Language Access Plan Responsiveness Summary

^{Tabel of Contents}

• Final Plan 
• Background
• Opportunity for Public Comments 
• Public Comments & Agency Response 
• Additional Information & Resources 

^{Final Plan}

On January 6, 2025, the Illinois Environmental Protection Agency (Illinois EPA) issued its final Language Access Plan. The Final Plan presents the Agency’s resources and protocols available to Agency employees for interacting with identified Limited English Proficient (LEP) individuals including the availability of interpretation and translation services at no cost to the requestor.

The Final Plan is reorganized to include detailed information about the Agency’s language assistance services, procedures, protocols, and processes for assessment and implementation. The Final Plan supports the goals, elements, and strategies outlined in the Agency’s EJ Policy and bolsters the Agency’s compliance with Title VI of the Civil Rights Act of 1964 (Title VI) 42 U.S.C. § 2000d and overall commitment to advancing environmental justice.

The Agency expresses its gratitude to everyone who reviewed the plan and provided comments.

^Background 

Illinois EPA receives federal financial assistance and, as a contractual recipient of federal funding, the Agency is obliged to comply with applicable provisions of federal civil rights laws and policies prohibiting discrimination, including Title VI. Title VI specifically prohibits recipients from discriminating on the basis of race, color, or national origin. 

Pursuant to Title VI, and the Agency’s Environmental Justice Policy, Illinois EPA is committed to ensuring meaningful access to its programs and activities for all persons, including Limited English Proficiency (LEP) individuals. 

On February 14, 2024, Illinois EPA voluntarily entered into an Informal Resolution Agreement (IRA) with the U.S. Environmental Protection Agency (U.S. EPA) to resolve a civil rights complaint concerning the Illinois EPA’s issuance of an air construction permit for a metal shredder to be located on the Southeast Side of Chicago. Under the IRA, Illinois EPA committed to revising several of its plans and polices, including its previous Language Access Plan.

^{Opportunity for Public Comments} 

The issuance of the final Language Access Plan (“Plan”) was followed by a public review and comment period, in accordance with the IRA. The draft Plan and accompanying public notice prepared by the Illinois EPA was made available for review by the public for a total of 30 days. The comment period began on October 7, 2024 and closed on November 6, 2024.

The public notice alerted the public to the proposed plan and instructed the public on when and how to participate and make comments to help inform the Agency’s finalization of the plan. Translated versions of the public notice and draft Plan were also available on the Illinois EPA’s webpage.

Illinois EPA shared information and publicized the draft plan for public review and comment through its Agency Environmental Justice Listserv, through the Illinois Commission on Environmental Justice, and by posting on the Agency’s homepage for the entirety of the public comment period.

The draft Plan generated comments from the Greater Chicago Legal Clinic, Inc. on behalf of the Chicago EJ Network (CEJN). CEJN is an alliance of several community-based environmental justice organizations, located on the south and west sides of Chicago. CEJN is comprised of organizations including Little Village Environmental Justice Organization, Blacks in Green, People for Community Recovery, Southeast Environmental Task Force, and Neighbors for Environmental Justice. 

^{Public Comments & Agency Response} 

Outlined below are: 

• Public comments the Agency received
• The Agency's responses to the comments 
• Specific indication of where in the Plan the Agency addresses the comment, if at all, and as appropriate

Comments from CEJN were organized by general comments as well as comments specific to each language that the draft Plan and Public Notice were initially released in.

Illinois EPA addressed and resolved comments specific to each language that the draft Plan was released in by making the Plan available via the Agency website, as its own webpage. By publishing the final Plan as its own webpage, Illinois EPA has made the final Plan consistent with other State of Illinois’ webpages and materials. Publishing the Plan as a webpage allows the public to utilize the translation feature on the top right of the webpage to view the Plan in Spanish, Arabic, Polish, Russian, Chinese (simplified and traditional), and Tagalog. Additional translations of the Plan are available upon request. It is important to note that the Plan links to documents on webpages not maintained by the Illinois EPA (for example, federal language access guidance) that may not have translated versions. Illinois EPA will work with individuals or groups to ensure that resources are available to translate the documents upon request.

Public Comment: When available, communities should be able to request dialect specific translation services. An example of a common language spoken in Illinois that has multiple dialects is Spanish. Mexican Spanish speakers in Pilsen and Little Village may have a different dialect and derive different meanings from certain words when compared to Puerto Rican Spanish speakers in Humboldt Park. Additionally, Puerto Rican Spanish speakers in Humboldt Park may have a different dialect and derive different meanings from certain words when compared to Dominican Spanish speakers in Humboldt Park.

Agency Response: As noted in the Plan, to support the needs of Spanish-speaking LEP individuals, Illinois EPA utilizes both in-house Spanish translation services as well as external interpretation and translation services through State Limited English Proficient (LEP) contracts. Illinois EPA’s Spanish-speaking staff members coordinate when translating documents to help ensure that documents are readily understandable by Spanish-speakers with various cultural and educational backgrounds. Illinois EPA has staff that are multilingual and that are aware of the various dialects of the Spanish language. Staff are of diverse backgrounds, representing a variety of countries in Latin America. These staff utilize their knowledge of the various dialects when translating in-house Agency documents to Spanish. For Spanish interpretation services available at public meetings and hearings, Illinois EPA utilizes its contractors to make that service available to the public. Depending on the type of the language assistance services needed, a qualified multilingual staff member can be used. When the services of a multilingual staff member are not appropriate, the program or regional office will seek interpretation assistance through the LEP contract. When appropriate, the Illinois EPA will request that the contractor provide an interpreter with a dialect best suited for the community where outreach is conducted and is dependent on available resources. Illinois EPA encourages the public to reach out to the Office of Environmental Justice at EPA.OEJ@illinois.gov for questions or concerns regarding various dialects of Spanish documents, translation, and interpretation services.

Specific Indication in the Final Plan:

• Under “Language Assistance Services & Protocols”, #4 within “Bilingual Staff and Training”.
• Under “Language Assistance Services & Protocols”, #4 within “Interpretation”.

Public Comment: Information published in languages known to have multiple dialects used within Illinois should be proofread by individuals who use different dialects to ensure the information being distributed can be understood regardless of dialect used by the reader. For example, a Mexican Spanish speaker, Puerto Rican Spanish speaker, and Dominican Spanish speaker would proofread materials set be published in Spanish.

Agency Response: Illinois EPA is committed to, depending on the type of the language assistance services needed, utilizing a qualified bilingual staff member. When the services of a multilingual staff member are not appropriate, the program or regional office will seek interpretation assistance through the Agency’s LEP contract. When appropriate, the Illinois EPA will request that the contractor provide an interpreter with a dialect best suited for the community where outreach is conducted and is dependent on available resources. Additionally, if community organizations identify issues with the dialect of Agency materials, Illinois EPA encourages the public to reach out to the Office of Environmental (OEJ) Justice at EPA.OEJ@illinois.gov. OEJ will strive to work with those organizations to assist in the proofreading process.

Specific Indication in the Final Plan:

• Under “Language Assistance Services & Protocols”, #4 within “Interpretation”.

Public Comment: Illinois EPA should clarify whether citizens that request uncommon languages will receive information and materials in the requested language. For example, Illinois EPA should include a provision that specifies the Language Access Plan is only available in the languages it is set to be published in or that the Language Access Plan could be translated into another language, such as Italian, upon request.

Agency Response: As noted in the Final Language Access Plan, additional translations are available upon request. The Final Language Access Plan links to documents on webpages not maintained by the Illinois EPA (for example, federal language access guidance) that may not have translated versions. Illinois EPA will work with individuals or groups to ensure that resources are available to translate the documents upon request.

Specific Indication in the Final Plan:

• Under “Background” section in paragraph 2.

Public Comment: Some of the websites the Plan and LAP Public Notice routes the reader to have different languages available than the ones being used for the Plan and LAP Public Notice. There should be a specific section in the Language Access Plan that mentions if an individual goes on a website in a language not available for translation, Illinois EPA will provide resources to the individual in the language needed.

Agency Response: As noted in the Plan, Illinois EPA included in the final Plan language mentioning that links to documents on webpages not maintained by the Illinois EPA (for example, federal language access guidance) may not have translated versions. Illinois EPA will work with individuals or groups to ensure that resources are available to translate the documents upon request.

Specific Indication in the Final Plan:

• Under “Background” section in paragraph 2. 

^{Additional Information & Resources}

Questions about the public comment period process and the final Plan should be directed to:

Office of Environmental Justice
Illinois Environmental Protection Agency
2520 W Iles Ave
P.O. Box 19276
Springfield, Illinois 62794-9276
EPA.OEJ@illinois.gov

As noted in the final Plan, Illinois EPA has staff members fluent in Spanish who can communicate directly with the Spanish-speaking LEP public. To speak to someone in Spanish, contact the Office of Environmental Justice.

Office of Environmental Justice
(217) 782-3440
EPA.OEJ@illinois.gov

For additional language access services, individuals may fill out the Request for Language Access form.

In accordance with the Illinois EPA’s Grievance Procedure and Notice of Nondiscrimination, LEP individuals who feel they have been discriminated against on the basis of language access may also submit a Grievance Form to the Illinois EPA.