Metro Bus Limited English Proficiency (LEP) Plan

This Limited English Proficiency Plan has been prepared to address Metro Bus’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 federal 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 St. Cloud Metropolitan Transit Commission which receives federal assistance through the U.S. Department of Transportation [U.S. DOT].

LEP persons include those individuals whose primary language is not English and who have a limited ability to read, write, speak or understand English and have reported to the U.S. Census that they do not speak English well or do not speak English at all. A link to the Metro Bus LEP Plan is included on the Metro Bus website.

Metro Bus has developed this Limited English Proficiency (LEP) Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency (LEP) who wish to access public transportation services provided by the transit authority.

This plan utilized the U.S. DOT four-factor LEP analysis to identify individuals who may need language assistance; ways in which assistance may be provided; staff training; and how to notify LEP persons that assistance is available. The analysis considers the following:

1. The number or proportion of LEP persons in the service area who may be served or are likely to encounter a Metro Bus program, activity or service.
   The 2010 Census Report identified that 103,000 people live in the St. Cloud, Sauk Rapids, Waite Park and Sartell. These communities comprise Metro Bus’s four city service area. Between 2000 and 2010 the Asian, Black, and Hispanic/Latino populations increased at a rate of 50.9%, 59.8% and 74.5% respectively, as compared with the white population which increased by only 2.8%.
   2010 Census Data indicates 7.1% of people living in St. Cloud, 2.5% of people living in Sartell, 3.6% of people living in Sauk Rapids and 7.6% of Waite Park residents speak languages other than English in the home.   Somali was the number one language spoken, other than English. It is estimated by the St. Cloud School District that 90% of adult learners that do not speak English well or do not speak English at all are Somali immigrants. It is estimated the other 10% are people who speak Spanish. There are a total of 38 languages spoken in the St. Cloud Metropolitan Area, primarily due to a large international student population at St. Cloud State University.
   In consideration of demographic changes in the area since the 2000 Census, a survey of other organizations serving the same demographic population and Metro Bus front line staff was conducted.
   1. Cloud District #742 Adult Education and Sauk Rapids/Rice Adult Education programs serve the immigrant populations in the service area, both long-term and recent immigrants. As of mid-September, in 2024 St. Cloud Adult Basic Education had roughly 750 enrolled learners. Approximately 150 of these learners are enrolled in the beginning English as a Second Language classes, meaning they do not speak English well or speak English not at all.
   2. MN Workforce Center. A survey indicated they serve a growing Somali population and a smaller number of immigrants from other countries. The Workforce Center estimates a population of 6000+ Somali residents in the St. Cloud Metropolitan Area. It is their experience that Somali individuals aggressively proceed to learn the English language. There is a smaller Hispanic population that is not as interested in learning language. Hispanic people utilize the Workforce Center at a lower rate than Somali residents. The Workforce Center has experienced that individuals from countries other than Somali and Mexico typically speak some of English.
   3. Other organizations serving the recent immigrant populations (including St. Cloud Area Somali Salvation Organization [SASSO]; Hands Across the World, Catholic Charities, Lutheran Social Services, Community Anti-Racism Education [CARE] task force; and the newly formed United South Sudanese Organization) indicate a continued growth in the recent immigrant population to the St. Cloud Metropolitan Area.
   4. Fixed Route Dispatch and Drivers reported an annual increase in Somali ridership. They stated that the majority of Somali passengers are adult females and most travel with a companion who is somewhat fluent in English. They also reported that most Spanish-speaking passengers are able to understand simple English words and communicate using single words or nonverbal communication.
2. The frequency with which LEP persons come in contact with Metro Bus programs, activities or services.
   LEP individuals ride Metro Bus Fixed Route service daily as they travel to school, appointments, shopping and social activities. As more and more LEP individuals receive travel training in their native Somali or Spanish language from Metro Bus Travel Guides it is expected that ridership by Somali and Spanish speaking individuals will consistently increase. The small, but consistently growing LEP population in this region, combined with a quality travel training program, will steadily increase contact between individuals with limited English proficiency and Metro Bus operators and dispatch staff.

3. The nature and importance of programs, activities or services provided by Metro Bus to the LEP population.
   There is a growing geographic concentration of Somali LEP individuals in the Metro Bus service area. The overwhelming majority of the population, 93% in St. Cloud Metropolitan Area, speaks only English. There are social services, professional and leadership organizations within the Metro Bus service area that focus on outreach to LEP individuals. Metro Bus works closely with these organizations.
   Metro Bus provides two transportation services: 1) Fixed Route and 2) Dial-a-Ride that serves those whose disabilities prevent them from riding the Fixed Route system. Metro Bus has a Community Outreach and Travel Training program which provides individualized and group route training for the Fixed Route system.
   3. Travel training in the English language for those requesting route training on our Fixed Route system.
   4. Specialized travel training in Spanish and Somali language for individuals who do not speak English proficiently. Metro Bus has identified that Spanish and Somali speaking individuals learn the Fixed Route system faster when taught in their native language.

4. The resources available to Metro Bus and overall cost to provide LEP assistance.
   Metro Bus assessed its available resources for providing LEP assistance. Interpretative services are available at a reasonable cost through local organizations. Community volunteers are available on a no cost basis to assist with verbal and document translation on an as-needed basis. Metro Bus has one (1) Somali-speaking Travel Trainer and one (1) Spanish-speaking Community Outreach and Mobility Specialist. Each of these employees is available during normal business hours to work exclusively as Travel Guides training Spanish and Somali-speaking individuals to ride the Fixed Route service.
   Metro Bus’s website can convert all transit information into 53 different languages through Google translate. Metro Bus also translates several marketing, training and informational materials in Spanish and Somali. The materials are provided in print, on the website and via QR code for mobile access.
   Based on the four-factor analysis, Metro Bus developed its LEP Plan as outlined in the following section.
   The following actions have been taken by Metro Bus to identify and assist LEP individuals to utilize its public transportation services:
   4. Distribution of Information
      Bus schedules, website information and fliers are distributed at ESL schools, daycare centers, health and human service agencies, health care providers, and posted onboard buses. These materials contain contact information to Metro Bus Community Outreach Staff and the dedicated Spanish and Somali speaking staff.
   5. Travel Trainers
      Bilingual employees who speak both English and Somali or Spanish are employed by Metro Bus as Travel Trainers. Travel Trainers are assigned as part of a community outreach program to provide assistance to LEP individuals to utilize Metro Bus public transportation services.
   6. Resource Tables
      Resource tables are scheduled and maintained throughout the community at organizations, agencies and special events which target an LEP audience to provide information regarding Metro Bus services to individuals and groups.
   7. Agency Website
      An agency website is maintained by Metro Bus with key information including schedules, route maps, and How to Ride the Bus videos filmed onboard a Metro Bus route. These videos are presented in English, Somali and Spanish and provide visual demonstration on how to board the bus, pay the fare, pull the chord and exit the bus. LEP individuals may watch the video with a Travel Trainer as part of the travel training process.
   8. Training Opportunities
      4. Classroom and Onboard Training – Metro Bus provides classroom or onboard training opportunities to the general public including English and non-English speaking individuals.
      5. Travel Training – Travel training is provided free to those individuals who need assistance in learning how to ride the fixed route bus, read schedules and navigate the system. Travel training is provided to English and non-English speaking individuals. Translation services are also provided. Travel Training is provided through use of a You Can Ride training guide. Metro Bus staff will ride with the individual from pick-up to destination and demonstrate how to ride Metro Bus public transportation service.
   9. Communication Tools
      4. Census Bureau Language Identification Flashcards – these flashcards are used at the Transit Center. Individuals self-identifying as persons not proficient in English may not be able to be accommodated with immediate translation assistance. However, this system assists Metro Bus staff to identify language assistance needs.
      5. Destination Cards – passengers are provided destination cards to use on future rides if they have trouble identifying their travel destination.
      6. Picture Books – Metro Bus Picture Books are available and provided to individuals unable to speak English who do not have a companion rider to assist with translation. The picture book includes pictures of Metro Bus facilities and buses and the most common destinations within the
      7. Metro Bus service area. This book is used by the individual to communicate with either dispatch or operator staff. All Metro Bus operators and dispatch staff have access to the picture book for use as needed.
      8. Route Maps – The Metro Bus System Map is a universal language. Metro Bus sells maps and has the map on its website ridemetrobus.com.
   10. Translated Materials
       4. Google Translate is available on the website to translate schedules into languages other than English.
       5. All bus schedules include the following message translated in Spanish and Somali:
          Need help learning how to ride the bus? Call Metro Bus: 320-528-6895.
       6. Metro Bus Code of Conduct is posted in English on all Fixed Route and Dial-a-Ride buses and includes pictures to depict expected behavior. The poster includes language in Spanish and Somali indicating the information will be translated upon request. Brochures of the Code of Conduct in
       7. Somali and Spanish are also available on all buses.
       8. Metro Bus’s website can convert all transit information into 53 different languages through Google translate.
       9. Metro Bus also translates several marketing, training and informational materials in Spanish and Somali. The materials are provided in print, on the website and via QR code for mobile access.
   11. Translation Services
       4. Metro Bus utilizes translation services through Bridge-World Language Center. Interpretive services are provided in all languages as needed.
       5. When available, family members and other service providers may also be called upon to interpret.