About Us

I. PLAN STATEMENT
BangorHousing has adopted this plan to provide meaningful access to its programs and activities by persons with Limited English Proficiency (LEP). In accordance with federal guidelines, BangorHousing will make reasonable efforts to provide or arrange for free language assistance for its LEP clients, including applicants, recipients and/or persons eligible for public housing, Section 8 New Construction, Section 8 Housing Choice Voucher Program and other BangorHousing programs.
II. MEANINGFUL ACCESS: FOUR-FACTOR ANALYSIS
Meaningful access is free language assistance in accordance with federal guidelines. BangorHousing will periodically assess and update the following four- factor analysis, including but not limited to:
The number or proportion of LEP persons eligible to be served or likely to be encountered by BangorHousing.
The frequency with which LEP persons using a particular language come into contact with BangorHousing.
The nature and importance of BangorHousing program, activity or service to the persons’ life.
BangorHousing’s resources and the cost of providing meaningful access. Reasonable steps may cease to be reasonable where the costs imposed substantially exceed the benefits.
III. LANGUAGE ASSISTANCE
A person who does not speak English as their primary language and who has a limited ability to read, write, speak or understand English may be a Limited English Proficient person and may be entitled to language assistance with respect to BangorHousing programs and activities.
Language assistance includes interpretation, which means oral or spoken transfer of a message from one language into another language and/or translation, which means the written transfer or a message from one language into another language. BangorHousing will determine when interpretation and/or translation are needed and are reasonable.
BangorHousing staff will take reasonable steps to provide the opportunity for meaningful access to LEP clients who have difficulty communicating in English. If a client asks for language assistance and BangorHousing determines that the client is an LEP person and that language assistance is necessary to provide meaningful access, BangorHousing will make reasonable efforts to provide free language assistance. If reasonably possible, BangorHousing will provide the language assistance in the LEP client’s preferred language.
BangorHousing has the discretion to determine whether language assistance is needed, and if so, the type of language assistance necessary to provide meaningful access.
BangorHousing will periodically assess client needs for language assistance based on requests for interpreters and/or translation, as well as the literacy skills of the clients.
IV. TRANSLATION OF DOCUMENTS
BangorHousing will weigh the cost and benefits of translating documents for potential LEP groups, considering the expense of translating the documents, the barriers to meaningful translation or interpretation of technical housing information, the likelihood of frequent changes in documents, the existence of multiple dialects within a single language group, the apparent literacy rate in a LEP group and other relevant factors. BangorHousing will undertake this examination when an eligible LEP group constitutes five percent of an eligible client group (for example, five percent of households living in BangorHousing’s public housing).
If BangorHousing determines that translation is necessary and appropriate, BangorHousing will arrange to translate the public housing lease and selected mailings and documents of vital importance into that language.
As opportunities arise, BangorHousing may work with other housing authorities to share the costs of translating common documents, which may include language groups, which do not (yet) reach the threshold level in BangorHousing’s client population.
BangorHousing will consider technological aids such as Internet-based translation services, which may provide helpful, although perhaps not authoritative, translations of written materials.
V. FORMAL INTERPRETERS
When necessary to provide meaningful access for LEP clients, BangorHousing will provide qualified interpreters, including BangorHousing bilingual staff and contract vendors, if available. At important stages that require one-on-one contact, written translation and verbal interpretation services will be provided consistent with the four-factor analysis used earlier.
BangorHousing may require a formal interpreter to certify to the following:
a. The interpreter understood the matter communicated and rendered a competent interpretation.
b. The interpreter will not disclose non-public data without written authorization from the client.
Formal interpreters shall be used at the following:
a. Formal hearing for denial of admission to public housing or Section 8 New Construction;
b. Informal settlement conferences and formal hearing for termination of public housing or Section 8 New Construction.
c. Hearings or conferences concerning denial or termination of Section 8 Housing Choice Voucher participation.
A BangorHousing staff interpreter may not be a subordinate to the person making the decision.
Bilingual BangorHousing employees, when available, can provide limited assistance to BangorHousing staff and LEP clients as part of their regular job duties.
VI. INFORMAL INTERPRETERS
Informal interpreters may include the family members, friends, legal guardians, service representatives or advocates of the LEP client. BANGORHOUSING staff will determine whether it is appropriate to rely on informal interpreters, depending upon the circumstances and subject matter of the communication.
An LEP person may use an informal interpreter of his or her own choosing and at their expense, either in place of or as a supplement to the free language assistance offered by BangorHousing.
If an LEP client prefers an informal interpreter, after BangorHousing has offered free interpreter services, the informal interpreter may interpret. In these cases, the client and interpreter should sign a waiver of free interpreter services.
If an LEP client wants to use his or her own informal interpreter, BangorHousing reserves the right to also have a formal interpreter present.
VII. OUTSIDE RESOURCES
Outside resources may include community volunteers, BangorHousing residents or Housing Choice Voucher/Section 8 participants.
Outside resources may be used for interpreting services at public or informal meetings or events if a timely request has been made.
VIII. MONITORING
BangorHousing will review and revise this LEP Plan from time to time. The review will include:
a. Reports from BangorHousing’s computer systems on the number of BangorHousing clients who are LEP, to the extent that the software and staff data entry can provide such information. Such reports may be supplemented by staff observations.
b. Reports from the computer systems and other sources listing the languages used by LEP clients.
c. A determination as to whether five percent from BangorHousing client group speak a specific language, which triggers consideration of document translation needs as described above.
d. Analysis of staff requests for contract interpreters: number of requests, languages requested and costs, etc.
e. The resident Advisory Board (RAB) will be asked to review the LEP Plan annually as part of updating the Agency Plan.
IX. LEP PLAN DISTRIBUTION AND TRAINING
The LEP Plan will be:
Distributed to all BANGORHOUSING staff.
Available at BangorHousing Administrative Office at 133 Davis Road Bangor, ME
Posted on BangorHousing’s website, www.bangorhousing.org
Explained in orientation and training sessions for supervisors and other staff who need to communicate with LEP clients.