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LW <br />IX. <br />Record Keeping <br />The Title VI Coordinator will ensure the maintenance of permanent records, <br />which include, but are not limited to copies of Title VI complaints or lawsuits <br />and related documentation, and records of correspondence to and from <br />complainants, and Title VI Investigations. A copy of the Complaint Monitoring <br />Log is attached as Appendix B. <br />Limited English Proficiency (LEP) Guidance <br />Title VI of the Civil Rights Acts of 1964, Executive Order 13166, and various <br />directives from the US Department of Justice (DOJ) and US Department of <br />Transportation (DOT) require federal -aid recipients to take reasonable steps to <br />ensure meaningful access to programs, services and activities by those who <br />do not speak English, proficiently. To determine the extent to which LEP <br />services are required and which languages, the law requires the analysis of <br />four factors: <br />• The number or proportion of LEP persons eligible to be served or likely <br />to be encountered by the City's programs, services or activities; <br />• The frequency with which LEP individuals come in contact with these <br />programs, services or activities; <br />• The nature and importance of the program, service or activity to people's <br />lives and; <br />• The resources available to the City and the likely costs of the LEP <br />services. <br />Four Factor Analysis <br />Using census data, Appendix C, the City has determined that LEP individuals <br />speaking English less than well represent approximately 76.6% of the <br />community. The City realizes that such statistical data can become outdated or <br />inaccurate. Therefore, the City contacted local law enforcement to validate the <br />proportion of LEP served by those entities. Spanish was reported to be the <br />prevalent LEP language with an estimate of 46% eligible to be served. <br />1. The City has received requests for translation or interpretation of its <br />programs, services or activities into Spanish and Russian. In addition, City <br />sponsored community outreach or public events are attended by LEP <br />individuals. Thus, the City estimates its contact with LEP individuals to be <br />high. <br />2. The City believes that transportation is of critical importance to its public, as <br />access to healthcare, emergency services, employment and other essentials <br />5 <br />