Environmental Justice Analyses When Considering Toll Implementation or Rate Changes—Final Report (2018)

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Appendix B ‐ 1  Appendix B Content Review Summaries: Planning and Project Level Technical Report Assessment: Treatment of EJ Considerations

Appendix B ‐ 1 Appendix B Content Review Summaries: Planning and Project Level Technical Report Assessment: Treatment of EJ Considerations

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 2 Sources Reviewed WASHINGTON ................................................................................................................................B-4 Washington State DOT. 2009. Environmental Justice Discipline Report: SR 520: I-5 to Medina Bridge Replacement and HOV Project Supplemental Draft EIS.......................................................B-4 Washington State DOT. July 2011. Alaskan Way Viaduct Replacement Project Final Environmental Impact Statement.....................................................................................................B-12 Washington State DOT. July 2011. Alaskan Way Viaduct Replacement Project: Final Environmental Impact Statement Appendix X: Tolling Re-evaluation Memo. ..............................B-17 CALIFORNIA .................................................................................................................................B-21 HDR Engineering. October 2013. MTC Regional Express Lanes Interstate 680 Corridor: Environmental Justice Technical Memorandum. ............................................................................B-21 California DOT. December 2013. I-580 Eastbound Express Lanes Project: Initial Study with Proposed Negative Declaration/Environmental Assessment...........................................................B-29 California DOT. October 2002. I-15 Managed Lanes Final IS/EA and Mitigated Negative Decision. ..........................................................................................................................................B-32 California DOT. 2010. The Interstate 10 (San Bernardino Freeway/El Monte Busway) High Occupancy Toll Lanes Project: Draft Environmental Impact Report/Environmental Assessment.......................................................................................................................................B-35 California DOT. July 2012. Community Impact Assessment: State Route 85 Express Lanes Project. .............................................................................................................................................B-39 California DOT. February 2010. The Interstate 110 (Harbor Freeway/Transitway) High- Occupancy Toll Lanes Project: Draft Environmental Impact Report/Environmental Assessment.......................................................................................................................................B-43 Los Angeles Metropolitan Transportation Authority. 2010. Metro ExpressLanes Project: Draft-Final Low-Income Assessment / LA ExpressLanes Program................................................B-47 TEXAS.............................................................................................................................................B-51 Texas DOT. June 2014. SH 45SW Environmental Study, Appendix F: CAMPO Regional Toll Analysis (2013) and Central Texas Regional Mobility Authority Toll Policy. ...............................B-51 Texas DOT. April 2013. Appendix E: Project Level Toll Analysis and Effects on Environmental Justice Populations, Technical Report [San Antonio, US 281]. .............................B-55 North Central Texas Council. June 2013. Regional Tolling Analysis for the Dallas-Ft. Worth Metropolitan Planning Area Based on Mobility 2035 - Plan Update; Appendix B: Social Considerations..................................................................................................................................B-59 North Central Texas Council. January 2014. Regional Tolling Analysis for the Dallas-Ft. Worth Metropolitan Planning Area Based on Mobility 2035 – Plan Update. .................................B-63 Alamo Area MPO. December 2011. Draft Report, Appendix F: San Antonio – Bexar County MPO Regional Toll Analysis...........................................................................................................B-68

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 3     FLORIDA ........................................................................................................................................B-72 Florida DOT. July 2013. St. Johns River Crossing Project Development and Environmental Study: Environmental Discipline Report. ........................................................................................B-72 GEORGIA........................................................................................................................................B-77 Georgia DOT. March 2013. Technical Memorandum: Evaluation of Tolling Effects on Low- Income Populations: I-75 Express Lanes Project, I-75 Express Lanes, Atlanta Metropolitan Region, GA. .....................................................................................................................................B-77 Georgia DOT. January 2010. Atlanta Regional Managed Lane System Plan, Technical Memorandum 9: Social Equity and Environmental Effects Evaluation. .........................................B-82 NORTH CAROLINA ......................................................................................................................B-86 North Carolina DOT. May 2013. I-77 High Occupancy/Toll (HOT) Lanes From I-277 (Brookshire Freeway) to West Catawba Avenue (Exit 28). ............................................................B-86 VIRGINIA .......................................................................................................................................B-90 Virginia DOT. September 2011. I-95 HOT Lanes Project Environmental Assessment. ................B-90 VDOT. December 2013. Interstate 64 Peninsula Study: Socioeconomic / Land Use Technical Memorandum...................................................................................................................................B-93 MARYLAND ..................................................................................................................................B-98 Maryland DOT. November 2004. Intercounty Connector, Socioeconomic and Land Use Technical Report. .............................................................................................................................B-98 Maryland DOT. May 2004. Environmental Assessment Section 100: I-95, I-895(N) Split to North of MD 43. ............................................................................................................................B-102 RHODE ISLAND ..........................................................................................................................B-105 Rhode Island DOT. January 2013. FEIS Reevaluation for Sakonnet River Bridge Rehabilitation or Replacement, Appendix B: Environmental Justice. ..........................................B-105

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 4 WASHINGTON Washington State DOT. 2009. Environmental Justice Discipline Report: SR 520: I-5 to Medina Bridge Replacement and HOV Project Supplemental Draft EIS. Document Title SR 520: I-5 to Medina Bridge Replacement and HOV Project Supplemental Draft EIS, Environmental Justice Discipline Report Website/Source http://www.wsdot.wa.gov/NR/rdonlyres/BE2A35CA-8EA3-408D-AC25- F62CA5CB9EE6/0/Att7_EnvJust_DR.pdf Document Type Environmental Impact Statement Type of Sponsoring Agency or Organization Washington State Department of Transportation Federal Highway Administration Geographic Distribution What geographic area does this document address?  Central Puget Sound region primarily King County, WA and southern Snohomish County Type of Tolled Facility & Features What type of tolled facility? What change is being made? Variable Pricing on existing SR 520 Bridge Tolling Context What is the tolling context?  Facility-specific: SR 520 Bridge  New toll  Tolling technology/equipment: all-electronic with transponders  Methods of payment at time of report: 1. Pay with transponder connected to a Good To Go! account 2. Pay by license plate capture connected to a Good To Go! account 3. Pay by Mail (for those without an account)  Methods of payment now: 1. Pay with transponder connected to a Good To Go! account 2. Pay by license plate capture connected to a Good To Go! account 3. Pay by Mail (for those without an account) Pricing Arrangements What type of pricing scheme: Time of day Decision Question/ Decisionmaker What decision, if any, is being made? Tolling of existing SR 520 Bridge to help pay for new SR 520 Bridge At what agency or governmental level are the decisions being made? Federal (Federal Highway Administration) and State (Washington State Department of Transportation) Stage of Decisionmaking What stage of decisionmaking does this document address? Project Development and NEPA; Mitigation implementation and compensation Identification of Affected Populations What populations does this document address? Low-income, minority, limited English proficient (LEP) populations Are there other affected stakeholders that are referenced? Bus riders, Native American tribes.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 5 Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? Primarily focused on King County and southern Snohomish County, and more specifically the areas directly adjacent to the bridge. Even more specifically, the focus of some of the evaluation was on actual bridge users. The report used three study areas: the project study area, the Evergreen Point Bridge travelshed study area, and the Pontoon Construction and Transport study area. 1. Analysts used the project study area to determine the effect of project construction and operation on the human environment within a specified distance of the construction limits, including the effects on residents and people who work in the project study area. 2. Analysts used the Evergreen Point Bridge travelshed study area to understand the effects of tolling on bridge users. The Evergreen Point Bridge travelshed study area includes the geographic area from which traffic on the Evergreen Point Bridge originates. 3. The Pontoon Construction and Transport study area included the sites WSDOT was evaluating for construction of the supplemental stability pontoons required for a new 6-lane floating bridge. The Pontoon Construction and Transport study area also included the haul route that would be used to transport the pontoons from the production site to the bridge construction site. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Environmental justice analysts used six approaches to collect information on low-income and minority populations: 1. Travelshed determination 2. Demographic analysis 3. Surveys of Evergreen Point Bridge users 4. Focus groups and Spanish-language telephone interviews with Evergreen Point Bridge users 5. Public involvement activities 6. Windshield surveys Travelshed Determination - To determine the Evergreen Point Bridge travelshed, WSDOT placed video cameras on SR 520 in May 2008. WSDOT placed cameras at on- and off-ramps and on the mainline during the morning and evening peak periods, as well as midday and weekends. The Washington State Department of Licensing provided WSDOT with the addresses associated with the registered owners of each videotaped vehicle. Using those addresses, analysts developed a map of the Evergreen Point Bridge travelshed. Demographic Analysis - Analysts used data from the 2000 U.S. Census to collect information on demographic characteristics of populations in the project study area, Evergreen Point Bridge travelshed study area, and the Pontoon Construction and Transport study area. The U.S. Census Bureau provides statistics on minority and poverty status, English proficiency, and the primary language spoken at home for populations in the study areas. In accordance with WSDOT standards, analysts also verified findings with the National Center for Education Statistics (NCES) demographic data on students enrolled in schools in the study area for the 2006-2007 school year. Were the locations of affected populations mapped? Yes, including percent at or below poverty level, percent minority populations, percent languages other than English spoken, percent limited English proficient, and areas likely to have unbanked populations. What was the geographic scale for mapping and analysis? Census blocks

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 6     Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Yes. Public involvement teams conducted outreach activities to provide the public with information about the project and engage them in identifying potential adverse effects and benefits of the project. Methods included:  Analysts reviewed public and social service agency comments from the Draft EIS (WSDOT 2006) that pertained specifically to tolling.  In addition, analysts examined the outcomes of public outreach conducted since 2006 for the I-5 to Medina project SDEIS and the SR 520 Variable Tolling Project Environmental Assessment.  The public involvement teams met with social service agencies throughout the Evergreen Point Bridge travelshed.  Throughout the Evergreen Point Bridge travelshed, the public involvement team staffed project information booths at local fairs, festivals, and farmers markets that cater to low-income or minority populations.  The public involvement team also hosted public information meetings throughout the Evergreen Point Bridge travelshed. To announce meetings, the team posted flyers at transit stops and placed advertisements in publications that cater to low-income, minority, or LEP populations.  To make sure that tribal concerns are properly considered and addressed, outreach to tribes was based on a process of early and continuous communication with tribes as the project progresses.  In addition, the public involvement team placed unstaffed information kiosks throughout the Evergreen Point Bridge travelshed at locations that serve low-income, minority, or LEP populations.  The public involvement team provided project materials in several different languages, including Spanish, Russian, Chinese, Japanese, and Vietnamese. Some materials were also translated into Amharic (Ethiopia), Laotian, Somali, and Tigrinya (Ethiopia and Eritrea).  The team sent general mailings to minority-owned businesses from a purchased mailing list. The public involvement team also offered to give briefings to minority-owned business coalitions.  The public involvement team also maintained a project web site.  Environmental justice analysts reviewed phone books and web sites to generate a list of additional social resources, businesses, and public services that serve low-income, minority, or LEP populations. For example, analysts looked for ethnic churches or churches that provided community services to low-income populations.  Analysts also consulted comprehensive plans developed by the cities of Bothell, Seattle, Bellevue, Kirkland, and Renton for specific information about low-income and minority populations in these cities.  Lastly, the public involvement teams drove through neighborhoods in the study area to validate and add to their findings. Does the document describe efforts to provide information about toll implementation or rate changes? Yes, through various public outreach efforts. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? Yes, mapping was used to target the public outreach efforts, as well as to target where retail outlets for transponder sales would be offered for the unbanked populations. Does the document describe how feedback was given by those in attendance? The following methods were used to record feedback:  Public comments from the draft EIS  Public comments received at open houses, fairs, and festivals

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 7        Data from interviews with social service agencies  Summaries of meetings with Native American tribes Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? Yes, information from the feedback was considered when assessing the impact of the construction and the operation of the various build alternatives, including the no build alternative. In addition, feedback was considered when assessing the impact of tolling. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? Public meetings were held in a wide variety of locations and at different days of the week and times of the day. Invitations to attend public meetings were in a variety of languages, locations, including media in a variety of languages. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? Does not seem to. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? Yes Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? To understand how tolling of the existing Evergreen Point Bridge might affect low-income or minority populations, environmental justice analysts conducted a telephone survey of 685 individuals who use the Evergreen Point Bridge two or more days a week. Some 318 respondents qualified as a member of a population protected under environmental justice laws and guidance – that is, were self-identified as Black, Hispanic, Asian or Pacific Islander, American Indian, or Alaskan Native, or indicated that their household income fell below the federal poverty level. Because the license-plate videotaping did not capture regular transit users who travel across the Evergreen Point Bridge, analysts also conducted a transit intercept survey in June 2008. Transit- intercept survey questions were similar to those asked during the telephone survey. To collect more detailed information about how tolling might affect low-income or minority populations, analysts conducted two focus groups. To collect information on how tolling might affect LEP populations, researchers conducted six telephone interviews in Spanish with Evergreen Point Bridge users. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) Yes, the telephone survey and intercept survey measured income, poverty level, race, ethnicity, age, and gender. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? To identify the ways in which the project would specifically benefit or adversely affect low-income or minority populations in the study area, environmental justice analysts examined the following documents regarding the following potential impacts:  Air Quality  Construction Techniques and Activities    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 8  Cultural Resources  Ecosystems  Hazardous Materials  Land Use, Economics, and Relocations  Navigable Waterways  Noise  Recreation  Social  Transportation  Visual Quality and Aesthetics Analysts also reviewed outcomes from the public involvement process conducted for this project specifically and for tolling implementation in general. What considerations, measures and metrics were used to conduct analysis? For the effects of project construction and operation on the project study area, analysts used geographic information system (GIS) data to map the adverse effects over Census block groups in the project study area. This allowed a comparison of the poverty and minority status of those who would be affected by the project with those who would not be affected by the project. The analysts also assessed the possibility that LEP populations would be disproportionately affected. In addition, analysts considered the following:  Would measures to avoid or minimize high and adverse disproportionate effects be implemented?  Are there any project benefits that would affect low-income or minority populations? According to the FHWA implementing order, to offset disproportionate adverse effects on low-income or minority populations, project benefits also would have to disproportionately benefit low-income or minority populations.  Did WSDOT modify the project to avoid or minimize high and adverse disproportionate effects? Did the analysis consider access to transit, access to private vehicle, and residential or work locations? Yes Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities? Did the study rely upon proxy arguments –(toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The study relied on proxy arguments -- including results of travel behavior surveys and maps of where trips originated from relative to a video capture of license plates of bridge users. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? This issue is not covered in this report, but it is covered in other reports related to the project. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? Does not appear to be included, although there are six pages of references at the end of the report. The

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 9       basis for support of the tolled facility came directly from FHWA. The overall public benefit of replacing the bridge was found to outweigh EJ impacts, and the potential for catastrophic failure would disproportionately impact low income/minority populations. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) Yes, see below:  Air Quality  Construction Techniques and Activities  Cultural Resources  Ecosystems  Hazardous Materials  Land Use, Economics, and Relocations  Navigable Waterways  Noise  Recreation  Social  Transportation  Visual Quality and Aesthetics Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The findings for this study cover more than 30 pages and are broken out for construction, operation, and tolling impacts, and then further broken out for each of the Build and the No Build alternatives, and then further broken out relative to a phased construction approach. Overall, it was determined that low-income populations would experience disproportionately high and adverse effects because of tolling. The cost of the tolls would present a burden to low-income populations and social service agencies that serve those populations. However, if reasonable mitigation strategies such as those proposed in the Mitigation section of this report are adopted, they would minimize disproportionately high and adverse effects on low-income populations. Still, despite mitigation efforts undertaken by WSDOT, some low-income populations—especially car- dependent populations and populations living in areas with limited transit service—would continue to experience disproportionately high and adverse effects. Consistent with USDOT 5610.2 and FHWA Order 6640.23, however, analysts concluded that the project could still be implemented, for two reasons.  First, there exists a substantial need for this project, based on the overall public interest. The aging floating bridge is vulnerable to catastrophic failure. Furthermore, forecasted demand for transportation along the already congested SR 520 corridor is expected to increase substantially, because of expected population and job growth.  Second, the potential catastrophic failure of the floating bridge would have substantially more severe impacts on all populations, including car-dependent low-income populations and low- income residents of communities that are not well-served by transit. In addition, unmitigated increases in congestion along the SR 520 corridor would create much more severe mobility challenges and air quality and noise concerns for all populations, including low-income and minority populations. Analysts identified four other effects that would have disproportionately high and adverse effect on low-income, minority, or LEP populations, all of which would be offset somewhat by mitigation:  Native American tribes would experience disproportionately high and adverse effects because of construction activity on ancient tribal burial grounds on Foster Island. Option K would disturb a greater area on Foster Island than Options A or L, because Option K includes additional

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 10     construction of a land bridge. WSDOT would require the contractor to take additional measures to avoid or minimize disruptions to Foster Island.  Native American tribes would experience disproportionately high and adverse effects because of construction activity on usual and accustomed tribal fishing areas. However, WSDOT and the contractor would take measures to avoid or minimize adverse effects on tribal fishing areas. Furthermore, the 6-Lane Alternative would include treatment of stormwater runoff, which would improve fish habitat in tribal fishing areas. WSDOT would continue to coordinate with tribes during construction of the 6-Lane Alternative to identify and address any concerns.  Native American tribes would experience disproportionately high and adverse effects because the new bridges will have a substantially wider footprint than the existing Evergreen Point Bridge, reducing access to usual and accustomed tribal fishing areas. WSDOT would continue to coordinate closely with the Muckleshoot Tribe to understand the extent to which the wider bridges would affect access to their usual and accustomed fishing areas. WSDOT would also work with the Muckleshoot to develop a plan for mitigating adverse effects on access.  The requirements of electronic tolling would present a burden to low-income and LEP populations, but the strategies outlined in the Mitigation section of the report would minimize those effects. Additional key points related to environmental justice include:  Analysts conclude that low-income, minority, and LEP residents of the affected neighborhoods would be affected the same as the general population. This is because the neighborhoods that would be most affected by project construction and operation do not have larger proportions of low-income, minority, or LEP populations than adjacent neighborhoods. However, it is important to note that even if low-income residents of affected neighborhoods are exposed to the same adverse effects as other residents, the impact of this exposure may represent a bigger hardship for them than other residents. For example, low-income residents may not have the resources to relocate for periods of nighttime construction. They may not be able to purchase an air conditioner to use when construction-related dust forces them to close their windows in the summertime.  There are subtle differences between Options A, K, and L in how they affect low-income, minority, or LEP populations, but no substantial differences between the build options. Under the Phased Implementation scenario:  Tolling would be implemented; therefore, some car-dependent low-income populations and low-income populations living in areas with limited transit service would still experience disproportionately high and adverse effects.  Potential effects on tribal burial grounds on Foster Island would be delayed until later phases of the project are constructed.  Effects on usual and accustomed tribal fishing areas would occur under the first phase. However, stormwater would also be treated at this point, offsetting some of the adverse effects. What criteria did they apply to support findings? The basis for support of the tolled facility came directly from FHWA. The overall public benefits of replacing the bridge outweighed EJ impacts, and the potential for catastrophic failure of the bridge would disproportionately impact low income/minority populations. The team also consulted with the regional FHWA office over a period of several months and they provided guidance directly. What type of documentation was provided? The report author developed a memo in consultation with WSDOT and FHWA outlining the issues and their guidance.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 11     Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? Prior to the start of tolling WSDOT implemented a system that would allow low-income drivers to establish and replenish their prepaid accounts with their electronic benefit transfer (EBT) cards. EBT cards function like debit cards and allow recipients who receive federal benefits to pay for products and services, such as groceries and health care. However, EBT recipients would have to use their existing benefits to establish or replenish their accounts; no additional funds would be added to their EBT accounts to cover tolls. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? Does not seem to be covered in the report. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? WSDOT has implemented measures to reduce the likelihood of conflict with tribal fishing:  WSDOT is coordinating with the Muckleshoot Tribe to document important access points to usual and accustomed fishing areas in areas where proposed structures would be built. There would be additional coordination to avoid construction conflicts with tribal fishers harvesting salmon in Portage Bay, Union Bay, and Lake Washington.  Stormwater treatment facilities would be constructed as part of the project to treat roadway runoff before it discharges into the water and adversely affects fish habitat in tribal fishing areas.  During construction, contractors would be required to use best management practices to minimize the potential adverse effects of pile drivers, falling debris, unintentional discharge of sediment, and other construction effects that could harm fish habitat. Other construction-related mitigation efforts identified included:  Measures to mitigate for effects on ancient burial grounds  Measures to mitigate for effects on usual and accustomed tribal fishing areas Operation-related mitigation efforts identified included:  Measures to mitigate for effects on usual and accustomed tribal fishing areas  Measures to mitigate for the burden that tolls would present to low-income or LEP drivers  Measures to mitigate for the burden that electronic tolling options would present to low-income or LEP drivers  Measures to mitigate for the burden that tolls would present to social service agencies Status Current status of project: Tolling on current SR 520 Bridge began in December 2011. Construction of new bridge is underway. Critical Assessment Please generally critique the approach, methods and/or resources presented in this document. Do you see any gaps, room for improvement, or best practices? This is an EJ analysis, so as far as that goes, it was the most thorough approach at the time. For future analyses, it would be great to identify a way of calculating the actual costs to EJ populations compared with others. Also, wish there was a way to address individuals who do not quality as EJ but are functionally low-income (“lower income) because they live in an expensive region. Additional Comments  

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 12 Washington State DOT. July 2011. Alaskan Way Viaduct Replacement Project Final Environmental Impact Statement. Document Title Alaskan Way Viaduct Replacement Project Final Environmental Impact Statement, Social Discipline Report, Appendix H Website/Source http://data.wsdot.wa.gov/publications/viaduct/AWVFEIS-AppendixH.pdf Type of Sponsoring Agency or Organization Federal Highway Administration Washington State DOT City of Seattle Geographic Distribution The project study area comprises approximately five city blocks around the proposed alignment of three build alternatives in Seattle, Washington. Type of Tolled Facility & Features Fully tolled facility with possible variable tolling at different times of the day. Tolling Context The facility is a replacement of an existing route which will have a new toll imposed. The tolling technology will include gantries electronic transponders which can be billed or paid ahead with cash or credit. Pricing Arrangements Possible variable pricing at different times of the day. Decision Question/ Decisionmaker The key decision is on which alignment will be selected for building as part of the FEIS. The decision-maker is primarily the Federal Highway Administration working with the Washington DOT. Stage of Decisionmaking NEPA review process Identification of Affected Populations What populations does this document address? Discussions are presented throughout the report in regards to different issues which including low- income, minority, Black/African American, Asian/Pacific Islander, Hispanic/Latino, Native American, elderly, disabled, limited English proficient, homeless, and limited mobility. However, the focus of the EJ review for tolling is limited to low-income populations. Are there other affected stakeholders that are referenced? Social service agencies and transit providers are key stakeholders that have provided a great deal of input into the environmental review process. More than 70 social service providers were consulted during the public outreach program in 2001. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? Three areas of analysis are described include:  Project corridor which includes the alignment of the three build alternatives.  Study area which extends approximately .5 miles on each side of the project alignments and includes census tract block groups.  Effect area which extends approximately 2 blocks from construction activities and was used to access noise, vibration, light and glare to residents and businesses from construction activities.  Neighborhoods within the study area were defined by the City of Seattle in 2005. Six unique neighborhoods are examined and social resources are mapped for housing, government institutions, religious institutions, exhibit halls, landmarks, museums, cultural/social institutions, social/employment services, park/recreation, pedestrian bridge, railroad station, trail and shoreline access. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)?

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 13 U.S. Census Bureau 2000 statistics were used along with local government agencies websites, 2009 database from the Crisis Clinic to update low-income and special needs housing as well as social and employment services in the study area. The study area has about 17,336 people which is about 3% of the city’s population. Approximately 75% of the population in the study area is white and 25% non-white. Blacks and Asians account for 16% of minority population and 9% is Hispanic. While the per capita income of households in the study area is higher than the city at large, 23% lived at or near poverty. This signals very high and very low income populations living in the study area. The area also included more than 5% LEP populations (Hispanic and Asian ancestry). Most of the population in the study area is 18 to 64 years old. Nearly half of the households in the study area have no vehicle available for personal use. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? The study area minority population is less than the percent minority for the city which is 32%; however, several census tracts in two neighborhoods have higher than the city average. Both minority and low-income populations were mapped by block group. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? A public involvement discipline report exist (Appendix A) which provides detailed information on public involvement activities. Activities included the following:  Publishing notices  Holding dozens of community briefings  Holding dozens of public scoping meetings with translated meeting materials  Creating folios and factsheets  Setting up information booths  Newsletters and emails  Creating program website  Project telephone information line  Inviting local disadvantaged business enterprises to meetings  Outreach to more than 70 social service providers Minimal information is provided in this report on opinions of affected EJ populations with regard to toll implementation; however, reference is made to the Urban Partnership SR 520 Variable Tolling Project Study (2009). Focus group interviews of low-income drivers suggested they would be willing to pay the $3.50 toll for that project for faster, reliable trips. There was also a telephone survey for this project where 51% low-income respondents said they would use transit to avoid paying the toll. However, 63% said using transit would greatly increase their travel time. 67% of survey respondents said they would use non-tolled routes. Project staff from the Viaduct study did meet with some social service providers to ascertain their thoughts on the toll. All interviews suggested that non-tolled routes are preferable. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? Yes. Of particular importance was the demographic characteristics data which was used to determine languages use to translate published materials, engage interpreters to assist at public meetings and identify foreign-language newspapers for advertising meetings. Does the document describe how feedback was given by those in attendance? Is there any evidence

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 14 that feedback may have influenced alternatives, impact assessment, and/or mitigation? See information above related to public outreach. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations? See information above related to public outreach. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? There are not performance measures provided to assess if the public outreach was effective at engaging EJ population groups. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? Detailed information should be provided in the public involvement discipline report. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? Detailed information may be provided in the public involvement discipline report or the transportation discipline report. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) Detailed information may be provided in the public involvement discipline report or the transportation discipline report. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? A travel shed was used for the Bored Tunnel Alternative to determine characteristics of the populations most affected by tolling the SR replacement facility. The travel shed considers were users live and work (i.e. the origins of trips on SR 99 through downtown Seattle). The analysis only considers impacts to low-income populations. The analysis includes the census tracts with the greatest number of trips origins for SR 99 according to the modeling work summarized in the transportation discipline report. The percent of households below the federal poverty level is shown for these high-trip tracts. The tracts are mapped along with alternative non-tolled routes. Special attention is given to the tracts with residents rather other land uses because these trips would be made from the workplace rather than home. What considerations, measures and metrics were used to conduct analysis? Did the analysis consider access to transit, access to private vehicle, and residential or work locations? Several alternative routes are mapped to show different options available for population groups. 2030 vehicle travel times and transit times are also discussed in general concluding that travel times would be approximately 18 to 24 minutes longer than tolled SR 99. Tolling would increase transit travel moderately for transit using general purpose traffic. Cost of transit is also reviewed as a comparison to cost of the toll. Fares range from $1.75 to $4.75 depending on carrier as compared to the $2.45 for the toll. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads?

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 15 No behavior modeling techniques were presented. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? See above discussion. The discussion did not conclude if traffic diversion was disproportionately borne by specific communities. The analysis just included communities with higher than average minority populations and low-income populations but no analysis was provided to comprehensively evaluate traffic diversions other than through outreach which suggested low-income drivers would avoid the toll. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? Both SR520 Variable Tolling Project (2009) and the Columbia River Crossing proposal was cited as example of projects where tolls were determined to not adversely affect EJ populations. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) The location, intensity, and duration of potential environmental impacts due to tolling were reviewed as part of other discipline report including the Transportation Discipline Report, Air Quality Discipline Report and Noise Discipline Report. The Social Discipline Report reviews impacts to housing, community facilities, parks, recreation and public access facilities, religious institutions, social and employment services, cultural and social institutions, neighborhood cohesion, property values and transportation services. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? “The analysis of the equity of tolling concluded that the effects would not be disproportionately high and adverse for the following reasons:  Viable options for avoiding the toll exists  Acquisition of transponders which could cause adverse impacts to EJ population can be minimized or mitigated as described in the section below. What criteria did they apply to support findings? Conclusions were based upon alternative non-tolled travel routes being available, minimal increased travel times (18 to 24 minutes) and any negative impacts can be minimized or mitigated through careful planning and design along with coordination with groups and agencies which served EJ populations. What type of documentation was provided? Discipline Report Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? Not discussed What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? Not discussed. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues?

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 16 “Negative impacts can be minimized or mitigated through careful planning and design along with coordination with groups and agencies which server EJ populations”. Mitigated measures for potentially adverse impacts associated with acquiring transponders includes the following:  Establish customer service centers using storefronts in the travelshed.  Enable people without credit cards or checking accounts to pay with cash or electronic benefit transfer (Quest) cards issued by the State Social and Health services agency.  Provide public service announcements in multiple languages regarding the Good to Go! TM  Establish Good to Go! Retail outlets at convenient locations, such as grocery stores, convenience stores, or pharmacies throughout the travelshed and convenient to low-income communities.  Share information with and throughout other public service providers.  Provide social service agencies with tolling information and options to avoid tolls.  Promote rideshare opportunities such as those in Rideshareonline.com, carpoolworld.com, and commuteseattle.com, and vanpool providers. Status Current status of project: Under Construction Critical Assessment Please generally critique the approach, methods and/or resources presented in this document. Do you see any gaps, room for improvement, or best practices? The work is thorough from a community impact standpoint; however, the tolling analysis did not consider behavioral aspects of how travel costs would affect travel choice. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 17 Washington State DOT. July 2011. Alaskan Way Viaduct Replacement Project: Final Environmental Impact Statement Appendix X: Tolling Re-evaluation Memo. Document Title Alaskan Way Viaduct Replacement Project: Final Environmental Impact Statement Appendix X: Tolling Re-evaluation Memo. Website/Source http://data.wsdot.wa.gov/publications/viaduct/AWVFEIS-AppendixX.pdf Document Type Memorandum to assess if a supplemental DEIS will be required. The information in the memorandum was prepared as part of the FEIS. Type of Sponsoring Agency or Organization Federal Highway Administration Washington Department of Transportation Geographic Distribution The SR 99 route in the Seattle Region. Travel data is generated from the Puget Sound Regional Council’s model. The area includes four counties: Snohomish, King, Kitsap, and Pierce. Type of Tolled Facility & Features The facility is a replacement facility that will have a fixed toll. Several different toll scenarios were evaluated. Tolling Context This project is for a replacement facility which includes highway, bridge and potential and tunnel segments. Transponders would be used to track users and for billing purposes. The report states that non-banking alternative will be provided to those without money accounts or credit cards. Pricing Arrangements The report does not state specifically if dynamic pricing was considered; however, several single prices options are evaluated. The short section on tolling rates scenarios states that “toll rates would be higher for more congested times of the day; weekend tolls would be lower than tolls at the same time of the day on the weekday. Five toll scenarios are presented but only the highest toll option (C) is used for traffic analysis because was considered the worst case scenario of environmental impacts. Decision Question/ Decisionmaker The study is focused on determining the preferred alternative as well as best rate option. The decision-makers include both FHWA and Washington DOT. Stage of Decisionmaking Project Development and NEPA. Identification of Affected Populations The report focuses primarily on traffic changes from the 2010 Supplemental DEIS and does not specifically address effects to populations groups. Reference is provided to the 2011 Social Resources Discipline Report, Appendix H, and Section 7.1 which addressed EJ. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? See below. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? See below. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? See below. All these questions may be answered in the referenced discipline report cited above. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? See below. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? See below.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 18 Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? See below. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations? See below. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? See below. All these questions may be answered in the referenced discipline report cited above. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? See below. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? See below. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) See below. All these questions may be answered in the referenced discipline report cited above. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? The most important change in analysis is related to the design year traffic date. The 2010 Supplemental DEIS used 2015 and the re-evaluation study which will become part of the FEIS is using 2030. For the traffic analysis is based on the Puget Sound Regional Council’s model. Detailed documentation of the toll modeling methodology, sensitivity tests and results can found in the document titled: “Technical Analysis to Support the SR 99 Alaskan Way Viaduct Replacement Finance Plan, February, 2010” Of particular importance is reference to the difference travel times from the current analysis to the 2010 analysis due to the process used for summarizing travel time data from VISSIM. VISSIM was updated between the 2010 analysis and the current analysis to better capture the effect of diversion on both through trips and trips existing at the ramps. The older method did not accurately capture the effects of diversion and overestimated the travel times for through-vehicles and underestimated the travel time for existing vehicles at the major diversion points. The current analysis used two separate travel time segments to isolate through trips from exiting trips. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) Four metrics were reporting on for system-wide performance including vehicles miles traveled, vehicle hours delayed, vehicle hours traveled and travel speeds. The traffic analysis is presented for all four metrics for four build alternatives plus the no build alternative. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? There is no evidence of this type of analysis in the subject report. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 19       the usage of toll and non-tolled facilities? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads? The report did not provide information on this; however, this information may be in the above mentioned reference report. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? The primary reason for the re-evaluation is based on understanding traffic conditions in 2030 versus 2015 such that traffic diversion onto non-tolled facilities can be better understood as part of the final decisionmaking process. The report states “Scenario C is being evaluated for all three build alternatives since it has the highest toll rates and therefore provides a conservative analysis of the upper end of potential effects.” Six routes called screenlines are examined for traffic diversion from scenario C for all build alternative and the no build in the report. In additions, diversions are evaluated at three screenlines on Alaskan Way (surface street) and three at screenlines on I-5. No information is provided regarding how diversions may affect EJ populations. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? None Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) The report states “the project team reviewed the effects of tolling on traffic, air quality, and noise, seeking to identify whether any of these impacts may also have consequences for environmental justice.” Further the report states “indications are that disproportionately high and adverse effects on environmental justice populations under the build alternatives could be avoided or reduced by careful planning and design, continued outreach to minority and low-income populations.” Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The report concludes “analysis of potential effects to environmental justice populations since the 2011 Supplemental Draft EIS has found the options to avoid tolls and measures to make transponders available result in no disproportionately high and adverse effects. “The reduction in effects (relative to the potential effects discussed in the 2010 Supplemental DEIS) does not merit further supplemental NEPA documentation.” What criteria did they apply to support findings? This information may be available in the Social Discipline Report referenced above. What type of documentation was provided? This information may be available in the Social Discipline Report referenced above. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? See below. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? See below. Were any other commitments expressed in the document or in the record of decision relating to equity    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 20 and environmental justice issues? See below. This information may be available in the Social Discipline Report referenced above. Status Current status of project: Under Construction. Critical Assessment Please generally critique the approach, methods and/or resources presented in this document. Do you see any gaps, room for improvement, or best practices? More information may be available in the Social Discipline Report referenced. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 21 CALIFORNIA HDR Engineering. October 2013. MTC Regional Express Lanes Interstate 680 Corridor: Environmental Justice Technical Memorandum. Document Title MTC Regional Express Lanes Interstate 680 Corridor: Environmental Justice Technical Memorandum (HDR Engineering, Inc., October 2013, Prepared for the Metropolitan Transportation Commission (MTC), Oakland, CA) Website/Source Not available online – Public records request made to the Metropolitan Transportation Commission Document Type Technical Study (Environmental Justice Technical Memorandum) Type of Sponsoring Agency or Organization MPO – Metropolitan Transportation Commission is the transportation planning, coordinating and financing agency for the nine-county San Francisco Bay Area. Geographic Distribution San Francisco Bay Area, California Type of Tolled Facility & Features What type of tolled facility? What change is being made? HOV to HOT Lane Conversions with Pricing (still allowing HOV2+ to travel for free), as part of a proposed regional express lane network. (The Express Lanes are envisioned to let paying SOVs into the system only if there is available capacity with existing carpoolers.) Pricing of the tolls was undetermined at the time of the report; however, dynamic pricing is the preferred pricing strategy for the MTC express lanes. Tolling Context What is the tolling context?  The first phase of a regional network would include 24.39 miles of existing HOV lanes converted to express lanes, to include five segments including approaches to three bridges and interstate segments on I-680 and I-880.  New toll  Tolling technology/equipment: Primary-automatic collection (electronic) with transponders; Secondary-license plate recognition (LPR) cameras would capture license plate images of vehicles that do not display a recognizable transponder.  Methods of payment at time of report: credit card, debit card (although this method is discouraged), cash, check, money order  Methods of payment now? Toll facility is not open yet, previous planned payment methods are anticipated to remain the same Pricing Arrangements What type of pricing scheme (e.g., dynamic, time of day, single price)? Pricing of the tolls was undetermined at the time of the report; however, dynamic pricing is the preferred pricing strategy for the MTC express lanes. Decision Question/ Decision maker What decision, if any, is being made? MTC and the California Department of Transportation (Caltrans) are pursuing development of an integrated express lane network. In doing so, the MTC and Caltrans are evaluating potential impacts of the I-680 Corridor improvements (proposed project) on minority and low-income populations. At what agency or governmental level are the decisions being made? State DOT and regional/metropolitan planning organization Stage of Decision making What stage of decision making does this document address? Policy and program evaluation; project development and NEPA; mitigation implementation;

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 22       community participation Identification of Affected Populations What populations does this document address? Primarily low-income and minority populations. Are there other affected stakeholders that are referenced? Mention of limited English proficient, unbanked populations, foreign born populations, individuals who want to remain “anonymous,” individuals in the Extended Resource Area (ERA – study area which encapsulates the majority of likely users of the I-680 freeway). Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? The overall study area was determined by mapping the percentage of trips and number of trips originating in each TAZ that use one or more of the roadways that would include express lanes within the MTC Program for a portion of the trip. The analysis suggests that Alameda, Contra Costa, and Solano Counties represent an appropriate study are for the MTC Program. Then, for the project-level analysis, three study areas are defined and considered in the analysis:  Direct Impact Area (DIA): the area most likely to experience the potential direct impacts from the project construction and operation; this includes all census tracts within ¼ mile of the I-680 corridor  Extended Resource Area (ERA): which includes the likely users of the proposed express lane facility; this includes the entirety of Alameda and Contra Costa Counties  Region of Comparison (ROC): the study area identified for the MTC Program, used to determine if potential project-related adverse impacts are disproportionate in comparison to the greater area; this includes Alameda, Contra Costa, Solano, and Santa Clara Counties (Santa Clara County was added because part of the express lane extends into this county) What data sources were used to identify affected populations?  MTC’s regional travel demand model (Travel Model one) was used to review regional travel patterns and identify the area most affected by the express lanes within the MTC Regional Express Lanes Program (MTC Program). The analysis was performed using a process called select link analysis which simulates the travel patterns of all Bay Area residents on a typical weekday and estimates the traffic flow on every major roadway in the region.  U.S. Census Bureau and American Community Survey (ACS) data were collected to determine the census tracts that comprise the Direct Impact Area that include EJ populations of concern. For race and ethnicity data, 2010 decennial data was available for the full population. For poverty information, only sample data was available; ACS five-year estimates (2006 to 2010) were used to identify low-income populations. What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)?  MTC has identified concentrations of minority populations in geographic units where 70 percent of more of the population is identified as minority.  MTC has identified concentrations of low-income persons where 30 percent or more of individuals within a geographic unit are below 200 percent of the poverty level. Poverty levels are defined at the national level. MTC uses 200 percent of the poverty level to account for the region’s high cost of living relative to the nationwide federal standard.  The appropriateness of these determination thresholds were analyzed in the report. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes, the location of affected populations at the DIA scale were mapped/analyzed (although a full map of all DIA areas was not included). The geographic scale for mapping and analysis of the DIA areas

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 23 was the census tract. The location of affected populations in the ERA and ROC areas were not mapped, but they were analyzed. However, the EJ populations were only analyzed at the county level for both ERA and ROC areas, which did not allow a small enough geographic analysis unit to identify EJ concentrations. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Yes. MTC conducted an outreach and engagement effort throughout the study area for the overall Regional Express Lane Network. The purpose of the outreach and engagement effort was to inform members of the public, targeting minority and low-income populations, of the express lanes systems and elicit their opinions and concerns for consideration in the planning process. The outreach effort included the collection of quantitative data through intercept surveys and qualitative data through focus group meetings. In addition, MTC has prepared a Bay Area Express Lanes Public Involvement and Communications Approach (MTC, 2013) which outlines the intention to conduct a series of public outreach meetings in the Bay Area Express Lane corridors. Does the document describe efforts to provide information about toll implementation or rate changes? Information is provided about toll implementation to the extent it is known or determined. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? Mapping of affected populations within the region appeared to influence where public involvement was conducted (however, if was not clear if the mapping was performed before or after the public involvement efforts themselves). Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? Yes, the document summarizes how feedback was given by those who completed a survey or were involved in a focus group. A full summary of responses for both medium was included in Appendix A. It is likely feedback from the public may have influenced the mitigation and access strategies for the transponder system given the breadth of strategies used to broaden access to the FasTrak® transponder system. There is evidence that the public feedback was taken into consideration in the impact assessment, but due to the project benefits and other considerations the input did not impact the final impact assessment. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)?  The intercept surveys were available in three languages (English, Spanish, Chinese).  The intercept surveys were conducted at six locations typically frequented by a large and diverse number of people throughout the entire study area.  Six focus groups were conducted at various community-based organizations (CBOs) in the study area. Focus group meetings were conducted in either English, mixed English and Spanish, or primarily Spanish with some English.  The intercept surveys and focus groups were administered on various days at various times.  The public information meetings that were planned were targeted at EJ populations, but all populations would be welcome. Does the report assess its effectiveness reaching low-income, minority or other traditionally

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 24 disadvantaged populations? Yes. The report assesses the extent to which focus group and intercept survey respondents were low- income or minority populations. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? Yes, focus groups and intercept surveys were conducted. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? “The purpose of the outreach and engagement effort was to inform members of the public, targeting minority and low-income populations, of the express lanes systems and elicit their opinions and concerns for consideration in the planning process. Specifically, the data gathered from the EJ communities included their perceptions about express lanes, their ability and willingness to pay to use express lanes, and any potential barriers to using express lanes by low-income and minority populations.” Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) Travel surveys or travel diaries were not gathered with this study. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? See “Evaluation of Environmental Justice Impacts” section below. Focus group meetings and intercept surveys were also used to inform the overall impact assessment; noting that the decision to use the express lane is dependent on the users’ ability to obtain a toll tag (transponder), their willingness to pay the toll, and their perceived benefit from using the lane. It appears that no other data sources or analytical methods were applied to conduct the impact assessment. The benefits of the project were also noted and informed the overall impact assessment. The following assumptions were also noted with respect to the impact assessment:  “Low-income and minority populations can choose to pay the fee to improve the level of service of their travel and experience lesser congestion. … Low-income and minority populations who cannot use the express lane will not have any change in their travel; however, there is the potential for congestion in the general purpose lanes to improve as traffic shifts to the extra capacity in the express lanes.”  Providing EJ populations an option to have an improved travel time with use of the express lanes (which can be particularly beneficial to those who would otherwise incur a larger cost if they were late to their destination), “whether they choose it on a regular basis or just in emergency situations, is a benefit and would not adversely impact their travel time.”  “There is no direct economic impact to those who opt to not use the express lane.” What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) See “Evaluation of Environmental Justice Impacts” section below. No other measures or metrics were used to conduct the analysis in this report (however, the analyses in other I-680 report documents may have conducted their analyses based on metrics or measures). Other considerations included focus group meetings and intercept surveys to inform the overall impact assessment Did the analysis consider access to transit, access to private vehicle, and residential or work locations?

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 25       The analysis did consider both residential and work locations, and to a lesser degree considered access to private vehicles. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The analysis in this report did not directly discuss modeling of the travel behavior of EJ populations. However, the report referenced other surveys on the use of HOV lanes by low-income and minority populations via both before and after implementation of managed lane projects, research conducted to date on the usage of HOV/HOT lanes by EJ populations, and the public perception of study area individuals on HOV/HOT lane planned improvements along I-680. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g.,. low-income and minority populations)? No, this analysis did not assess impacts of trips diverted to non-toll facilities. However, this study is based on technical studies prepared for the I-680 Corridor Project so such analysis may be included in other studies such as the Traffic Impact Study. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? Many other studies were cited as examples of previous research and other projects were cited as examples of other managed lane projects. Other studies were not, however, necessarily cited as support for the tolled facility; citations were typically used to support the understanding of the state of the practice. Studies and projects references in the report covered the following topic areas:  Information available on the use of HOV lanes by low-income or minority populations in the region;  Studies/reports that documented the results of Express Lane surveys (before and after implementation) and usage patterns of Express Lanes;  Toll tag account options, fees, and requirements on Express Lanes in operation;  Transportation costs of low-income households (compared to higher-income households) and transportation perspectives of low-income adults;  Studies documenting that many low- and lower-income users do not have bank accounts, debit cards, or credit cards;  Strategies to expand access to toll tags on Express Lane systems in operation; and  Average tolls for Express Lane systems in operation. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) Yes – noise, air quality, visual, displacements, land use, public and community facility use and access, and community cohesion. There were no impacts to EJ populations in any of these categories that would not be mitigated (mitigation for construction-related emissions and air quality impacts) or no disproportionate adverse impacts borne by EJ communities (noise). These resource topics were addressed in addition to traffic congestion, travel time, access and connectivity, and economic impacts (ability to obtain a toll tag, willingness to pay toll, willingness to pay varying express lane fees). Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The I-680 Corridor Project will not result in disproportionate adverse direct impacts or disproportionate adverse economic impacts to minority and low-income populations.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 26 What criteria did they apply to support findings?  Along I-680, adjacent to the only census tract identified as a community of concern within the Direct Impact Area, “there are no HOV lanes that will be converted to carpool lanes. However, advanced signage in the southbound direction will be installed.”  The analyses of potential direct impacts on the EJ communities in the report were based on technical studies prepared for the I-680 Corridor Project, including the Noise Summary Report, Air Quality Technical Report, Visual Impact Assessment, and Traffic Impact Study.  The following were the criteria used for each of the direct project impacts evaluated: o Noise: long-term noise impacts based on increase in capacity to I-680 (no increase) and location of lanes in relation to noise-sensitive receptors (existing lanes will not be relocated closer to receptors); length or duration of potential impacts (temporary and short in duration); time periods of construction activities outside of freeway itself (would be performed during approved construction hours) o Air Quality: long-term operational AQ impacts from local traffic were evaluated by a quantitative method which modeled roadside carbon monoxide concentrations associated with the project compared to National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS), modeling was conducted for the busiest mainline segments; construction-related emissions in conjunction with mitigation efforts; diesel exhaust impacts – extent and duration of diesel equipment usage o Visual: impacts to views of Mount Diablo, particularly those views between the one EJ community identified and Mount Diablo o Displacements: displacements of residents or businesses, disruption to existing businesses during construction o Land Use: alteration of existing or planned land uses in the Direct Impact Area o Public and Community Facility Use and Access: alteration or impact to community facilities or access impacts to neighborhood communities o Community Cohesion: anticipated changes in travel patterns or impacts to local traffic, access, and circulation in the neighborhood  The transportation impacts on minority and low-income populations were not directly evaluated at the level of the Direct Impact Area (all census tracts within ¼ mile of the I-680 corridor), only “potential disproportionately high and adverse human health and/or environmental impacts to EJ populations are evaluated” for the Direct Impact Area.  Because no EJ communities of concern were identified for the other larger study areas (Extended Resource Area or Region of Comparison), impacts on EJ communities outside of the Direct Impact Area (including transportation impacts) were not found to have disproportionate adverse impacts on EJ communities. What type of documentation was provided? See above responses. Also, focus group and intercept survey results as well as regional travel patterns were also evaluated, as well as additional research on travel behavior of low-income or minority populations’ use of HOV lanes (although data on “minority” is limited). Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No approaches specifically aimed at EJ communities. See below list for general incentives offered. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? N/A Were any other commitments expressed in the document or in the record of decision relating to equity

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 27 and environmental justice issues? Yes, as well as some incentives. Below is a list of strategies to expand access to toll tags planned for the project (these strategies are already in place for other Bay Area Toll Authority systems in operation in the San Francisco Bay Area). Strategies to Establish or Maintain the Toll Tag Account:  One regional service center or numerous retail locations (Safeway, Costco, or Walgreens), includes $5.00 for use to pay tolls and a deposit of $20.00.  Permits payment by cash or check to open the account.  Currently, can replenish account by mailing check or money order payable to service center, or payment in cash at service center.  Can check account balances, make a one-time toll payment, pay a violation notice, and pay an invoice at numerous Cash Payment Network (CPN) locations.  Can have “anonymous” accounts that do not require personal identification, and pay with cash or money order. Toll Tag Account Incentives or Other Benefits:  Spanish- and Chinese-language application pdfs online.  Online customer handbook.  FasTrak® hours of operation include Saturday mornings.  First 3 months of system operation only, user could get a $10.00 credit for getting an account (I- 680 promotion only).  If receive a first-time violation and set up a new account within 30 days, the violation penalty of $25.00 is dismissed (can pay by check). Status Current status of project: Planning Critical Assessment The analysis was very thorough in methodology and approach, research of comparable projects, examination of local travel patterns, and conduct of public outreach to collect input of low-income and minority populations in the study area. As shown above, the EJ analysis overall was very thorough and well developed in many areas. The “Summary of Express Lane Surveys Before and After Implementation” (Appendix C) is a valuable tool for this EJ analysis that could be used to inform the evaluation of potential other managed lane projects. Also, Table 6-2 “Toll Tag Account Options, Fees, and requirements on Express Lanes in operation” (which summarizes the procedures and costs for establishing and managing an account on other systems around the nation) and Table 6-3 “Strategies to Expand Access to Toll Tags on Express Lanes Systems in Operation” across the U.S. which may also be useful tools to inform the evaluation of other managed lane projects. One area where there was not sufficient attention was the impacts to travel time based on whether users chose to take the express lanes or regular lanes. The report notes “the potential for overall freeway operations to improve with the express lanes, as more cars move from general purpose lanes to an express lane with additional capacity, [that] drivers in general purpose lanes may experience less congestion” (p.68). Without a travel time and capacity analysis (which may or may not be included in other analyses or reports for the I-680 Corridor Project), this statement is unsubstantiated. Additionally, the analysis of the Extended Resource Area at only the county level, and not a smaller geographic area of analysis, precluded a thorough evaluation of the impacts to EJ communities in this larger study area. (However, because this report, a project-level analysis, was underscored by a context analysis prepared for the full Regional Express Lane System, additional analysis may have

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 28 been performed in other studies that were not included in this document. If this is the case, analysis at a smaller geographic area of analysis for the Extended Resource Area would still have been warranted and necessary.) Additional Comments The “Summary of Express Lane Surveys Before and After Implementation” (Appendix C) is a valuable tool for this EJ analysis that could be used to inform the evaluation of potential other managed lane projects.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 29 California DOT. December 2013. I-580 Eastbound Express Lanes Project: Initial Study with Proposed Negative Declaration/Environmental Assessment. Document Title I-580 Eastbound Express Lanes Project: Initial Study with Proposed Negative Declaration/Environmental Assessment (State of California Department of Transportation (Caltrans) in cooperation with Alameda County Transportation Commission, 2013) Website/Source http://www.alamedactc.org/app_pages/view/11406 Document Type Initial Study/Environmental Assessment Type of Sponsoring Agency or Organization State of California Department of Transportation in cooperation with Alameda County Transportation Commission Geographic Distribution  San Francisco Metro area Type of Tolled Facility & Features HOV to HOT lane conversions along a 12-mile corridor. HOVs would continue to travel free. Tolling Context  Tolling on a single lane of a highway (12-mile corridor) during peak hours. Also, construction of an additional (second) express lane for part of the corridor, in one direction.  New toll (conversion of an HOV lane to a HOT lane).  Tolling technology: All tolls would be collected with electronic transponders (Fastrak) already used to pay tolls on other bridges and HOT lanes in the region.  “Toll tags can be obtained online; by phone, mail, or fax; in person from the Bay Area Toll Authority (BATA) Regional Customer Service Center (RCSC); or from retail outlets such as Walgreens, Safeway, and Costco. Toll tags can also be obtained anonymously (without providing personal or vehicle information) from the RCSC. There is no charge to open a FasTrak account, but each account holder must keep a minimum balance in a prepaid account.” (page 1-12)  The report directs readers to a website for more information on payment. The link was broken. However, as for 12/1/14, the FasTrak FAQ website says: “There are no fees to open or to maintain a FasTrak account. As toll tags are leased, refundable security deposits do apply. The security deposit is $20 per toll tag. The deposit is refunded to you when you close your account and return the toll tag in good condition. If you maintain a valid credit card on your account, the security deposit for up to three toll tags is waived. “FasTrak is not a ‘pay as you go’ system. You deposit money into your FasTrak account and each time you use your tag, the toll amount is deducted from your account balance. An initial balance is required upon account opening so that you have a prepaid balance from which tolls can be deducted. To open an account using a valid credit card, an initial prepaid balance of $25 per toll tag is collected. To open an account using cash or a check deposit, an initial prepaid balance of $50 per toll tag plus a $20 per toll tag deposit is collected. The deposit is refunded to you when you close your account and return the toll tag in good condition. Any remaining balance on your account will also be refunded to you upon account closure.” (https://www.bayareafastrak.org/en/support/faq_general.shtml) Pricing Arrangements The toll would be charged only during peak hours. The report does not mention specific toll rates. Instead, it says the rates will be determined as follows: “If the monitoring system finds that congestion is low and the express lanes can accommodate more vehicles, the toll rate would be low. If the express lanes have less capacity, the toll rate would be increased as needed, up to a maximum toll rate to be determined, to deter SOVs from entering. The toll increase for SOVs would be used to maintain the

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 30 minimum average operating speed of 45 mph for HOVs (set by 23 USC 166[d][2]) and the target LOS of C or D for HOVs (California Streets and Highways Code Section 149.5[b]) (Section 1.2.2.3). If the express lanes reach capacity, the message on the DMS would change to read ‘HOV only.’ At that point, only HOVs would be allowed into the lanes. SOVs would not be allowed even if they have a FasTrak toll tag.” (page 1-11) Carpools (2+) would pay no toll. Decision Question/ Decisionmaker Decision to be made: Conversion of HOV to HOT lanes (or no build alternative). Caltrans, the state DOT, would make the formal decision, as described in the report. However, Caltrans is working with Alameda County Transportation Commission (Alameda CTC) and would not build the project without county agreement. Alameda CTC is described in the report as the “project sponsor.” The project is included in the plan of the MPO (Metropolitan Transportation Commission, or MTC). Stage of Decisionmaking Decision on whether or not to convert an existing HOV lane to a HOT lane. Identification of Affected Populations No population groups were identified as possibly impacted. “Environmental Justice: The proposed project would not cause disproportionately high and adverse effects on any minority or low-income populations. The project corridor has a generally consistent ethnic and income profile; the population is predominantly white (averaging 60.64 percent; U.S. Census Bureau 2010a), and the 2010 median household income averaged $105,000 (U.S. Census Bureau 2010b). The median household income is above the Department of Health and Human Service poverty guideline ($23,050 for a family of four in 2012; Federal Register, Vol. 77, No. 17, 4034– 4035). Therefore, this project is not subject to the provisions of Executive Order 12898.” (pages 2-2 and 2-3). Threshold Criteria & Geographic Mapping N/A – no work of this kind done. Description of Public Involvement Activities These are described in Chapter 3. None specifically targeted EJ populations. Outreach activities were:  The proposed project has been presented during the public outreach phase of MTC’s region-wide express lanes network study. It has also been discussed at some of the major public outreach meetings held for I-680 Southbound Express Lane Project.  Agency consultation and public participation for this project have been accomplished through a variety of formal and informal methods, including a focus group discussion, meetings with stakeholders (Chamber of Commerce and members of the business community), city council meetings, ground breaking ceremonies, Alameda CTC Policy Advisory Committees meetings, and other public outreach meetings.  Public notification for the I-580 express lane began in 2008 during the public groundbreaking ceremony for the I-580 HOV lane, when Alameda County Supervisor Scott Haggerty described the project as a planned express lane. Formal outreach within the I-580 corridor began on September 15, 2009, with a presentation to a meeting of the Pleasanton City Council including a video of the I-580 express lane operations and question and answer (Q&A) with those present. The city council meeting was open to and attended by the public, with the express lane presentation as a listed element of the agenda. In addition, the meeting was broadcast on the city's cable television station. The presentation received page 1 coverage in the Pleasanton Weekly newspaper edition of September 25, 2009.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 31        Outreach with community organizations along the I-580 corridor began with a presentation to the Pleasanton Chamber of Commerce breakfast meeting of November 12, 2009. The presentation was similar to the presentation to the city council two months earlier. In addition, the project has been listed several times on the agenda of the Alameda CTC Policy Advisory Committee, which includes the mayors of local cities. The I-580 Eastbound Express Lanes project was also presented at the Alameda County Transportation Improvement Authority’s east county transportation forums held in April 2010 and April 2011. (page 3-1) Attitudinal Surveys, Focus Groups, and Interviews No studies of these types were described in any detail. The only one mentioned was a “focus group” mentioned in passing on page 3-1, in the section on public outreach. No details of any kind are given about this focus group. Regional Travel-Related Measures and Impacts N/A Traffic Diversion Effects No consideration was given of possible traffic diversion. (The project would add SOV capacity, but not reduce HOV capacity.) Case Study or Referenced Authority N/A Other Resource Topics N/A Evaluation of Environmental Justice Impacts N/A – none were discussed. Revenue Recycling / Other Mitigation Strategies No discussion of impact that paying the (optional) toll would have on low-income people. There are no commitments in the document relating to equity and environmental justice issue. Status From a separate “Project Fact Sheet”:  Environmental clearance for the full project was achieved March 2014 with the approval of the eastbound express lane environmental document and project study report  Civil design for the combined project has been completed and construction of the civil elements is underway  Electronic toll system implementation will begin spring 2015, with the new express lanes scheduled to open in fall 2015 http://www.alamedactc.org/files/managed/Document/11071/ACTC_I580ExpressHOTLanes_factsheet. pdf Critical Assessment No assessment of EJ or equity was done at all. This could have been added, as an improvement. Additional Comments N/A

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 32       California DOT. October 2002. I-15 Managed Lanes Final IS/EA and Mitigated Negative Decision. Document Title I-15 Managed Lanes Final IS/EA and Mitigated Negative Declaration Website/Source http://www.dot.ca.gov/dist11/I15managed/I-15/ea_is/final_is.pdf Document Type Environmental Assessment/Initial Study Type of Sponsoring Agency or Organization California Department of Transportation & Federal Highway Administration Geographic Distribution What geographic area does this document address?  San Diego Metropolitan areas including San Diego County (Cities of San Diego and Escondido) Type of Tolled Facility & Features Expansion of Interstate 15 to construct four Managed Lanes in the median for a total project length of 21.1 miles. The project will expand I-15 from about 1.5 miles south of SR-162 in San Diego to 0.3 miles north of SR-78 in Escondido. Tolling Context What is the tolling context?  New separated Managed Lanes along I-15  New Toll  All-electronic transponders  No payment information provided. Pricing Arrangements Dynamic Value Pricing to maintain a service level of D (approx. 1600-1800 vehicles per hour/lane). Decision Question/ Decisionmaker This is a new infrastructure project with a tolling component. The decision is being made by the California Department of Transportation Stage of Decisionmaking This document is an environmental assessment and is part of the NEPA and California Air Quality review processes. Identification of Affected Populations What populations does this document address? The document addresses racial/ethnic groups and poverty groups. Are there other affected stakeholders that are referenced? No other stakeholders are referenced in relation to environmental justice. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? The document indicates that Sub Regional Areas were identified as the unit of geography because they had the best available data. The boundaries of the study area are all SRAs within or adjacent to the I-15 corridor. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? The SANDAG Demographic and Economic Mapping system was the primary data model identified. However, no additional information was presented. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) No map was provided. Description of Public Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes?

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 33         Involvement Activities Yes. Public involvement appears to be extensive and comprehensive. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? Yes, public outreach mailers were targeted to two low-income, high minority, high HOV-user neighborhoods. A 2% response rate was reported. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? Yes. However, limited attendance was reported at the meetings in the two target neighborhoods. A total of seven attendees at three meetings. Comments were received at the meeting. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? Targeted mailings to the two target neighborhoods. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? Yes, response rates and attendance figures are presented, however they are not critically assessed. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? Yes Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? Intercept surveys were administered to 50 carpoolers and 50 transit riders at a park-and-ride facility. In addition a telephone survey of 800 peak period corridor users was conducted. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) Yes, income and demographic information were received from the Intercept surveys; 22% of respondents made less than $50,000 per year and 20% were minorities. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? None, only the public outreach data was employed. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) None Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 34 EJ populations, therefore EJ populations were no less able to access or use toll roads)? No Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g.,. low-income and minority populations)? No Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) No, these topics were addressed but not with respect to EJ communities Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The document finds that the impact to EJ communities would be minimal. What criteria did they apply to support findings? The establishment of transit service in the corridor that will have access to the Managed Lanes was cited as a mitigation technique that will reduce the impact to EJ communities. What type of documentation was provided? An environmental significance checklist was provided that described if there would be an impact and the level of significance if there was an impact. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No, these were not discussed. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? Not presented. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No Status The project was completed in 2012. Critical Assessment The document describes a potentially effective public outreach model to target efforts to engage EJ communities. Following the identification of EJ communities in the data analysis, mailings, meetings and other outreach efforts were targeted to two distinct communities. However, it is important to note that they meetings themselves were not well-attended. In total, this assessment is lacking in a few areas, including identification of travel patterns of EJ populations and other potential impacts. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 35 California DOT. 2010. The Interstate 10 (San Bernardino Freeway/El Monte Busway) High Occupancy Toll Lanes Project: Draft Environmental Impact Report/Environmental Assessment. Document Title The Interstate 10 (San Bernardino Freeway/El Monte Busway) High Occupancy Toll Lanes Project: Draft Environmental Impact Report/Environmental Assessment Website/Source http://www.dot.ca.gov/dist07/resources/envdocs/docs/I-10%20HOT%20Lanes%20EIR%20EA.pdf Document Type Draft Environmental Impact Report/Environmental Assessment Type of Sponsoring Agency or Organization The document was prepared by the State of California Department of Transportation (Caltrans) Geographic Distribution What geographic area does this document address? Please consider:  Los Angeles Metropolitan Areas – Corridor Type of Tolled Facility & Features What type of tolled facility? What change is being made? HOV to HOT Lane Conversions with Pricing Tolling Context What is the tolling context?  Facility specific tolling context – I-10 or the San Bernardino Freeway  New toll pricing replaces existing HOV lanes  All-electronic tolling  No formal fee structure had been finalized at time of report  Current payment methods available are Credit/Debit cards, Cash, Check or Money Order Pricing Arrangements The pricing scheme is dynamic to maintain consistent flow of traffic at 45 mph Decision Question/ Decisionmaker What decision, if any, is being made? (e.g., new infrastructure project, implementation of HOT lane, rate increase, etc.? Conversion of HOV lanes to dynamic pricing HOT lanes At what agency or governmental level are the decisions being made? (e.g., Federal, State DOTs, regional/metropolitan planning organizations, local agencies, etc.) State Department of Transportation Stage of Decisionmaking What stage of decisionmaking does this document address? Environmental Assessment/Environmental Impact Identification of Affected Populations What populations does this document address? The document identifies populations living within a defined study area and includes demographic information about the residents of the area. Race, income and housing status are also considered. The 2009 Poverty Guideline from the US Department of Health and Human Services defines the poverty threshold. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? Census block groups and tracts within the ¼ mile buffer of the I-10 HOT Lane alignment were defined as the extent of the study area. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Census data was used to identify the affected populations. Tracts/block groups with racial representation greater than 50% were identified and as well as tracts/block groups with more than

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 36 30% individual poverty. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes, a map is prepared which illustrates the census block groups and tracts that intersect the ¼ mile study area. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? Yes, two outreach efforts were undertaken to engage the public during the assessment process. First was the scoping phase to examine the proposed project. Second, a larger public participation effort was undertaken that included conference booths, briefings for community governments and organizations, public workshops and email/flyer notification. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? There was no discussion presented to determine if these community meetings were targeted for the study area. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? No, only a summary of community outreach efforts was presented. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? None presented Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No surveys or interviews were specifically discussed. Metro conducted meetings of the Corridor Advisory Groups (CAG) to solicit feedback from community leaders and representatives. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? Communities that would potentially be impacted by the HOT lanes project were represented on the CAG. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? Census data and the defined poverty level of 2009 were the primary data sources. More geographic refinement was present with only tracts and block groups within the study area (1/4 mile from the corridor) used to identify potentially impacted populations. However, no true analytical methods were applied. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 37       traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) None Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? No Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No, none cited. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) Yes, these topics were addressed, however they were not presented in a manner that highlighted the impact to disadvantaged communities. Rather in the larger regional context. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The report finds that there are benefits and negative impacts to low-income and minority communities. However, these impacts are presented as minor. Recurring charges and fees associated with the transponder will have a negative impact. However, traffic improvements are cited as a benefit for these communities as well. What criteria did they apply to support findings? No clear criteria were presented. There was no discussion of how these impacts were quantified, only that these communities exist within the study area. What type of documentation was provided? No documentation was presented. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? Yes, a suggestion to mitigate the transponder fees for low-income users. Households within five miles of the corridor that are low-income would be eligible for one such waiver per household. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? No, weighing of the costs and benefits presented. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 38     Status Current status of project: Operation underway. Critical Assessment Overall this document adequately identifies potentially impacted communities at a sub-county geographic level. However, there is limited discussion on the basis for the determination that low- income households within 5 miles of the corridor will be eligible for the transponder credit. In addition, there is very little discussion on how these communities would be adversely impacted aside from their location within the study area. There is room for more thorough and detailed analysis here. Additional Comments  

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 39     California DOT. July 2012. Community Impact Assessment: State Route 85 Express Lanes Project. Document Title Community Impact Assessment: State Route 85 Express Lanes Project, Santa Clara County, California Website/Source http://www.dot.ca.gov/dist4/documents/85ExpressLanesProject/ea_4a7900_sr_85_el_community_ impact_assessment.pdf Document Type Community Impact Assessment Type of Sponsoring Agency or Organization State of California Department of Transportation Santa Clara Valley Transportation Authority Geographic Distribution What geographic area does this document address? San Jose-Sunnyvale-Santa Clara Metropolitan Area Type of Tolled Facility & Features What type of tolled facility? What change is being made? Conversion of existing HOV lanes to Express lanes restricted to HOVs and vehicles paying a toll. The pricing will be dynamic based on congestion and time/date. Tolling Context What is the tolling context?  State Route 85 and US-101  Conversion from HOV only to HOV (free) and SOV tolling.  All-electronic toll transponders, known as FasTrak. FasTrak is already in use in other parts of the region  Cash, check, credit/debit cards, money order are acceptable forms of payment Pricing Arrangements Dynamic pricing that adjusts to reduce congestion along the roadway. Decision Question/ Decisionmaker The decision in this document is to evaluate the implementation of tolling on the SR-85 and US-101 corridor. Managed lane implementation is a result of state legislation. The program is being implemented by the State Department of Transportation. Stage of Decisionmaking What stage of decisionmaking does this document address? This document is a Community Impact Assessment which supports compliance with the NEPA process and the California Environmental Quality Act. Identification of Affected Populations Populations identified in this document include ethnic/racial groups and individuals living below the poverty line. Are there other affected stakeholders that are referenced? No Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? All census block groups within 0.5 miles of the corridor were selected as the geographic boundary. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Data from the American Community Survey 2006-2010 (ACS) by the U.S. Census Bureau was used to identify potentially impacted populations. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ)    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 40       No map was prepared for the report to illustrate the location of affected populations. However, as mentioned previously spatial data was used to determine the location of potentially impacted populations. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? Yes. Public involvement was discussed within the document. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No. There is no relationship directly with the mapping. However, demographic data was used in determining the makeup of the focus groups. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? Yes, the public outreach program consisted of polling and interviewing about 750 Santa Clara County citizens. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? No, none discussed. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? Yes, focus groups and interviews were conducted. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? Corridor travelers were identified as part of the polling and interviewing process of the public outreach program. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) The only indication is that it was reported that respondents from all income levels surveyed believed they would use the lanes. Otherwise no travel behavior was assessed. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? Low-income persons were defined using the Census Bureau’s poverty threshold. Census block groups containing 50% and greater shares of minority persons were defined as EJ communities. In addition, those with 25% and greater shares of low-income persons were defined as EJ communities. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) No, only demographic measures were identified, no travel measures. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 41 Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads? No Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No, no discussion presented Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? Yes. VTA had previously done studies which they referenced: “VTA began seeking public input on express lanes for SR 85 and US 101 in Santa Clara County in 2004. A primary focus of the public outreach has been fairness and equity issues of charging tolls for express lane use. A study prepared for VTA during early express lane planning, Assessing the Equity Implications of HOT Lanes (Weinstein and Sciara 2004) examines these issues and provides strategies to address equity concerns, including public outreach and education, documentation of equity analysis in project planning, and project design elements and approaches that increase equity in express lane benefits and costs.” Also, “in 2008, VTA conducted a research, public outreach, and education program to gauge public sentiment about the adoption of express lanes. The program consisted of polling and interviewing approximately 750 Santa Clara County citizens, including 681 SR 85 and US 101 users, four focus groups of HOV users and solo drivers who use SR 85, 13 one-on-one interviews with community stakeholders, and 10 one-on-one interviews with VTA managers and staff.” Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) Yes, environmental and land use impacts were presented, however these were not in a context that related to EJ communities. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The assessment found there was minimal impact to EJ communities. What criteria did they apply to support findings? The assessment identifies that while there may be a greater economic burden placed on low-income users of the road, the toll is voluntary and not required to continue mobility through the corridor. As such, use of the toll facility is a choice, not a requirement. What type of documentation was provided? No documentation was provided. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? None

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 42 Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No Status Current status of project: Operation underway. Critical Assessment Overall the assessment makes a good effort to identify the EJ community with demographic and spatial data. The public outreach component by VTA was thorough, although it did not specifically target the EJ communities identified in this final assessment because the outreach was published prior to this document. However, the final justification that EJ communities will have minimal impact is very weak and not clearly defined. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 43     California DOT. February 2010. The Interstate 110 (Harbor Freeway/Transitway) High- Occupancy Toll Lanes Project: Draft Environmental Impact Report/Environmental Assessment. Document Title The Interstate 110 (Harbor Freeway/Transitway) High-Occupancy Toll Lanes Project Draft Environmental Impact Report/Environmental Assessment Website/Source http://www.dot.ca.gov/dist07/resources/envdocs/docs/I-110_draft-EIR_EA_HOTL.pdf Document Type Environmental Assessment Type of Sponsoring Agency or Organization State of California Department of Transportation Geographic Distribution Los Angeles Metropolitan Area, City of Los Angeles and Los Angeles County Type of Tolled Facility & Features What type of tolled facility? What change is being made? Conversion of High Occupancy Vehicle Lanes to High Occupancy Toll Lanes The lanes will be managed through congestion pricing to maintain a threshold speed flow of 45 miles per hour. If lane speeds drop below this threshold, SOVs will no longer be allowed to use the HOT lanes. Tolling Context What is the tolling context?  Facility specific tolling context – I-110 or the Harbor Transitway  New toll pricing replaces existing HOV lanes  All-electronic tolling  No formal fee structure had been finalized at time of report  Current payment methods available are Credit/Debit cards, Cash, Check or Money Order Pricing Arrangements The pricing scheme is dynamic to maintain consistent flow of traffic at 45 mph Decision Question/ Decisionmaker What decision, if any, is being made? Conversion of HOV lanes to dynamic pricing HOT lanes At what agency or governmental level are the decisions being made? State Department of Transportation Stage of Decisionmaking What stage of decisionmaking does this document address? Environmental Assessment/Environmental Impact Identification of Affected Populations What populations does this document address? The document identifies populations living within a defined study area and includes demographic information about the residents of the area. Race, income and housing status are also considered. The 2009 Poverty Guideline from the US Department of Health and Human Services defines the poverty threshold. Are there other affected stakeholders that are referenced? No Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? The study area encompasses all of Los Angeles County as there are a large number of potential users. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Census data and the poverty threshold data from U.S. DHHS were used to determine affected    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 44       minority and low-income populations. The study area was defined as all of Los Angeles County. There was very little methodology discussion on this. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? No, there are no maps of the affected populations. County level demographic data was presented only. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? Yes, there was a public outreach process conducted by Caltrans as well as Metro that was described in the document. Information was presented at conferences, community briefings, and public community workshops as well as through participation in Corridor and Technical Advisory Group meetings and public hearings on toll rates. There is mention of select locations to distributed information and feedback, including an AME church and a non-profit housing conference. Fact sheets in both English and Spanish were provided, and participants were invited to submit their input via comment cards, registration forms, and exit surveys. Also, mention of various media outlets in foreign-language and English newspapers. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No, because all of Los Angeles County was determined to be the study area, there was no refinement to target affected populations below the county level. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? There is no comprehensive discussion of how public comments were addressed. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? Outreach included flyers and emails to announce community workshops. Fact sheets with English and Spanish were distributed. However, there was no discussion on how this approach was or could have been tailored specifically to address the disadvantaged communities. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? Comment cards were provided and exit surveys conducted following outreach at two conferences, but not other discussions of focus groups or surveys. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? There was no targeting for these surveys as attendees of the conference participated. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No. Regional Travel- Related Measures What data sources, assumptions and analytical methods were applied to conduct the impact assessment?    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 45 and Impacts Census data and the defined poverty level of 2009 were the primary data sources. No true analytical methods were applied. The document discusses how transponders and tolls could potentially impact low-income users. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) None were used. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? No modeling or methods were presented. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) No. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The findings reported a minimal level of impact because Metro intends to provide a credit to acquire a transponder as noted in the report. What criteria did they apply to support findings? The establishment of the transponder credit was found to offset any potential impact for households that earn at or below $35,000 and live within 5 miles of the toll road. What type of documentation was provided? None Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? Yes, the transponder credit system to allow low-income users the ability to apply their transponder costs to the initial toll payment. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies?

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 46       It is not clear how the determination of the low-income households within 5 miles of the facility was selected as the geographic beneficiary. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? Yes, mitigation in the form of transportation improvements is discussed. Enhancements to transit services including the acquisition of new buses for the I-110 corridor. Status Current status of project : Operation underway Critical Assessment Please generally critique the approach, methods and/or resources presented in this document. Do you see any gaps, room for improvement, or best practices? Overall this document is lacking the assessment of the impacted communities. There is no refinement of data from the county level to determine the location of low-income users. There is limited discussion on the determination that low-income households within 5 miles of the corridor will be eligible for the transponder credit. There is room for more thorough and detailed analysis here. Additional Comments  

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 47     Los Angeles Metropolitan Transportation Authority. 2010. Metro ExpressLanes Project: Draft-Final Low-Income Assessment / LA ExpressLanes Program. Document Title Metro ExpressLanes Project: Draft-Final Low-Income Assessment / LA ExpressLanes Program Website/Source https://www.metroexpresslanes.net/en/about/low_income_draft_final_report.pdf Document Type Technical Study Type of Sponsoring Agency or Organization Los Angeles County Metropolitan Transportation Authority Geographic Distribution Los Angeles County Type of Tolled Facility & Features What type of tolled facility? What change is being made? Conversion of HOV Lanes to HOT Lanes Tolling Context What is the tolling context?  Transition carpool lane to HOT lane on regional network links;  New toll for SOV(all times) on portions of I-10 and I-110 in LA County. New toll for HOV (2 passengers) during peak hours only on I-10.  All-electronic transponder (FasTrak)  Credit Card or Cash (required by authorizing legislation)  Credit/Debit Card can be used to create an account online; Cash/Check accepted by mail with account request application Pricing Arrangements Congestion Pricing; tolls are continually adjusted according to traffic conditions to maintain free-flow conditions Decision Question/ Decisionmaker Implementation of HOT Lanes Decision made by Los Angeles County Metropolitan Transportation Authority - Regional Transportation Planning Agency Stage of Decisionmaking This document presents the results of an analysis of the impact on low-income commuters of the congestion pricing project known as Metro ExpressLanes. The analysis is required by SB 14222, 2008. Identification of Affected Populations This document assesses the impact on low-income commuters and users. Low-income is defined in the authorizing law, SB 1422, as consistent with low income eligibility for other specified state and local programs. Based on an assessment of local low income eligibility, the final report recommends an individual low-income threshold of $35,000. A sensitivity analysis is also included to consider $50,000 as the threshold in this report. Are there other affected stakeholders that are referenced? No Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? Travel survey data from SCAG was used to determine the trip origins to determine the study area What data sources were used to identify affected populations? Four data sources were used to identify affected populations. These include 2000 Census commuting data by income group prepared by SCAG; the State of the Commute travel survey conducted by SCAG in 2005; respondents to the License Plate Survey conducted as part of the Congestion Pricing Operating Plan for Los Angeles County in 2009; and from travel modeling conducted by Parsons Brinckerhoff.    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 48 What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Income thresholds were the primary determinant to identifying impacted communities. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) No. There is no detailed mapping in the report. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? No Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? No What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? None described; no public involvement Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No, no public involvement Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No. Past survey data was used, but no new surveys were conducted Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? Not applicable Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) Not applicable Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? None. The report does not address regional travel-related measures and impacts. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) The analysis only considered travel patterns of the I-10 and I-110 corridors with respect to income levels. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? The analysis considered the current transit ridership along the I-110 and I-10 corridors. However,

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 49 total ridership was reported by Metro and Parsons Brinckerhoff. No ridership data specific to low- income populations was reported. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The analysis reviewed trip data to determine origins and then coupled this information with county income statistics, from the census, to identify the share of trip origins generated by low-income users. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? Yes.  Parsons Brinckerhoff et al., “HOT Credit Lanes Feasibility Study,” prepared for Alameda County Congestion Management Agency, August 2005. o This study was referenced to determine the federal poverty income threshold that should be used in the analysis in the Express Lanes report  Ecola and Light, “Equity and Congestion Pricing: A Review of the Evidence,” 2009, RAND Corporation (sponsored by Environmental Defense Fund). o This research, as referenced in the report, indicates that HOT lanes create fewer concerns over equity than other pricing schemes. It also suggests that low-income members may be better off under a HOT lane system.  Taylor, B. D. and Norton, A.T., “Paying for Transportation: What’s a Fair Price?,” forthcoming publication in Journal of Planning Literature, 2010. o This research is referenced to identify three dimensional frameworks through which equity should be considered with respect to transportation: individual, group and geographic.  Ungemah, D., “This Land Is Your Land, This Land Is My Land: Addressing Equity and Fairness in Tolling and Pricing,” Transportation Research Record: Journal of the Transportation Research Board, No. 2013, Washington, D.C., 2007, pp. 13‐20. o The research here indicates that while some issues with respect to tolling and pricing have subsided, equity and fairness continue to be recurring issues. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) None. The report states that those issues are to be addressed by the project environmental document being prepared by Caltrans. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The analysis finds that low-income drivers who travel alone would be unlikely to use the toll lanes on a regular basis and would instead use it only in urgent situations. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? Yes, a credit program to waive the initial transponder fee for low-income users. What methods were followed, if any, to assess who pays for and who receives benefits from these

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 50 mitigation strategies? Limited discussion on this. Low-income users (of which there are two groups identified as potentially “low-income”) would be the beneficiary. No discussion of revenue strategies to fund these credits. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No. Status Current status of project: Construction Critical Assessment Please generally critique the approach, methods and/or resources presented in this document. Do you see any gaps, room for improvement, or best practices? This analysis is very narrowly focused solely on determining the low-income population and the potential aggregate financial costs and benefits of the project. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 51     TEXAS Texas DOT. June 2014. SH 45SW Environmental Study, Appendix F: CAMPO Regional Toll Analysis (2013) and Central Texas Regional Mobility Authority Toll Policy. Document Title SH 45SW Environmental Study, Appendix F: CAMPO Regional Toll Analysis (2013) and Central Texas Regional Mobility Authority Toll Policy (2014) (Central Texas Regional Mobility Authority & Texas DOT, 2014) Website/Source http://www.sh45sw.com/environmental/2014%2006%2020_SH45SW%20DEIS-AppendixF.pdf Document Type What kind of a document is this? The overall document is an EIS. Appendix F includes two separate documents: 1. CAMPO Regional Toll Analysis – includes an analysis involving the effect of toll roads and managed roadways on EJ populations throughout the CAMPO (Austin Metro) Area. 2. The Central Regional Mobility Authority Policy Code – A short document (7 pgs) that establishes procedures for operations and pricing on specific toll roads in Texas. It does not deal directly with EJ issues. The second document is a supplement to the first as the Central Regional Mobility Authority operates two toll expressways in the Austin Metro, and therefore the majority of the report will be referring to the CAMPO Regional Toll Analysis. Type of Sponsoring Agency or Organization Who is the project sponsor or other entity stakeholder that prepared the report? Central Texas Regional Mobility Authority, Texas DOT, and Capital Area Metropolitan Planning Organization. Geographic Distribution What geographic area does this document address? The Austin Metro Region ~2 million large urban/suburban. Type of Tolled Facility & Features What type of tolled facility? What change is being made? A network of existing and planned tolled facilities. Some operated by Texas DOT and some operated by CTRMA. Planned facilities will have managed lanes, although they are not described in detail. The change includes the addition of highway projects and managed lanes. Tolling Context What is the tolling context?  Regional Network  New tolls  Transponder cards and pay by mail  Check and credit card at the time of report and now. Pricing Arrangements What type of pricing scheme (e.g., dynamic, time of day, single price)? On the existing TXDOT and CTRMA facilities pricing is dynamic and varies by road, vehicle type, and time of day. The pricing scheme for the planned managed lanes is not described in detail. Decision Question/ Decisionmaker What decision, if any, is being made? An analysis of new infrastructure and managed lanes At what agency or governmental level are the decisions being made? State and MPO Stage of Decisionmaking What stage of decisionmaking does this document address? Statewide and metropolitan planning. Identification of What populations does this document address?

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 52     Affected Populations Low income and minority populations. Are there other affected stakeholders that are referenced? (e.g., bus rider, women, neighborhood residents, transit agency, social services agency, etc.) No. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? The geographic boundary is the CAMPO boundary. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)?  2005 median family income levels provided by CAPCOG, based on the 2005 Bureau of Economic Analysis Data to calculate low-income thresholds;  2008 and 2009 poverty data from the Census Bureau to analyze poverty; and,  2005 ethnicity data, based on 2000 census data ethnicity ratios applied to 2005 population data.  Data for a family of three is used because CAMPO travel demand model indicates that the average household size in the CAMPO region is 2.75 people in 2010 and 2.73 people in 2035. Rounding up to avoid partial people results in an average household size of 3. 1. Have at least 50% of the population living in families earning less than 80% of the county median family income: and/or 2. Have at least 25% of the population with income falling below the 2009 federal poverty level for a family of three ($17,098 for a family of 3). 3. Have at least 25% of the population with income falling below the 2009 federal poverty level for a family of three ($17,098 for a family of 3). Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes. TAZ. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? While the policies for the 2035 involve guideline for public involvement, the document itself is purely an analysis of scenarios and does not address public involvement in the making of the plan. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? N/A Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? N/A What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations? N/A Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? N/A Attitudinal Were surveys, focus groups or interviews conducted?

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 53     Surveys, Focus Groups, and Interviews No Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? N/A Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) N/A Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? EJ TAZs were built on the data and categories described under “Threshold Criteria & Geographic Mapping.” A travel demand model was used to analyze travel times. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) The metric of lane miles was used to determine the amount of tolled facilities within EJ TAZs. After determining the amount of tolled facilities inside and outside of EJ areas on the existing network, they then looked at the amount of planned facilities, tolled and un-tolled, that fall within, versus outside, of EJ areas. Travel times are also used as a metric to quantify the accessibility of EJ and non EJ zones in terms of square miles that can be reached in 5 minute intervals using the regional network. They want to see if the distance one is able to travel is the same when the origin is within an EJ zone as when it is located outside of an EJ area. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? The analysis considered access to transit, as well as residential or work locations, and summarized the findings as follows: the locations of many of the planned transit improvements are based on existing EJ TAZs, and the transit vehicles are exempt from toll roads. This is seen as a mitigating factor against the overall impact of toll roads on EJ communities. Additionally, the future land use preferred condition was used in the modeling. This assumes the implementation of a “centers” concept has been implemented which aligns much of the development with transit lines and includes more walkable connections between residences and work locations. Several activity centers are planned in EJ areas. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? Relies upon proxy argument. Mainly, that the analysis shows that the travel times for both EJ and non-EJ areas are similar. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No specific analysis was done to look at the effects of diverted trips. However, projected travel times    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 54 are statistically similar for both EJ and non-EJ areas, and congestion increases are equally sustained by both areas. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No case studies were referenced. This analysis was actually used as an Appendix to an Environmental Study for a roadway project and is used to support the proposed project. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) A brief mention that the area is currently in attainment and that emissions are expected to be lower in 2035 than 2010. As well as land use strategies within the plan that emphasize increased development around centers, and the fact that many of the activity centers are planned in EJ areas. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The finding is that the implementation of the 2035 Plan will benefit the EJ population. What criteria did they apply to support findings? Expanded travel options including an improved transit service, emphasis on mixed use, transit friendly growth in activity centers, many located in EJ areas. What type of documentation was provided? The Travel Time Analysis indicates that existing and 2035 travel times for EJ and non-EJ areas are similar. One TAZ in Bastrop County showed a probable 2035 travel time disadvantage that met the disproportionate threshold. However, since there were no toll roads or managed lanes in this county it was reasonable to conclude that toll roads or managed lanes did not contribute to the disadvantage. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? The buses are exempt from tolls. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? N/A Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No Status Current status of project: Planning Critical Assessment The report did not include explanation as to how the tolling might influence trip network movements. This could have provided a greater level of detail concerning EJ implications. The comparison of travel times between trips (of the same origin and destination) that utilized toll roads and trips that did not utilize toll roads could have been used to show disproportionate impacts between those that are able to pay and those that are not. Overall, the adequacy of the assessment is difficult to determine considering it was part of a larger transportation plan that may have addressed other issues of EJ. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 55     Texas DOT. April 2013. Appendix E: Project Level Toll Analysis and Effects on Environmental Justice Populations, Technical Report [San Antonio, US 281]. Document Title Appendix E: Project Level Toll Analysis and Effects on Environmental Justice Populations, Technical Report. [US 281] (FHWA, TxDOT, Alamo Regional Mobility Authority, April 2013) Website/Source http://www.411on281.com/us281eis/assets/File/19%20-%20Appendix%20E%20- %20Environmental%20Justice%20Analysis%20-%20Technical%20Report.pdf Document Type Technical Report - Appendix to the US 281 Environment Impact Statement (EIS), which evaluates the impacts of improvements to the US 281 corridor between Loop 1604 and the Bexar County Line near Borgfeld Drive. Type of Sponsoring Agency or Organization FHWA TxDOT Alamo Regional Mobility Authority Geographic Distribution What geographic area does this document address? San Antonio Metro Region ~2 Million urban/suburban Type of Tolled Facility & Features What type of tolled facility? What change is being made? The change includes improvements to US 281 between Loop 1604 and the Bexar County Lane, and three alternatives: managed lanes (Toll and HOV), fully tolled facility, or a non-tolled facility. Tolling Context What is the tolling context?  Facility Specific  New toll  Electronic Transponders  Methods of payment are not described in detail. Pricing Arrangements What type of pricing scheme (e.g., dynamic, time of day, single price)? Not specified Decision Question/ Decisionmaker What decision, if any, is being made? New infrastructure and updated expressway as well as the potential implementation of HOT lane or fully tolled facility. At what agency or governmental level are the decisions being made? MPO/State DOT/Federal Stage of Decisionmaking What stage of decisionmaking does this document address? Project Development and NEPA Identification of Affected Populations What populations does this document address? Low income and minority populations. Are there other affected stakeholders that are referenced? No. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? The criteria for setting the geographic boundaries are not specifically mentioned although it appears to relate to the available regional model (SA-BC MPO Regional Travel Demand Model), as this was utilized in calculating impacts. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Areas (TAZs) with greater than or equal to 50% EJ populations. The source of the EJ populations is

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 56       not identified. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes. TAZ. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? While the toll policy (outlined in the “Amended and Restated Policies and Procedures for Toll Collection Operations on the Alamo RMA Turnpike System”) describes public outreach to minority and disabled communities in order to allow full access to the toll facility, the specifics of public involvement in the planning process is not discussed. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? N/A Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? N/A What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? N/A Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? N/A Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? N/A Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? N/A Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) N/A Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? The SA-BC MPO Regional Travel Demand Model was used to conduct the analysis. The model used input parameters including speed and travel time based on observed congested – peak hour – conditions. The model then assigned trips to roadways under these peak conditions, and reported forecasted peak hour speeds and volume-to-capacity (v/c) ratios, and daily traffic volumes. To calculate the impact of toll roads a cost was added in terms of travel time by converting an assumed toll rate per mile of travel with value-of-time assumptions. This was applied to links coded as toll links.    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 57       The model was then used to determine “candidate” trips for the corridor based on fastest route and determined by isolating the corridor and identifying trip origin and destination pairs (TAZs) that use any segment along the corridor. The No Build and Tolled Expressway alternatives were analyzed with three (per mile) toll pricing scenarios ($0.17, $0.32, $0.50). What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) Travel times Did the analysis consider access to transit, access to private vehicle, and residential or work locations? Residential, work locations, and services were used in creating origin and destination TAZs for the model. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The study used modeling and methods to compare travel behavior and EJ populations by analyzing the time savings for trips from EJ and non-EJ TAZs in each scenario (i.e., a proxy argument). Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? Yes, as part of the project a series of adjacent access roads will be built along the length of the toll that provides an alternative for travel and avoids the toll. In the non-toll scenario the savings were 14 minutes for all candidate trips and 16 minutes for EJ travelers compared to the No Build scenario. In the first toll scenario the savings were 14 minutes across the board compared to the No Build scenario. This was due to the $0.17 per mile cost that affected the initial travel time advantage of the EJ population. Travelers unwilling to the pay the toll still saw time benefits of 8 to 9 minutes due to the access roads. The time savings increased on the toll roads and decreased on the non-tolled, access roads as the price of the toll increased. This was due to fewer trips utilizing the toll road, providing less congestion, and more trips utilizing the access roads, which caused more congestion. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) No Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The findings were that both EJ and non-EJ would benefit from any of the Build scenarios. What criteria did they apply to support findings? The travel time savings increased under all build scenarios. Although the EJ population would be spending a greater portion of their income on the tolls as shown in the cost analysis, their travel time savings would still improve along the non-tolled portion of the toll way.    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 58 What type of documentation was provided? Travel times for the EJ and non-EJ trips in each scenario, as well as daily out of pocket costs, based on the scenarios, and as a percentage of median household income. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? There is a brief mention of a possible EJ exemption of the toll under the Alamo Regional Mobility Authority tolling policy, although this is not expanded upon further within the document. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? In terms of whom pays there were none. In terms of who benefits, it was determined that all users would benefit from the project whether or not they were utilizing the tolled sections. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? The majority of the future planned toll facilities for the San Antonio Metro are situated away from EJ zones. Status Current status of project: Funding was authorized in early 2014. Still in project planning phase. Critical Assessment The analysis is thorough, succinct, well-organized, and clearly presented. The amount of detail given as to the model used and the variables used in deriving the output provides a clear understanding of the methodology used. The comparison of alternatives, within the context of the modeling, also provides a deeper level of EJ analysis than many EISs. The access roads provide improved travel times without the necessity of a toll, which avoids EJ impacts. An additional level of analysis could have included the utilization of “On the Map” to qualify the assumed origins and destination for specific TAZs. This might have provided a more accurate model, and therefore a more accurate interpretation of EJ impacts. Additionally, the fact that the sources used to determine EJ populations were not provided was an unfortunate oversight. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 59     North Central Texas Council. June 2013. Regional Tolling Analysis for the Dallas-Ft. Worth Metropolitan Planning Area Based on Mobility 2035 - Plan Update; Appendix B: Social Considerations. Document Title Regional Tolling Analysis for the Dallas-Ft. Worth Metropolitan Planning Area Based on Mobility 2035 - Plan Update; Appendix B: Social Considerations (North Central Texas Council of Governments, January 2014) Website/Source http://www.nctcog.org/trans/mtp/2035/AppendixB.pdf Document Type Technical report/study: Accompanies a regional plan update Type of Sponsoring Agency or Organization Who is the project sponsor or other entity stakeholder that prepared the report? MPO - North Central Texas Council of Governments Geographic Distribution What geographic area does this document address? Dallas/Ft. Worth Region ~9 million large urban/suburban Type of Tolled Facility & Features What type of tolled facility? What change is being made? This report is a general analysis of basic EJ demographics in the region and does not include tolling projects. There is, however, a public comment/response section towards the end of the report in which the public address concerns over tolling projects and the agency responds. Tolling Context What is the tolling context? N/A Pricing Arrangements What type of pricing scheme (e.g., dynamic, time of day, single price)? N/A Decision Question/ Decisionmaker What decision, if any, is being made? This report accompanies a plan update that includes several regional roadway and transit projects. At what agency or governmental level are the decisions being made? MPO Stage of Decisionmaking What stage of decisionmaking does this document address? Metropolitan Planning Identification of Affected Populations What populations does this document address? Low-income, minority, disabled, limited English proficient, limited mobility Are there other affected stakeholders that are referenced? No. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? The study area is the same as the MPO area. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? 2000 Census information (low-income, race, ethnicity) 2000 Census information was used due to the fact that income information was not available from the 2010 Census at the time that the report was created. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes, block groups.    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 60     Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? The report includes a review of public participation requirements and a public comment and response section. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? No. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? According to the report the public meetings were held in diverse locations throughout the region, accessible to individuals with disabilities, preferably near transit lines or routes, at both day and evening times. Public meeting materials and summaries are archived online and hard copies can be mailed upon request. A series of public comments are included and responded to in the report, however it is not clear how or if these influenced alternatives, assessments, or mitigation. Does the report assess its effectiveness reaching low-income, minority, or other traditionally disadvantaged populations? No. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? N/A Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? The analysis included a review of key system performance measures, such as number of jobs accessible within 30 minutes by automobile or 60 minutes by transit and the overall roadway level of service. These performance measures were compared between areas determined to have significant populations of protected class populations versus unprotected class populations. They compared these metrics in both a Build and No Build scenario. The analysis consisted of determining the protected and unprotected status. This metric was based on whether or not a protected population (minority and low-income) was below or above the regional average. Areas that were above the regional average were referred to as protected and areas that fell below were unprotected. These populations were then applied to TSZs (categorically identical to TAZs) based on block groups. The TSZs were used to analyze auto and transit accessibility, congestion levels, travel time, and travel distance.    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 61       What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) For auto: AM shortest path time plus the time spent at trip end points going to and from the vehicle. For transit: Minimum of the sum of the Initial Wait Time, Transfer Wait Time, Transfer Time, Access Time, Egress Time, Drive Time, and Dwell Time from the Bus, Rail, and Bus-Rail matrices for Peak Park-and-Ride and No Park-and-Ride. Additionally, the metrics of congestion level, travel time, and travel distance were used for the network as a whole. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? Yes, explained directly above. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The analysis compared direct linkages. Discussed above in analytical methods and performance measures. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) No. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The metrics were relatively similar for both protected and unprotected populations. What criteria did they apply to support findings? They compared the regional average by block group and the total population for each EJ population group, based on 2000 Census data. This was done for each performance measure. What type of documentation was provided? The results were included in tables within the report. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? Not discussed. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies?    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 62       None. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No. Status Current status of project: Planning. Critical Assessment The analysis never looked at the direct impact of tolled roads, but instead looked at general accessibility and performance measures encountered by users based on whether they were originating from protected areas. The impact of toll roads would have supplied a greater level of possible impacts on people who are able to pay versus those who are not. Additionally, the report looks at public input, but does not directly explain the ways, if any, that public comment/input affected the outcomes of the study or plan. The accessibility analysis offers a simple and relatively cost-effective method of looking at network impacts on EJ populations. Additional Comments  

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 63 North Central Texas Council. January 2014. Regional Tolling Analysis for the Dallas-Ft. Worth Metropolitan Planning Area Based on Mobility 2035 – Plan Update. Document Title Regional Tolling Analysis for the Dallas-Ft. Worth Metropolitan Planning Area Based on Mobility 2035 – Plan Update (North Central Texas Council of Governments, January 2014) Website/Source http://www.nctcog.org/trans/mtp/2035/documents/RTAJan2014.pdf Document Type Technical Report Type of Sponsoring Agency or Organization Who is the project sponsor or other entity stakeholder that prepared the report? MPO Geographic Distribution What geographic area does this document address? Dallas/Ft. Worth Region ~9 million large urban/suburban Type of Tolled Facility & Features What type of tolled facility? What change is being made? The analysis involves a regional network of planned tolled/managed roadways. The projects include new tolled lanes, new tolled roadways, HOV conversions to HOT lanes, and a mix of dynamic, peak- period, and fixed tolls. Tolling Context What is the tolling context? Regional Network  New tolls, on both new and existing roadways, and conversions of HOV to HOT lanes.  Transponders/tags (TxTag, TollTag, and EZ TAG) and video based tolling system (ZipCash), that captures the license plate and mails a bill. Additionally, a toll road ran by the airport operates traditional toll booths.  Credit card, debit card, cash, or check/money order for the transponders. Types of payment allowed for ZipCash are not listed. Pricing Arrangements What type of pricing scheme (e.g., dynamic, time of day, single price)? There is a combination of dynamic, fixed, and peak-period toll roads in the transportation plan. Decision Question/ Decisionmaker What decision, if any, is being made? A series of new road projects, including new capacity, new infrastructure, and new tolls on both existing and planned roadways, in a long-term transportation plan overseen by the MPO. At what agency or governmental level are the decisions being made? MPO Stage of Decisionmaking What stage of decisionmaking does this document address? Metropolitan Planning Identification of Affected Populations What populations does this document address? Low income and minority Are there other affected stakeholders that are referenced? Yes. Transit agencies and transit users. Transit agencies are discussed in terms of funding methods, and transit users are discussed in terms of travel impacts occurring due to the planned roadway project. Threshold Criteria & Geographic What were the criteria used for setting the geographic boundaries for the study area? The boundary of the MPO is used in the analysis.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 64     Mapping What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Based on 2000 census data, three variables, including percent below poverty, percent minority, and person per square mile, were used to classify block groups into protected and non-protected categories. Additionally, TSZs (Transportation Survey Zones) (categorically identical to TAZs) for the Dallas Metro were divided into four categories: Non- EJ, minority alone, low-income alone and both minority and low-income TSZs. The minority TSZs were identified based on 2010 census data, where the minority population exceeded 50%. The low-income TSZs were based on 2005-2009 ACS data and were identified where 50% or more of the TSZ resided in a block group where the median household income was below the 2009 poverty level of $22,050 established by HHS for a family of four. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) In the appendix. TSZs (categorically identical to TAZs). Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No public involvement was conducted for the EJ analysis. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? N/A What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? N/A Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? N/A Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? N/A Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? 2010 census data and 2005-2009 ACS data were used to identify four categories of TSZs: low- income alone, minority alone, low-income and minority, and non-EJ zones. The analysis was extensive and looked at several performance measures to determine levels of accessibility. The first part of the analysis looked at Accessibility and Mobility Performance Measures. This analysis compared protected and non-protected populations and looked at the differences between the    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 65       2035 Build Network (2035 recommended roadway and transit facilities with 2035 population) and the 2035 Full No Build Network (2013 roadway and transit facilities with 2035 population). The analysis looked at # of jobs accessible within 30 minutes by automobile; # of jobs accessible within 60 minutes by transit; and percent of lane miles congested. Performance measures were used to compared between EJ (a summed total of the low-income, minority, and low-income and minority TSZs) and non-EJ zones. A regional origin–destination study showed the number of daily trips originating from EJ TSZs that encountered priced facilities in the 2013 network, 2035 No Build, and 2035 Build network. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?)  Jobs accessible within 30 minutes by car  Jobs accessible within 60 minutes by transit  Congested lane-miles  Daily VMT  Average Loaded Speed  Travel time  Morning peak period  Average trip time  Average trip length  Average travel speed  Total transit trips  Congestion levels Did the analysis consider access to transit, access to private vehicle, and residential or work locations? Yes. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The analysis contained modeling methods that examined the relationship between the travel behavior of higher concentrated EJ population zone and the usage of toll/non-tolled facilities (i.e., proxy argument). The analysis did not apply costs to the toll roads to look at changes in congestion between tolled and non-tolled roads based on price, they did look at specific trips that included tolled roads and originated in EJ areas. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g.,. low-income and minority populations)? No. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No.    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 66     Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) Yes. Land Use – Discusses Vision North Texas and the guiding principles of center development, return on investment, diversity, distinct communities, and green region. Acknowledges that changes in growth patterns can bring about changes in the financial, social, and environmental sustainability of transportation systems. The proposed 2035 network was developed in response to predicted land use changes. Air Quality - A brief discussion of how the planned network would mean better air quality. No connections made to EJ. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? It was determined that the recommended transportation projects included in Mobility 2035-2013 Update do not have a highly adverse impact on protected populations. What criteria did they apply to support findings? For protected (EJ) areas, due to the 2035 network  # of jobs accessible within 30 minutes by car would increase by 26%,  # of jobs accessible within 60 minutes by transit would increase by 76%. Similarly for non-protected areas  # of jobs accessible within 30 minutes by car would increase by 1% and  # of jobs accessible within 60 minutes by transit would increase by 113%. Also, average trip times increase for both EJ and non-EJ populations.  24.2% for non-EJ zones  11.6% for EJ zones Finally, a higher level of trips originating from non-EJ zones encounter tolled roads than trips originating from EJ zones. 2013 trips encountering tolled roads are:  64.8% for non-EJ zones  35.2% for EJ zones 2035 trips encountering tolled roads are:  67% for non-EJ zones  33% for EJ zones What type of documentation was provided? Tables that show the outcome of all performance measures are supplied in the report. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? Yes. Recommendations are made to be used as mitigation if future analysis determines it is necessary. They include:  Improve availability and accessibility to alternate transportation options such as transit  Provide discounted transit fares and tolls  Offer HOV discounts on existing or future priced facilities  Provide better accessibility to regional transportation systems    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 67        Enhance community-level congestion mgmt.  Promote sustainable development to help minimize VMT What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? The report looked at funding methods in terms of gas tax, sales tax, and federal funds for and how they are allocated for different transportation projects, but the discussion of who pays and who benefits did not extend beyond that descriptive section. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? Land use changes (i.e., mixed use, centers, transit-oriented development, increases in density) that make transportation systems more equitably sustainable via improvements in accessibility of all users (i.e., transit riders, active transportation) are briefly discussed. Status Current status of project: Regional Planning Critical Assessment The performance measures were extensive and the analysis was extremely comprehensive. There was no mention of community engagement throughout the entire document. Additional Comments The methodology used in the study was based on NCHRP Report 532: Effective Methods for Environmental Justice Assessment.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 68 Alamo Area MPO. December 2011. Draft Report, Appendix F: San Antonio – Bexar County MPO Regional Toll Analysis. Document Title San Antonio-Bexar County MPO, Regional Toll and Managed Lane Analysis (2011): Draft Report, Appendix F: San Antonio – Bexar County MPO (now referred to as the Alamo Area MPO) Regional Toll Analysis Website/Source http://www.411on281.com/us281eis/assets/File/20%20-%20Appendix%20F%20-%20SA- BC%20MPO%20Regional%20Toll%20Analysis.pdf Document Type What kind of a document is this? Technical Report Type of Sponsoring Agency or Organization Who is the project sponsor or other entity stakeholder that prepared the report? MPO Geographic Distribution What geographic area does this document address? Regional; San Antonio Metro Region ~2 Million urban/suburban Type of Tolled Facility & Features What type of tolled facility? What change is being made? The report is not project specific. It is intended to be a guiding document for planned tolled facilities included in the FY 2011-2014 Transportation Improvement Program and Metropolitan Transportation Plan. Tolling Context What is the tolling context? A series of potential managed lane and tolling, improved capacity projects. Pricing Arrangements What type of pricing scheme (e.g., dynamic, time of day, single price)? There is a baseline toll policy that excludes first responders and public transportation and charges additional vehicles based on number of axles. Decision Question/ Decisionmaker What decision, if any, is being made? Provides guidance on assessing, evaluating, and mitigating EJ impacts for future managed roadway projects. At what agency or governmental level are the decisions being made? MPO Stage of Decisionmaking What stage of decisionmaking does this document address? Statewide and Metropolitan Planning; Policy Development Identification of Affected Populations What populations does this document address? Low income, minority, persons with disabilities, limited English proficient populations Are there other affected stakeholders that are referenced? No. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? All proposed projects fall within the San Antonio-Bexar County MPO (Alamo Area MPO). What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? 2000 Census, U.S. Census Bureau. TAZs were selected based on the Census 2000 block groups of 50% or greater minority and low-income population within a zone. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes, EJ and non-EJ TAZs identified from block group data. Description of Does the document specifically describe efforts to conduct public involvement? Does the document

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 69     Public Involvement Activities describe efforts to provide information about toll implementation or rate changes? The MPO states that one of the core principals of EJ analysis if the significant involvement of potentially impacted minority and low-income populations in the decisionmaking process. While the MPO states that it recognizes the need for and the clear benefits of EJ community participation there are no detailed requirements or policies as to how this should be accomplished in the planning of projects. It does state that a variety of communities were involved in the long range planning process, but does not state how EJ populations were identified or reached out to for this process. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? No. What approaches, tools or techniques were described to encourage the attendance or engage low-income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? None. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? No. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No. Regional Travel-Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? 2000 Census Block Groups with populations equal to or greater than 50% low-income or minority. These were allocated to EJ and non-EJ TAZs. Additionally nine TAZs were added that did not fall into the original EJ category. They were determined to be low-income areas based on the 2009 U.S. Health and Human Services Poverty Guidelines. The analysis looked at potential impacts that tolled/managed lane facilities may have on accessibility of all persons by analyzing impacts on travel time choices of people residing in EJ zones and non-EJ zones. As mitigation, all existing roadways that have tolls added will have adjacent non-tolled lanes or access roads that will provide public non-tolled access. The question then becomes whether the introduction of the tolled/managed lane facilities has a significant or disproportionate adverse effect on EJ populations. TransCAD was used to conduct a selected link analysis for all trips, tolled and un-tolled. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) Travel Times between tolled and un-tolled roadways was the main performance measure.    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 70       Did the analysis consider access to transit, access to private vehicle, and residential or work locations? Yes. The report briefly mentions improvements such as VIA’s modern streetcar system that is proposed to serve the urban core and improve mobility. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The analysis linked the EJ and non-EJ zones to the roadway links/possible future tolled and un-tolled road areas to see if the travel time increased at the same rate for both categories. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? Yes, the analysis looked at trip links on both tolled and un-tolled facilities, and attempted to determine whether there was a difference in travel times for EJ and non-EJ TAZs. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.? No. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? There appeared to be no adverse impacts of the toll/managed lane future roadway system on EJ populations, as the time savings were comparable for trips form both categories of TAZs. What criteria did they apply to support findings? This was determined due to fact that there was similar average time savings for trips from EJ and non-EJ zones on both tolled and un-tolled roadways. What type of documentation was provided? The report included tables that showed the model results for # of trips with time savings and the # of trips without time savings for both EJ and non-EJ zones. They then found the average trip length for the # of trips with time savings and the # of trips without time savings and looked at how the trip length changed between trips for both EJ and non-EJ zones. There were two tables. One looked at work trips from home, and the other looked at non-work trips from home. A table from the report is included for clarity purposes (Table 8).

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Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 72 FLORIDA Florida DOT. July 2013. St. Johns River Crossing Project Development and Environmental Study: Environmental Discipline Report. Document Title St. Johns River Crossing, Environmental Justice Discipline Report Website/Source http://www.firstcoastexpressway.com/SJRBridge/documents-and-publications.shtml Document Type Environmental Justice Discipline Report Type of Sponsoring Agency or Organization Florida Department of Transportation Geographic Distribution An area identified as the Region of Comparison (ROC) is the geographic area which includes portions of Clay, St. Johns, Putnam and Duval Counties all in Florida. Type of Tolled Facility & Features The toll facility is a new limited access highway corridor from Branan Field- Chafee Road to the 9B interchange with I-95 and includes a new bridge over the St. Johns River. The toll would be a flat rate. Tolling Context The toll road would operate as a fully electronic toll facility. All vehicles using the facility would be required to have transponders that would be read by toll gantries placed along the corridor to determine where a vehicle entered and exited. Each transponder would be registered to a specific user and deducted from an account set up for each user. Pricing Arrangements Single Price (.15 cent to .20 cents per mile). Decision not made on the exact price. Decision Question/ Decisionmaker FDOT is trying to make a decision on a preferred alternative. Stage of Decisionmaking Project Development and Environmental Study (PD&E) stage Identification of Affected Populations The population groups addressed in the study include racial, ethnic and low-income populations. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? For the demographic analysis, a 1,500 foot buffer was applied around each alternative alignment under consideration. Census blocks and tracts included wholly within or intersecting the buffer for each alternative were examined. The 1,500 foot buffer was selected because most environmental effects resulting from the project are less than 1,500 feet. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? The primary source for information on racial, ethnic, and low-income information is the 2010 Census and American Community Survey (ACS) data. The Summary File 1 was used for race and ethnicity. The Census Bureau’s ACS was used to estimate vehicle ownership rates, mode of transportation to work, economic conditions including labor force, occupations, major employers, household income and the ability of the population to speak English. Block level data was used for race, ethnicity and age. Income data was available at the census tract level. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ)

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 73       The criteria used to identify census blocks or tracts with high concentrations of minority and /or low- income populations was developed based on the guidelines established by the Council on Environmental Quality (CEQ) report, Environmental Justice Guidance under the National Environmental Policy Act. Census blocks were identified (and mapped) as those areas where the minority population s was greater than 50%, and/or where a block had a meaningfully greater percentage of minority individuals. For the purposes of this study meaningfully greater was determined to be twice the percentage of the ROC average of the total minority population. In 2010 the minority population within the ROC was 21% so the meaningfully greater percent set at 42%. The same procedure was used for low-income populations. The ROC average during the ACS 2005-2009 was estimated at 7% so the meaningfully greater percent was set at 14%. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? The report notes that since 2001 FDOT has held numerous meetings to discuss the project concept. Beginning in 2004 a robust outreach effort was undertaken including at least 20 different meetings with the public. The last meeting noted was in 2006 but the report states “public involvement will continue to conduct outreach to all potentially affected groups throughout the life of the project.” “These activities may include public displays, direct mailings, advertisements in local newspapers and other activities determined appropriate. “ Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? The report suggests that the demographic data informed efforts to engage minority and low-income populations and that “county planners and officials further delineated boundaries of potential EJ communities and identified potential concerns of these populations”. No further specific detail on engaging these affected populations are provided. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? At one meeting 259 persons attended. A project brochure was provided including a survey and comment card. A total of 108 survey and comment cards were submitted along with 33 oral comments. The report states “none of the 141 comments received at this meeting addressed tolling or the effects of the proposed project on EJ populations”. At another similar meeting held later in the process 317 people attended with 183 completing surveys and comment cards. Again no comments were received related to EJ populations. Two meetings were held in 2006 and a total of 10 comments were received on tolling but none on EJ population concerns. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? None specifically mentioned. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? See above response. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? No    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 74 Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? Only direct impacts were accounted for as part of the environmental review. Then areas identified as minority and low-income populations with meaningfully greater populations than the ROC where considered to determine if disproportionate impacts were being suffered by the affected populations. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) Only travel distance was considered as part of the evaluation for overview of effects and benefits. For each alternative the alternate route was calculated to avoid the tolls and compared to the tolled travel distance. The purple and black alternatives provided an alternate route that was comparable in length to the tolled route. The alternative non-tolled route to the brown, green orange and pink alternatives was considered unreasonable because it is 36.7 miles longer than the tolled route. The report states that these alternatives “would disproportionately low-income and minority populations in the project area.” Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? No Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? Ten alternatives are examined for impacts as part of the study. A comparison of length of travel distance is made for all the alternatives comparing the alternate routes to the toll route. The rate for the toll route is provided in each case but not a comparison cost for the alternate route. The bridge toll would be about $2.3 per trip and avoid a 36.7 mile longer alternate route. The report claims that the benefits associated with the bridge include increased system capacity, decreased system deficiency, reduced congestion, improved speeds, travel time savings and a reduction in the personal time lost and cost of excess fuel consumed when compared to the no build alternative. No specific data is provided to substantiate these claims. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? N/A What was the level of detail or argument provided as rationale? No Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.)

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 75       The report examines other impacts including noise, utility relocations, visual changes, temporary construction impacts, and relocations of residences and businesses. Each of the 10 alternatives is reviewed. There are some impacts that vary by alternative such as relocation which represent issues that are considered “disproportionate”. For example, the orange and green alternatives as well as the pink and brown alternatives claim “these business relocations are disproportionate because of the high percentage of relocations occurring in EJ areas. However, the FDOT has determined that the project corridor contains abundant replacement resources which are currently available in the Green Cove Springs area and elsewhere for relocating these businesses. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? Each alternative was examined for effects of tolling both low-income population and minority populations. The following information is presented as a summary of the impacts and findings.  Purple alternative: residents would be affected by noise, utility relocations, temporary construction and permanent visual changes. However, the report states “these impacts would generally occur in a uniform distribution along the entire length of any alternative; there, none of these effects is expected to present a disproportionately high impact to minority or low-income populations.” Because there are “viable non-tolled route alternatives” the report finds that “no disproportionately high and adverse impacts to low-income populations from tolling are anticipated.”  Black alternative: same as the purple alternative.  Orange and Green Alternatives: same explanation provided for noise, utility relocations, temporary construction and permanent visual changes as black and purple. However, business relocations for these alternatives were considered “disproportionately high and adverse impact on EJ communities” because all four of these alternatives required relocation of 10 businesses. These businesses provided essential services to the nearby communities. There are also 38 residential relocations associated with these alternatives; however, the report states “abundant replacement resources are available to mitigate” these adverse impacts. FDOT’s decision to eliminate the bridge toll for the southern alternatives between the US 17 interchange and the CR 16A interchange will “preclude any disproportionately high, adverse impacts to low-income drivers.”  Pink and Brown Alternatives: same explanation provided for noise, utility relocations, temporary construction and permanent visual changes as black and purple. The primary impact of concern for these alternatives is related to business and residential relocations. The report outlines that 42 to 45% of the project area for these alternatives are in the EJ areas of concern but 60% to 100% of business relocations are within EJ areas; therefore, it is considered “disproportionately high for EJ communities.” However, report finds that these impacts can be mitigated because there is “abundance of replacement resources.” These routes also provide a viable non-tolled route which “precludes any disproportionately high and adverse impacts. What criteria did they apply to support findings? See above. What type of documentation was provided? Environmental Justice Discipline Report Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No What methods were followed, if any, to assess who pays for and who receives benefits from these

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 76 mitigation strategies? No Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No Status Project Development & Environmental Study completed; preliminary design and right of way acquisition, but construction not funded. Critical Assessment Please generally critique the approach, methods and/or resources presented in this document. Do you see any gaps, room for improvement, or best practices? The analysis relies heavily on comparing demographic data for affected block groups to the ROC. The travel behavior analysis is limited to travel distance. The assessment appears elementary at best from a travel behavior standpoint. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 77 GEORGIA Georgia DOT. March 2013. Technical Memorandum: Evaluation of Tolling Effects on Low- Income Populations: I-75 Express Lanes Project, I-75 Express Lanes, Atlanta Metropolitan Region, GA. Document Title Technical Memorandum: Evaluation of Tolling Effects on Low-Income Populations: 1-75 Express Lanes Project Website/Source http://www.dot.ga.gov/travelingingeorgia/expresslanes/I75expresslanes/Documents/Appendix%20E. pdf Document Type Technical Study / Memorandum of an Environmental Analysis (EA) Type of Sponsoring Agency or Organization Georgia Department of Transportation (State DOT) Geographic Distribution What geographic area does this document address?  Atlanta suburbs Type of Tolled Facility & Features What type of tolled facility? What change is being made? Variable Pricing of New Express Lanes or HOT lanes. (While the toll policy was undetermined at the time of the report, both HOV3+ and ETL toll policies were used in the travel demand model analysis. The report acknowledged that the preferred toll policy for the I-75 Express Lanes was ETL, and because results between ETL and HOV3+ analysis were similar the report included only the analysis of ETL modeling in the main report (HOV3+ results were in an appendix)) Tolling Context What is the tolling context?  Toll lanes parallel a highway; the toll lanes are the second toll lanes in the Atlanta metropolitan area  New toll facility  Tolling technology / equipment: not described, likely all-electronic with transponders  Methods of payment? Online or credit card, but cash based and cash-preferred methods available Pricing Arrangements Variable – Pricing details were still to be determined Decision Question/ Decisionmaker What decision, if any, is being made? New infrastructure project (including implementation of an HOT or ETL element) At what agency or governmental level are the decisions being made? Federal for environmental approval; State DOTs/ regional/metropolitan planning organizations and local governments will determine specifics afterwards. Stage of Decisionmaking What stage of decisionmaking does this document address? Project Development and NEPA, operational considerations that address environmental commitments of the EA Identification of Affected Populations What populations does this document address? Low-income Are there other affected stakeholders that are referenced? No

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 78 Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? The criteria for setting the geographic boundaries for the study area were not stated explicitly. However, the study area represents all of the area within the three counties containing the proposed project (two counties) or those within the metropolitan area planning model that would be most likely to use the road as it provides access to downtown Atlanta (one county, one was excluded because it was not within the metropolitan model). What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Income data within the Atlanta Regional Commission’s (ARC’s) most recent travel demand model (the most up-to-date modeling tool available in the region) was used. The document did not specify the source of the income data used in the ARC model came. Criteria used to identify the location of affected populations:  Low-income households were defined as those with annual incomes under $20,000. The $20,000 threshold was chosen because it falls between the poverty threshold of $17,378 for a three person household and the threshold of $22,314 for a four person household, as defined by the U.S. Census.  The percentage of low income households in the 177 TAZs was then broken down by quartile and mapped in relation to the proposed facility.  Three household income variables were established for use in the analysis: -Dichotomous (two category) variable: designated either low-income or non-low income depending on whether its percentage of households with incomes below $20,000 is greater or less than 15 percent (greater than 15% = low income). [No reasoning was given for using the 15% threshold.] -Continuous variable: percentage of households in the TAZ with annual incomes below $20,000 -Extremely low income and extremely high income TAZs Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes. The geographic scale for mapping and analysis was the TAZ. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? No. This information may be included in the project EA, but it was not reviewed. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? N/A (see above) Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? N/A (see above) What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? N/A (see above) Does the report assess its effectiveness reaching low-income, minority or other traditionally

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 79       disadvantaged populations? N/A (see above) Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No. This information might be addressed in other document, but they were not examined within the scope of this content review. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? N/A (see above) Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) N/A (see above) Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment?  Data sources: Atlanta Regional Commission’s (ARC’s) most recent travel demand model and data within  Assumptions: Because income is often the most significant driving variable impacting trip generation, ARC’s trip generation algorithm used income level information for households in calculating the total number of trips that a household is likely to make over the course of a typical weekday. (Trips were calculated based on select link analysis of the travel demand model.)  Analytical methods: The relationship between various household income variables and express- lane trip-related variables using statistical significance, mapping, and/or regression analysis. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) Express lane trips per TAZ Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No, not quantitatively, but regional maps of residential and work locations for low income earners and low paying jobs were included for context and additional information. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? No, the analysis did not contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations and the usage of toll and non-tolled facilities. The analysis relied on a proxy argument: because statistical analysis demonstrates that express lane usage rates from low-income areas are not statistically different than usage rates from high-income areas, low income users are projected to use the express lanes. However, the model did not separate trips by income level (all trips for all income levels were represented in each TAZ’s express lane trips) and individual trips were not associated with a particular income level, so direct linkage of impacts for low income individuals was not provided. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 80 specific communities (e.g.,. low-income and minority populations)? Because of the fact that the I-75 express lanes would parallel the existing general purpose lanes, diversion of the proposed express lanes traffic was thought to be captured in the analysis of the general purpose lanes. The study did note, however, that “it is anticipated that all trips in the corridor may benefit from added capacity, including those in the express lanes, those in the general purpose lanes, and even those along parallel facilities as a result of additional corridor capacity.” Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale?  State Road and Tollway Authority, November 2012, I-85 Express Lane Monthly Travel Data. See Appendix F.  FHWA, December 2008, Income-based Equity Impacts of Congestion Pricing. Report and Appendix D. (Referenced twice, below are the two references; second reference includes additional text from the source paragraph) Examples of use of referenced authorities:  “In addition, stated preference surveys demonstrate widespread support for these facilities across all income groups.”  “Other priced managed lane systems have demonstrated that there is not a disproportionate adverse impact on low-income populations. Evidence shows that ‘approval ratings are equally high for all income groups, 60-80 percent range, because all income groups value the ‘insurance’ of a reliable trip time when they absolutely need it.’ Overall, travelers across all income levels appreciate the choice to pay for a reliable travel time. These facilities have proven usage across all household income levels, therefore it is reasonable to assume that the I-75 Express Lanes project may also realize usage across all household incomes.” Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? Not in this report. Additional resource topics may have been analyzed in the EA. Evaluation of Environmental Justice Impacts Evaluation/Analysis Approach Method: The analysis compared projected express lane trips originating from TAZs with more low income households to express lane trips originating from TAZs with fewer low income households. The purpose was to determine if there is evidence that low-income individuals are less likely to use the I- 75 Express Lanes than higher income groups. What were the findings? What was the level of impact?  “The analysis shows that there are projected trips coming from low-income areas that use the express lanes, based on the select link analysis output of the regional travel demand model. The subsequent statistical analysis demonstrates that express lane usage rates from low-income areas are not statistically different than usage rates from high-income areas. This quantitative analysis demonstrates that the benefits of the I-75 Express Lanes are likely to be enjoyed by users irrespective of income level.” [However, there is no linkage that shows the individual trips from low-income areas are in fact by low-income individuals and not from other individuals (who are not low-income).]  The benefits of the project accrue to all users of the managed lanes, regardless of income, and to all users of the general purpose lanes, regardless of income, as a result of the additional corridor capacity.  “Based on this analysis and evidence from other similar facilities, the implementation of new tolled capacity is anticipated to generate adverse, but not disproportionately high impacts to the low-income community.”

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 81       What criteria did they apply to support findings? Express lane trips per TAZ and concentration or percentage of low-income households in a TAZ What type of documentation was provided? Statistical significance testing and regression analysis See “Critical Assessment” section below for critique of the above evaluation analysis. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? N/A Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? N/A Status  Environmental analysis  Construction began in 2014 and should be open for traffic by 2017 Critical Assessment  The analysis method suggests that some low-income users will use the toll roads, but does not demonstrably prove that low-income users of the project area will actually use the toll roads. This lack of a connection is due to the limitations of the select link analysis method within a travel demand model that is not differentiated by income segments.  The analysis could benefit from sensitivity testing.  As with most travel demand models, it has a limitation with the TAZ unit of analysis in that distribution of trips throughout the transportation network may not be accurate based on the location of low income TAZs.  The analysis did not draw upon any survey related or focus group input from EJ communities to determine the extent to which different segments of society would value the option of toll lanes. The report itself concedes that “the concept of tolled, managed lanes is new to Georgia and is untested [therefore] the actual public acceptance of these types of transportation solutions is unknown.” (The report itself states that “there are limitations to this analysis and some uncertainties inherent in predicting future acceptance of express lanes in the corridor.”)  The case study references to FHWA’s Income Equity report and other information -- supporting arguments for tolling’s relative equity based upon polls and prior usage studies that all incomes have been known to use toll roads – is probably insufficient to support a defensible finding for an environmental justice analysis. It should be appreciated that travel needs to places of opportunity might vary significantly by region and availability and cost of transit, parallel roads and the possible need for other forms of mitigation should be assessed and not dismissed through argumentation.  The analysis only focuses on low-income individuals; it could therefore be improved by focusing on both low-income individuals and minorities. Additional Comments  

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 82 Georgia DOT. January 2010. Atlanta Regional Managed Lane System Plan, Technical Memorandum 9: Social Equity and Environmental Effects Evaluation. Document Title Atlanta Regional Managed Lane System Plan, Technical Memorandum 9: Social Equity and Environmental Effects Evaluation (HNTB, January 2010) Website/Source https://www.dot.ga.gov/Projects/studies/managedlanes/Documents/Social%20Equity%20and%20En vironmental%20Effect%20Evaluation.pdf Document Type Technical Report Type of Sponsoring Agency or Organization Who is the project sponsor or other entity stakeholder that prepared the report? State DOT Geographic Distribution What geographic area does this document address? Atlanta Metropolitan Region ~4 million Urban/Suburban Type of Tolled Facility & Features What type of tolled facility? What change is being made? The report includes an analysis of the existing tolled network. The majority of the network includes HOT lanes/managed lanes and dynamic pricing. There is no change being made in the context of the analysis. Tolling Context What is the tolling context? A regional network with a series of managed lanes and electronic transponders. Methods of payment are not addressed. Pricing Arrangements What type of pricing scheme (e.g., dynamic, time of day, single price)? Dynamic Decision Question/ Decisionmaker What decision, if any, is being made? Whether or not the current system is equitable. At what agency or governmental level are the decisions being made? State DOT Stage of Decisionmaking What stage of decisionmaking does this document address? Statewide and Metropolitan Planning. Identification of Affected Populations What populations does this document address? Low-income, minority, disabled, limited English proficient. Are there other affected stakeholders that are referenced? No. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? The EJ study area included block groups that abutted the highway/toll network of the Atlanta region. These block groups included 1.1 million people and were all located within the 20 county Atlanta Metro. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? 2000 U.S. Census Block Groups. The criteria used to identify the study area involved identifying block groups that directly abutted Atlanta highways. The individual corridors were compared to see if there were higher level of minority or low income populations within these pre-identified block groups. These block groups were determined to have a percentage of minority populations if the African-American population was greater than 45% or if the Hispanic populations was greater than 9%. They were considered to be low income if more than 9% of the population fell below the poverty line.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 83       Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes. Block groups. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? No. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? N/A Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? No. N/A What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? N/A Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? N/A Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No. Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? The acceptance rates and other statistics from case studies should serve as an indicator of what to expect if managed lanes are implemented in the Atlanta Region. Sources of data include: U.S. Census, ozone rating for the Atlanta 10-county region in 2008 from American Lung Association State of the Air, exceedance of ozone levels by the Atlanta Regional Commission, environmental data from EPA data set, vehicle emissions data. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) The concentration of low-income and minority populations adjacent to the highways was the main metric used in the analysis. Did the analysis consider access to transit, access to private vehicle, and residential or work    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 84 locations? No. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The analysis did not look at issues of access, but instead looked at populations adjacent to the highways. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? Yes. Minnesota, South Florida, San Diego, and Houston studies were looked at in the analysis. These studies were significant because all of them successfully passed public scrutiny and were eventually implemented, compared to other toll way projects that did not pass public scrutiny. However, there was not a comprehensive analysis presented in the report analyzing ways in which these case studies compared to the toll projects that failed to pass. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) There was a large section that assessed the Air Quality of the Atlanta region. It was determined that a managed lane system would have a positive impact on the level of Air Quality for the region. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The study found that managed lanes are not price discriminate; everyone pays the same to get the same travel time benefits. The level of impact for the Atlanta region was never fully analyzed. The report seemed to provide the DOT and the MPO block groups that should be analyzed to determine impacts in the future, instead of providing an overall conclusion on the current level of equity in the existing system. The conclusion did mention the case studies, and specifically the San Diego study, which found that the managed lanes decreased congestion levels for both EJ and non-EJ populations. They also pointed out that the study found that a mitigating aspect of tolled systems came about if funds were directed towards transit activities. What criteria did they apply to support findings? N/A What type of documentation was provided? The results of other case studies. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? Yes. To balance impacts the report recommends to direct revenue collected on managed roadways for use on transit services. They also recommend some form of cash payment, in addition to the transponders, as some users may not have bank accounts.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 85       What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? None. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No. Status Current status of project: Planning Critical Assessment The analysis is lacking in data, methods, and approach. The study is basically a review of case studies with supplemental information concerning the makeup of populations that live close to Atlanta highways. The fact that the study only looks at block groups adjacent to the highways means the study may overlook existing EJ populations. There is no travel data, and no analysis of mobility, accessibility, or travel impacts. This report supplies a summary of case studies, an analysis of air quality, and not much else. Additional Comments  

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 86 NORTH CAROLINA North Carolina DOT. May 2013. I-77 High Occupancy/Toll (HOT) Lanes From I-277 (Brookshire Freeway) to West Catawba Avenue (Exit 28). Document Title I-77 High Occupancy/Toll (HOT) Lanes From I-277 (Brookshire Freeway) to West Catawba Avenue (Exit 28) (NCDOT, 2013. Mecklenburg County Federal Aid Project NHF-077-I(209)9, WBS No. 45454.1.1 STIP Project No. I-5405) Website/Source http://www.ncdot.gov/download/projects/publichearings/1_i- 77_hot_final_ea_070113_formatted_online.pdf Document Type Administrative Action Categorical Exclusion (CE) Type of Sponsoring Agency or Organization USDOT (FHWA) and NCDOT Geographic Distribution The project in located in Mecklenburg County, North Carolina and expands for 17 miles on I-77 from I-277 to West Catawba Avenue (Exit 28). The demographic study area includes 25 block groups located adjacent to the project study area. Type of Tolled Facility & Features The project consists of the conversion of the existing HOC lanes to HOT lanes as well as the extension of the HOT lanes in each direction from I-485 to West Catawba Avenue. Variable pricing is proposed to ensure traffic keeps moving by pricing vehicles off the lanes during peak demand. Tolling Context Project is located in an Interstate Route and tolls will be collected through technology and equipment. Pricing Arrangements Dynamic pricing will be used to manage demand. Decision Question/ Decisionmaker The Categorical Exclusion (CE) outlines the preferred alternative and associated impacts. A CE is a decision document used by FHWA in conjunction with the state DOT. Stage of Decisionmaking The decision is being made as part of the federal action associated with the NEPA process. Identification of Affected Populations Low-income, minority, ethnic and limited English proficient population are identified in the report through census data. No other disadvantaged populations are discussed in the report. Based on information in the report the demographic study area has 42% minority population as compared to 30.8 % for the county. Eleven of the 25 block groups have more than 70% African Americans and 4 of the 25 block groups have populations with median incomes below the county level. Residents living below the poverty level were slightly higher (13.8%) than the county average (12.5%). The Hispanic population in the designated study area is slightly less than the county average. There are 9 block groups with more than 5% LEP which meets the Safe Harbor threshold to require meetings materials in the appropriate language. Threshold Criteria & Geographic Mapping Block group adjacent to the project study area were utilized to collect demographic characteristics. The block groups where mapped and symbols were used to designate low-income, African-American and Hispanic populations. However, it is unclear from the text as to what threshold was used to identify these populations groups. The report does not provide details.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 87 Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? Two citizen workshops were held with a total of 13 comments received from residents and local agency representatives. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? Absolutely done. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? Such a small number participated in public meetings it unclear how this might have affected decisionmaking. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? None. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? No Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No. When asked at the public meeting if they were willing to pay a toll to use the HOT lane 6 of 10 respondents replied “yes.” Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? See below. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) See below. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? See below. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? See below.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 88       None of these types of studies were undertaken. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? SR 167 HOT Lanes Social Economic and Environmental Justice Report, WsDOT, January 2007 and the EA for I-85 HOV to HOT Conversion Project (GDOT, 2010) were cited as the resources referenced. The study concluded from these studies that “no information from those projects indicated equity-based impacts to low-income populations.” Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) No, however, correspondence from the MPO suggested noise could be an issue for EJ populations. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? Report states “no disproportionately high and adverse impact to low-income/or minority populations would occur as a result of implementing this project.” What criteria did they apply to support findings? The report briefly lists three areas that are referenced in FHWA’s Environmental Justice Emerging Trends and Best Practices Guidebook which should be considered including income equity, modal equity, and equity in participation. Below is summary of the reports statements on these areas.  Income Equity: “Studies of other HOT lanes projects around the US have found that broad spectrum of income groups express approval of the projects because they are given the option of using the tooled route when reliable travel times are important but are also provided a free route if they don’t want to pay the toll. In addition to the general purpose lanes, Statesville Road provides an alternative free route on the east side of I-77 through the project area.”  Modal Equity: “The proposed project would not affect transit or HOV vehicles, which would not be charged a toll and would continue to have priority for use of HOT lanes. Transit service would actually be enhanced by the enhanced by the extension of HOT lanes since transit vehicles would have priority along additional lane miles.”  Equity in Participation: The report declares “All communities and stakeholders potentially affected by the project are invited to participate in the project development process.” The report interestingly refers to the MPO’s final stages of adopting a Title VI expansion for its public involvement plan which is scheduled for final action in July, 2012. The report says this plans includes strategies for enhanced involvement of minority and low-income populations but gives no information about how that affects this particular study. The portion of the report also references the two studies conducted for HOV to HOT conversions as well as the FHWA primer. What type of documentation was provided? The report refers to a Community Impact Assessment report as the basis for the findings of the CE. No such report is appended to the CE. Revenue Recycling / Other Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? See below.    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 89     Mitigation Strategies What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? See below. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? See below. None of these were addressed but the report noted that consideration of providing transponders at low or no cost to low-income commuters, and allowing cash payments for people who do not have debit or credit cards may allow easy and convenient access. Status Current status of project: Unsure about current status of project. Critical Assessment Please generally critique the approach, methods and/or resources presented in this document. Do you see any gaps, room for improvement, or best practices? There are clearly low-income and minority population affected but there is no analysis to substantiate the claim that there are no disproportionate impacts except to cite other studies that concluded these type of HOV to HOT conversion do not affect EJ populations. The only information utilized was limited census data and two studies by state DOTs (Washington DOT and Georgia DOT) as well as the FHWA primer on Income-Based Equity Impacts of Congestion Pricing. Additional Comments The MPO provided comments during the scoping process regarding impacts to EJ communities: “There are significant environmental justice populations along the corridor, particularly south of exit 16. MUMPO’s Degree of Impact (DOI) analysis of EJ populations indicates that the corridor passes through areas with a “moderate” DOI impact, which translates into 3-4 of the six EJ populations being represented at levels exceeding regional thresholds for those populations.” DOT response to these comments was found in the appendix “With the exception of one block group containing a Hispanic population that meets NCDOT’s criteria for defining a notable EJ population, all block groups that include notable EJ populations are located south of I-85 where there will be no change to the existing footprint of I-77 (only conversion of the existing southbound HOV lane). All proposed improvements will be within the existing right of way and no direct impacts to EJ populations as a result of project construction are anticipated. With regard to income equity, studies of other HOT lanes project around the U.S. found that a broad spectrum of income groups express approval of HOT lane projects because they are given the option of using the tolled route when reliable travel times are important (e.g., to get to work on time or to pick up a child at daycare on time to avoid late charges), but are also provided a free route (general purpose lanes) or the option to carpool to qualify to use the HOT lane for free if they don’t want to pay the toll (Income-Based Equity Impacts of Congestion Pricing, FHWA).” EPA also provided a comment about the “potential for controversy” of which NCDOT responded, “this potential controversy is noted in the Community Impact Assessment, which also states that an organized and effective public outreach and education effort will be critical to the success of this project.”

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 90 VIRGINIA Virginia DOT. September 2011. I-95 HOT Lanes Project Environmental Assessment. Document Title I-95 Hot Lanes Project, Environmental Assessment; Spotsylvania, Stafford, Prince William and Fairfax Counties and City of Fredericksburg (Virginia Department of Transportation, 2011) Website/Source http://www.vamegaprojects.com/tasks/sites/default/assets/File/pdf/95HOVHOT/110908_I- 95HOTLanesEA_ApprovedbyFHWA.pdf Document Type Environmental Assessment Type of Sponsoring Agency or Organization Virginia DOT Geographic Distribution Washington DC Metro Area Type of Tolled Facility & Features What type of tolled facility? What change is being made? HOV to HOT Lane Conversions with Pricing Tolling Context What is the tolling context?  Facility specific toll  New toll  All-electronic toll transponder  Methods of payment at time of report? Not determined Pricing Arrangements Dynamic pricing depending on traffic conditions. Decision Question/ Decisionmaker What decision, if any, is being made? Conversion of existing HOV lanes to HOT lanes At what agency or governmental level are the decisions being made? Virginia DOT Stage of Decisionmaking What stage of decisionmaking does this document address? This environmental assessment is part of the NEPA review process. Identification of Affected Populations What populations does this document address? None Are there other affected stakeholders that are referenced? No Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? None presented What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? None Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) None discussed

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 91     Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? No Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? No What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations? None described Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? Not applicable Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? None presented What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) No Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? No Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No Case Study or Referenced Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale?    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 92 Authority No Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) No Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The report finds that there are no low-income or minority populations that would suffer disproportionately high or adverse effects from the project. What criteria did they apply to support findings? None What type of documentation was provided? None Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? No Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No Status Opened on December 14, 2014 Critical Assessment This document appears very deficient and incomplete in defining any EJ communities or populations. There is no discussion or presentation of any communities or maps presented to identify the locations of EJ populations. Additional Comments

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 93       VDOT. December 2013. Interstate 64 Peninsula Study: Socioeconomic / Land Use Technical Memorandum. Document Title Interstate 64 Peninsula Study: Socioeconomic / Land Use Technical Memorandum Website/Source http://www.virginiadot.org/Projects/resources/hampton_roads/64_deis/Updated%20Technical%20Do cuments/Socioeconomic- Land%20Use%20Technical%20Memorandum%20and%20Errata%20Record%20December%202013 .pdf Document Type Technical Memorandum of a Final EIS Document Title VDOT, December 2013, Interstate 64 Peninsula Study: Socioeconomic / Land Use Technical Memorandum. Type of Sponsoring Agency or Organization Who is the project sponsor or other entity stakeholder that prepared the report? Virginia Department of Transportation (VDOT) Geographic Distribution What geographic area does this document address?  Virginia – specific corridor from medium sized urban/suburban at ends and suburban/rural in between end points Type of Tolled Facility & Features What type of tolled facility? What change is being made? Study is examining the following alternatives, in addition to a No Build alternative and an alternative that just adds general purpose lanes: 1. Convert existing facility to full toll lanes with additional capacity 2. Addition of separated managed lanes (decision of HOV, HOT, or Express Toll Lane has not been determined). Tolling Context What is the tolling context?  Facility-specific: highway corridor  New toll (among other options)  Tolling technology / equipment: all-electronic with transponders  Methods of payment at time of report? TBD Pricing Arrangements Not yet decided (there may not even be a pricing scheme) Decision Question/ Decisionmaker What decision, if any, is being made? The form in which the highway will be upgraded and expanded, including the possibility of managed or express toll lanes At what agency or governmental level are the decisions being made? State DOT and regional/metropolitan planning organization Stage of Decisionmaking What stage of decisionmaking does this document address? Project Development and NEPA Identification of Affected Populations What populations does this document address? Low income and minority, with the largest minority population in the study area being African American Are there other affected stakeholders that are referenced? Age and gender was also analyzed for each block group Threshold What were the criteria used for setting the geographic boundaries for the study area?    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 94 Criteria & Geographic Mapping Census block groups (CBG) that border the existing I-64 corridor from the City of Richmond to the City of Hampton (the 75 mile study area being studied). [The study area did not capture the full area of users of the I-64 corridor.] What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)?  The report uses 2010 U.S. Census data and when that data was not available, 2000 U.S. Census data.  Populations were identified as minority if the minority population of the census block group was 29% or greater of the census block group’s (CBG) total population (which is the total minority population of the Commonwealth of Virginia based on 2012 Census data).  CBGs were identified as having low income populations when the median household income for the census block group was below the U.S. DHHS poverty threshold, which was $23,550 for a family of four in 2013. [This threshold for designating low-income areas is very low and not consistent with typical practices which designate small areas as low-income if the percentage of low-income households exceeds the average percentage for the larger area or the state.] Were the locations of affected populations mapped? Maps of the affected populations were provided in an Appendix. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? No. The FEIS provides some information about public involvement, but the text did not indicate that their efforts explicitly targeted low income or minority residents. Public involvement noted in FEIS: two citizen information meetings, two citizen information meetings for alternatives development, three Location Public Hearings for the purpose of providing the public with the opportunity to review and comment on the draft EIS, mailing list, website, print and brochure media. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? The document does not describe how feedback was given by stakeholders, but the FEIS does provide information on how feedback was given. Public feedback was taken into account with other evaluation criteria when identifying the preferred alternative. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? None specified within the text. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? N/A (see above)

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 95       Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? See “Threshold Criteria & Geographic Mapping” section above. Assumptions:  “If the alternative included tolls, local traffic could continue to utilize the vast local road network and not be subject to tolls.”  The tolled facilities benefit all drivers because they provide better access and mobility (less congestion and more reliable travel times). [This statement assumes that low-income users will use the toll facilities.] Besides quantitatively determining the CBG that met the low-income or minority criteria, no other analytical methods were applied to conduct the EJ impact assessment. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) No specific metrics were used to conduct the analysis. Qualitatively, the following two criteria were used: (1) access to alternate non-tolled routes; and (2) benefits that accrue to users of the project with the assumption that all potential users will use the project. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? No to both questions. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)?  Yes – the traffic studies included a toll diversion analysis. But, this report did not consider how or whether the traffic diversion impacted specific communities. This information may or may not be contained in an accompanying traffic study (traffic study was not reviewed).  This EJ analysis did not discuss if the toll diversion analysis, or the assumption that “local traffic could continue to utilize the vast local road network and not be subject to tolls”, took into account time impacts of diverted trips. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? With regards to the EJ analysis, no other studies were cited. However, the following statement was made in the EJ conclusion, which could have been influenced by other studies: “also, tolled facilities experience less congestion and therefore provide more reliable travel times. This benefits all drivers, regardless of income level because they provide better access and mobility.” (This statement assumes low income/minority drivers will use toll roads, which is not    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 96 discussed or shown in the analysis.) Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.? Other resource topics were addressed but not with respect to an environmental justice assessment. Each of the resource sections within the FEIS were not examined for EJ impacts. Evaluation of Environmental Justice Impacts Evaluation/Analysis Approach Method: The document makes this statement: “The EJ analysis was conducted in accordance with FHWA guidance. The study area was defined, and the demographic analysis was initiated to identify EJ populations. Census data was used at the block group level. Minorities and low income populations were identified to determine the area of potential impact, and the demographic information was examined to determine how potential impacts and benefits to the total population would affect the EJ populations. Finally, a determination was made whether or not the project would have disproportionately high and adverse impacts on the EJ populations in the study area.” What were the findings? What was the level of impact?  For all alternatives, EJ populations would not be impacted disproportionately compared to non- EJ groups.  Tolls are not expected to have a disproportionately high and adverse impact on EJ populations. What criteria did they apply to support findings?  “If the alternative included tolls, local traffic could continue to utilize the vast local road network and not be subject to tolls.”  The tolled facilities benefit all drivers because they provide better access and mobility (less congestion and more reliable travel times). This statement assumes that low-income users will use the toll facilities. What type of documentation was provided? None Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? N/A / None (see above) Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No Status Current status of project: On April 21, 2014, FHWA issued a Record of Decision (ROD) for the first operationally independent section to be implemented from the Interstate 64 Peninsula Study FEIS. The award of the Design- Build contract is planned for winter 2014, with project completion in winter 2018. The remaining sections of I-64 improvements will be done in phases. Critical Assessment The analysis that “determine[d] how potential impacts and benefits to the total population would affect the EJ populations” gave no criteria or metrics to establish what would be considered impacts or benefits and it also provided no criteria for how to gauge the level of impacts or benefits. While

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 97       the analysis is qualitative, more supporting documentation and information could have been provided about the conclusions presented (e.g., how toll facilities benefit all drivers regardless of income if low-income drivers may not utilize the facility in the first place? What parallel local roads could be used and what would the time “costs” of using these local roads be vs. the toll road?). Without any criteria/metrics or supporting information, the conclusion is unsubstantiated. Additionally, the EJ analysis states the following purpose: “To identify any disproportionately high and adverse effects on EJ populations, and to ensure that EJ populations have been included in I-64 study public involvement.” However, the report itself provides no documentation supporting the public involvement activities that were conducted to engage low-income and minority populations. Additional Comments  

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 98       MARYLAND Maryland DOT. November 2004. Intercounty Connector, Socioeconomic and Land Use Technical Report. Document Title Inter-County Connector, Socioeconomic and Land Use Technical Report (Maryland State Highway Administration, 2004) Website/Source http://pdf.iccstudy.org/DEIS/pdf/tech_reports/setr.pdf Document Type Technical Study Type of Sponsoring Agency or Organization Maryland Department of Transportation Geographic Distribution Washington DC Metropolitan Area Type of Tolled Facility & Features What type of tolled facility? What change is being made? New multi-modal east-west highway linking Interstate 270 in Montgomery County, Maryland with Interstate 95 in Prince George’s County, Maryland. Tolling Context What is the tolling context?  Tolled facility with variable tolls Pricing Arrangements Variable tolls based on time of day or congestion. Not many other details were determined at the time of publication. Decision Question/ Decisionmaker What decision, if any, is being made? New construction of a highway At what agency or governmental level are the decisions being made? Maryland Department of Transportation Stage of Decisionmaking What stage of decisionmaking does this document address? This document is part of the environmental review process. Alternatives are still being discussed. Identification of Affected Populations What populations does this document address? The environmental justice portion of the document identifies minority and low-income populations. However, as part of the larger socioeconomic impact section, population, income and household statistics are presented. Are there other affected stakeholders that are referenced? No Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? Census tracts within the defined study area were used to determine statistics from the U.S. Census. The study area was defined based on the alternative routes presented. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? U.S. Census bureau data from the 2000 Census was used at the tract level to identify EJ communities. In addition, racial composition data of study area schools from the National Center for Educational Statistics was used. Government assisted housing program data as well as data from other county

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 99       service providers was used to identify low-income communities. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes, maps showing tracts that met the EJ community criteria were shown in the report. These communities are shown in context of the proposed routes as well. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? Yes Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? Yes, mailings and flyers were directed to specific EJ communities and provided in Spanish to accommodate all communities. Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? Yes, feedback cards were mostly provided during public workshops. No evidence is provided to indicate that feedback may have influenced an alternative. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? Two information desks were stationed at shopping centers in EJ communities to provide information on the project. In addition, all open houses, information sessions, workshops had materials available in Spanish and English. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No, the report assesses overall outreach and comment, but not EJ populations in particular. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? A Transportation/Community Impact Survey was given to willing participants at public outreach events. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? Attendees of the outreach events, no specific targeting. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? A map analysis was conducted to identify what environmental effects would be disproportionate for EJ communities. Potential adverse impacts were mapped against the location of identified EJ communities. The analysis did not fully consider travel-related impacts as the final tolling determination was not available at the time of this report. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?)    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 100 No travel information was used. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? Yes, transit access was a consideration as low-income residents could use these services along the new corridor as an alternative to private vehicles subject to the toll. Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? No, no travel information cited. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No, the impact of parallel roads was not assessed. The study only mentions that the new facility would divert traffic from local roads to the new tolled facility. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? Yes, survey findings from the SR 91 Express Lanes in Orange County, CA were referenced to identify correlations between income and toll lane use, but also to suggest that the facilities by economically diverse groups including low-income persons when they have a pressing need (e.g., daycare, second jobs, and other appointments. “This day-to-day decision ultimately provides all motorists with an equal choice.” Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.) Yes, EJ communities were assessed according to residential displacement, property acquisition, access and mobility, community cohesion, noise, visual and aesthetic character and parks and community facilities. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? No disproportionate high and adverse effect was found on any one EJ community. What criteria did they apply to support findings? The EJ communities were evaluated according to: residential displacement, property acquisition, access and mobility, community cohesion, noise, visual and aesthetic character & parks and community facilities. In comparing impacts in the EJ communities with other communities according to these metrics, no disproportionate impact was found. What type of documentation was provided? Summary text describing the impact was presented. Specific residential displacements were presented with exact locations. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No. Final tolling determinations were not finalized for this report. What methods were followed, if any, to assess who pays for and who receives benefits from these

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 101       mitigation strategies? No Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No. Status Open and Operating Critical Assessment This report uses several data sources to identify low-income and minority (EJ) populations. Beyond census data, school, housing and community service data was incorporated to identify the location of EJ communities. The report is reviewing a project that still has many options, no build vs. build and an array of routes to be selected; all without a defined toll structure. As such, it was very limited in the presentation of travel impacts and other potential impacts to EJ communities. However, the robust data deployed and geographic presentation was strong. Additional Comments  

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 102 Maryland DOT. May 2004. Environmental Assessment Section 100: I-95, I-895(N) Split to North of MD 43. Document Title Environmental Assessment Section 100: I-95, I-895(N) Split to North of MD 43 (Maryland Transportation Authority, Maryland Department of Transportation, May 2004) Website/Source http://www.mdta.maryland.gov/I95section100DELETE/i95-sect100_purpose.html Document Type Environmental Assessment Type of Sponsoring Agency or Organization Maryland Transportation Authority of the Maryland Department of Transportation Geographic Distribution Baltimore Metropolitan Area Type of Tolled Facility & Features What type of tolled facility? What change is being made? Expansion of I-95 from I-895 to just north of MD-43 to add two managed lanes per direction. The managed lanes would be tolled (one of three alternatives, and the only proposed tolling strategy). Tolling Context What is the tolling context?  Managed toll lanes Pricing Arrangements No clear pricing scheme defined within the document, but a range of pricing strategies are discussed. Decision Question/ Decisionmaker The decision is whether to add two lanes to the I-95 corridor between I-895 and just north of MD-43 and whether to place restrictions or tolls on these lanes. The Maryland Department of Transportation will make the final decision on the project. Stage of Decisionmaking This document is an Environmental Assessment and is prepared as part of the NEPA process. Identification of Affected Populations What populations does this document address? The document identifies low-income populations, defined according to the US Census Bureau poverty thresholds as well as minority populations. Data from the 2000 Census was used to identify the populations with data prepared at the tract level. In addition, low-moderate income housing developments in the study area were also identified through Baltimore County data. Unemployed populations were also identified. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? Census tracts that intersected the Section 100 corridor were defined as the boundaries of the study area. What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? Census 2000 data was used with support from Baltimore County Office of Planning and Baltimore City Department of Planning. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) The four potential EJ communities were not mapped, however, they were identified at the neighborhood/housing development level.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 103 Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? No Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? No What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? No Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? No Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? No Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various groups of interest? (e.g., income, race, age, gender etc.) No Regional Travel- Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? The analysis did not fully consider travel-related impacts as the final tolling determination was not available at the time of this report What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) No Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads? No

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 104 Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment?(e.g., noise, air quality, property values and land use, safety, social cohesion, etc.? Yes, the analysis assessed impacts to the potential EJ communities with respect to a number of parameters. These include: Right of Way acquisition, Displacement, Access, Noise Levels, and Visual Quality. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The analysis here largely centered on other construction related impacts to EJ communities. The analysis found that there was no disproportionately high impact to EJ communities compared to other communities in the corridor. What criteria did they apply to support findings? The analysis compared potential impacts in all areas throughout the corridor for ROW, displacement, access, noise, and visual quality. What type of documentation was provided? A table illustrating the individual impacts in EJ communities was presented. Revenue Recycling / Other Mitigation Strategies Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.? No What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? No Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No Status Opened December 2014 Critical Assessment This document was prepared prior to the identification of a tolling strategy and has little consideration of the potential tolling impacts on low-income or minority populations. However, there is robust presentation of other construction-related impacts on EJ communities, including low-moderate income housing developments. This is a thorough and detailed approach that identifies impacts at the neighborhood/housing development level as opposed to a census geography.

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 105 RHODE ISLAND Rhode Island DOT. January 2013. FEIS Reevaluation for Sakonnet River Bridge Rehabilitation or Replacement, Appendix B: Environmental Justice. Document Title FEIS Reevaluation for Sakonnet River Bridge Rehabilitation or Replacement, Appendix B: Environmental Justice. (Rhode Island DOT and FHWA, January 2013) Website/Source http://www.rilin.state.ri.us/commissions/bridgefunding/bridgedocs/Final_Environmental_Impact_Statem ent.pdf Document Type Final Environmental Impact Statement (FEIS) Type of Sponsoring Agency or Organization Rhode Island Department of Transportation and the Federal Highway Administration Geographic Distribution What geographic area does this document address? Part of a state planning process including several towns, counties, the RIDOT, and the Rhode Island Turnpike and Bridge Authority. Mainly addresses the area of Newport County, RI, including the communities of Portsmouth, RI and Tiverton, RI. Specifically the EJ analysis looks at areas that are likely to be origins or destinations for trips over the Sakonnet River Bridge. These include: Providence, RI; East Providence, RI; Barrington, RI; Warren, RI; Bristol, RI; Portsmouth, RI; Middletown, RI; Newport, RI; Jamestown, RI; Tiverton, RI; Little Compton, RI; Seekonk, MA; Rehoboth, MA; Swansea, MA; Fall River, MA. Type of Tolled Facility & Features What type of tolled facility? What change is being made? Fixed tolls. The implementation of a new toll and tolling system to cover the cost of the construction and maintenance of a new bridge. Tolling Context What is the tolling context? Facility-specific (Sakonnet Bridge), new toll, all-electronic collection. The types of payments allowed (credit card/cash/check) were not mentioned in the report. Pricing Arrangements What type of pricing scheme (e.g., dynamic, time of day, single price)? Fixed-price. Decision Question/ Decisionmaker What decision, if any, is being made? New infrastructure (Sakonnet Bridge), as well as the implementation of a new tolling system. At what agency or governmental level are the decisions being made? State DOT Stage of Decisionmaking What stage of decisionmaking does this document address? Project Development and NEPA. Identification of Affected Populations What populations does this document address? Minority populations and the population below the poverty line. Are there other affected stakeholders that are referenced? No. Threshold Criteria & Geographic Mapping What were the criteria used for setting the geographic boundaries for the study area? “…areas were selected since travel over the Sakonnet River Bridge, to and from Aquidneck Island, are likely to begin or end in these municipalities.”

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 106       What data sources were used to identify affected populations? What criteria were used to identify the location of affected populations (e.g., communities of concern, EJ concentration zones, etc.)? U.S. Census Bureau American Community Survey (ACS) for 2011 was used to examine minority and low-income patterns. The percentage of low-income and minority populations at the city and county level was compared with percentages at the statewide level. If the area had an EJ population higher than the statewide level it was considered to be a community of concern. Were the locations of affected populations mapped? What was the geographic scale for mapping and analysis? (e.g., block, block group, census tract, MCD, TAZ) Yes, on a regional scale. The scale of the map is 1”= 5 miles or 1:325,000. It highlights the municipalities of the study area. The initial analysis utilized city, county, and statewide populations, followed by a more detailed table comparing census tracts to the statewide average. The table comparing census tracts is included in the appendix and not used in the analysis. Description of Public Involvement Activities Does the document specifically describe efforts to conduct public involvement? Does the document describe efforts to provide information about toll implementation or rate changes? There were two community workshops which included an open-ended response session with no time limit and a questionnaire filled out by attendees. The questionnaires were also sent to 140 businesses, tourist attractions, and major employers in the study area and were submitted in a separate report included in the appendix of the FEIS. Is there any evidence that the mapping of affected populations influenced how public involvement was conducted? No specific section that details whether or not the mapping of the affected populations influenced how the public involvement was conducted. The meetings were held at the two directly affected communities’ high schools, and open to the public. (These communities were not identified as EJ areas, although they each had census tracts in which the percentage of minorities or people below the poverty line was higher than the state average). Does the document describe how feedback was given by those in attendance? Is there any evidence that feedback may have influenced alternatives, impact assessment, and/or mitigation? The feedback to the questionnaire was submitted in a separate report as an appendix to the FEIS. It is not included in this version of appendices. No evidence that the feedback influenced alternatives, impact assessment, or mitigation efforts. What approaches, tools or techniques were described to encourage the attendance or engage low- income, minority and other traditionally disadvantaged populations (e.g., advertising, language translation, event /meeting location, time of day, etc.)? It is not clear from the report that any efforts were made to encourage the attendance of or engage low- income or minority residents. Does the report assess its effectiveness reaching low-income, minority or other traditionally disadvantaged populations? No. Attitudinal Surveys, Focus Groups, and Interviews Were surveys, focus groups or interviews conducted? Yes. A questionnaire was passed out and collected at the two community workshops. Who were the targets for these market research activities regarding travel patterns, attitudes, perceptions and travel behavior? (e.g., general public, corridor travelers, specific residents or travelers)? The workshop attendees, businesses, tourist attractions, and employers. Were travel surveys or travel diaries used to gather detailed, specific travel behavior data of various    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 107       groups of interest? (e.g., income, race, age, gender etc.) No. Regional Travel-Related Measures and Impacts What data sources, assumptions and analytical methods were applied to conduct the impact assessment? 2010 Census, 2011 ACS 5 year. A travel demand model was created for 2030 conditions taking into account the new toll. The model provided estimates for total trips, VMT, and VHT. The details of the model used or the variables identified are not included in the report. What considerations, measures and metrics were used to conduct analysis? (e.g., vehicle miles traveled (VMT), vehicle hours traveled (VHT) and vehicle hours delayed (VHD), travel speeds, travel time, traffic volumes, transit ridership, accessibility, etc.?) Vehicle trips, VMT, and VHT. Did the analysis consider access to transit, access to private vehicle, and residential or work locations? No Did the analysis contain modeling and methods capable of supporting a direct linkage or relationship between the travel behavior of environmental justice populations (e.g., low-income populations) and the usage of toll and non-tolled facilities (i.e., specific modeled trips were not able to be identified by income category)? Did the study rely upon proxy arguments – toll trips came from an area of higher EJ populations, therefore EJ populations were no less able to access or use toll roads)? The study only looked at municipalities as origins and destinations and determined that the only two municipalities with a higher proportion of EJ populations were not impacted by the tolling project. Traffic Diversion Effects Did the analysis assess the impacts of trips diverted to non-toll facilities such as parallel roads? If so, did the analysis consider how or whether the traffic diversion was disproportionately borne by specific communities (e.g., low-income and minority populations)? No. The analysis does not discuss impacts specific to the road network. Case Study or Referenced Authority Were other studies cited as support for the tolled facility? If so, which studies and/or locations? What was the level of detail or argument provided as rationale? No other studies were cited as support. Other Resource Topics Were other resource topics addressed with respect to the environmental justice assessment? (e.g., noise, air quality, property values and land use, safety, social cohesion, etc.? Other resource topics were not addressed. Evaluation of Environmental Justice Impacts What were the findings? What was the level of impact? The finding was that EJ populations did not incur disproportionate impacts. What criteria did they apply to support findings? The areas with a higher proportion of minority populations “are not as impacted by the Project.” The areas with a higher proportion of low-income populations “are not as impacted by the Project.” What type of documentation was provided? A table and maps comparing the proportions of low-income and minority populations by city. A table and maps showing the changes in vehicle trips and VMT/VHT to cities surrounding the project area. They determined that areas with higher EJ populations were not impacted by changes in vehicle trips, VMT, and VHT incurred from the project. Revenue Recycling / Were any approaches mentioned or proposed for recycling revenues, discount programs, exemptions, transit credit programs, etc.?    

Project NCHRP 08-100 Environmental Justice Analyses When Considering Toll Implementation or Rate Changes Appendix B ‐ 108 Other Mitigation Strategies No. What methods were followed, if any, to assess who pays for and who receives benefits from these mitigation strategies? No. Were any other commitments expressed in the document or in the record of decision relating to equity and environmental justice issues? No. Status Current status of project: Constructed. The toll was initially implemented, but has since been removed, and a lawsuit has been levied by the city of Portsmouth, RI against the Rhode Island Turnpike and Bridge Authority concerning the legality of the toll. Critical Assessment The report lacked a thorough approach and appropriate use of data to support findings EJ populations were only analyzed at the city level (while demographics at the census tract level were included in an appendix they were not discussed in the analysis), and they used the minority/low income ratios compared with the state population as their main method of EJ analysis. The planning process included a questionnaire and two meetings, but none of the results of the questionnaires were included in the report. (The report pointed towards a memo concerning the results, but the appendix was not included in the report). Additionally, there was no attempt made to account for representation of EJ populations at the workshops. The analysis was never brought to a level of synthesis. In other words, they made no model projections considering household makeup, # of cars per household, mode change, and income levels in an attempt to ascertain the tolling’s impact on people of varying incomes. If these variables were included in the model they were not discussed in the report. Also, the report lacked details concerning the travel model and variables used in the projection. Additional Comments