention and
developing procedures for engaging employees’ assistance, along with simply providing an
opportunity for new employees to add their name to that list, could increase employee
support for these efforts. A Bilingual Pay Policy may provide one additional incentive for
bilingual employees to be recognized for using their language skills at work.
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Training on Limited English Proficiency Requirements
The key to a successful LAP is having staff who understand the state and federal laws,
regulations, and guidance for providing service to individuals with LEP and know what
resources are available at SANDAG to meet the mandate.
As part of the orientation for new employees, a training session about civil rights and
language assistance at SANDAG should be provided. The training should cover state and
federal laws, regulations and guidance, and the resources available at SANDAG. Each new
project manager should be provided with the Language Assistance Toolkit, and employees
likely to receive phone calls from the public must be trained in the use of the over the phone
interpretation service.
Language assistance training for continuing employees should be provided each time the
LAP is updated; if convenient, the training can be combined with other civil rights training
programs.
Advocate for Measures to Advance Access for Persons with
Limited English Proficiency
Internal
In the past, one of the challenges for SANDAG to providing service to individuals with LEP
was the absence of a dedicated resource committed to overseeing the implementation of
previous LAPs. Prior to 2018 and the creation of the Department of Diversity and Equity there
were limited staff dedicated to Title VI and language assistance. There was no one at
SANDAG actively looking at the LAP to ensure that recommendations were being
implemented or that translation and interpretation were being provided appropriately.
Today, responsibility is more clearly defined and going forward implementation and
compliance will be enforced.
External
One of the issues that was raised in the focus groups was the lack of multilingual signage for
SANDAG-provided services along highways in San Diego County. Signs for Motorist Aid/511,
call boxes, and warning and explanations for the I-15 Express Lanes and South Bay
Expressway were specifically mentioned in several focus groups for this project.
The Federal Highway Administration has developed signage standards for highways in the
United States. The standards are found in the Manual on Uniform Traffic Control Devices
(MUTCD); in addition, individual states can add on to the standards for signs found only in
their state. California has created a California MUTCD that supersedes the federal document
and contains a number of signs and devices unique to California.
Other states near the Canadian border have signs with English and French in recognition
that there are a significant number of French-speaking persons who drive across the border
into the United States. Examples of the signs are shown in Figure 6-5 and provide a variety of
information, from directions to regulations or just welcoming visitors. In some cases, the
signs have French and English side by side so that people can become familiar with the
meaning and still understand the English version of the sign when the French version is not
present farther from the border.
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Figure 6-5: Examples of Bilingual U.S. Highway Signs Near Canadian Border
Vermont
New York
New York
Massachusetts
New Hampshire
New York
Caltrans District 11 includes San Diego and Imperial Counties and is the only district along the
Mexican border. SANDAG should join with Caltrans District 11 and request that the California
MUTCD be updated to include signage for use within fifty miles of the border that
incorporates pictograms, universal symbols, or Spanish. The signs would not replace the
existing signage; they would provide additional information to enable persons with LEP to
understand the basic function of the toll roads, express lanes, emergency call boxes, and 511
Motorist Aid.
This change would be beneficial to local LEP residents as well as border crossers from Mexico,
who contribute significantly to the San Diego economy. Caltrans receives federal funding
and is therefore also subject to Title VI of the Civil Rights Act and its LEP requirements, as
well as State of California requirements, to serve LEP communities. Advocating for improved
highway signage for LEP communities within San Diego County is consistent with the
SANDAG Commitment to Equity.
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7. Monitoring and Updating
Introduction
The LAP will be reviewed and updated, if necessary, every three to five years, to ensure
alignment with the most recent Four Factor Analysis, the SANDAG Equity Action Plan, and
any significant changes in the SANDAG Title VI Program. The Director of Diversity and Equity
is responsible for the review and update of the documents and for monitoring the
implementation of the plan, which falls under the Department of Organization Effectiveness.
The overall goal of the monitoring program is to measure the performance of SANDAG’s
language services and make adjustments and improvements as required. Both qualitative
and quantitative data should be examined. The monitoring program will ensure SANDAG is
compliant with federal regulations and that its efforts to communicate to persons with LEP
are cost-effective and provide meaningful access for target populations. The monitoring
program will reveal the strengths and weaknesses of the current program and point toward
potential enhancements.
As part of the update of the LAP, a working group of SANDAG staff members was convened
to review the work and provide input on the project. Creating a permanent working group of
staff members to provide input on language assistance services would be beneficial. Linking
the group to the staff panel on social equity issues would reaffirm the importance of
language assistance at SANDAG.
Quantitative Data
Monitoring quantitative data would aid in preparing updates of Factors 1, 2, and 4 in the
Triennial Four Factor Analysis. There are four elements to measuring language programs
quantitatively:
• Documenting the number of resources committed to the program
• Identifying the number of contacts with individuals with LEP
• Tracking the number of products produced in alternative languages
• Identifying changes in the demographics of the county that could affect the safe harbor
language list
Documenting the number of resources committed to meeting LEP requirements will require
additional changes to the accounting practices at SANDAG. It will not be possible to track
every penny, however major expenses include:
• Number and costs for translations
• Number and costs for interpretations
• Capital costs or leasing costs for hardware and software related to interpretation
• Bilingual pay differentials (if implemented)
• Printing/design costs for products in alternative languages
• Costs for advertising in alternative language media including newspapers, television,
social media, and the internet
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• Costs of language assistance training programs including staff time
• Cost of reviewing and updating Four Factor Analysis and LAP
• Cost associated with handling of complaints for language issues
• Staff time associated with creating tracking systems and compiling reports
Other non-cost-related quantitative data that need to be collected to monitor the program
include:
• Number of requests received for translations and interpretation from public
• Number of contacts made in person, by phone, electronically or in writing with
individuals with LEP for all SANDAG locations/services
• Number of products produced in alternative languages (documents, videos, tweets, etc.)
• Monitoring utilization rates of bilingual IVR systems and over the phone interpretation
service
• Records of the number of staff who have received training on LAP measures at SANDAG
• County demographics for persons who do not speak English very well broken down by
their native language
County demographics usually do not shift radically in a relatively short period such as three
years. However, recent events such as have those that occurred in Afghanistan and Ukraine
have shown that the impact can quickly be felt in San Diego. Those speaking a particular
language can quickly reach the 1,000-person level requiring safe harbor protection.
Qualitative Data
The monitoring of qualitative data will assist in completing Factor 3 of the Four Factor
Analysis Updates and provide a picture of the effectiveness of the programs identified in the
LAP in providing meaningful access to SANDAG programs, facilities, and services.
Qualitative data can be more difficult to collect and requires greater effort. Examples of the
types of data that should be included are as follows:
• Surveying staff members about their use of language assistance services including
translation/interpretation requests and the over the phone interpretation service
• Soliciting suggestions for improvements to the language assistance program from staff
and individuals who are LEP and contact SANDAG
• Conducting surveys or focus groups of SANDAG’s consumers about their experiences
using SANDAG language assistance services
• Conducting surveys of focus groups with CBOs that act as intermediaries with
disadvantaged groups in San Diego County on behalf of SANDAG
• Assessing how well staff members understand LEP policies and procedures and how to
access resources
• Reviewing the nature and importance of activities to persons with LEP and identifying
any trends that might influence how resources should be adjusted
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A major source of information about the effectiveness of the language assistance services
can include focus groups. Focus groups were used in the preparation of this plan. However,
as discussed in Section 4.1, because the persons recruited to participate may not actually
have had prior contact with SANDAG, they were unable to provide comments about the
quality of the language assistance available at the agency.
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8. Summary of Conclusions and
Recommendations
Factor 1: Identifying Individuals with Limited English Proficiency
The following safe harbor languages were identified:
Safe Harbor Languages
1 Spanish
2 Tagalog (incl. Filipino)
3 Vietnamese
4
Chinese (Mandarin and
Cantonese)
5 Arabic
6 Korean
7 Persian (incl. Farsi, Dari)
8 Japanese
9 Russian
10 Portuguese
11 Hindi
12 French (incl. Cajun)
13 Khmer
14 Telugu
15 Lao
16 Somali
17 Ukrainian
Factor 2: Frequency with Which Persons with LEP Come in Contact with SANDAG
The greatest number of contacts with individuals who have LEP are in Spanish, which is
consistent with the findings of Factor 1 and reflective of SANDAG’s cross-border planning
relationship and San Diego County’s geographic proximity to Mexico. The absence of data
showing contact with other language groups appears largely to be due to people not being
aware of SANDAG, its role, and the services it provides. Greater awareness of SANDAG’s role
and services in the LEP community will increase contacts.
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Factor 3: Nature and Importance of Contact with SANDAG
The individuals who participated in the focus groups placed a high level of importance on
being able to communicate with elected representatives though the board and policy
committees. Transit riders also felt it was important to be able to comment on fare changes.
Even though few had used the services, or even knew of their existence, the individuals
participating in the focus groups found the Motorist Aid Services, including the Freeway
Service Patrol and call boxes, to be particularly important. The 511 system, except for
requesting Motorist Aid, was not seen as particularly important because more easily
accessible traffic/transit information alternatives exist. iCommute was not viewed as
important because none of the participants had a need for the services provided.
Factor 4: Resources Available to SANDAG and Estimated Costs
A full and accurate accounting of the cost of providing service in languages other than
English is not possible because of previous limitations of the budgeting system used by
SANDAG. Using a simple comparison between the percentage of the LEP population and an
estimate of the percentage of budget committed to LEP communications, SANDAG is
meeting the goal suggested in the U.S. DOT guidance for resourcing of LEP support.
A new cost code for translation and expenditures was created in the budget tracking system.
It is hoped that the financial record-keeping system will more clearly capture costs
associated with actual (and future) expenses.
Language Assistance Plan Recommendations
The 17 safe harbor languages have been divided into three priority groups, as shown below,
based on LEP population and other factors such as geography and historical relationships:
Priority 1 Priority 2 Priority 3
Spanish
Tagalog/Filipino
Vietnamese
Chinese: Mandarin (oral);
Simplified (written)
Arabic
Chinese: Cantonese (oral);
Traditional (written)
Korean
Persian
Japanese
Russian
Portuguese
Hindi
French
Khmer
Telugu
Lao
Somali
Ukrainian
A range of specific recommendations are included throughout the LAP, including:
• Follow Vital Documents and language group prioritization policies and procedures to
guide translation efforts. Vital documents are organized into three tiers, with different
translations requirements for each tier; Tier 1 documents—those with the highest
priority—would be translated manually for all languages in Priority Groups 1 and 2, and
made available in Priority Group 3 languages through machine translation.
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• Continue to manually translate documents and materials into languages other than
those identified above if/when a project is located in a community with a large number of
persons with LEP.
• Improve oral communications by ensuring front-line positions include bilingual
employees, delays for interpretation are tracked, interpreters are provided at public
outreach events, and all staff are trained on use of the over the phone interpretation
service. Identify availability of interpretation and languages available at Board and
Committee meetings in notice requirements.
• Improve written communications by ensuring vital documents are correctly translated
according to priority groups. Implement a designated icon or pictogram, along with a
Free Language Assistance notice, to identify any toolbars, QR codes, or links to translated
documents. Support improvements to SANDAG webpages which will improve language
access (expected to be rolled out during the website redesign).
• Develop and distribute an updated Language Assistance Toolkit, and improve and
distribute various other tools to expand employees’ ability to provide language assistance
• Consider implementation of a bilingual pay differential program for positions in which
speaking a Priority 1 language is required or desirable. Annual costs of providing a
bilingual pay differential, identification of positions that might be designated as requiring
bilingual staff, and requirements to confirm the fluency of existing and potential new
bilingual employees should be estimated during development of the new policy.
• Provide training on communicating with individuals with LEP and the resources available
at SANDAG for all new SANDAG employees. Training for continuing employees should be
provided when the LAP is updated
• It is recommended that staff advocate for LEP measures throughout the agency, and that
SANDAG advocate to the state for allowing signage to be placed along state-controlled
freeways and highways that provides multilingual explanations of SANDAG programs
and services, such as tolls and express lanes, call boxes, 511, and Highway Service Patrol.
(Note that such improvements can be made as signage is added, updated, or replaced.)
Monitoring and Updating
The plan contains recommendations for updating the LAP and for monitoring language
assistance efforts to ensure language access services are being made available. In particular,
it is recommended that SANDAG significantly increase the collection of quantitative and
qualitative data on services for and contacts with persons with LEP.
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9. Appendix 1: Employee Survey Form
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11.
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10. Appendix 2: Community-Based
Organization Focus Group Moderator
Guide and Consent Form
SANDAG 2022 Language Assistance Plan Update
Community-Based Organization Focus Group
Moderator’s Guide
INTRODUCTION: (5 minutes)
Thank you very much for joining us today to share your opinions about the San Diego
Association of Governments, or SANDAG, as it’s commonly known and some of the programs
and services the organization offers.
My name is ___________ and my role at ______________ is _______________. I will be moderating
today’s discussion. I am not a SANDAG expert, so you can ask questions, but please know that
I may not have the answer and would have to get it for you later.
I am joined today by _____________________. (Introduce the Notetaker)
NOTE-TAKER: I am __________ and my role at _____________ is _____________. I will be taking
detailed notes of our conversation today. [Mention use of recorder if included.]
You are here because you may have used some of SANDAG’s programs or services and you
have indicated that you are most comfortable speaking in a language other than English.
SANDAG wants to hear about your opinions and your experiences using its programs
services so that its staff can better assist customers who don’t speak English very well.
The information you provide will help SANDAG update the Language Assistance Plan, a
document that outlines how SANDAG helps people with limited English skills access
SANDAG’s program and services.
This session will last about two hours. If you need to visit the restroom during this session,
[insert location of restroom].
GROUND RULES: (10 minutes)
As your moderator, my role is to create a space where everyone feels comfortable to
participate or ask questions, facilitate a discussion, and make sure that everyone has an
opportunity to share, listen, and be heard. To that end, I would like to go over some
guidelines to help the discussion go smoothly.
• We want to hear from each one of you, and I know some of you may be more
comfortable speaking in groups than others. One of my roles is to make sure all of you
have a chance to share, so if you are sharing a lot, I will probably ask you to give others
time to speak, and if you aren’t sharing much, I may call on you to share your opinion.
• We have a very full agenda. In addition to using a timer [only if a timer is being used], I
may interrupt if the conversation seems to be going off topic or if there are many people
that want to speak at the same time.
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• Also, we expect there to be different perspectives; you may not agree with each other, but
please listen respectfully as others share their views, and please do not counter or debate
them.
• This is an information gathering session, so all perspectives are welcomed and
encouraged.
• Please speak one at a time and do not interrupt. I will make sure you all have an
opportunity to share and be heard.
• Idea sharing is the focus, and the views shared are confidential and will be summarized as
a whole.
Does anyone have any questions about these ground rules? Does everyone agree to abide by
these basic ground rules?
We will start with a brief introduction of SANDAG and what programs and services it provides
and then we will narrow our discussion to cover a few of these items. Toward the end of this
session, we will open it up to discuss anything we haven’t covered yet.
But, before we continue, I would like everyone to have the opportunity to introduce
themselves.
Please introduce yourself by letting us know your name (first name is okay) and if you are
familiar with SANDAG.
SANDAG INTRODUCTION: (10 Minutes)
San Diego is a big place and people get around in different ways. How do you get around?
Some of you are familiar with SANDAG. You may not be aware of all the programs and
services it offers residents in San Diego County. I’m going to name off a few of SANDAG’s
responsibilities. Please raise your hand for each one if you knew this before you were
recruited for this group.
• SANDAG is the regional planning agency for San Diego and develops the long-range
transportation plan that guides the development of roads, freeway, transit, and active
transportation projects in the County as well as dealing with regional issues such as
housing, social equity, transborder issues, energy, public safety, and shoreline
preservation [Show photo/logo]
• SANDAG plans, designs and builds bus, Trolley, and train projects on behalf of MTS and
NCTD and sets the fares that these agencies collect for their services [Show photo/logo]
• SANDAG manages the 511 phone system and website, a free service that consolidates the
region’s transportation information into a central resource for the public [Show
photo/logo]
• SANDAG manages Motorist Aid Services, including the Freeway Service Patrol and Call
Box Program [Show photo/logo]
• SANDAG manages the iCommute program, that includes Commuter Assistance, such as
Guaranteed Ride Home and Vanpool Program, and Employer Services, such as the
Commuter Benefits Program [Show photo/logo]
• SANDAG manages the FasTrak Program on the I-15 Express Lanes and operates the
South Bay Expressway/SR 125 Toll Road [Show photo/logo]
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As you can see, SANDAG is an organization with many programs and areas of service. For our
purposes today, we are going to focus on a few specific topics.
We will spend approximately 10-15 minutes on each of these topics. As we mentioned earlier,
we will leave time toward the end of the session to cover other topics that you are interested in.
QUESTIONS:
SANDAG Meetings, Transportation Planning and Regional Planning (15 minutes)
The first set of questions will focus on Transportation Planning and Regional Planning.
Federal law requires SANDAG to prepare a Regional Transportation Plan every 3 years, and
during that process the public is invited to participate in its development. SANDAG also deals
with other regional issues such as housing, energy, shoreline preservation, public safety and
cross border coordination.
1. Have you attended SANDAG board or committee meeting or public participation event?
• Did you understand conversations in English? Did friends or family translate for you?
Were SANDAG interpreters available?
• Were you able to participate in the event?
• If not was it due to language?
2. Have you tried to read or browse a SANDAG Planning report?
• Was the report available in your language?
• What was the subject?
• If not available in your language, did you ask SANDAG or someone to translate the
report for you?
• Was the lack of a translated document a barrier for you?
3. What could be done to improve language access?
Public Transportation (15 minutes)
The next questions will focus on fare setting for public transportation including Trolley,
Coaster, and the Sprinter in San Diego County.
1. Were you aware that fares on MTS and NCTD are set by SANDAG?
2. Are you aware that that the public is invited to comment on proposed fare changes?
• If you did not know do you think it was due to a language barrier?
• If you were aware of the opportunity, did you participate?
• Were you able to participate in the language of your choice?
• If language were less of a barrier, would you participate in the future?
3. Have you seen notices for public hearings about transit fares changes or increases?
• Was language a barrier to understanding how fares might change?
4. What is the best means of reaching you in your language to discuss possible fare
changes?
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511 Website and Phone System (15 minutes)
The next set of questions will cover the 511 system. As some of you may know, 511 is available
through an automated phone line and online. 511 provides traffic information, transit schedules,
traffic maps, and more. [NOTE FOR MODERATOR: The 511 automated phone system is available
in Spanish. All SANDAG websites, including 511sd.com, have the Google Translate toolbar.]
1. Have you accessed the 511 system by phone or web?
• If by phone did you speak English, have someone else speak in English for you or
request an interpreter be brought onto the call?
• Did you know that interpreters are available on 511 calls for your language?
• If by web, did you, do it English? Have someone do it for you in English? Or did you
use Google Translation online? Was Google Translate acceptable translation
2. How could it be made easier for you to use 511 in your language?
Motorist Aid Services Program (15 minutes)
Now we will move on to discuss the Motorist Aid Services Program. SANDAG administers
services to aid distressed motorists and help remove stranded vehicles on the region’s most
congested freeways. Some of you may have recognized the Freeway Service Patrol trucks
that patrol the highways to provide free roadside assistance. Motorists can call 511 from a cell
phone for free roadside assistance, available on most urban freeways during peak commute
periods. You also may have seen yellow call boxes on rural highways. These are free phones
that connect stranded drivers in locations with poor cellular signal to an operator who can
dispatch help, 24 hours a day.
1. Did you know about these services before today?
• Have you used a highway call box?
• What language did you use to speak with the operator?
• Was the operator able to speak your language? Did someone with you interpret for
you? Did SANDAG provide an interpreter?
• Did you know you can request an interpreter?
2. Did you receive assistance from Freeway Service Patrol?
• Did patrol driver speak your language? Did someone with you provide interpretation?
Did the patrol driver get an interpreter on the phone?
3. What can be done to make these services more accessible for LEP persons?
iCommute (15 minutes)
Now let’s talk about iCommute. iCommute provides information on transportation choices
for commuters in the San Diego region including carpool services, a subsidized vanpool
program, transit solutions, regional support for biking, the Guaranteed Ride Home program,
information about teleworking, and bike and pedestrian safety program support for schools.
iCommute has a commute cost calculator tool that allows you to see how much an
alternative commute could save you, among other resources. iCommute also provides
assistance to local businesses, helping them develop and implement customized employee
commuter benefit programs.
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1. Have you ever contacted iCommute? (Online, phone, or in person with an account
executive)
2. If contact was in person or by phone, was it in English or was someone at iCommute able
to help you in your language? Did someone at your end help you communicate with
iCommute?
• Did you know that you could request a translator on your call?
• If contact was on the web was Google Translate used? And was it effective for you?
3. What ideas do you have for making this information easier to access and use for people
who do not speak English very well?
FasTrak (15 minutes)
Our next section will cover the two toll roads in San Diego, the I-15 Express Lanes and the
South Bay Expressway on SR 125, and FasTrak transponders.
1. Do you own and drive a car or truck?
2. Do you ever drive on I-15 or SR 125?
3. Do you have a FasTrak transponder? Are you familiar with FasTrak?
• How did you learn about FasTrak? Was the information in your language? Did you use
family or friends to translate? Did you get information from SANDAG in your
language?
4. If you don’t have FasTrak would you get a transponder if information was available in your
language?
Concluding Questions (15 minutes)
Our final section will cover some general questions about SANDAG assistance to the public.
1. Have you ever tried to call SANDAG or visited SANDAG offices?
• Were you able to communicate with SANDAG in your language?
2. Have you ever used the SANDAG or Regional Plan website?
• Did you use in English or use Google Translate?
• If you used Google Translate, was it effective?
3. What are some of the ways that SANDAG could do better in informing people who speak
limited English?
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SANDAG 2022 Language Assistance Plan Update
Focus Group Consent Form
<INSERT ORGANIZATION NAME> is helping the San Diego Association of Governments
(SANDAG) assess ways to improve its programs and services. You have been invited to
participate in a focus group as part of this effort. The purpose is to examine how people who
do not speak English well use SANDAG programs and how to improve services for this group.
Your participation is completely voluntary, and you may withdraw at any time without
penalty.
Your participation may benefit you and others by helping to improve SANDAG programs and
services. No risk greater than ordinary conversation is anticipated.
Everyone will be asked to respect the privacy of the other group members. All participants
will be asked not to disclose anything said within the context of the discussion, but it is
important to understand that other people in the group with you may not keep all
information private and confidential.
Anonymous data from the focus group will be analyzed and reported to SANDAG. No
individual participant will be identified or linked to the results. All information will be kept
strictly confidential.
By signing this consent form, you are indicating that you fully understand the above
information and agree to participate in this focus group.
Participant’s signature
Date
Printed name