Audit Report on the Compliance of the New York City Landmarks Preservation Commission with Local Law 30 Regarding Access to City Services for Residents with Limited English Proficiency
Executive Summary
In 2017, the New York City Council enacted Local Law 30, effective July 1, 2017, which requires New York City (City) agencies that provide direct public services or emergency services to have a language access plan that allows residents meaningful access to City services regardless of their proficiency in English. Translation services must be provided in the top 10 designated Citywide languages, consisting of the top 6 limited English proficiency languages spoken by the population of New York City as determined by the Department of City Planning and the Mayor’s Office of Language Services Coordinator, based on U.S. census data, and the top 4 limited English proficiency languages spoken by the population served or likely to be served by the agencies of the City of New York, excluding the 6 languages designated based on U.S. census data. This audit focuses on whether the Landmarks Preservation Commission (LPC) complied with Local Law 30.
LPC, the largest municipal preservation agency in the nation, is the New York City agency responsible for protecting the City’s architecturally, historically, and culturally significant buildings and sites by granting them landmark or historic district status and regulating them after designation. Among other things, LPC evaluates and considers dozens of potential landmarks and historic districts each year. The landmark designation process includes outreach to property owners, public meetings, and public hearings. LPC also works with elected officials and community groups to ensure these historically significant sites are preserved for future generations. According to the Landmarks Law, the purpose of safeguarding the buildings and places that represent the City’s cultural, social, economic, political, and architectural history is to: stabilize and improve property values, foster civic pride, protect and enhance the City’s attractions to tourists, strengthen the City’s economy, and promote the use of historic districts, landmarks, interior landmarks, and scenic landmarks for the education, pleasure, and welfare of the people of the City.
Audit Findings and Conclusion
We found that LPC generally complied with Local Law 30. Our review of LPC’s Language Access Plans dated 2009, 2018, and 2020 found that LPC has made continuous progress in providing meaningful language access to the agency’s services for Limited English Proficient (LEP) customers. Its Language Access Plans describe the steps that LPC has taken to provide its services to the LEP population.[1]
Specifically, we found that LPC provides direct public services in the top 10 languages as required by Local Law 30. Further, we found that through Citywide contracts with Language Line Services, LLC, and by utilizing the City’s Volunteer Language Bank and agency staff, LPC has the ability to provide documentation, translation, and phone interpretation services in at least 100 languages.
In accordance with Local Law 30, LPC has developed and updated its Language Access Plan and designated a Language Access Coordinator. LPC has trained its frontline workers on the appropriate procedures to follow when coming in contact with the LEP population. LPC’s office uses the City’s standard LEP signage to inform the public that LEP services are available. The signage and its locations are documented in the LPC 2019 and LPC 2020 plans.
Due to the closure of LPC’s office, we attended LPC’s virtual hearings and observed that translation services are available in the required LEP languages when requested. Any person requiring language assistance services in order to participate in a hearing or attend a meeting may contact LPC or make the request on the LPC website calendar no later than five business days before the hearing or meeting so that LPC can arrange for an interpreter to be present. We found that LPC’s website has instructions for the LEP population on how to gain access to LPC and its calendar. We also observed recorded hearings held in LPC’s office prior to its closure, and we were able to observe the LEP signage. Further, we requested and received photographs of the signage in LPC’s office as of September 2020 that were date and time stamped.
However, we also found that LPC’s essential documents were not available in the top 10 designated Citywide languages on its website or in its office. These documents are currently only available for translation by LPC upon request. The unavailability of these essential documents on LPC’s website and in its office were reported in a previous audit.
During this audit, LPC stated that it plans to make its essential documents available in the top LEP languages on its website and in the common areas of its office pending additional resources. Appendices I and II contain details of the specific items we tested and the results of our tests. Appendix III illustrates LPC’s efforts to ensure compliance with Local Law 30.
Agency Response
In its response, LPC agreed with the audit’s findings and recommendations. LPC stated, “The Landmarks Preservation Commission appreciates the opportunity to respond to the above referenced draft report, which states that your audit found that LPC generally complies with Local Law 30. LPC is committed to providing equitable service to the population it serves, including persons with Limited English Proficiency (LEP). LPC has taken and continues to take reasonable steps to ensure LEP persons have access to the agency’s programs and services.”
[1] LPC’s Language Access Plan of 2009 was designed under the Mayor’s Executive Order 120, which preceded Local Law 30.