Testimony of Amy Taylor- Language Assistance Services

Testimony of Amy Taylor, Legal Services NYC Language Access Project Coordinator, on behalf of Legal Services NYC and The Legal Aid Society before the New York City Council Housing & Buildings Committee, Re: Language Assistance Services at the New York City Department of Housing Preservation and Development

March 27th, 2008
       
My name is Amy Taylor and I am the Language Access Project Coordinator at Legal Services NYC.  I am testifying today on behalf of both Legal Services NYC and the Legal Aid Society.  Legal Services NYC provides civil legal services through a network of community based-offices located in low-income neighborhoods in New York City’s five boroughs.  The Society’s Civil Practice also operates neighborhood offices as well as city-wide units serving residents of all five boroughs.  Both of our organizations serve thousands of housing clients a year.  Many of our clients are limited English proficient or LEP and come into contact with HPD on a regular basis through the Section 8 program and through various aspects of code enforcement.  Intro 596 would greatly expand access to HPD services for our LEP clients.  For example, last month our Brooklyn housing hotline received a call from a Russian-speaking Section 8 tenant who had tried to request a conference with HPD to review what she believed to be errors in the calculation of her rent share.  No one at the HPD office could speak to her in Russian and she could not explain her situation to anyone there.

In a city as diverse as New York, offering language services is simply good policy.  HPD is not the first agency to grapple with the difficult issues around serving New York’s linguistically diverse communities.  Many city agencies are currently reassessing how they provide access to LEP individuals.  While HPD and all other city agencies are bound by federal law to provide equal access to programs and services for LEP communities, there is a dire need for a more specific mandate. There are also many hidden benefits to providing linguistically and culturally appropriate services.  While the benefits for LEP individuals are obvious – improved access to the wide array of important services offered by HPD, providing language services can also increase the agency’s efficiency.  

When language services are provided to LEP individuals, the amount of per interaction time is reduced because bilingual staff and interpreters can answer questions directly instead of struggling to communicate or making the applicant contact the agency multiple times in the hopes of findings someone who speaks their language.  When formal language policies and systems replace a “patchwork” approach, this standardized approach allows for greater use of cost-efficient mechanisms like the central translation of forms or the sharing of bilingual staff resources.  The provision of translated documents increases the likelihood that LEP tenants can read, understand and fill out required forms without needing to interact excessively with the agency in a struggle to understand requirements.  Without translated forms or bilingual personnel to assist an LEP applicant in the completion of forms, there is a higher likelihood of error and longer completion times leading to miscalculations of benefits or eligibility.  These mistakes often lead LEP tenants to contact our offices for assistance – leading to more litigation and administrative effort on the part of HPD.

While communication through an interpreter often takes longer than communicating with an English-speaking tenant, that time is often made up for by the decreased need to reschedule appointments and speak to the same tenants multiple times in an effort to understand them.  Additionally, for the most commonly encountered languages, the use of bilingual staff eliminates the extra time needed to communicate through an interpreter.

We would like to thank the IBO for their testimony on the cost of Intro 596.  I would also like to take this opportunity to point out that HPD can meet the mandates of Intro 596 in many ways, and that the hiring of bilingual inspectors and a full-time translation staff, while ideal under some circumstances, is only one of those ways.  For the most commonly spoken languages, it may make economic sense to hire bilingual inspectors and full-time translation staff.  However, for less commonly encountered languages, it may be cost effective for HPD to have currently employed inspectors trained to use language line to communicate with LEP tenants, as ACS inspectors currently do, and to contract out for translations, as many city agencies currently do.  Sharing in citywide contracts that currently exist would also keep translation prices down and be cost effective for the whole city.  Intro 596 does not require that HPD meet the mandate to provide language services in any of these specific ways, but rather requires that they provide language services to limited English proficient tenants.  How they chose to provide these services is up to them.

We applaud HPD in its effort to begin making their programs and services accessible for LEP individuals.  Intro 596 will expand on the services already being offered and ensure that they continue to be provided under future administrations.   Housing services are vital services for low-income New Yorkers and Intro 596 will ensure that housing services are accessible to all eligible New Yorkers.

Thank you.

Respectfully Submitted:

Amy Taylor, Language Access Project Coordinator
Language Access Project Coordinator
The Legal Support Unit
Legal Services NYC
350 Broadway, 6th Floor
New York, NY 10013-9998
Ph: 646-442-3664

Steven Banks, Attorney in Charge
Adriene Holder, Attorney in Charge Civil Practice
Scott Rosenberg, Attorney in Charge, Law Reform
Judith Goldiner, Supervising Attorney
THE LEGAL AID SOCIETY
199 Water Street, 3rd Floor
New York, New York 10038
(212) 577-3332