Language Access Plan

I. Introduction

This Language Access Plan has been prepared to address Port of Alaska’s responsibilities as a recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d, et seq, and its implementing regulations, which state that no person shall be subjected to discrimination on the basis of race, color or national origin.

Executive Order 13166, titled Improving Access to Services for Persons with Limited English Proficiency, indicates that differing treatment based upon a person’s inability to speak, read, write or understand English is a type of national origin discrimination. It directs each agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to all state and local agencies which receive federal funds, including the Municipality of Anchorage.

Pursuant to Anchorage’s Municipal Policy and Procedure #16-6, the Municipality of Anchorage must “provide timely and meaningful access to LEP and deaf or hard-of-hearing individuals in the conduct of municipal business.” Part of meaningful access is up-to-date plans for each Municipal Agency to best support residents and visitors of this city, not only to meet Federal Civil Rights laws, but also to create a more welcoming municipal government and community for all people.

Department Description

Port of Alaska is a Municipality of Anchorage owned and operated facility that handles half of all Alaska inbound marine freight – some 3.5 million tons of fuel and cargo annually – half of which is delivered to final destinations outside of Anchorage. It is:

Intermodal transport hub that efficiently connects Alaska’s primary marine, road, rail, pipeline and air cargo systems
Department of Defense commercial strategic seaport that projects U.S. power across Alaska, the Pacific Rim and the Arctic
Anchorage’s only foreign trade zone (FTZ no. 160) that extends U.S. Customs benefits to businesses and sites throughout surrounding community
More inbound cargo-handling capacity than all other Southcentral Alaska ports combined

Port of Alaska serves deep-water vessels operating year-round. Matson Inc. and TOTE Maritime Inc. each provide twice-weekly, scheduled container ship service from Port of Tacoma. Domestic and foreign carriers provide routine bulk deliveries of petroleum products, cement, building materials and other commodities.

Plan Summary

Port of Alaska has developed this Language Access Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency [LEP] who wish to access services provided. As defined Executive Order 13166, LEP persons are those who do not speak English as their primary language and have limited ability to read, speak, write or understand English. This plan outlines how to identify a person who may need language assistance, the ways in which assistance may be provided, staff training that may be required, and how to notify LEP persons that assistance is available.

To prepare this plan, Port of Alaska used the four-factor LEP analysis which considers the following factors:

Number or proportion of LEP persons in the service area who may be served by Port of Alaska
Frequency with which LEP persons interact with or use Port of Alaska
Nature and importance of services provided by Port of Alaska to the LEP population.
Interpretation services available to Port of Alaska and overall cost to provide LEP assistance

II. Meaningful Access: Four Factor Analysis

1. Number or proposition of LEP persons in the service area who may be served or are likely to require Municipality of Anchorage services:

The Mayor’s Language Access Liaison examined the U.S. Census Bureau’s 2009-2013 American Community Survey, Table B16001 “Language Spoken at Home by Ability to Speak English for the Population 5 years and Over.” Through an analysis of population sorted by census tracts within the Municipality of Anchorage, it was determined that approximately 6.2 percent of the Anchorage population (17,050 individuals) speak English “less than very well”. It should be noted that “less than very well” is inclusive of responses indicating they spoke English “not well,” and “not at all.”

Primary Language Spoken	# of Individuals	% of Population
Tagalog Spanish or Spanish Creole Hmong Korean *Other Pacific Island Languages	3881 3287 1687 1539 1379	1.4 1.2 0.6 0.6 0.5

* "Other Pacific Island Languages" includes, but is not limited to: Chamorro, Hawaiian, Ilocano, Indonesian, and Samoan

2. Frequency with which LEP persons interact with Port of Alaska:
The Port of Alaska has had zero (0) reported or otherwise noted occasions where the an LEP individual needed assistance

3. Nature and importance of services Port of Alaska provides to LEP population:
Due to the great diversity of languages spoken in the Municipality of Anchorage, Port of Alaska officials recognize the potential for staff to come into contact with the LEP population. Port staff are most likely to encounter LEP individuals through phone conversations and community meetings or gatherings.

4. Resources available to Port of Alaska and overall costs to provide LEP assistance:
Port of Alaska reviewed its available resources that could be used for providing LEP assistance and documents that it would be most useful to translate. Port of Alaska will use Language Link for telephonic interpretation services, the Alaska Institute for Justice-Language Interpreter Center for in-person interpretation and Port staff will seek quotes for necessary translation from both entities. Currently, Language Link does not provide services in any Alaska Native Language. Port of Alaska will exclusively use the Language Interpreter Center for these needs.

III. Language Access Plan Outline

A. Identification of a LEP Person who needs language assistance services

A person whose primary language is not English and who has limited ability to read, write, speak or understand English may be a Limited English Proficient person who is entitled to language assistance with respect to Municipal services. Language assistance can include interpretation, which means oral or spoken transfer of a message from one language into another language and/or translation, which means the written transfer of a message from one language into another language.

How the Port of Alaska staff may identify LEP individuals who needs language assistance:

Signage about language services in different languages
“Point to your language” posters
Self-identify as needing an interpreter
Anticipate need for assistance based upon previous interactions and requests.
At public meetings, use sign-in sheet and have staff member greet and briefly speak to each attendee. This method will allow staff to informally gauge the attendee’s ability to speak and understand English, while asking an open-ended question that requires a full sentence reply.
Survey frontline staff regarding any direct or indirect contact with LEP individuals.

B. Language Assistance Measures

Port of Alaska uses Language Link and the Language Interpreter Center. Port staff will use invoices from these vendors to track use and necessity.

1. Port of Alaska staff will take reasonable steps to provide opportunities for meaningful access to LEP clients who have difficulty communicating in English.

2. The following resources will be available to accommodate LEP persons:
i) Point-to-your-language posters and brochures will be in easy view at front desk
ii) Language Link brochures with “Point to Your Language” language identification and instructions will be given to all Port of Alaska employees and interns
iii) Port of Alaska staff will be trained how to identify language of LEP
iv) Staff will utilize Google Translates for quick LEP assistance if required. Staff will determine if paid translation of long documents is necessary.

IV. Staff Training

The following training will be provided to all staff:

Information about Title VI policy and LEP responsibilities
Description of language assistance services that are offered to the public
Use of point-to-your-language cards and posters
Documentation of language assistance requests
Title VI/LEP complaint procedures
Working with an interpreter
Note that Port of Alaska staff / all Municipal employees are prohibited from asking for any individual’s citizenship status

All contractors or subcontractors performing work for Port of Alaska and/or Municipality of Anchorage must follow applicable Title VI/LEP guidelines.

V. Translation of Documents

When necessary, Port of Alaska will use Language Link and/or the Language Interpreter Center services to translate documents for LEP individuals
Documents will be translated on an as needed basis
Port of Alaska has not needed to translate any documents to date

VI. Monitoring

Monitoring and Updating the LAP

Port of Alaska will update its LAP as required. At a minimum, the plan will be reviewed annually and updated with data points from following year and incorporate any new U.S. Census data as available. Updates will incorporate data gained from the reporting tool and staff observation, including:

Evaluate number of documented LEP persons encountered during previous year
Access current LEP population in the service area
Determine if LEP needs have been accommodated
Determine if translation services needs have changed
Determine if local language assistance programs have been effective and sufficient to meet needs
Verify Port of Alaska financial resources are sufficient to fund necessary language resources
Determine if Port of Alaska meets the goals of this Language Access Plan
Access complaints regarding Port of Alaska’s failure to meet LEP needs

VII. Dissemination and Complaint Procedures

Post signs at office notifying LEP persons of the LAP and how to access language services
Post notice of public Title VI rights and complaint procedures at entrance to Port of Alaska offices
LAP will be posted on PortOfAlaska.com
Copies of the LAP will be provided to any person(s) requesting the document via phone, in person, by mail or email.

Questions or comments regarding this plan should be directed to:

Port of Alaska Language Access Representative
PortOfAlaska@muni.org
(907) 343-6200
2000 Anchorage Port Road
Anchorage, AK 99501

AND

MOA Mayor’s Office Language Access Liaison Amy Coffman
P.O. Box 196650 Anchorage, AK 99519-6650 (907)-343-7112 amy.coffman@anchorageak.gov

Language Access Services Complaint Process:

Complaints regarding denial of language accessible services or the quality of language accessible services, including interpreters or translated materials, may be made in person, or in writing, or online at: https://moa_onlineforms.formstack.com/forms/language_access_complaint
The complaint should specify date of incident, individuals involved, and the nature of the client (i.e. the interpreter was summarizing, or an LEP individual was denied services because he/she did not bring his/her own interpreter);
All complaints will be directed to the department’s Language Access Plan Representative, and the Mayor’s Language Access Liaison, who will respond timely and make recommendations for corrective action, if needed;

Complaint form is online at: https://moa_onlineforms.formstack.com/forms/language_access_complaint

Hard Copies will be available at the front desk and will be translated into Spanish, Tagalog, Korean, Hmong, Samoan and Yup’ik.

VIII. Definitions

A. Essential Public Information: Any information used by a department when dealing with the public which is necessary to accomplish the department’s mission and with respect to public safety, public health, and economic development.

B. Department Language Access Representative: The employee designated by the department director to be responsible for the department Language Access Plan (LAP) program.

C. Four Factor Analysis: The procedure to determine the level of need for language services by documenting: 1) the number and proportion of LEP persons as reported by the most recent census; 2) the frequency with which LEP persons visit various MOA locations; 3) the nature and kind of programs or activities LEP persons use; and 4) the available resources and overall costs for LEP services.

D. Frontline: Applies to departments and/or personnel that have regular and substantive contact with the public via in person or telephonic communication. See addendum for MOA organization chart with highlighted departments required to have written Language Access Plans.

E. Interpretation: The immediate spoken communication of meaning from one language (the source language) to another (the target language).

F. Interpreter: A person who is bilingual or multilingual and possesses the ability to successfully convey a message from one language to another through oral communication.

G. Language Access Plan (LAP): Department specific documents outlining the procedures and practices that the department will implement to provide language access services to LEP individuals.

H. Limited English Proficient (LEP): Someone who is not able to speak, read, write or understand English at a level that allows the person to interact effectively with department staff. Individuals maintain the right to self-identity as a LEP person and should not in any circumstances be expected to pay for translation or interpretation services in order to effectively communicate with the department.

I. Mayor’s Language Access Liaison: The employee designated by the Mayor to support the LAP program and to support the Department Language Access Representative.

J. Telephonic Interpretation: A service that connects human interpreters via telephone to individuals who wish to speak to each other but do not share a common language. The telephone interpreter converts the spoken language from one language to another, enabling listeners and speakers to understand each other. Interpretation over the telephone most often takes place in a consecutive mode, which means that the interpreter waits until the speaker finishes an utterance before rendering the interpretation into the other language.

K. Translation: The written communication of meaning from one language (the source language) to another (the target language).

L. Translator: A person who is bilingual or multilingual and possesses the ability to translate from one language to another in written form.