Language Assistance Plan 7.7.2025

Language Assistance Plan  
 
This plan was developed to address Town of Waterford Language Assistance Plan to assist 
residents who are language deficient. At this time (93.0%) ninety-three percent of the Town of 
Waterford’s population indicated that they speak English “very well”. 7 % of the remaining 
population that describes themselves as speaking English less than “very well”, the census 
indicates that the non-English speaking individuals are fluent in either Spanish or Indo-
European Languages. 
 
Policy 
It is the policy of the Town of Waterford to provide timely and meaningful access to all agency 
programs and activities for Limited English Proficiency (LEP) persons.  Our primary goal is to 
communicate effectively with LEP individuals.  When staff has reason to believe that an 
individual is LEP, it is incumbent on the staff to respond to that individual in a language he/she 
understands.  Staff will provide or facilitate language assistance services to LEP individuals 
whom they encounter or upon request of the LEP individual at no charge and within a 
reasonable amount of time. Notice is posted in offices so that members of the public will be 
aware that language assistance services are available at no cost. A statement is also available 
on website in policies and procedures documents.  
 
Procedure 
Public Hearings, notices, and brochures will indicate that free language assistance is available.  
Upon request, written documents may be translated in the language of the LEP individual and 
then be returned to the LEP individual within a reasonable length of time.  Upon request, a 
language-interpreting vendor can provide interpretation services via the telephone.  There will 
be no charge to the LEP individual for this service.  
  
Four Factor Analysis 
 The TOW shall determine which items, if any, will be translated and available prior to being 
requested by a LEP individual by applying the four-factor analysis. These documents may 
include but not be limited to: 
 
Emergency Transportation Information 
 
Markings, signs, and packaging for hazardous materials and substances. 
 
Notices of public hearings (i.e. legal notices) regarding TOW’s proposed plans, projects, or 
changes, and reduction, denial, or termination of services or benefits. 
 
 
 
 
 
 

The Four Factor Analysis that will be taken into consideration are as follows: 
 
1. The number or proportion of LEP persons eligible to be served or likely to be 
encountered by a program, activity, or service provided by Senior Services.  
 
2. The frequency with which LEP individuals come in contact with the program, activities or 
services.  
 
3. The nature and importance of the program, activity, or service provided by the TOW to 
the     LEP population. (Make a determination as to whether denial or delay of access to 
services or information could have serious or even life threatening implications for the 
LEP individual.) 
 
4. The resources available to the TOW and the overall costs to provide LEP assistance. 
(Examine cost and benefit; limiting services must be well substantiated before using this 
factor as a reason to limit language assistance.) 
 
Currently the only document available in a language other than English is the Spanish version of 
the transportation registration form.  Other documents are not routinely available in languages 
other than English due to lack of demand.  
                                                                  
The Fact Finder Surveys will be reviewed biennially to determine whether changes in the 
Town’s population indicate that 5% or more of the population are unable to speak English “very 
well”.  If the review indicates a significant population of Spanish speaking (or other language) 
individuals then documents such as, brochures, registration forms, policies, and procedures will 
be translated to the alternate language identified as being the most prevalent and will be 
available to LEP individuals.  
 
Language Assistance Measures  
 
In the event that a resident/customer with Limited English proficiency (LEP) requests the 
services of an interpreter, either by phone or in person, Senior Services staff will respond to the 
request in a reasonable amount of time.  Staff can either contact the Title VI coordinator to 
arrange for interpretive services or staff can show the LEP individual the “I Speak” poster or 
cards in order to determine what language the person speaks.  If staff can use the services of a 
Spanish-speaking staff member they will make the appropriate arrangements.  If the LEP 
individual needs a translator for any other language, Staff will then dial 1-800-752-6096 to 
request the services of an interpreter who can translate for the individual and for the staff.  The 
Town of Waterford has a contract with Language Line Solutions to provide on demand 
translation services via telephone to LEP persons. 
 
Interpreters should demonstrate proficiency in and ability to communicate information 
accurately in both English and in the other language and identify and employ the appropriate 
mode of interpreting (e.g., consecutive, simultaneous, summarization, or sight translation). 
Interpreters should have knowledge in both languages of any specialized terms or concepts 

particular to the program or activity and of any particularized vocabulary and phraseology used 
by the LEP person; and understand and follow confidentiality and impartiality rules to the same 
extent as the person for whom they are interpreting and/or to the extent their position 
requires. They should understand and adhere to their role as interpreters without deviating 
into a role as counselor, legal advisor, or other roles.   
 
In certain cases, a LEP individual may prefer to choose her/his own interpreter.  In this case 
staff should consider whether a record of that choice and the recipient's offer of assistance are 
appropriate. Where precise, complete and accurate interpretations or translations of 
information and/or testimony are critical, or where the competency of the LEP person's 
interpreter is not established, the TOW may decide to provide its own, independent 
interpreter, even if the LEP person wants to use his or her own interpreter as well. Extra caution 
should be used when the LEP person chooses to use a minor as an interpreter. 
 
Monitoring the Language Assistance Plan (LAP): 
The Town of Waterford will monitor the LAP through biennial demographic reviews and post-
program surveys tailored for LEP clients. Surveys will be translated as needed and assess access 
to services, satisfaction with language support, and overall program experience. Feedback will 
guide improvements to language services and staff training. 
 
Staff Training 
 
Through Language Line Solutions, Senior Services will seek training and materials to assist us 
with providing effective access to programs and services to LEP individuals through our 
orientation program for new employees.  
 
Public Participation Plan for Transportation 
Town of Waterford-Senior Services Department 
 
In order to reach out to low-income, minority, and Limited English Proficiency residents in the 
Town of Waterford, Senior Services has established the following plan. 
 
Senior Services will ensure that significant changes that are proposed to the transportation 
service such as, adding/deleting service days, changing the coverage area, extending or 
shortening the time the service is provided, the proposed changes will be listed as an agenda 
item for consideration by the Senior Citizens Commission and announced to the community 
through the following means:  
 
 Posted on the Town of Waterford Website 
 Posted in Town Hall 
 
 As the transportation service is provided to approximately (650) registered passengers, 
current users of the services may also be notified personally through a mailing. 
 

 Conducting spot surveys or establishing a transportation advisory group may also be 
considered in order to determine if we are meeting the needs of the community.   
 
 Senior Services staff  works closely with the area Senior Center directors as well as the 
Eastern CT Transportation Consortium to discuss transportation and how best to fill the 
needs of the residents.   
 
 Articles about the transportation program appear regularly in the Senior Services 
Newsletter, which is mailed free of charge to Senior households, housing sites for 
elderly and disabled and seniors, as well in the Town of Waterford Recreation and Parks 
circular that is delivered to every household in town at no cost.