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VIII. 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 /> IX. 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, the City has determined that LEP individuals speaking <br /> English less than well represent approximately 33.8% of the community. The <br /> City realizes that such statistical data can become outdated or inaccurate. <br /> Therefore, the City contacted local law enforcement to validate the proportion <br /> of LEP served by those entities. Spanish was reported to be the prevalent LEP <br /> language with an estimate of 25% 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 />