Language Assistance Plan

Language Assistance Plan for the City of Watertown Transportation Department (CitiBus)


The purpose of a language assistance plan is to meet Federal Transit Administration’s requirements to comply with Title VI of the Civil Rights Act of 1964, which prohibits discrimination on the basis of race, color, or national origin. As a recipient of FTA funds, our CitiBus department will take reasonable steps to ensure meaningful access to our transit services for persons who do not speak English at a level of "very well" according to census standards and who have a limited ability to write, read, speak or understand English. These persons are referred to as Limited English Proficient (LEP) by the FTA.

This plan conforms to the requirements as set out by FTA Circular 4702.1B Title VI Requirements and Guidelines for Federal Transit Administration Recipients dated October 1, 2012.

The language assistance plan for the City of Watertown CitiBus operation contains:

    A.    needs assessment based on the four-factor analysis
    B.    Language assistance measures
    C.    A staff training plan
    D.    Methods for notifying LEP persons about language assistance
    E.    Methods for monitoring, evaluating, and updating the plan

A. LEP Needs Assessment-the Four-Factor Analysis

Factor 1. The number or proportion of LEP persons in our transit service area who may be served or are likely to encounter our transit program.

We assessed the following information about LEP persons to determine the number or proportion of LEP persons who might use or want to use our transit services:

US Census Bureau: Language Spoken at Home: 2009-2013 American Community Survey 5-Year Estimates Reports from drivers and dispatchers about contact with LEP persons

According to the data obtained by the US Census Bureau:
    1.    The total number of LEP persons in our service area is 298. Our service area covers the boundaries of the City of Watertown with 2 routes that have stops just outside of our boundaries serving major shopping areas.
    2.    The total eligible population in our area is: 27,453
    3.    The proportion of LEP persons to the total eligible service population is 1.2%
        a.    Spanish-0.6%
        b.    Indo-European-0.5%
        c.    Asian and Pacific Islander-0.1%
Factor 2. The frequency with which LEP persons come in contact with our transit program:

Our drivers and our dispatchers report very little interaction or contact with LEP persons. Our drivers report that annually they have 2 to 3 encounters with LEP patrons. We are developing internal procedures to better track this data to aide in assisting this population. We are putting in place a log for our drivers and any other staff who may come in contact with our LEP population to use should they come into contact with an LEP person. This log will include the driver’s name, LEP person’s name, date, their proficient language, as well as the pick-up and drop-off locations. We will also include I Speak cards to better identify the language which is spoken by our LEP population. It is our hope that this data will help us to better analyze the frequency of our interaction with LEP populations as well as possible outreach opportunities should LEP persons have a common pick-up and/or drop-off location.

Factor 3. The nature and importance of our transit program provided to the LEP population.

Our CitiBus operation considers our transit programs to be an important and essential service for many people living in our service area.

CitiBus provides services to the general population, the elderly and disabled members of our community. CitiBus operates 3 regional routes with most of these routes contained fully within the City limits. 2 routes have stops just outside of our City limits servicing major retail locations including Seaway Plaza, Salmon Run Mall, and Hannaford Foods/K Mart. 3-30 passenger buses with lift capacity operate Monday thru Saturday. Our buses also accommodate 2 wheelchair riders. We also contract with a paratransit provider who operates 2-14 passenger-2 wheelchair paratransit vehicles.

Public transit in the City of Watertown is a vital asset to our community. The total ridership for 2014 was 145,213 with patrons using our services for access to our local community college, places of employment, shopping, recreation, and for obtaining health services.

Factor 4. The resources available to our transit system and the overall cost to provide language assistance.

Our current budget does not include any items for communicating with LEP persons in their language about transit services that are available to them. We have decided to allocate $500 for these services in the 2015/2016 City of Watertown budget. We feel this is more than adequate given our limited LEP population and the limited frequency in which LEP persons come in contact with CitiBus operations. We will re-assess this allocation annually and adjust it based upon the frequency of the request for these services. The 2015/2016 breakdown for these services is as follows:

Language Interpretation-Language Line-$400
Language Translation-Language Line-$100
B. Language Assistance Measures
There are several language assistance measures that we will make available to our LEP population should the need arise. These include:

Arranging for the availability of oral translators. We will use the pay as you go service from Language Line in times of need for oral translation.
Posting notices in appropriate languages informing LEP persons of available services. Documents that need to be translated will be done so by either Language Line or Google Translate.

Staff Training

To ensure the effective implementation of this plan, CitiBus will properly train our staff upon orientation, on an as needed basis, and annually in the following:

Our Language Assistance Plan-All transit supervisors, operators, and office staff responsible for answering the telephone will receive this training.

Census demographic data about our LEP population-All transit supervisors, operators, and office staff responsible for answering the telephone will receive this training.

Completion of the LEP log-All transit operators and office staff responsible for answering the telephone will receive this training.

How to handle requests for transit service from our LEP population- All transit operators and office staff responsible for answering the telephone will receive this training.

Responsibility to notify the City Manager’s Office about any LEP persons with unmet needs- All transit supervisors, operators, and office staff responsible for answering the telephone will receive this training.

C. Notice to LEP persons about available language assistance

Our CitiBus operation will post within all of our public communication that our LEP persons will have access to the language assistance measures outlined above. Documents that can be translated are the Civil Rights complaint procedures and the Civil Rights complaint form. Translation will be completed by either using the service of Language Line of Google Translate. Should our driver/dispatcher log show the need, we will take the necessary steps to translate our public communications in the language(s) with which there is a documented need.

D. Annual Monitoring, Evaluating, and Updating Plan

CitiBus will review this plan annually and will assess:

Its effectiveness
The appropriateness of the budget allocation
A review of complaints from LEP persons
E. Dissemination of this Plan

This Language Assistance Plan will be available on our City’s website,, and at no cost in English upon request by telephone, mail, e-mail, or in person.

Este Plan de Asistencia de idioma estará disponible en la página web de nuestra ciudad,, y sin costo en Inglés bajo petición por teléfono, correo, correo electrónico o en persona.

F. Questions or comments about this plan may be submitted to:

Human Resources Manager
The City of Watertown
245 Washington Street, Suite 302
Watertown, NY 13601
Hearing impaired citizens in need of relay service can dial 711.

General Information
Phone Numbers
(315) 785-7772 (315) 785-7778
Fax: (315) 755-9379
Emergencies: Dial 911
544 Newell St.

Monday - Friday
7:00 am - 3:00 pm