LIMITED ENGLISH PROFICIENCY (LEP) PLAN
I. PLAN STATEMENT
The City of Roanoke Redevelopment and Housing Authority (RRHA) has adopted this plan to provide meaningful access to its programs and activities to persons with Limited English Proficiency (LEP). In accordance with federal guidelines, RRHA will make reasonable accommodation to provide or arrange free language assistance for its LEP clients, including
but not limited to; applicants to Public Housing (PH) and Housing Choice Voucher (HCV), formerly known as (Section 8) programs, participants in Public Housing and (HCV) programs, homeownership programs, and other RRHA programs.
II. FOUR-FACTOR ANALYSIS Factor One: The number or Proportion of Limited English Proficient (LEP) Individuals to be Served or Likely to be Encountered
1. Public Housing Program:
The service area of the RRHA Public Housing Program is the City of Roanoke, Virginia. As of March 15, 2023, RRHA operated 1,281 public housing units and had 1,249 families who reported a family language participating in the program. The breakdown for the primary languages spoken by these families is as follows:
A. English – 1179 families – 94.42%
B. Arabic – 7 families –0.56 %
C. Haitian/Creole – 14 families – 1.1%
D. Kirundi – 8 families – 0.64%
E. Spanish – 27 families – 2.23%
F. Kiziguwa – 4 families – 0.32%
G. Swahili – 4 families – 0.32%
H. Vietnamese – 5 families – 0.40%
2. Housing Choice Voucher (HCV) (Section 8) Program:
The service area of RRHA HCV Program is the City of Roanoke, City of Salem, Town of Vinton, Virginia, and surrounding counties such as Franklin, Floyd, Bedford, Botetourt, Alleghany. As of March 15, 2023, RRHA has 1,983 families who reported a family language participating in the program. The breakdown for the primary languages spoken by these families is as follows:
A. English – 1904 families – 96%
B. Arabic – 16 families –.79 %
C. Croatian- 1family – .05%
D. Drdary- 1family- .05%
E. Haitian/Creole – 3 families – .016%
F. Pashto- 2 families- .011%
G. Spanish – 55 families – 3%
H. Ukrainian- 2 families – .11%
3. 2020 Census for the City of Roanoke:
100,011 families. The breakdown of the primary languages spoken in the City of Roanoke:
A. English – 39,061 families – 91.20%
B. Spanish – 1,633 families– 6.1%
C. Other Indo-European Languages – 592 families – 1.39%
D. Asian and Pacific Islander Languages – 614 families – 3.08 %
E. Other – 578 families – 1.90%
Based on the 2010 – 2019 American Community Survey 5-Year estimates for the City of Roanoke, 91,127 of the 99,920 (91.20%) residents over the age of five speak English only at home. For the remaining 8,793 (8.8%) residents who speak a language other than English at home, 4,079 do not speak English “very well.” This equates to 4.5% of the total number of residents over five years old in the City. The largest language group within the City that does not speak English “very well” is the group that speaks Spanish or Spanish Creole at home, 3,957 residents, which comprise 4.4% of the City residents over the age of 5.
Factor Two: The Frequency With Which LEP Individuals Contact the Program
In addition to undertaking research required to identify LEP in RRHA’s area of operations, RRHA shall also compile information regarding the frequency of contact with LEP persons while providing housing services. The more frequent the connection with a particular language group, the more likely the need for enhanced language services in that language.
The minimum frequency of contact for the total 3,481 households (combined PH and HCV programs) includes initial application, voucher briefing, yearly annual re-exam, and yearly annual inspection. Some participants may have one or more additional re-exams (interim re-exams) to report income or family composition changes, and public housing residents may need to request maintenance through the work order system. In addition, some families receive emergency inspections for health and safety or life-threatening conditions in their housing unit before the annual inspection. Some applicants/participants may have informal reviews and hearings, attend a movers briefing, or have various questions regarding the program throughout the year.
It is estimated that approximately 370 applications for housing assistance through the PH program are received monthly when the PH waitlists are open, and the RRHA is accepting applications for an annual average of 4,440 applications. The last time when the waitlist for the HCV program opened for receipt of applications was in August of 2022, and at that time, more than 4,106 applications were received. As of March 15, 2023, 4,429 applicants remain
on the waitlist for the HCV program.
Factor Three: The Nature and Importance of the Program, Activity, or Service the Program Provides
RRHA’s mission is to take a leadership role in affordable housing and self-sufficiency programs while investing in our communities. It is the vision of RRHA to become an innovative leader among public housing authorities, providing affordable housing for individuals and families of the City of Roanoke and the surrounding counties in its service area. Housing is a basic human need, the lack of which can have severe or life-threatening implications for any individual. Therefore, RRHA takes its responsibility as an affordable housing provider very seriously. To provide full access to affordable housing programs, the RRHA recognizes the potential for LEP to limit access for individuals and families to those programs. RRHA intends to provide the resources required for meaningful access to those programs for all applicants and participants. Therefore, when needed, RRHA is committed to providing competent language services with the understanding that some services and documentation related to those services are more vital than others.
Factor Four: The resources Available and Costs to the Recipient
Due to limited resources, RRHA shall use the most cost-effective means for providing competent language services for the individuals and families for which housing services are provided. In the process of determining which services are required or to be delivered, RRHA shall thoroughly document the steps taken in arriving at that determination.
III. LANGUAGE ACCESS PLAN (LAP)
RRHA’s LAP aims to ensure that all individuals and families (potential applicants, applicants, and participants) have meaningful access to the affordable housing services RRHA provides, regardless of the primary language spoken.
Identification of LEP persons:
After completing the four-factor analysis with consideration given to HUD’s “safe harbor” guidance, it is determined that there are currently no non-English language groups of sufficient percentage or number that require translation of written documents.
Identification of the points and types of contact the agency and staff may have with LEP persons:
The minimum frequency of contact for the total 3,232 households (combined PH and HCV programs) includes initial application, voucher briefing, yearly annual re-exam, and yearly annual inspection. Some participants may have one or more additional re-exams (interim re-exams) to report income or family composition changes, and public housing residents may need to request maintenance through the work order system. In addition, some families receive emergency inspections for health and safety or life-threatening conditions in their housing unit before the annual inspection. Some applicants/participants may have informal reviews and hearings, attend a movers briefing, or have various questions regarding the program throughout the year.
It is estimated that an average of 3,360 applications are received per year for the PH program. Applications are submitted online or at RRHA’s Central Administration Offices by the receptionist and at each public housing development rental office for Reasonable Accommodations. In the City of Roanoke, 8.8% of the population does not speak English very well. Therefore, it is estimated annually that 296 applicants for PH assistance do not speak
English very well. Of the over 4,100 applications received in 2022 for HCV program assistance, it is estimated that 396 were submitted by applicants who do not speak English well.
In addition, there exists a continual opportunity for LEP persons to contact staff at any of RRHA’s properties with questions regarding services provided by RRHA’s affordable housing programs.
Identification of Ways in Which Language Assistance Will be Provided:
Currently, RRHA provides language assistance through “I Speak” cards which are available at each public housing rental office “Language Line” and “VOLATIA” interpretive services, which can be accessed via telephone at each public housing rental office. In addition, HCV program staff has access to “I Speak” cards, “Language Line,” and “Volatia” services. The administrative staff at RRHA’s Central Administration Office, which has the potential for direct interaction with LEP persons, has access to “I Speak” cards, “Language Line,” and “Volatia” services. RRHA currently has multiple contracts with firms that provide competent translation services for written documents if required and onsite interpreter services if needed.
Effective Outreach to The LEP Community:
RRHA’s LEP Plan will be made available to the public via RRHA’s web page by May 2023.
All of the RRHA staff for PH (including PH maintenance staff) and HCV programs, which have the potential for direct interaction with LEP persons, received Fair Housing Training, Annually. This training is repeated annually and is required of all new hires during onboarding orientation.
Site management staff and HCV staff have been trained in the use of “I Speak” cards, “Language Line,” and “Volatia” services. Volatia provided Training to RRHA Staff in July 2020. Administrative staff at RRHA’s Central Administration Office shall receive further training in accessing and use of “I Speak” cards, “Language Line,” and “Volatia” services.
Determination of Vital Documents and Informational Materials:
At a minimum, the following documents are considered “vital”: Consent and compliant forms; Intake forms with the potential for essential consequences; Written notices of rights, denial, loss, or decreases in benefits or services, and other hearings; Notices of eviction; Notices advising LEP persons of free language assistance; Notices of public hearings; Leases and tenant rules; applications for participation in PH or HCV programs; and on a case-by-case basis any other document that is determined to be essential for LEP person to have access to a particular service RRHA provides.
Translation of Informational Materials in Identified Language(s) That Detail Services and Activities Provided to Beneficiaries:
RRHA will provide written translations of vital documents for each eligible LEP language group that constitutes 5 percent or 1,000 persons, whichever is less, of the population of persons eligible to be served or likely to be affected or encountered. Translation of other documents, if needed, can be provided orally; or if there are fewer than 50 persons in a language group that reaches the 5 percent trigger, RRHA may not translate vital written materials, but will provide written notice in the primary language of the LEP language group of the right to receive a competent oral interpretation of those written materials, free of cost.
Due to the high costs equated with the translation of written documents and when the translation of written documents is not required by regulation, all requests for translation of written documents will be given consideration only in limited situations where there is an action to be taken that will have a severe impact on the person or family making the request. Such measures may include denial of program assistance or termination of program assistance. Consideration of such requests shall be conducted in a reasonable and nondiscriminatory manner. The Director of the applicable program shall review such requests for written document translation and will recommend approval or denial of translation of pertinent program documents. The Vice President of Housing and the Executive Director shall review the recommendations made by the Directors.
The person requesting a translation of written documents will be offered a competent oral translation of written documents. Requests for oral translation will always be provided free of charge.
Provision of Appropriately Translated Notices to LEP Persons:
When determined to be necessary to provide meaningful access for LEP clients, RRHA will weigh the costs and benefits of translating documents for potential LEP groups, considering the expense of translating the documents, the barriers to meaningful translation or interpretation of technical housing information, the likelihood of frequent changes in documents, the existence of multiple dialects within a single language group, and other relevant factors. The RRHA will undertake this examination when an eligible LEP group constitutes 5 percent of an eligible client group (for example, 5 percent of households living in the PHA’s public housing) or 1,000 persons, whichever is less.
Provision of Interpreters for Large, Medium, Small, and One-On-One Meetings:
When determined to be necessary to provide meaningful access for LEP clients, the PHA will provide qualified interpreters, including PHA bilingual staff and contract vendors. At important stages requiring one-on-one contact, written translation, and verbal interpretation, services will be provided consistent with the earlier four-factor analysis.
Development of Community Resources, Partnerships, and Other Relationships to Help With the Provision of Language Services
RRHA will seek community and outside resources to help provide language services. RRHA will consult with other Housing Authorities regarding services for LEP persons.
Provision for Monitoring and Updating The LAP:
Monitoring and implementation of the plan will be executed daily on a case-by-case basis by the Vice President of Housing, Manager of the HCV Program, Public Housing Site Managers, and HCV Specialists. The Four-Factor Analysis and the LAP shall be reviewed and updated yearly by the Vice President of Housing and the Manager of the HCV Program. Complaints and comments received regarding LAP services shall be forwarded to the Vice President of Housing or the Manager of the HCV Program, depending on the participant’s program involvement.
The following sources of information will be incorporated into the yearly review:
- Reports from the RRHA’s computer business systems on the number of RRHA clients who are LEP, to the extent that the software and staff data entry can provide such information. Staff observations may supplement such
- Reports from the computer business systems and other sources list LEP clients’ languages.
- Determining whether 5 percent or 1,000 persons from an RRHA client group speak a specific language triggers consideration of document translation needs as described above.
- Analysis of staff requests for contract interpreters: number of requests, languages requested, costs,