Equity Analysis in Regional Transportation Planning Processes, Volume 1: Guide (2020)

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1 Transportation agencies that manage federally funded programs and projects are responsible for ensuring that their plans, programs, policies, services, and investments benefit everyone in their jurisdictions equitably. Historically, certain individuals and communities, including those from minority, low-income, and limited English proficiency (LEP) populations, have not benefited equitably from transportation investments and programs. Understanding the impacts of transportation investments on these individuals and communities and taking steps to address inequities are critical functions of transportation agencies. This guide describes a five-step framework for conducting an equity analysis for regional transportation plans and programs developed by metropolitan planning organizations (MPOs). Each step includes detailed methods and examples to help an agency develop and implement equity analyses that best meet the unique context of a community. After the fifth step, the guide provides a list of the major elements of each step and resources that can assist with that step. Purpose and Target Audience This reference guide is designed to help MPOs to analyze and address equity effectively in long-range, regional, multimodal transportation planning and programming processes. Equity analyses should be designed to support the legal requirements of Title VI of the 1964 Civil Rights Act (Title VI) as elucidated by the 1994 Executive Order 12898 on Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations (here- after referred to as E.O. 12898). Equity analyses should also include related assessments and engagement activities required for MPOs to comply with the 2000 Executive Order 13166 on Improving Access to Services for Persons with Limited English Proficiency (LEP) (hereafter, E.O. 13166). In accordance with the requirements set forth in Title VI and elucidated by the two executive orders, MPOs must conduct analyses of the Metropolitan Transportation Plan (MTP), the Transportation Improvement Program (TIP), and other plans and projects to ensure equitable access to their services and decision-making processes, and an equitable dis- tribution of the benefits and burdens generated by transportation investments. In this report, Volume 1 (the guide) provides quantitative and qualitative options for equity analyses, whereas Volume 2 (the technical report) summarizes the research process and policy considerations. Many of the approaches and concepts presented in this guide also can be applied to project- level assessments conducted by transit agencies, state departments of transportation (DOTs), local public works departments, and other transportation agencies. It is important to note, however, that project-level equity analyses are subject to detailed requirements that are not addressed deeply in this report. The focus of this guide is on the broader regional planning and decision-making processes that typically precede detailed project studies. C H A P T E R 1 Introduction

2 Equity Analysis in Regional Transportation Planning Processes MPOs are responsible for long-term transportation planning and for programming federal transportation funds in U.S. urban regions where 50,000 or more people occupy two or more jurisdictions. Every 4 years, each MPO adopts an MTP that outlines a 20-year (or longer) vision for the transportation system, accounting for all of the current and proposed transportation investments to be supported by estimated funds from federal, state, and local sources. To imple- ment the MTP, the MPO adopts and regularly updates a short-term TIP that lists and desig- nates funding for all regionally significant transportation projects to be moved forward during a period of 4 or more years. What Does Equity Mean for Transportation Planners? The following excerpts from materials published by the U.S. DOT, FTA, and FHWA discuss some key terms and concepts associated with equity, including environmental justice (EJ), Title VI, non-discrimination, and equity. According to the U.S. DOT’s Environmental Justice Strategy document (dated November 15, 2016), [e]nvironmental justice is the fair treatment and meaningful engagement of all people, regardless of race, ethnicity, income, national origin, or educational level with respect to the development, implemen- tation and enforcement of environmental laws, regulations and policies. . . . Fair treatment means that no population, due to policy or economic disempowerment, is forced to bear a disproportionate burden of the adverse human health and environmental impacts, including social and economic effects, resulting from transportation decisions, programs and policies made, implemented and enforced at the Federal, State, local or tribal level. The FTA’s Circular 4703.1 (dated August 15, 2012) comments on the agency’s commitment to EJ, specifically that the agency seeks to make EJ . . . part of our mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of our programs, policies, and activities on minority populations and/or low-income populations (collectively, ‘EJ populations’). Environmental justice at What is Equity in Transportation? Equity in transportation seeks fairness in mobility and accessibility to meet the needs of all community members. A central goal of transportation equity is to facilitate social and economic opportunities by providing equitable levels of access to affordable and reliable transportation options based on the needs of the populations being served, particularly populations that are traditionally underserved. This population group includes low income individuals, minority individuals, elderly persons, children, people with LEP, and/or persons with disabilities. An equitable transportation plan considers the circumstances that impact a community’s mobility and connectivity needs, and this information is used to determine the measures needed to develop an equitable transportation network. To attain an equitable transportation network, all components of Title VI, EJ, and non-discrimination must be considered. Source: FHWA EJ program website (www.fhwa.dot.gov/environment/environmental_ justice/ equity)

Introduction 3 FTA includes incorporating environmental justice and non-discrimination principles into transportation planning and decision-making processes as well as project-specific environmental reviews. As federal financial recipients, MPOs are responsible for managing their programs in accor- dance with federal requirements, and FTA is responsible for ensuring that recipients follow federal statutory and administrative requirements. Further, the FHWA’s Environmental Justice Reference Guide (dated April 1, 2015) states, EJ at FHWA means identifying and addressing disproportionately high and adverse effects of the agency’s programs, policies, and activities on minority populations and low-income populations to achieve an equitable distribution of benefits and burdens. This also includes the full and fair participa- tion by all potentially affected communities in the transportation decision-making process. Why Conduct Equity Analyses? A strong transportation system provides all community residents with equitable access to economic opportunities, such as jobs or schools, and to destinations that are vital to health and livability such as grocery stores and healthcare. However, transportation projects can also have adverse effects on the quality of life, such as increasing pollution or bisecting communities. Historically, the benefits and costs of transportation investments have often been distributed inequitably, with underserved persons bearing a higher share of the burdens of the transporta- tion system and a lower share of the benefits. Recognizing these patterns of inequity in transpor- tation decision making, federal policies were implemented that have required regional agencies to consider equity impacts in their planning processes. A comprehensive regional equity analysis can support (but not replace) an MPO’s Title VI plan, LEP, and/or EJ documentation. That said, this report is not intended to provide detailed guidance on meeting federal requirements. Rather, it focuses more broadly on approaches and methods for using equity analyses to support regional plans and initiatives that strive to address the current and anticipated needs of underserved persons, and to correct decision-making patterns that have generated unbalanced benefits or burdens in the past. By conducting robust equity analyses and addressing identified inequities within the trans- portation system, an MPO can improve its ability to make transportation investments that con- tribute to the health, prosperity, and quality of life for all persons and communities in a region. “Since the landmark civil rights legislation of the 1960s, government has primarily used a color-blind approach to combat racial discrimination and establish a race- blind standard. This approach is founded on the well-intended idea of equality, which means that everyone receives the same treatment. Unfortunately, equality assumes sameness—that everyone faces the same barriers. Equality does not take into account historical or current forms of discrimination that are present in our public institutions and structures, such as redlining, which prevented many people of color from owning property and accruing wealth, or predatory lending practices targeting communities of color. As a result, color-blind policies have not reversed racial inequity. People of color continue to experience the worst outcomes.” Source: Oregon Metro Strategic Plan to Advance Racial Equity, Diversity and Inclusion (Oregon Metro 2016)

4 Equity Analysis in Regional Transportation Planning Processes What Requirements Are Relevant to Equity Analyses? Three important equity-focused federal laws and directives merit discussion at the outset: • Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq.); • E.O. 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations (Exec. Order No. 12898, 59 FR 7629 [February 16, 1994]); and • E.O. 13166, Improving Access to Services for Persons with Limited English Proficiency (Exec. Order 13166, 65 FR 159 [August 16, 2000]). Title VI prohibits discrimination on the basis of race, color, and national origin in programs receiving federal assistance. Transportation agencies are legally required to comply with Title VI, and FTA and FHWA monitor their compliance. E.O. 12898 protects low-income persons and minority persons and directs federal agencies to develop an agency-wide EJ strategy to address disproportionately high and adverse effects of their programs, policies, and activities. E.O. 13166 requires federal agencies to identify any need for services to LEP persons and to develop and implement a system to pro- vide language services to LEP persons so that they can have meaningful access to information. Title VI requires agencies to ensure there is not discrimination based on race, color, and national origin, which involves (1) analyzing whether design, construction, or future changes in service delivery for transportation projects have a disparate impact on those populations, and (2) if disparate impacts are found, either demonstrating that these impacts are unavoidable or identifying ways to mitigate them. EJ analysis is similar in nature, but focuses on a determination of whether minority and low- income individuals experience disproportionately high and adverse effects at all phases of planning, design, construction, and future changes for a project. Equity analysis for transit planning in the Title VI context usually refers to (1) a siting or locating equity analysis (dis- cussed in FTA Title VI Circular 4702.1B, Chapter 3, Section 13); (2) a service equity analysis (discussed in the Circular in Chapter 4, Section 7.a); or (3) a fare equity analysis (discussed in the Circular in Chapter 4, Section 7.b). In practice, the analysis that would arise specifically for MPOs is discussed in the Circular in Chapter 6, Section 2.a(5) and is folded into review of the demographic maps required by Chapter 6, Section 2.a(4). The requirements of the Title VI statute and E.O. 12898 are distinct, but, there is overlap between the two, and transportation agencies often conduct regional equity analyses that address Title VI, EJ, and other non-discrimination regulations. E.O. 13166 requires agencies to make federally funded services, programs, and activities acces- sible to persons with a limited ability to read, write, speak, or understand English. This executive order does not require an analysis of potentially disparate benefits and burdens of transporta- tion investments on LEP populations; however, consideration of LEP needs and concerns can complement an equity analysis. Guidance issued by the U.S. Department of Justice (DOJ) in 2002 notes that failure to ensure that LEP persons can effectively participate in or benefit from federally assisted programs and activities may violate the Title VI prohibition against national origin discrimination. To support compliance with both the Title VI statute and E.O. 12898, transportation agencies must identify required populations. For Title VI analyses, agencies must analyze whether pro- posed plans or projects have a disparate impact on protected population groups. The EJ analysis process involves analyzing whether proposed plans or projects could generate disproportion- ately high and adverse effects on one or more covered groups. The authorities and requirements associated with these federal policies differ—compliance with one does not necessarily indicate

Introduction 5 compliance with the other. It is helpful, however, to consider the implications of both when evaluating the impacts of a proposed plan or project, as noted in the following example: For example, while a bus rehabilitation project may not impose disproportionately high AND adverse effects on EJ populations, the use of those buses subsequent to the rehabilitation may be subject to a Title VI analysis to ensure that vehicles assigned to a particular area do not result in a disparate impact on the basis of race, color, or national origin. In addition, if there are substantive changes to the service levels in the future for which the rehabilitated or other buses will be used, i.e., the vehicles are deployed in such a way that the nature and quantity of service in a particular area is changed, then a service equity analysis must be conducted under Title VI to determine whether this change results in a disparate impact on the basis of race, color, or national origin (FTA Circular 4702.1B). “Because many planning documents and processes require joint review from FHWA and the Federal Transit Administration (FTA), Division Office planners should coordinate with FTA regional staff to ensure that recipients meet the EJ requirements of both agencies. The agencies’ approaches are similar, since FHWA and FTA are both governed by joint planning regulations and the TMA [Transportation Management Area] planning certification process. However, coordination is important because they each have different EJ policies that respond to the uniqueness of their programs. The FTA EJ Circular 4703.1 provides information specific to transit. FHWA and FTA are jointly responsible for providing oversight of the transportation planning process, including TMA certification reviews, the statewide planning finding, and planning documents such as the statewide long– range transportation plan (LRTP), metropolitan transportation plan (MTP), statewide transportation improvement program (STIP), transportation improvement program (TIP), unified planning work program (UPWP), and participation plan.” Source: Federal Highway Administration Environmental Justice Guide (FHWA 2015) Fundamental Principles of EJ The essence of effective EJ practice, distilled into three fundamental principles, has been summarized in U.S. DOT and FHWA guidance: • Avoid, minimize, or mitigate disproportionately high and adverse human health and environmental effects, including social and economic effects, on minority populations and low-income populations; • Ensure the full and fair participation by all potentially affected communities in the transportation decision-making process; and • Prevent the denial of, reduction in, or significant delay in the receipt of benefits by minority and low-income populations. Source: Federal Highway Administration Overview of Transportation and Environmental Justice (released May 2000). Table 1 broadly summarizes the key elements in Title VI, E.O. 12898, and E.O. 13166 that relate to transportation planning.

6 Equity Analysis in Regional Transportation Planning Processes Terms Used in This Guide Researchers and practitioners use a wide variety of terms to describe the populations specified in federal laws, directives, and requirements. This guide uses the following terms: • Required populations or required population groups will refer to the population groups for which analyses are required for an MPO to comply with federal laws and guidance relating to Title VI, E.O. 12898, and E.O. 13166 (the EJ and LEP executive orders). These include minority and non-minority racial/ethnic populations, low-income and non-low-income populations, and LEP and non-LEP populations. Beyond these required populations, MPOs can and should consider and address the needs of other populations in their regions that may face disproportionate transportation-related burdens or inequities. • Underserved persons will refer more broadly to any person of a population group that an MPO might want to consider for inclusion in an equity analysis. This term includes persons of the required population groups as well as members of other groups that may face dispro- portionate transportation-related burdens or inequities, such as older adults or persons with disabilities. • Underserved communities will refer to geographic areas or neighborhoods in which under- served persons live, and includes areas that agencies have designated as high-priority areas for any given population of underserved persons. • Transportation disadvantaged will refer to those persons who, because of physical or mental disability, income status, or age, are unable to transport themselves or to purchase transportation and who are, therefore, dependent on others to obtain access to health care, employment, education, shopping, social activities, or other life-sustaining activities. Many MPOs also identify other persons or communities within the region who may be under- served by the transportation network or by the transportation decision-making process, such as persons with disabilities, older adults, or children and youth. These regionally defined persons or groups are sometimes combined with required populations for the purpose of conducting plan analyses and designing public engagement campaigns, and identified as “vulnerable popula- tions,” or “communities of concern.” These regionally defined broader designations of persons or communities are generally referred to as “underserved” throughout this guidebook. Title VI Environmental Justice (EJ) Limited English Proficiency (LEP) Authorizing Directive Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq.) E.O. 12898 (1994) E.O. 13166 (2000) Required Populations Race, color, and national origin Minority persons and low-income persons Individuals with a limited ability to read, write, speak, or understand English Applicable Agencies/ Programs Programs receiving federal assistance Federal agencies and recipients of federal financial assistance Federally funded programs and activities Guidance 23 CFR Parts 200 and 450; FTA Title VI Circular 4702.1B (2012) FTA EJ Circular 4703.1 (2012) U.S. DOJ Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons (2000) Table 1. Key elements in Title VI, E.O. 12898, and E.O. 13166.

Introduction 7 Organization of This Guide This guide begins with a chapter that emphasizes the importance of a strong foundation of public engagement. Subsequent chapters detail the five steps of the equity analysis process. A diagram appears at the beginning of each chapter to reinforce the importance of continuing to integrate public engagement throughout the five steps (Figure 1). Chapter 2 is titled “Lay the Foundation with Public Engagement.” This chapter describes the important role of public engagement and describes elements of inclusive public engagement, which is critical to the success of each step in the equity analysis process. Chapter 3 is titled “Step 1: Identify Populations for Analysis.” This chapter describes methods for defining and identifying populations of underserved persons and communities for which equity analyses will be conducted. Chapter 4 is titled “Step 2: Identify Needs and Concerns.” This chapter describes how public engagement and data analysis can be used to identify the needs and concerns of selected popu- lations to help focus and measure the equity impacts. Chapter 5 is titled “Step 3: Measure Impacts of Proposed Agency Activity.” This chapter describes options for selecting appropriate equity indicators and technical methodologies to assess the benefits, burdens, and relative impacts of transportation plans and projects. The analyses of plans and programs will determine whether the benefits and burdens they are expected to generate will be equitably distributed among underserved and non-underserved persons and communities. Chapter 6 is titled “Step 4: Determine Whether Impacts Are Disparate or Have DHAE.” This chapter describes methodologies for determining whether identified differences in the impacts generated by transportation plans and programs on underserved persons versus non- underserved persons are disparate or have disproportionately high and adverse effects (DHAE). Chapter 7 is titled “Step 5: Develop Strategies to Avoid or Mitigate Inequities.” This chapter describes approaches for addressing and mitigating equity issues identified in the analysis. Mean- ingful equity analyses, even ones that do not find disparate impacts or DHAE, often spur broader actions to address systemic disparities and needs of underserved persons, such as institutional changes in decision-making processes (such as equity-related project-selection criteria and robust public engagement). Figure 1. Organization of this guide.

8 Equity Analysis in Regional Transportation Planning Processes The guide concludes with an appendix detailing the Pilot Case Studies. The appendix describes the experiences of four MPOs that tested elements of the five-step equity analysis frame- work. The chapters in this guide provide an overview of key points to remember, discuss key actions and resources for conducting each step of a meaningful equity analysis, and provide case-study examples based on testing of the process. When using the five steps, it is important to remember that public engagement is a continuous and iterative process; thus, even as each step is completed, ongoing monitoring, assessments, and other activities will likely continue. Published separately, Volume 2 of TCRP Research Report 214 provides an overview of the research con- ducted in TCRP Project H-54 to identify ways equity in public transportation can be analyzed through an integrated participatory and quantitative approach that (1) is adaptable to plans and programs developed by MPOs in partnership with transit agencies and (2) relates to environ- mental justice analysis and Title VI procedures, implementation, and reporting compliance. Quick References for Planners, Policy Makers, Analysts, and Modelers Planners, policy makers, data analysts, and modeling staff play complementary roles through- out an equity analysis. Table 2 summarizes the key responsibilities of these players that are associated with each step of the process. For quick reference, the tasks in the table are keyed to the relevant chapters and subsections in this guide. Chapters Tasks Involving Planners/Policy Makers–Chapter Section(s) Tasks Involving Data Analysts/ Modelers–Chapter Section(s) Lay the Foundation with Public Engagement (Chapter 2) • Develop an Inclusive Public Engagement Plan • Evaluate Progress Step 1: Identify Populations for Analysis (Chapter 3) • Define Population Groups for Analysis • Identify High-Priority Areas • Understand Demographic Change • Define Population Groups for Analysis • Identify High-Priority Areas • Identify Regional Distribution of Underserved Persons Step 2: Identify Needs and Concerns (Chapter 4) • Validate Results • Identify Needs at the Regional Level • Identify Needs at the Neighborhood Level • Document Findings for Use in Other Steps Step 3: Measure Impacts of Proposed Agency Activity (Chapter 5) • Select Indicators • Differentiate Project Types for Evaluation • Measure Outputs • Measure Outcomes • Document Measurements for Use in Next Steps Step 4: Determine Whether Impacts Are Disparate or Have DHAE (Chapter 6) • Validate Findings with Qualitative Methods and Stakeholder Engagement • Explore Causes and Mitigation Options (If disparate or disproportionately high and adverse impacts are found, diagnose why.) • Review Data to Identify Differences Among Population Groups • Screen for Disparate Impacts Using Quantitative Methods Step 5: Develop Strategies to Avoid or Mitigate Inequities (Chapter 7) • Invest in Projects That Advance Equity • Address Equity in all Phases of Planning and Decision Making • Evaluate and Measure Progress Table 2. Tasks involving planners/policy makers and analysts/modelers, keyed to chapter sections in this guide.

Introduction 9 Equity Analysis Elements and Resources Several key elements should be considered when initiating a successful equity process. First, identify and engage members of underserved populations to make sure the process is fully informed by their input. Next, make sure to clearly articulate their needs and concerns before attempting to assess the benefits and costs of plans and programs. No matter how well- intentioned the effort, a planning agency can fail to meaningfully address equity issues by neglecting to involve the appropriate stakeholders. Because each region has a unique set of communities and challenges, identify approaches and resources for each step that reflect the local context. This guide includes case studies of equity analyses conducted by a variety of MPOs that may help agencies identify applicable solutions. Regardless of the local context, and the agency’s capacity for analysis and engagement, strive to bring the planning process closer to assessing and addressing equity concerns fully. Resources, including this guide, identify many practices that MPOs of any size can implement to take addi- tional steps toward equitable decision making. The resources listed in Table 3 can help agencies to assess their current equity analysis activities and to consider resources, methods, and strate- gies to address equity more fully. Citations and URLs for specific resources also appear in the resource lists that follow each chapter and in the references section of this guide. Table 3. Equity analysis elements, resources, methods, and strategies. Lay the Foundation with Public Engagement Resources • Develop an inclusive Public Engagement Plan: connect, educate, and sustain • FTA EJ Circular 4703.1 (2012); FTA Title VI Circular 4702.1B (2012); FTA 5310 Program Circular 9070.1G Enhanced Mobility of Seniors and Individuals with Disabilities Program Guidance (2014) • FHWA public involvement website • NHI/NTI EJ and public involvement courses • Develop a performance-based approach to conducting tailored engagement • Establish goals and metrics; evaluate progress • FHWA public involvement website • NHI/NTI EJ and public involvement courses • FHWA Performance-Based Planning and Programming Guidebook • Collect data to measure the effectiveness of outreach and engagement efforts • Outreach: number and distribution diversity of emails, social media posts, and “snail-mail” postcards or newsletters; number and diversity of media releases; number and locations of posted flyers • Engagement: number and diversity of participants engaged (home and work zip codes, household demographics, etc.) compared to regional demographic characteristics; participant evaluations of workshops, surveys, or focus groups; numbers and diversity of persons engaging in multiple ways Step 1: Identify Populations for Analysis Analysis Methods/Resources • Low-income households • U.S. Department of Health and Human Services poverty guidelines • U.S. Census Bureau • Ethnic and cultural minority households (e.g., Black, Hispanic/Latino, Asian American, American Indian, Native Hawaiian) • U.S. Census Bureau Persons with LEP •• U.S. Census Bureau • Local adult literacy programs or English as a second language programs (continued on next page)

10 Equity Analysis in Regional Transportation Planning Processes Table 3. (Continued). • Analyze access to transit and to destinations • Travel-demand model • Census journey to work data • Transit rider surveys and ridership statistics • Safe Routes to School program data • Stakeholder input • Conduct neighborhood-level analysis to hone in on issues identified at the regional level • GIS-based analyses • Stakeholder input • Neighborhood-level audits (e.g., conducting a walkability audit in a neighborhood that has a high number of pedestrian fatalities) Step 3: Measure Impacts of Proposed Agency Activity Analysis Methods/Resources • Assess transportation-related environmental impacts on underserved communities (e.g., air quality, noise, vibration, stormwater runoff) • Air quality or noise exposure analysis (using travel- demand model outputs) • GIS overlays • Stakeholder input • Consider destruction or disruption of community cohesion, economic vitality, use of public facilities and services, or potential displacement of persons or businesses • GIS analysis to identify potential physical barriers, land use impacts, or other disruptions introduced by new projects • Travel-demand model analyses • Identify potential denial of, reduction in, or significant delay in the receipt of, benefits of transportation programs, policies, or activities • Travel-demand model analyses to compare forecast outcomes • Transit analysis to identify potential reductions/ improvements in services • Comparative analyses of levels and types of transportation investments to improve safety, accessibility, and/or to address other needs identified • Other underserved persons relevant to the region • Stakeholder input • Create heat maps and dot-density maps to show how the numbers and concentrations of each population group vary across the region • GIS • Demographic data • Add demographic information to the travel-demand model’s traffic analysis zones (TAZs) to support assessments of relative benefits to various populations • Travel-demand model • Equivalency tables to match census data to TAZs • Identify high-priority areas for each required population • Heat maps and dot-density maps • Stakeholder input Step 2: Identify Needs and Concerns Analysis Methods/Resources • Gather qualitative data on needs of underserved persons • Stakeholder input • Survey the public on their needs. Include questions on demographics to ensure the demographics of the respondents reflect the demographics of the region; if not, conduct targeted surveys to reach the missing population groups • Assess environmental health and safety conditions • Guidance and resources relating to EJ • Analyze relative exposure to mobile source emissions (regional emissions models) and fatal crashes (Fatality Analysis Reporting System [FARS] data) • Walk/bike audits and other field research supplemented by public input Step 1: Identify Populations for Analysis Analysis Methods/Resources

Introduction 11 Table 3. (Continued). • Apply infrastructure design strategies to improve multimodal safety and accessibility • • • • Implement transit and ridesharing program improvements to support increased accessibility • • • • Develop strategies to reduce transportation-related household costs • • • Complete Streets policies that promote multimodal roadway design Strategic application of safety countermeasures in communities most at risk Road diets (e.g., reducing roadway lane widths to create safe spaces for cyclists and pedestrians) for existing or proposed facilities Increased transit service frequencies, headways, hours of service for underserved communities Improved pedestrian and bicycle access to transit for underserved communities Public-private transit and ride-hailing service programs to fill gaps and improve access to transit services Transit fare discounts and free services Highway toll discounts and vouchers Coordinated housing affordability programs in transit- accessible locations • Validate assessments using qualitative methods • Existing studies, surveys, and other supplementary information • Stakeholder input • If disparate impacts are found, determine why to help develop mitigation options • Ask “why?” . . . then “why?” . . . then “why?” • Eventually, answers will point toward actions the agency can take • Stakeholder input Step 5: Develop Strategies to Avoid or Mitigate Inequities Example Strategies • Implement institutional changes in decision making to address systemic disparities or needs • Equity goals, objectives, and targets to adopt a performance-based planning and programming approach to equity • Equity criteria in project evaluation criteria • Improve engagement with underserved persons • Examine decision-making structures for opportunities to give more organizational power to underserved communities • Examine how any modal funding targets address equity considerations • Apply roadway design and vehicle technology strategies to improve air quality • • • Retrofitted buses with increased emission control technologies Vegetated buffers along the highway to trap particulates Considering air quality when siting high-density housing Step 4: Determine Whether Impacts Are Disparate or Have DHAE Analysis Methods/Resources • Apply quantitative screening methods to evaluate levels of difference • Benchmarks • Statistical significance • Location quotients (LQs)