Crook County commissioners on Monday approved Order 2024-54 to amend the county’s Title VI plan to incorporate a federal four-factor analysis of limited English proficiency (LEP) needs for transit services.

County staff member (Speaker 3) told the commission the federal partner and ODOT asked that subrecipients include a full four-factor analysis to document how the county provides access to people with limited English proficiency. Speaker 3 said the county was given a January 6 deadline to submit the completed analysis and had circulated a draft to the county’s ODA representative, who confirmed the draft “looks good.”

The analysis presented to the commission found Crook County’s LEP population is small: the highest subgroup is Spanish-speaking residents at 0.65 percent, or about 53 people, and the regional call center logs roughly 12 Spanish-language calls per month related to transit services. Speaker 3 described the four required factors — population, frequency of contact with the program, program importance, and resources/costs — and concluded that "the county is doing now is reasonable and is the correct mix considering the number of LEP persons and the funds that we have available." (Speaker 3)

Speaker 3 also noted the county received one Title VI complaint this summer; the complaint, they said, was not about Crook County or Cascade East Transit (CET) and was included in the amendment’s appendix. The amended plan updates Appendix D with current LEP numbers and documents the county’s existing accommodations, including translation services, translated website materials, and staff training.

After the presentation, Speaker 3 moved to approve the order and Speaker 2 seconded. The commission approved the amendment by voice vote (two ayes). Speaker 3 said they would sign the order and submit the amendment to ODOT/ODA.

The amendment does not create new services beyond what is described in the analysis; rather, it records the county’s assessment and the resources the county intends to maintain to help LEP residents access transit services. Staff will proceed with submission to the state/federal partner and the county will monitor whether additional measures are warranted if LEP counts or service contacts increase.