Language Access Plan
Millcreek Township developed their Language Access Plan (LAP) to identify reasonable steps to help provide language assistance to Limited English Proficiency (LEP) persons seeking meaningful access to programs within Millcreek Township as required by Executive Order 13166. The purpose of this LAP is to provide assurance and demonstrate that residents of Millcreek Township are being provided meaningful access to information, benefits, and services although they may be limited in their English proficiency.
Additionally, Millcreek Township recognizes the importance of effective and accurate communication between its Police Department and the community that they serve. Language barriers can sometimes inhibit or even prohibit individuals who are LEP from accessing and/or understanding important rights, obligations, and available services, or from communicating accurately and effectively in difficult situations. Hampered communication with LEP victims, witnesses, alleged perpetrators, and community members can present the department with safety, evidentiary, and ethical challenges.
Millcreek Township will offer a qualified interpreter from the Multicultural Community Resource Center (MCRC) free of charge to any resident that wishes to access township resources. Read the details below or in the full plan.
Should an LEP person require an interpreter, the Township will access interpreter services via the Multicultural Community Resource Center ("MCRC") located in Erie Pennsylvania. The MCRC currently provides interpreters in the following languages: Spanish, Nepaly, Swahili, Arabic, Ukrainian and French. These languages generally line up with the foreign languages that the Township has encountered. Representatives of the Township will communicate with the LEP individuals through this service either with an in person interpreter or via telephone or via video conference.
Professional, trained interpreters and translators are available in Spanish, Arabic, Nepali, Swahili, Ukranian, and French. Interpreters may be obtained for other languages as well, please call the MCRC for availability.
1. Identifying LEP Persons and Their Language
Millcreek Township will promptly identify the language and communication needs of the LEP person. If necessary, staff will use a language identification card (or “I speak cards”3 ) or posters to determine the language.
Millcreek Township Police Department employees who have face to face contact with LEP persons who are in need of interpretation services will attempt to identify the LEP individual's primary language through the use of "Language Identification Flashcards" from the Census Test or "I speak cards," if necessary. All employees will have direct access to the language identification resources in their vehicles, at their workstations.
2. Obtaining a Qualified Interpreter
The Multicultural Community Resource Center will be the resource used to provide qualified interpreter services. NOTE: It is the Township's responsibility to develop and ask any questions. Under no circumstances will an interpreter independently question an LEP individual. The interpreter's role is to serve as a neutral third party, taking care not to insert their perspective into the communication between the parties.
Millcreek Township Police Department employees are expected to follow the general procedures outlined in this policy; however, exigent circumstances may require some deviations. In such situations, employees are to use the most reliable, temporary interpreter available. Examples may include the need to obtain descriptive information on a fleeing suspect, or identifying information on an injured person. The use of temporary interpreters will be documented in any reports generated. However, once an exigency has passed, all employees are expected to revert to the general procedures in this policy and shall determine whether a continued need for interpretation services exists.
Some LEP persons may prefer or request to use a family member or friend as an interpreter. However, family members or friends of the LEP person will not be used as interpreters unless specifically requested by that individual and after the LEP person has understood that an offer of an interpreter at no charge to the person has been made by the facility. Such an offer and the response will be documented in the person’s file. If the LEP person chooses to use a family member or friend as an interpreter, issues of competency of interpretation, confidentiality, privacy, and conflict of interest will be considered. If the family member or friend is not competent or appropriate for any of these reasons, competent interpreter services will be provided to the LEP person. Additionally, other than in exigent circumstances, Millcreek Township Police Department employees should only use friends, family, or bystanders for interpreting in very informal, nonconfrontational contexts, and only to obtain basic information at the request of the LEP individual. Millcreek Township Police Department recognizes that using family, friends, or bystanders to interpret could result in a breach of confidentiality, conflict of interest, or inadequate interpretation.
3. E911 (Police Radio) Responsibilities
When the Township Dispatch Center dispatches a call known to involve an LEP individual, it currently relies upon the State Department of Human Services, which is a paid services funded by Erie County. This practice will continue of the LAP.
4. Providing Notice to LEP Persons
Millcreek Township will inform LEP persons of the availability of language assistance, free of charge, by providing written notice in languages LEP persons will understand. Notification will also be provided through one or more of the following: outreach documents, telephone voice mail menus, local newspapers, radio and television stations, and/or community-based organizations.
5. Monitoring Language Needs and Implementation
On an ongoing basis, Millcreek Township will assess changes in demographics, types of services or other needs that may require reevaluation of this policy and its procedures. In addition, Millcreek Township will regularly assess the efficacy of these procedures, including but not limited to mechanisms for securing interpreter services, equipment used for the delivery of language assistance, complaints filed by LEP persons, feedback from patients and community organizations, etc.
Millcreek Township employees that interact with the public on a formal basis (e.g., code enforcement, police department) will be provided with a copy of the plan and will familiarize themselves with the process and procedures to follow to use the interpreter services offered so they can efficiently use the service should it be needed. The employees will be provided with a written procedure flyer to provide assistance with the steps that need to be taken.
The LAC will routinely provide training to staff related to language access policies and procedures. The training is offered to new employees during onboarding and offered to existing employees at least every two (2) years. The Language Access Coordinator may offer training on the following topics:
The Language Access Plan and its application.
- Telephone interpretation.
- Tips for working with interpreters.
- Plain language principles.
- Requesting document translation.
- Requesting in-person interpretation.
If additional training is needed, the Coordinator will work to accommodate those requests.
These scenarios potentially involve statements with evidentiary value upon which a witness may be impeached in court. As such, accuracy is a priority. Moreover, a failure to protect the rights of LEP individuals during arrests and interrogations presents risks to the integrity of the investigation. Department officers must recognize that miscommunication during the interrogations or crime witness interviews may have a substantial impact on the evidence presented in any related criminal prosecution.
A qualified bilingual officer or other language assistance service shall be used for any interrogation or taking of a formal statement where the suspect’s or witness’ legal rights could be adversely impacted.
The Board of Supervisors shall appoint a Language Access Coordinator (LAC). The Coordinator is responsible for Plan implementation and serves as a resource to the Township Departments to help resolve issues that arise related to language access. The Language Access Coordinator’s responsibilities include:
- Develop processes to be followed by the various Township Departments, Commissions and Boards for pre-planned meetings as well as needs arising under more immediate circumstances.
- Provide training to Department staff, including developing training tools.
- Track and resolve issues related to language services.
- Respond to language services complaints.
- Conduct regular data review.
- Conduct outreach.
- Collect feedback from community organizations.
- Periodically review the LAP for update
The designated LAC for Millcreek Township is Community Relations and Sustainability Director Jessica Stutzman. She can be contacted at 814.833.1111 ext.317.
The Township's LAC will review and respond to all language access complaints. The LAC will also review all complaints received by the Township in a language other than English to determine if any underlying systemic issues exist.
Any LEP individual has the right to file a complaint with the LAC of Millcreek Township when such individual believes the Township has not provided the necessary LEP services. The LAC shall take reasonable steps to inform the LEP service user about the availability of complaint forms, which shall also be available on the Township website.
All complaints regarding the LAP shall be sent to:
Millcreek Township Language Access Coordinator
3608 W. 26th street Erie, PA 16506
The LAC will investigate any complaints that allege noncompliance with this LAP. If the investigation results in a finding of compliance, the LAC will inform the complainant of the determination in writing. If the investigation results in a determination of noncompliance, the LAC will inform the complainant in writing and outline the steps to be taken to correct the noncompliance.