Interoffice Memorandum
DATE: October 30, 2024
TO: Mayor Jerry L. Demings and County Commissioners
THROUGH: Jeffrey Newton, County Attorney
FROM: Joy Carmichael, Assistant County Attorney
CONTACT: Joy Carmichael, Assistant County Attorney
PHONE: 407-836-7320
DIVISION: County Attorney’s Office
ACTION REQUESTED:
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Approval of a new Administrative Regulation, titled “Language Assistance Services - Title VI Limited English Proficiency Plan” and proposed revisions to the following Administrative Regulations: Administrative Regulation 2.09.01, titled “Compliance with the Sunshine Law - Meetings of County Advisory Boards,” Administrative Regulation 6.17, titled “Neighborhood Grant Program,” Administrative Regulation 8.09, titled “Development of Facilities Exempt from County Zoning Regulations - Public Meeting Procedures,” and Administrative Regulation 11.05.07, titled “Sidewalk Policy.”
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PROJECT: N/A
PURPOSE: In accordance with certain federal requirements, Orange County adopts an Orange County Title VI Nondiscrimination Policy and Plan triennially. To comply with federal law and to retain eligibility for federal funds, all Orange County departments and divisions must comply with the Title VI Policy and Plan in their activities, programs, and projects.
During the triennial recertification process in 2021, the Transportation Planning Division of the Planning, Environmental, and Development Services Department determined to update certain administrative regulations to comply with the Title VI Policy and Plan. Those proposed revisions pertain to updating the notice requirements for public meetings to require certain additional translated text; updating requirements for compliance with the Americans with Disabilities Act of 1990 (ADA) and the Public Right of Way Accessibility Guidelines (PROWAG) standards for neighborhood grants; and updating requirements for the prioritization criteria for the sidewalk request policy to include identification and addressing of the disproportionately adverse effects of an agency’s programs, policies, and activities on minority and low-income populations.
The Title VI Policy and Plan includes a Title VI Limited English Proficiency Plan (also referred to as the “LEP Plan”). The Title VI Limited English Proficiency Plan sets forth the County’s determinations of the extent to which residents of Orange County require language assistance services and describes the language assistance services that the County will provide to meet the needs of such residents. Following the Board’s adoption of the Resolution and the corresponding Title VI Nondiscrimination Policy and Plan on April 5, 2022, the Board voted on October 10, 2023, to incorporate the provisions of the Title VI Limited English Proficiency Plan into an administrative regulation. The proposed Title VI Limited English Proficiency Plan administrative regulation informs staff of the requirements of the Title VI Limited English Proficiency Plan and provides guidance to department directors and division managers for training staff to utilize various resources to provide language assistance services to residents.
The proposed revisions to the current administrative regulations and the proposed new administrative regulation for the Title VI Limited English Proficiency Plan were reviewed and circulated among the affected departments and divisions to ensure that the regulations will meet the needs of Orange County. The revisions proposed by staff were revised as necessary following legal review and incorporated into the draft administrative regulations.
BUDGET: N/A