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Table 3 Responses regarding sources of LEP guidance (Question 6)
DOT LEP FTA LEP State or local DOT Order
EO 13166 guidance guidance requirements 5610.2
Aware 36 36 44 38 37
Relied on 33 36 34 22 29
Neither/none 16 13 7 25 19
compliance activities (Question 9), and outreach ground research on LEP requirements and a survey
strategies (Question 10). Only those agencies that questionnaire distributed by TRB to almost 300 tran-
had self-identified as having had complaints (Ques- sit agencies nationwide. Phase 1 also included query-
tions 4 and 5) were asked to complete Part II. As ing the FTA Chief Counsel and FTA Civil Rights
requested, the five agencies that indicated complaint/ Office on LEP compliance issues, as well as attempt-
compliance issues completed the questions concern- ing to contact transit advocates who have raised
ing compliance activities and outreach strategies. Title VI issues with transit agencies. The research
In addition, three agencies voluntarily completed indicates that while LEP compliance is indeed an
Question 9, two completed Question 10, and four- issue of interest to transit agencies, there are no
teen completed both. Table 4 aggregates the three reported transit-related LEP cases and--based on the
responses to Question 8, Table 5 aggregates the questionnaire responses--very limited LEP com-
seventeen responses to Question 9, and Table 6 plaint activity. Moreover, to date there has been little
aggregates the sixteen responses to Question 10. in the way of transit LEP enforcement action, although
it appears that the FTA is preparing to report addi-
SUMMARY OF PHASE I tional LEP deficiency findings from recent triennial
RESEARCH CONCLUSIONS and state management reviews and is conducting a
larger review of civil rights enforcement.
The purpose of Phase 1 was to research LEP
Based on the Phase I Research, it was found that
requirements in the transit environment and to
the topic in general is of considerable interest to
determine the case activity associated with LEP
transit agencies and, in fact, that LEP compliance
implementation. Phase 1 activity included back-
issues do exist. The dearth of reported complaints
may be due to several factors. Many LEP persons--
Table 4 Responses regarding compliance issues
(Question 8)
Table 5 Responses regarding compliance activities
Agencies (Question 9)
Compliance Issues With Reporting
Which Agency Has Compliance Agencies
Been Involved Issues Reporting
LEP Trip Information Engaging
LEP deficiencies documented 2 Activities in Activity
by FTA
LEP issues with employees 0 LEP needs assessment 11
Suspension of federal 0 Evaluation of agency's 10
funding due to LEP language access activities
noncompliance Multilingual information on 15
Administrative action related 0 agency website
to LEP compliance Multilingual brochures and signs 15
Litigation related to LEP 0 Multilingual telephone services 15
compliance Bi/multilingual drivers 11
Actions related to 1 Bi/multilingual customer service staff 14
environmental justice Multilingual ticket machines 5
Complaint filed with FTA 1 Translated recorded announcements 8
re: service changes Symbolic trip information (pictograms) 3
7
