City of Portland Language List and Guidance
Factor 1 analysis and City of Portland Languages List
As Portland continues to diversify, it is becoming home to a significant number of people who are multilingual and multicultural and have limited proficiency in speaking and/or reading English. As a City that is committed to equity and needs to work for everyone, it is imperative that appropriate support be provided to this segment of the population. However, the native languages spoken by these groups differ and Factor 1 analysis is the tool that helps draw a list of various languages and prioritize language services to Portland residents who have limited proficiency in English.
A Factor 1 analysis involves assessing the number or proportion of LEP (Limited English Proficiency) persons by language group eligible to be served by a program, activity, or service. It covers the entire city of Portland service area. The analysis uses demographic data from the five-year American Community Survey and the Oregon Department of Education school enrollment data for school districts in Portland. Further, the analysis helps develop the safe harbor language list. The non-English language groups qualify for the safe harbor provision by having an LEP population of 1,000 people or more within the Portland service area. The analysis also helps generate spatial distribution of LEP population in the City which in turn will serve as citywide equity tools. The current set of Factor 1 analysis maps are housed in CGIS and will be accessible through the Office of Equity & Human Rights’ Language Access webpage. This analysis is conducted approximately every three years. The next analysis will be conducted Spring 2021 when the census releases its decennial data.
To use plain language, the list will now be referred to as the City of Portland Languages List instead of using the legal terminology. The City of Portland Languages List was previously referred to as the Safe Harbor Language List.
What does “safe harbor” mean?
Safe harbor refers to a legal provision to reduce or eliminate liability in certain situations if certain conditions are met.
What does “Limited English Proficiency” (LEP) mean?
Limited English Proficiency (LEP) refers to “Individuals who do not speak English as their primary language and who have a limited ability to read, speak, write, or understand English can be limited English proficient, or "LEP." These individuals may be entitled language assistance with respect to a particular type of service, benefit, or encounter.” (Source: lep.gov)
LEP individuals are community members who often are multilingual and may be English language learners. An LEP individual may be able to communicate in English to a certain degree or in certain circumstances depending on the topic/vocabulary, but have the civil right, in accordance with Title VI, Civil Rights Act 1964 & E.O. 13166, to request access to information, services, and programs in their preferred language, from the City, free of cost. Language proficiency is a spectrum. For example, a multilingual individual may prefer to read in their language of preference when receiving pertinent information, i.e. communications with legal language and/or financial impacts.
II. City of Portland Language List
The languages listed are languages spoken by approximately 1,000 or more Limited English Proficiency (LEP) individuals in the City of Portland service area:
Additional languages spoken by many of Portland’s LEP community members (numbers did not reach the 1,000 threshold, but are important to note due to the number of community members who speak the language):
- Laotian (Lao)
- Mon-Khmer Cambodian
*LEP maps: http://gis-pdx.opendata.arcgis.com/datasets/limited-english-proficiency
Please note that the City of Portland Language List is for the entire City service area and should be used for city-wide programs and services. Using the language list to determine language services is usually applied to translations (written), vital documents, and planned, non-requested, interpretation.
The list is best employed for planning program and communication strategies particularly when we have undetermined language needs. It should be used to remove general barriers and anticipate and ensure access at the broadest level.
The service provided based on this list demonstrates proactive language services and simultaneously will be considered strong evidence of compliance with Title VI obligations.
Best practice includes defaulting to the top two to four languages at minimum when assessing which languages to translate vital documents or signage into or for providing proactive, planned interpreting for community engagement. In general, the top four languages rarely tend to change from assessment to assessment.
When a program or activity impacts a specific or smaller service area, best practice is to assess the language needs of the LEP populations in that area (a “mini” Factor 1 analysis). The results will help the bureau provide better and more targeted programs, services, and communications.
When an LEP individual requests language services you are not limited by the City of Portland Language List and should seek professional language services in the language requested by the member of the public.
IV. Community Engagement
Conduct robust community engagement prior to, or in conjunction with, document translation.
Community engagement is best practice in providing effective language access to multilingual community members. It is important to use community engagement best practices at key decision points instead of simply translating documents. In-person interactions such as engaging with the community at a meeting to disseminate information is often most effective and preferable to multilingual populations versus stacks of translated documents and fliers. A recommended language access resource for bureaus engaging with multilingual communities is the Community Engagement Liaisons (CELs).
To ensure culturally responsive engagement, partner with culturally and linguistically specific organizations, and community leaders to inquire how the communities prefer to be engaged with. Center community voice in your public engagement efforts in order to conduct equitable community engagement.
Robust community engagement includes research on behalf of the bureau to find out what languages community members speak in the service area served by the bureau’s programs, services, and activities.
Effective, culturally and linguistically specific community engagement fosters trust between city government and immigrant/refugee communities (multilingual communities).
V. Communication Path
The most important consideration by the institution (City government) is to keep in the forefront that the “end user” is a community member. Consider the communication path that is being created by the institution (bureau/government). The communication path helps guide the institution in navigating the institution through the perspective of the LEP community. Communication path considerations at major decision points in planning, program and service design, communications, and policy design will help ensure the removal of barriers to government for LEP community members. Keep in mind the goal of the program, service, activity, communication, or policy, and follow the communication path to ensure institutional language access barriers are avoided, or, addressed and removed in order to provide equitable, meaningful access to achieve the intended outcomes and goals.
VI. Cultural considerations
Of course, there are many cultural considerations with regard to language access. There are many languages spoken in Portland which are indigenous languages and at present there are not many available language service providers that can fill those language requests. There should still be an effort to locate an interpreter or translator for the requested language. At times, using the commonly spoken language of the region could be an option in conjunction with a CEL (community engagement liaison) who may be able to speak the indigenous language (i.e. Spanish & Maya). Another important consideration is oral versus written preference for communication of information. This will vary from culture to culture. For example, the Somali population largely prefers oral communication of information. Even when a cultural group is willing/able to receive written communication, at times the best way to reach a larger swath of the community is through oral communication disseminated at cultural hubs, with trusted community leaders. Other important considerations include historical distrust of government, mixed status households and fear of authorities, acculturation spectrum and intergenerational issues, intergroup complexities, etc. These are only some of many complex cultural considerations when examining language access. These considerations are important because they are some of the complex factors at play in community engagement between multilingual and multicultural communities and city government.
Language and culture are fluid. Language Access is a continuous quality improvement process and recognizes the ever-changing demographics of our community.
For questions regarding Citywide Language Access, contact:
Equity and Language Access Analyst
Office of Equity and Human Rights
* The Factor 1 analysis for Portland was conducted by Uma Krishnan, Demographer and Analyst with Portland Housing Bureau and the LEP maps were produced by Neil Loehlein, GIS Analyst at The Bureau of Planning and Sustainability.
LEP maps: http://gis-pdx.opendata.arcgis.com/datasets/limited-english-proficiency