Item No. 11b_attach 1 Meeting Date: March 24, 2026 LANGUAGE ACCESS GUIDANCE MANUAL PREPARED BY THE OFFICE OF EQUITY, DIVERSITY, & INCLUSION Using This Guide and Why It Matters The Port of Seattle's Language Access Guidance Manual was developed in partnership by the Office of Equity, Diversity, and Inclusion (OEDI), External Relations (ER), and the Language Access Cohort. The content for the guidance manual was created by gathering data from the Language Access Cohort and documenting Port-specific practices, in addition to researching national best practices. This Guidance Manual is designed to support Port teams in providing timely and meaningful access to our facilities and services for Limited English Proficient (LEP) persons, as well as effective communication for individuals who are Deaf and speak American Sign Language (ASL). Port teams should strive to provide language assistance services to Limited English Proficient individuals whom they encounter or whenever a Limited English Proficient person requests language assistance services, as well as provide effective communication methods to individuals who are Deaf and speak American Sign Language (ASL). This guidance manual is to be used in conjunction with the Department Language Access Plan Template. This template and guidance manual are designed to support each department in building a strong, intentional foundation for delivering effective language access services. Quick Reference Guide Request Now: Interpretation | Translation Key Contacts and Resource Directory Annual Department Language Access Plan & Evaluation Template Most Common Languages at The Port of Seattle Language Access Services Interpretation (Spoken or Signed) Translation (Written) Pre-Translation Quality Assurance Checklist 2 3 4 5 6 7 8 8 Interpretation | Translation Request Process Language Access Training Public Communication and Outreach Community Engagement and Partnerships Complaint and Feedback Process Continuous Improvement, Monitoring, & Evaluation Appendices & Implementation Tools Appendix A: Key Definitions and Acronyms 9 10 11 11 12 13 14 14 Appendix B: Vital vs. Non-Vital Documents 16 Appendix C: Title VI and LEP Legal References 17 Appendix D: Non-Verbal Communication Card Samples 18 Appendix E: Annual Language Access Plan, Goals, and Evaluation Template 19 Appendix F: Complaint Form and Flow Chart 21 Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Request Now: Interpretation | Translation How to request on demand interpretation (spoken word) services: Are you in need of interpreation services immediately? Call Language Line 866-8743972 Department Have your 6digit Client ID. Indicate the Language you need. Be sure to document the interpreter's name and ID nuber for your reference. Brief the interpreter and give any special instructions. If you do not have a department client ID, please use: Central Services Non-Emergency Client ID: 663666 Client ID AV Landside Operations - OPI (Example: Parking services) Central Procurement Office - OPI Central Procurement Office - VRI External Relations - OPI External Relations - VRI Legal Aid Attorneys - OPI Legal Aid Attorneys - VRI Legal Department - OPI Legal Department - VRI Port of Seattle Fire Dept - OPI Port of Seattle Fire Dept - VRI Port of Seattle Police Dept - OPI Sea Tac Intl Air - OPI (Example: Customer service, Pathfinders, CBP) Sea Tac Intl Air Insight - VRI (Example: Customer service, Pathfinders, CBP) VRI = Video Remote Interpretation OPI = Over the Phone Interpretation 652627 659158 659159 710304 710305 655158 655159 657517 657518 663827 663829 143009 543400 577717 How to request video (video remote interpretation) services: Open the LanguageLine app on your work device. On your first visit you will be asked for a one-time authorization code. Enter the language you are requesting and an interpreter will appear on screen. How to request scheduled interpretation (spoken word) services: Are you requesting an interpreter for a later date? Submit your request using one of the resource links below How to request translation (written materials) services: Are you requesting a document for translation? Submit your request using one of the resource links below Links: Interpretation | Translation Request Form | Interpretation | Translation Request Email Template Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Key Contacts and Resource Directory This directory provides staff and partners with a one-stop reference for the Port of Seattle's Language Access Services. It should be reviewed and updated annually by the Office of Equity, Diversity, & Inclusion (OEDI) and department Language Access Leads. Internal Contacts Area/Function Language Access Coordinator / Civil Rights Program Manager OEDI Manager Policy/Comms Contact Name & Title LeAnn Blanco, Civil Rights Program Manager Jay Doran, Manger Policy and Communications Contracted Language Access Vendors Service Type Vendor / Provider Telephonic Language Line Interpretation Video Remote Fluentalk Interpretation Document Universal Language Translation Services Sign Language / Deaf Currently under and Hard of Hearing procurement Services Braille Pilot in Progress Community & Outreach Partners Organization Language / Community Served Washington State Visually Impaired School for the Community Blind/Ogden Resource Center Emergency and Accessibility Resources Resource Contact / Link Emergency Interpretation and Interpretation Language Services | Support Port of Seattle ADA Coordinator Candace Field TTY / Relay Service Dial 711 (Washington Relay 711) Email / Phone Blanco.l@portseattle.org Responsibility / Support Provided Language Access Anti-Human Trafficking Civil Rights (Title VI) Doran.J@portseattle.org OEDI Policy and Communications Access Method Phone, Tablet, App, etc. Notes / Availability SEA, Customer Service, Available upon request SEA Volunteers Only Tablet Contact OEDI - Fill out Request: Interpretation | Translation Request Form Contract Information All Port of Seattle Role / Partnership Purpose N/A Braille services Purpose Interpretation Services SEA Title II (ADA) Telephone access for Deaf or hard-of-hearing customers. Use Case Accessibility Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Annual Department Language Access Plan & Evaluation Template Every department must complete and submit an Annual Language Access Plan to the Office of Equity, Diversity, and Inclusion (OEDI). This plan documents goals, implementation activities, and performance indicators aligned with the Port's enterprise-wide Language Access Program. The purpose of the Language Access Plan is to establish measurable, annual goals that advance meaningful language access, and to monitor compliance, effectiveness, and equity outcomes across departments. Instructions for Departments Complete the Language Access Plan as part of your department's annual business planning process. Submit to the Civil Rights Program Manager for review and compilation into the Port-wide Annual Language Access Report. Section Department Overview LEP Population Summary Annual Language Access Goals Key Activities / Strategies Monitoring and Evaluation Metrics Resource / Budget Needs Evaluation Summary (End of Year) Description / What to Include Program description, primary public-facing services, contact for Language Access Lead/Liaison Top languages served, frequency of contact, data sources. 3-5 SMARTIE goals (Specific, Measurable, Achievable, Relevant, Timebound, Inclusive, Equitable) Planned actions: translation updates, staff training, signage, outreach partnerships Quantitative and qualitative indicators: # of interpreters used, # of translated documents, customer feedback results. Funding, staffing, or technology required to achieve goals Actual outcomes vs. goals, lessons learned, recommendations for next cycle. Language Access Plan Department Template: Appendix D: Annual Language Access Plan, Goals, and Evaluation Template Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Most Common Languages at The Port of Seattle Across the Port, certain languages appear more frequently. At the same time, language needs vary by department and facility. This means each team should consider both the system-wide languages commonly encountered and the languages most relevant to their own customer-facing environment when determining translation and interpretation needs. Port of Seattle - Languages Identified in Assessment (2024) Tier 1 Spanish Vietnamese Chinese Somali Japanese Korean Amharic Tier 2 American Sign Tagalog Language To view additional languages used throughout the Port, visit: LanguageAccessAssesment_March2024--1Consistent with Title VI requirements, the Port has adopted a tiered translation framework (Tiers 13) to guide decisions about written translation. This framework is intended to help departments assess language needs and apply language services in a manner appropriate to their operational context. Tier What This Means in Practice Common Signs • 1 - Translation Required You see/hear this language often, and people who speak it regularly use your services. • • • 2 - Translation Recommended 3 - Translation Encouraged You see/hear this language sometimes, or in specific situations, and translation would meaningfully improve access. You see/hear this language occasionally or rarely but offering translation can still be welcoming or inclusive. • • • • • • • • This is one of the top languages used by our customers Staff frequently receive requests for interpretation in this language This language appears often is customer data, feedback, or complaints Lack of translation would clearly limit access or create risk Requests for this language are regular but not constant Usage may be seasonal, locationspecific, or program-specific Interpretation is often used instead of written translation Translation helps people understand services but is not always critical Few documented requests for this language Contact is infrequent or one-time Language groups are small or emerging Translation improves inclusion but is not required for access Type of Documents Safety; rights, eligibility, legal notices, critical customer instructions Program info, standard customer service materials: Travel alerts Service changes Accessibility info Outreach or engagement materials Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Language Access Services The Port of Seattle provides a variety of language assistance services to ensure equitable participation in Port activities and communications. These services are available to any member of the public who requests or appears to need assistance in a language other than English. Language assistance is a shared responsibility: every department with public-facing programs must implement and maintain language assistance resources in accordance with this guidance and the Port's enterprise-wide Language Access Order. Service Type Description When to Use / Application Examples / Common Tools Onsite Interpretation (In-Person) A qualified interpreter is physically present to facilitate real-time spoken communication between staff and LEP individual. Complex, sensitive, or high-risk interactions Safety, enforcement, emergencies, or legal matters Public meetings, hearings, or community forums Contracted in-person interpreters Certified interpreters (medical, legal, or conference) Sign language interpreters Telephonic Interpretation Interpretation provided by phone, allowing immediate access to an interpreter without physical presence. Video Remote Interpretation (VRI) Interpretation delivered via video platform, allowing visual connection between interpreter and participants. Bilingual Staff Assistance Staff who are assessed and authorized to provide language assistance as part of their job duties. Documentation Translation Conversion of written materials from English into another language to ensure equal access to information. Digital Communication (Web, Text, Email, Apps) Digital Accessibility Library Immediate or unscheduled needs Short interactions Call centers, customer service lines When in-person interpretation is not feasible Situations where visual cues improve accuracy Deaf or hard-of-hearing individuals using sign-language Routine, non-complex interactions Customer service or information-sharing Not for complex, legal, or highrisk communications unless formally qualified Vital documents Language Line VRI platform Tablets, iPad, or laptop with camera Secure video conferencing tools Authorized bilingual staff lists Professional translation vendors Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Interpretation (Spoken or Signed) The Port requires that all interpreters - whether staff or contracted - be qualified and competent to provide accurate, impartial, and confidential language services. Standards include: • • • Demonstrated proficiency in English and the targeted language Knowledge of industry-specific terminology in one of the top nine Port languages Role must be public-facing, frontline customer service Interpretation Coordination A Checklist for Port Departments Best Practices to Integrate Interpretation into Your Event Planning 1. Plan and staff your event with your intended audience in mind a. When preparing your event, plan the appropriate logistics and staffing that will be needed for interpretation to go as smoothly as possible. Start by doing the following: ➢ Identify your Limited English Proficient (LEP) audience's points of participation and communication flow ➢ Identify how many interpreters are needed per language 2. Prepare in-language outreach materials a. Outreach materials should be translated in the target language(s) of your audience. b. Materials should include event and contact information, such as access information (virtual/remote) or address and location. 3. Create Interpreter Information Packet a. Send any relevant information to the interpreters as early as possible in advance of the event. For example: ➢ Event details, including point of contact for interpreters, venue access, and check-in instructions. ➢ Agenda, program, and run of show ➢ Event materials, presentations, websites, scripts, or planned talking points ➢ Post-related language glossaries if available, for term consistency ➢ Copes of in-language outreach materials used to promote the event 4. Meet with interpreters before your event IN PERSON EVENTS VIRTUAL EVENTS • Schedule interpreters to arrive early to go over the • Schedule a virtual run-through to ensure smooth program. transitions. • Designate support staff for equipment distribution • Test interpreters' connectivity, access, and signal and collection. clarity • Test equipment for clear signals (Tablets, Phones, • Establish lines of communication among interpreters, etc.) tech monitors, and event organizers/moderators • Coordinate with interpreters to ensure they are • Work with interpreters to coordinate: positioned where they can hear and will not interfere • In what order the interpreters will speak with each other • How interpreters will signal transitions • Remind event participants to speak slowly to allow for • Remind event participations to speak slowly to allow the best interpretation possible or the best interpretation possible 5. Follow up after the event and discuss lessons a. Identify lessons learned from your event to support future planning. For example: • Take note of what worked well to establish future protocols • If you host future events on the same subject matter, consider creatin a language or term glossary • Provide space for feedback and suggestions on improving coordination Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Translation (Written) Translation services provided by vendors or contractors should follow a two-step quality review process, consistent with recognized industry standards (such as ISO 17100). This includes translation by a qualified linguist and independent review by a second qualified linguist prior to delivery. Vendors and contractors remain responsible for the accuracy, completeness, and appropriateness of translated materials provided to the Port. Pre-Translation Quality Assurance Checklist Review this checklist before you send your English-language document to be translated. ☐ Check that your document uses the plainest language1 possible • Clear & Simple o Avoid puns, wordplay, or legal/industry jargon • Purpose Is Obvious o The reader can easily understand what this is, why it matters, and what they need to do. • Final & Ready o The content is complete and will not change after translation. ☐ Double check all key information, like phone numbers, links, dates and times. • Best practice: Use a month's name rather than a numeral to avoid confusion • Best practice: Make sure links lead to translated content • Best practice: If you choose to translate an agency name, consider also providing the English name or acronym so the audience can web search or ask for directions ☐ Include a context statement to the translator that describes the purpose of the document, the audience, and any other information that can help orient their work. • Remember the translator may be unfamiliar with your community and/or operations in your organization. 1 Order No. 2025-02 Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Interpretation | Translation Request Process This process streamlines how departments request interpretation and/or translation services through the Port of Seattle's, Office of Equity, Diversity, and Inclusion (OEDI). 1. Fill out a request form either online or copy and paste the template below into an email. a. Interpretation | Translation Request Form 2. Once submitted either online or via email, the Civil Rights Program Manager will commence the request with the vendor. a. All parties will be cc'd on all communications with vendors for accountability and transparency. 3. Expected a 24-hour turnaround time for a response from the vendor. The response will include: Project Number, Word Count, and a Quote. 4. Once the quote is approved by the appropriate parties, the Civil Rights Program Manager will communicate the approval to proceed with the request. Deliverables will be delivered in electronic format in the format in which the submission was received (Word, Pdf, etc.). Interpretation | Translation Request Email Template Project Name or Event Name: _____________________________________________________ Requestor Information (Name of person submitting): ________________________________ Specify what language service is needed: ☐Interpretation ☐Translation ☐Both Purpose or Intended Use: ☐Web Content ☐Public Meeting ☐Emergency Safety ☐Other Request Priority: ☐Standard (10-15 Business Days) ☐Expedited (5 Business Days) ☐Emergency (24-48 hrs. - Manager Approval Required) List Languages Requested: ___________________________________________________________________________________ Request Deadline (Date when deliverable is required): _______________________________ Has this request received approval from the necessary parties? (supervisors, directors, legal, etc.) ☐Yes ☐No ☐Not Applicable Budget Allocation: ☐Requestor Dept. has budgeted for this request. ☐Need OEDI to provide funding for this request. Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Language Access Training Language access is not just a compliance obligation; it is a core competency that advances the Port's mission of equitable service delivery. Training and professional development are therefore essential to embedding language accessibility as a standard part of customer service, community engagement, and civil rights compliance across all departments. Following foundational Lunch-and-Learns, micro-learnings will provide short, targeted learning opportunities that build awareness, reinforce key concepts, and support practical application of the Language Access Guidance Manual across Port departments. Roles and Responsibilities for Training Oversight Responsibility Role Office of Equity, Diversity & Inclusion (OEDI) Directors / Managers Language Access Leads Human Resources / Learning & Development Develops standardized training content; monitors compliance; analyzes completion data; reports annually Ensure staff complete required training within required timelines. Coordinate department-level training needs; support tracking and follow-up Maintains LMS records and supports reporting. Language Access Training Details Training Topic Audience Introduction to Language Access Guidance Manual All employees Who Needs Language Access Services Customerfacing roles Vital vs. NonVital Communication All Employees creating publicfacing content Interpretation Options & Tools Customerfacing staff Requesting Language Services All employees Learning Objectives Understand why language access matters and how it supports equitable service delivery Identify LEP populations and when language assistance is needed Distinguish between vital and non-vital information Understand interpretation modalities and appropriate use Learn how to request translation and interpretation services Intended Outcome Title VI / Compliance Alignment Shared baseline awareness of language access purpose and scope Establish baseline understanding of nondiscrimination obligations for LEP individuals Improved identification of language assistance needs Reinforces obligation to provide meaningful access to LEP individuals Reduced risk of Title VI violations Prioritizes translation of critical information impacting access to services Increased effective communication with LEP customers Supports timely access to oral language assistance Faster and more accurate service requests Supports consistent implementation of language access procedures All training will be accessible through our Learning Management System. Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Public Communication and Outreach The Port will ensure that the public, particularly limited English proficient (LEP) community members, receive timely, accurate, and accessible information about Port programs, services, and opportunities. Port Statement on Language Services Language assistance services - interpretation, translation, and communication access - are provided free of charge to any member of the public. At no time shall a person be denied, delayed, or charged for services because of language or communication barriers. All Staff must communicate this guarantee clearly and respectfully to ensure trust and equitable access. Required Public Notices Language Access Statement: Include the following statement in all public-facing materials, websites, and signage: "Free language assistance services are available. Please ask any Port staff member for help." Posting Locations: Display multilingual notices at customer-service counters, ferry/cruise terminals, meeting venues, public hearings, and Port websites. Translation of Key Notices: Translation of vital information, such as safety alerts, meeting announcements, complaint rights, and major service changes, into priority languages identified through the Port Language Access Assessment2 (Four-Factor Analysis). Digital Accessibility: Ensure that online materials meet ADA Title II. Community Engagement and Partnerships Collaborate with community-based organizations (CBOs) serving LEP and immigrant/refugee populations for message distribution, interpretation at outreach events, and feedback collection. • • Conduct listening sessions or focus groups at least once every two years to gather input on language-access effectiveness. Work with Port Communications and OEDI to develop multi-lingual communication plans for major capital projects or policy initiatives. Messaging Standards • • • 2 Use plain language and culturally responsive visuals. Avoid acronyms or technical jargon when possible. Validate translations for accuracy and tone with trusted community reviewers before publication. LanguageAccessAssesment_March 2024.pdf Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Complaint and Feedback Process This process is to ensure that all members, including individuals with limited English proficiency (LEP), can easily provide feedback or file complaints regarding language access, and that each concern is addressed promptly, respectfully and in compliance with federal and Port policies. The following will provide clear guidance for the public and staff to raise concerns about: • • • Delay of interpreter or translation services Lack of accessible information in preferred languages General feedback on the quality or effectiveness of language access services across the Port How to Submit a Complaint or Feedback Method Instruction By Phone By Email or Online Form Title VI Coordinator (206) 787-4156 TitleSixCoordinator@PortSeattle.org Printable form: TitleVI-Complaint-form_012024.pdf Online Form: Title VI Coordinator's Office Complaint Form | Port of Seattle OEDI Title VI Coordinator P.O. Box 1209 Seattle, WA 98111 By Mail Complaint Resolution Process Step Action Responsible Party Timeline Title VI Coordinator Manger EDI Policy & Comms Civil Rights Program Manager Acknowledge within 5-10 business days Intake & Acknowledgement Complaint or feedback is received, logged, and acknowledged (in the complainant's language when feasible) Review & Investigation Review complaint details, interview involved staff if needed and determine whether a Title VI or policy violation occurred. OEDI + Department Lead + EEO + Professional Standards + Legal if applicable Response & Resolution Provide written response outlining findings and corrective actions. Offer translated summary if requested. Title VI Coordinator Manger EDI Policy & Comms Civil Rights Program Manager EEO Professional Standards Follow-Up & Tracking Log outcome and identify trends for improvement. OEDI Initial Review: 10-15 days Investigation: 30-60 days Resolution: 60-90 days Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Internal Review and Escalation To ensure accountability and continuous improvement within Port operations, this structured process will allow staff and leadership to review, analyze, and correct issues related to language access implementation, whether discovered through: Step Issue Identification Preliminary Review Formal Escalation Corrective Action Plan Monitoring & Closure Action A potential language-access issue identified (e.g., repeated complaints, missing translations, noncompliance by vendor) The Language Access Lead/Liaison confirms facts, gathers documentation, and reports the issue to the Department Director and OEDI. If the issue involves a potential Title VI violation, failure to provide services, or resource gap affecting multiple customers, it is formally escalated to the OEDI Director and Legal Department. OEDI and Department Leadership develop a written plan outlining root cause, corrective steps, timeline, and responsible persons Progress is tracked quarterly until resolved; lessons learned shared with Language Access Workgroup Responsible Party Timeframe Staff, Language Access Lead/Liaison, or OEDI As needed Department Language Access Lead/Liaison Within 5 business days OEDI + Legal Within 10 business days OEDI + Department Director Within 30 business days OEDI Ongoing Continuous Improvement, Monitoring, & Evaluation In alignment with Commission Order 2023-05, the Port of Seattle recognizes language access as a continuous practice that requires regular monitoring, evaluation, and refinement. By reviewing data, training outcomes, service usage, and community feedback, the Port will identify gaps, strengthen practices, and adapt to changing needs. This commitment to continuous improvement ensures sustained compliance with Title VI while advancing equitable, inclusive, and accessible services for all communities. Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Appendices & Implementation Tools Appendix A: Key Definitions and Acronyms Word ADA Title II (Effective Communication) Bilingual Staff / Designated Bilingual Position CBO (Community-Based Organization) Complaint Cultural Competence Cultural Responsiveness DOT (Department of Transportation) Equity Essential Public Information / Vital Documents Executive Order Four-Factor Analysis Interpretation Language Access Language Access Coordinator Language Access Lead / Liaison Language Access Plan LEP (Limited English Proficient Individual) LEP Threshold Definition Requires state and local governments to ensure effective communication with individuals with disabilities, including those who are Deaf, hard of hearing or have speech impairments. An employee officially approved and qualified to use another language as part of their regular job duties to assist LEP customers. Proficiency should be verified and documented through assessment. A nonprofit or grassroots group that represents and provides services to a specific linguistic, cultural, or geographic community; often engaged as partners for outreach or feedback. A formal expression of dissatisfaction alleging that an individual or group was denied language access or discriminated against based on national origin, in violation of Title VI or Port policy. The ability of staff, systems, and organizations to understand, respect, and effectively respond to the cultural and linguistic needs of diverse populations. It includes awareness of one's own biases and commitment to continuous learning. The active practice adapting services, communication, and engagement strategies so they algin with the cultural values, communication styles, and expectations of the people being served. Federal agency that provides Title VI and LEP compliance oversight for transportation entities, including ports and airports. Fair treatment, access, opportunities, and advancement for all people while striving to identify and eliminate barriers that have prevented the full participation of historically oppressed communities. Improving equity involves increasing justice and fairness within institutions and systems and ensuring fair and intentional distribution of resources. As per the executive Order, "Essential Public Information" is any information developed or used by the department and deemed vital for purposes of public safety, public health and economic development. This term is used interchangeably with the term "vital documents". The Title VI-required assessment process used to determine language-access obligations by examining: Number/proportion of LEP people served or likely to be encountered. Frequency of contact Nature and importance of the service; and Available resources and costs. The oral rendering of speech from one language to another in real time (e.g., in-person, telephonic, or video-remote interpretation). Interpretation = spoken. The provision of oral and written communication assistance, such as interpretation and translation, enables LEP individuals to have meaningful access to a program, service, or activity. A senior staff member who will be responsible for policy compliance and implementation of the language access plan. A department-level contact is responsible for implementing language-access practices, completing annual plans, liaising with OEDI, and monitoring compliance within their department. A written plan outlines how a department or program will provide language assistance, monitor effectiveness, and achieve annal goals for meaningful access. A person who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English. (Title VI and Executive Order) The quantitative benchmark that determines when translation or interpretation is required for a given language group. (e.g., 5 % or 1,000 individuals, whichever is less, of the eligible service population). Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Meaningful Access Monitoring and Evaluation No-Cost Guarantee OEDI (Office of Equity, Diversity, and Inclusion) Qualified Interpreter Target Audience Title VI of the Civil Rights Act of 1964 Translation Vital vs. Non-Vital Communication Vital Documents Access is accurate, timely, and effective in enabling LEP persons to fully participate in or benefit from Port services, activities, or information. Meaningful access is the compliance standard under Title VI. The ongoing process of collecting, analyzing, and reporting data on language-access implementation to ensure continuous improvement and compliance with federal and Port policies. A Port commitment that interpretation and translation services are provided free of charge to LEP or Deaf/hard-of-hearing individuals. The Port office responsible for overseeing implementation of equity and language-access initiatives, training, monitoring, and compliance reporting. An individual who demonstrates proficiency in both English and the target language, understands industry-specific terminology, and adheres to confidentiality and professional-ethics standards. Family members, friends, or minors must not be used except in emergencies. The specific group(s) of community members or stakeholders for whom information, communication, or outreach is intended, defined by language, geography, or service use. Federal law prohibiting discrimination based on race, color, or national origin in any program or activity receiving federal financial assistance. (42 U.S.C. § 2000d et seq.) The written conversation of text from one language into another while preserving meaning, accuracy, and cultural appropriateness. Translation = written. Vital: Information that is critical for an individual to safety, effectively, or legally access, use, or participate in a program, service, facility, or activity. Non-Vital: Information or promotional materials that enhance understanding but are not critical to access or participation. A specific type of vital communication. Vital documents are any written materials that contain information critical to obtaining meaningful access to a program, service, activity, or facility. Example of Vital Documents • Consent forms • Complaint forms or Title VI/Title II notices • Applications for services or permits • Safety instructions and wayfinding • Eligibility criteria or program rules • Notices of rights, responsibilities, or deadlines • Instructions for accessing or navigating port services • Multilingual signage that directs behavior or ensures safety Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Appendix B: Vital vs. Non-Vital Documents Translation Decision Tree A document is considered vital if it: • Affects access to services, programs, or benefits • Involves health, safety, security, or emergency information • Explains legal rights, responsibilities, or obligations • Is required to obtain or maintain eligibility • Informs individuals how to file complaints or request accommodations Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Appendix C: Title VI and LEP Legal References Federal Statues Law/Regulation Title VI of the Civil Rights Act of 1964 Citation 42 U.S.C. § 2000d et seq. Section 504 of the Rehabilitation Act of 1973 29 U.SC. § 794 American with Disabilities Act (ADA) - Title II 42 U.S.C. § 12131 et seq. and 28 C.F.R. Part 35 Civil Rights Restoration Act of 1987 Pub. L. No. 100259 Federal Implementing Regulations and Guidance Agency / Document Citation / Year U.S Department of Transportation (DOT) - 49 C.F.R Part 21 Title VI Regulations DOT - Policy Guidance Concerning 70 Fed. Reg. Recipients' Responsibilities to Limited 74087 (Dec. 14, English Proficient (LEP) Persons 2005) Federal Aviation Administration (FAA) - FAA Order Nondiscrimination Compliance Program 1400.11 (2017) U.S Department of Justice - Title VI Legal Manual, Section IX: Limited English Proficiency Washington State and Local Authorities Authority Washington State Law Against Discrimination (WLAD) Office Financial Management (OFM) State Language Access Directive Port of Seattle Commission Order 2023-05 - Removing Barriers Through Language Access Updated 2023 Citation / Reference RCW 49.60 OFM Directive 2201 (2022) Adopted April 2023 Description / Relevance Prohibits discrimination based on race, color, or national origin in any program or activity receiving federal financial assistance. Language barriers that exclude or delay access for LEP persons constitute national-origin discrimination. Prohibits discrimination based on disability in federally assisted programs and activities. Includes communication accessibility obligations that complement language-access duties. Requires state and local government entities to ensure effective communication for people with disabilities (e.g. Deaf/hard of hearing, speech impairments). Often referenced alongside language-access requirements. Clarifies that Title VI covers all operations of a recipient organization, not only the federally funded program. Purpose / Relevance Implements Title VI within DOT and all funding recipients (includes ports, airports, and transportation programs). Defines the Four-Factor Analysis and best practices for providing meaningful access for LEP individuals. Directs airports / aviation recipients to implement title VI, Section 504, and LEP requirements, including annual certification and complaint procedures. DOJ's authoritative interpretation of Title VI as it applies to LEP populations; includes examples of complaint and noncompliant practices. Relevance Prohibits discrimination in employment, housing, and public accommodations; reinforces Title VI standards at the state level. Establishes statewide expectations for language access and translation in executive agencies. Formally commits the Port of Seattle to enterprise-wide language access, including annual department plans and equity-centered implementation. Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Appendix D: Non-Verbal Communication Card Samples (For more information contact: Candace Fields, AV F&I Accessibility Program Manager) Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Appendix E: Annual Language Access Plan, Goals, and Evaluation Template Port of Seattle - Language Access Plan for Departments Purpose: This Language Access Planning document is required for each of the 18 high usage departments. This form should be filled out in collaboration with the department's Language Access Cohort representative, your department lead/Director, and input from team members on annual activities planned. This document will be used to guide each Port of Seattle department in setting annual language access goals, monitoring implementation, and evaluating progress toward Title VI and equity compliance. Instructions: Complete this plan annually by January 31 and submit it to the OEDI Civil Rights Program Manager. Attach any supporting documentation, including but not limited to: Four-Factor Analysis worksheet, LEP statistics, or community feedback. OEDI will compile results for the Portwide Annual Language Access Report. Department Information Department Dept. Lead Language Access Lead / Liaison Reporting Year Date Submitted Reviewer (OEDI) Section A - Department Overview Describe your department's primary programs, services, or public contact points: (e.g., airport terminal operations, maritime customer service, community outreach, job postings, permitting, public meetings) Section B - Limited English Proficient (LEP) Population Summary Data Point Information Top 3 Languages Served Data Sources Used (e.g., customer logs, surveys, etc.) Estimated % or # of LEP Customers Frequency of LEP Contact (Daily / Weekly / Monthly / Seasonal) Identified Community Partners Serving LEP Populations Section C - Annual Language Access Goals List 3-5 SMARTIE goals (Specific, Measurable, Achievable, Relevant, Time-bound, Inclusive, Equitable) that reflect department needs and Port-wide priorities. Goal # Goal Statement Baseline Data Target Metric / Lead Target Outcome Responsible Completion Date Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Section D - Key Activities / Strategies Planned Activity Description / or Initiative Deliverable e.g., Update Translate multilingual wayfinding signs signage at cruise into top 5 terminals languages identified in FourFactor Analysis Staff Responsible Facilities Team Section E - Monitoring and Evaluation Metrics Indicator / Metric Data Source or Reporting Collection Frequency Method e.g., # of Language Access Quarterly interpreter Service Log requests per quarter Section F - Resources and Budget Needs Resource Type Estimated Cost / Support Needed e.g., Interpreter services contract, translation software license. Staff training hours allocation Status (Planned/In Progress/Completed) In Progress Responsible Person / Team Timeline Q2 2026 Notes / Comments Dept. Lead Funding Source / Request Justification / Notes Section G - End-Of-Year Evaluation Summary Provide a summary of key outcomes, challenges, and recommendations for next year. Questions Response Which goals were fully or partially met? What barriers or gaps impacted implementation? What community or staff feedback informed your evaluation? What are next year's priority actions? Sign-Off Name/Title Signature Date Dept. Lead Language Access Lead/Liaison OEDI Reviewer Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293 Appendix F: Complaint Form and Flow Chart Complaint Submitted Investigation •30-60 Business Days Intake and Acknowledgement Initial Review •10-15 Business Days •5-10 Business Days Resolution and Response •Within 60-90 Business Days Escalation (If needed) Need Help? Contact the Civil Rights Program Manager: blanco.l@portseattle.org | 206-867-1293