Under the Dymally-Alatorre Bilingual Services Act and the US DOT's Safe Harbor Provision, recipients must make every effort to provide language access services for any language group that constitutes 5% or more of the eligible service population. Spanish is the only language group in San Rafael that meets this threshold, making it the City's priority language for LD service delivery.

Factor 2: The frequency with which LD individuals of different language groups come in contact with the city and its services.

LD individuals access City services through various channels, including in person, online, over the phone, and by mail. To understand how frequently LD community members engage with City services, the City conducted a staff survey to gauge the frequency of contact. Additionally, the City conducted LD surveys and focus groups to determine the frequency of contact with City services.

According to the survey results, over 78% of City staff reported assisting at least one LD individual daily, and more than a quarter of respondents worked with three or more LD clients each day, clearly indicating that LD residents utilize city services. Moreover, 36% of staff noted encountering at least one LD client per day who could not be served due to language access barriers. Most of the LD individuals whom staff encounter speak Spanish. The City’s experience with LD populations has led it to focus on making efforts primarily to Spanish-speaking populations, by translating documents, for example. As shown in the table above, this experience is largely consistent with the U.S. Census Data that shows the share of the population by language spoken at home and English proficiency.

To assess how frequently Linguistically Diverse (LD) community members engage with City services, the City conducted a community survey reaching 82 residents and workers. Of respondents, 77% live in and 76% work in San Rafael. The most frequently accessed services included the Library, Recreation, and Public Works, departments that serve a broad cross-section of the community. Over half of respondents (54%) reported having needed language assistance when accessing City services, and 32% of those who interacted with staff in the past 12 months reported being offered language assistance. Consistent with Census data, 77% of survey respondents identified Spanish as their primary language, confirming that Spanish-speaking residents represent the most frequent LD contact point across City departments and supporting the City's ongoing prioritization of Spanish-language services.

Factor 3: The nature and importance of the program, activity, or service to LD individuals.

San Rafael is a full-service city that delivers a broad range of public services to all residents and visitors. These include public safety, law enforcement, planning and building, library and community programs, early childhood education, environmental sustainability, parking enforcement, and maintenance of roads, traffic signals, parks, and playgrounds. The City also supports business development and economic vitality.

Several of these services carry high stakes for individuals with limited language access, particularly those involving public safety, law enforcement, and legal processes.

The City conducts public business through City Council meetings, Planning Commission meetings, and other official bodies. Without language access, LD residents are effectively excluded from the decisions that shape their community.

The City is keenly aware that approximately 20 percent of the City’s residents are LD and, therefore, it is highly likely that LD individuals will be a stakeholder in all City projects, programs, and services. If City staff are not able to complete a conversation, staff will reach out to a certified bilingual employee to ensure the customer is able to be served. As such, when Staff has encountered the need for interpretation services, Staff has provided the services readily. Moreover, as mentioned, the City often proactively translates outreach materials into Spanish.

Factor 4: Determine the resources available to assist LD individuals.

The City of San Rafael recognizes that meaningful language access is crucial to providing equitable