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

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63 By conducting a thorough study of needs and concerns, the impacts of existing programs and policies, and the likely impacts of proposed trans- portation investments and actions, an MPO will have determined whether disparate impacts exist. This determination should be based on a thoughtful and robust study, starting with a clear understanding of the needs and concerns of underserved individuals and communities in the region. Mitigation strategies should directly address identified dis parate impacts/ DHAE related to the needs and concerns that were identified in Step 2, as well as the impacts of proposed plans determined in Step 3. If, in Step 4, the agency found disproportionate impacts/DHAE within existing conditions or in the forecast outcomes of planning or program- ming activities, the next step is to develop strategies that avoid or mitigate the inequities. By addressing these existing and potential equity concerns “up front” in the planning and programming process, an agency is laying the groundwork for more equitable and effective project delivery in later stages such as NEPA analyses and construction. Toward this end, this chapter describes two broad tasks the agency can undertake: (1) invest in projects that advance equity, and (2) address equity in all phases of planning and decision making. Each broad task contains subsets of actions to consider or perform. Invest in Projects That Advance Equity Revise Project Evaluation Criteria Agencies can use project prioritization methods to support investments in underserved com- munities and that address the needs identified by underserved persons. Although it may be tempting for an MPO and its project sponsors to assume that simply locating a project adjacent to an underserved community will improve accessibility, this is not necessarily true. Points may be awarded only for projects with verifiable benefits. The agency also may deduct points from projects that pose some level of burden to underserved communities. MPOs are encouraged to develop equity-based project evaluation criteria for an efficient and wide-reaching practice to advance equity and to address identified needs and imbalances in the region. Now that all the effort has been put into conducting a meaningful equity analysis, the agency can use what was learned to modify the project evaluation criteria. Establishing project evaluation criteria at early stages of the planning process can set expectations for equitable planning and help ensure that underserved persons benefit equitably from transportation investment. C H A P T E R 7 Step 5: Develop Strategies to Avoid or Mitigate Inequities 1 Identify Populationsfor Analysis 2 Identify Needs andConcerns 3 Measure Impacts of Proposed Agency Activity 4 Determine Disparity/DHAE 5 Develop Strategies to Avoidor Mitigate Inequities Pu bl ic E ng ag em en t

64 Equity Analysis in Regional Transportation Planning Processes Various options exist for project evaluation criteria (see Table 12), but the most effective options require that the project sponsor describe verifiable benefits to underserved persons and estimate potential adverse impacts. For some ideas, review both the “Examples in Practice: Project Evaluation” and the “Example in Practice: LQs.” If the population-based approach is adopted, an agency can ask project sponsors to forecast the demographics of the project’s opening-day users. For bicycle and pedestrian projects, which are not well represented in models, use the demographics within the mile around the project, or use another scale for which data is available. Once the demographics have been captured, the agency can ask questions such as the following: • Do those demographics match that of the region? • When taken together with the other projects being considered, does the scenario or project portfolio benefit a group of people that has demographics matching that of the region? • Did the needs assessment identify needs of underserved communities? If so, do the projects proposed in those areas address those needs? • Does the process for developing project proposals or applying for grant funding pose barriers to underserved communities? • Did the impact assessment show any disparities? What kinds of investments are needed to address those disparities? • Were modal funding targets considered? MPOs may use targets for the percentages of funding given to each mode in competitive processes they manage. For example, 30% may be targeted to transit, 50% to roads, and 20% to bicycles and pedestrians. This funding distribution also can involve equity issues that won’t be addressed in individual project evaluation criteria. Fund Activities That Remedy Disparate Impacts/DHAE Although equity analyses can be used to score or respond to proposed projects and programs, an MPO also can take proactive steps to address disparate impacts/DHAE, such as proposing projects to help mitigate these impacts/effects or projects that are otherwise beneficial to under- served populations. Examples of mitigation strategies that can be considered include transit and rideshare projects and strategies designed to improve household transportation costs, air quality, and safety. Project Evaluation Criteria MPO Reduce the score of a roadway project in the MTP if it adds vehicle lanes in an underserved area Charlotte County-Punta Gorda Award points for MTP transit system expansion projects serving an underserved community, and for TIP projects that benefit census tracts with high indicators of “Potential Disadvantage” communities DVRPC Award points depending on the degree to which a TIP project in an underserved community improves access to opportunities East-West Gateway Council of Governments Add or subtract points for TIP projects adjacent to underserved communities depending on net positive or adverse impacts to the adjacent communities (e.g., add points for transit improvements, safety enhancements, bicycle/pedestrian improvements, subtract points for displacement of residents or creating barriers) Memphis Urban Area MPO Award points to TIPs for projects that improve multimodal accessibility in EJ areas, and to projects that benefit public health (particularly in areas with health outcome disparities) by improving safety, providing community/social space, and/or improving access to parks/open space, health care, healthy foods, and opportunities for physical activity MATPB Table 12. Selected MPO MTP and TIP project evaluation criteria.

Step 5: Develop Strategies to Avoid or Mitigate Inequities 65 Transit and Rideshare In many areas, a high percentage of underserved households do not have access to a vehicle; therefore, the members of those households rely on transit. Gaps in mobility can be addressed by focusing investments in areas with high concentrations of low-income or zero-vehicle house- holds. Examples of transit and ridesharing programs improvements to implement include: • Increased transit service frequencies, headways, hours of service for underserved communities; • Improved pedestrian and bicycle access to transit for underserved communities; and • Public-private transit and ride-hailing service programs to fill gaps and improve access to transit services. Household Transportation Costs Underserved households often spend a greater share of their income on transportation. An agency can implement efforts to help reduce the cost of transportation for these households in several ways. Examples include: • Transit fare discounts and free services, • Highway toll discounts and vouchers, and • Coordinated housing affordability programs in transit-accessible locations. Examples in Practice: Project Evaluation • As part of its 2017 regional transportation plan, Oregon’s Rogue Valley MPO conducted a formal needs assessment study to understand the needs of underserved persons in the region. The agency then revised their project evaluation criteria to reward projects that would address the needs identified in the study (Rogue Valley MPO 2017). • The MORPC examines its project portfolio in relation to the region’s demographics to assess how the projects and scenarios benefit people with demographics matching that of the region (MORPC 2017). • In Missouri, the MARC identified that bicycle and pedestrian fatalities were disproportionately occurring in underserved communities in the urban core. They studied the distribution of safety funding (to see how well they were addressing the need), and realized that most of the safety funding was going to suburban communities. The agency investigated the reason for this pattern and learned that the grant-based safety funding was only awarded to communities that had the capacity to write government funding proposals. The MARC then began developing safety countermeasures to apply in the underserved communities that were experiencing the disparate impact (MARC 2015). • The PSRC in Washington State uses a performance matrix for equity for proj- ects in consideration for its TIP (PSRC 2017). A project’s ability to improve access to “opportunity” for minorities, low-income households, older adults, people with disabilities, and members of zero-car households can earn up to 10 points out of an overall total of 90 points. “Opportunity” is defined by 20 indicators related to education, economic health, housing and neighborhood quality, transportation/mobility, and health and environment.

66 Equity Analysis in Regional Transportation Planning Processes Air Quality Air pollution is often an issue for underserved populations that live in close proximity to highways. To address disproportionate impacts from air pollution, options include: • Retrofitted buses with increased emissions-control technologies, • Vegetated buffers along the highway to trap particulates, and • Considering air quality when siting high-density housing. Safety Safety is also often a concern that disproportionately impacts underserved communities. Options for MPOs include roadway design strategies that improve multimodal safety and accessibility, such as: • Complete Streets policies that promote multimodal roadway design, • Strategic application of safety countermeasures in communities most at risk, and • Road diets (e.g., reducing roadway lane widths to create safe spaces for cyclists and pedes- trians) for existing or proposed facilities. Safety considerations involve broader issues than just protection from cars. For example, transportation-related policing concerns also are common among communities of color and low-income populations. The Met Council’s long-range transportation plan, Thrive MSP 2040, includes safety strategies that address policing concerns by identifying best practices and recom- mendations for policing practices and building public trust (Met Council 2018). Address Equity in All Phases of Planning and Decision Making The first part of this chapter dealt with mitigation strategies focused on specific identified impacts. To advance equity over the long term, however, it is important to institutionalize concepts and processes in order to make equity analysis standard during all steps of the plan- ning and decision-making process. Including research and other initiatives in work plans will generate data or information that can be used in tangible follow-up activities. Such follow-up activities could include: • Level-of-traffic-stress bikeway network analyses to identify gaps in the low-stress network serving underserved communities; • Studying potential disparate impacts/DHAE in preservation/maintenance spending, in trans- portation infrastructure condition, and in safety outcomes; or • Setting objectives such as having 100% sidewalk coverage within 1 mile of all schools and grocery stores. Improve Underserved Persons’ Engagement in Planning Processes A theme stressed throughout this guide has been the critical importance of public engagement during each stage of the planning process. Under 23 CFR 450.316, MPOs are required to develop strategies and desired outcomes that are articulated through a participation plan. As stipulated in 23 CFR 450.316: (a) The MPO shall develop and use a documented participation plan that defines a process for providing . . . representatives of users of public transportation, representatives of users of pedestrian walk- ways and bicycle transportation facilities, representatives of the disabled, and other interested parties with reasonable opportunities to be involved in the metropolitan transportation planning process.

Step 5: Develop Strategies to Avoid or Mitigate Inequities 67 (1) The MPO shall develop the participation plan in consultation with all interested parties and shall, at a minimum, describe explicit procedures, strategies, and desired outcomes for: . . . (vii) Seeking out and considering the needs of those traditionally underserved by existing transportation systems, such as low-income and minority households, who may face challenges accessing employment and other services. . . . Beyond the legal mandates, effective engagement helps to ensure that the end product of the planning process is meaningful to the communities it is intended to benefit. Take a holistic approach focused on including underserved persons throughout the transportation decision-making process, especially when actions could impact their well-being. Inclusion strategies are discussed in more detail in Chapter 2 on public engagement, and include tech- niques for improving public involvement such as ensuring that advisory committees and decision-making bodies have diverse representation and that their role as advisors rather than decision makers is clearly defined. Adopt Equity Goals in Plans and Policies Agency plans and policies can incorporate policy goals to promote equity and access for underserved persons. Equity goals can be integrated at various levels. For example, • High level policy goals can be useful for explaining to constituents why equity should be improved in the region. Example in Practice: Using Community Input to Develop and Refine a Technical Approach Following an equity assessment, the Oregon Metro received criticism from underserved persons during public engagement efforts. The criticism reflected the fact that the agency’s methodology had failed to evaluate the outcomes and impacts that mattered most to this population. To remedy this failure, Metro convened the Transportation Equity Assessment Working Group for the development of its 2018–2021 MTIP Transportation Equity Assessment. The process was to be led by representatives of underserved groups who had identified accessibility, affordability, safety, and public health as key areas of concern. These themes were translated into system evaluation measures that could be applied to the analytical framework developed in consultation with this group. This assessment took the form of an equity-based scenario planning analysis that will compare base-year conditions and anticipated conditions resulting from the short-term investment program (Oregon Metro 2016). The Oregon Metro’s Data and Research Department then developed a suite of tools for this effort that could support the modeling of changes in eco- nomic, demographic, land use, and transportation activity. As developed, the tools also use GIS and the region’s travel-demand model to assess connectiv- ity, safety, and other outcomes of the investment program on underserved communities. The Oregon Metro’s effort to involve underserved persons early and throughout the duration of its equity assessment will help to ensure that (1) the perspectives of underserved persons are well represented, and (2) the outcomes of these efforts will be meaningful to the populations they are designed to serve.

68 Equity Analysis in Regional Transportation Planning Processes • Specific goals can be created that relate to equity issues that have been identified in the region, such as avoiding displacement or reductions in transportation access. These specific goals usually focus on either reducing burdens or improving access to benefits for underserved populations. • Equity goals also can be incorporated into other work. For example, the pedestrian element of a plan could include a goal to improve pedestrian infrastructure in neighborhoods with high numbers of underserved residents. Evaluate and Measure Progress Mitigation efforts, such as adopting policies or increasing participation of underserved popu- lations in the planning process, need to be accompanied by efforts to evaluate progress and ensure that the measures undertaken have a positive impact on underserved persons. As with any performance-based planning and programming approach, it is important to define perfor- mance measures, set targets, and measure progress. Measuring progress helps the planning process be more transparent and holds the agency accountable for actions. Equity performance measures can provide quantifiable ways to measure progress and increase the transparency and accountability of equity-focused planning activities. Likewise, a performance-based approach can be used to incorporate quantifiable equity considerations into project prioritization in MPOs’ TIPs. These performance measures can be shared with the public using online dashboards (such as those powered by Tableau and Highcharts), which allow visitors to intuitively engage with the performance data. The San Francisco MTC’s Vital Signs dashboard is one example. Select measurable goals, targets, and other metrics to reflect the priorities of the region and underserved persons within the region. Examples of measurable goals include (but are not limited to) minimizing disparate impacts/DHAE in transportation costs, commute times, bicycle and pedestrian infrastructure, safety, and asset conditions, and/or accessibility to jobs, services, schools, recreation, retail, and other important destinations. While taking steps to address identified disparate impacts/DHAE, continue to involve underserved persons to ensure that the agency’s strategies are in line with their needs and con- cerns. Continuing to track progress and conduct meaningful public engagement throughout all stages of the planning process will help prioritize equity goals and anticipate challenges faced by underserved persons. Include Equity Initiatives in UPWPs Include research and other initiatives in work plans in order to generate data or information that can be used in a tangible follow-up activity. Such initiatives can include activities such as level-of-traffic-stress bikeway network analyses to identify gaps in the low-stress network serv- ing underserved communities; studying potential disparate impacts/DHAE in preservation/ maintenance spending, in transportation infrastructure condition, and in safety outcomes; or setting objectives such as having 100% sidewalk and ADA-compliant curb ramp coverage within 1 mile of all schools and grocery stores. Resources Charlotte County-Punta Gorda MPO. 2015. 2040 Long-Range Transportation Plan, Chapter 9: “Socio-Cultural Project Prioritization Criteria.” Retrieved from: https://ccmpo.com/wp/2040-long-range-transportation- plan-lrtp-update/.

Step 5: Develop Strategies to Avoid or Mitigate Inequities 69 DVRPC (Delaware Valley Regional Planning Commission). 2013. Connections 2040 Plan for Greater Philadelphia. Retrieved from: http://www.dvrpc.org/Connections2040/. DVRPC. 2017. Transportation Improvement Program [main document and Appendix D]. Retrieved from: http://www.dvrpc.org/TIP/. East-West Gateway Council of Governments. 2016. Transportation Improvement Program, FY2017–2020. Retrieved from: http://www.ewgateway.org/trans/tip/tip.htm. FHWA. 1999. Interested Parties, Participation, and Consultation. 23 CFR 450.316. Retrieved from: https:// www.fhwa.dot.gov/legsregs/directives/fapg/Cfr450c.htm. Madison Metropolitan Area Transportation Planning Board. 2018. Madison Metropolitan Area and Dane County Transportation Improvement Program 2019–2023. Retrieved from: http://www.madisonareampo.org/ planning/documents/2019_2023TIPFinalWeb.pdf. Memphis MPO. 2016. FY 2017–2020 Transportation Improvement Program. Retrieved from: http:// www.memphismpo.org/plans/fy-2017-20-transportation-improvement-program. Met Council (Metropolitan Council of Minneapolis–Saint Paul). 2018. Thrive MSP 2040: Transportation Policy Plan, Chapter 10: Equity and Environmental Justice. Retrieved from: https://metrocouncil.org/ Transportation/Planning-2/Key-Transportation-Planning-Documents/Transportation-Policy-Plan/tpp- update/2018-Transportation-Policy-Plan-Update/Chapter-10-Equity-and-Environmental-Justice.aspx. MTC (San Francisco Bay Area Metropolitan Transportation Commission). 2015. Regional Equity Working Group. Retrieved from: https://mtc.ca.gov/about-mtc/what-mtc/mtc-organization/interagency-committees/ regional-equity-working-group. MARC. 2015. Transportation Outlook 2040. Retrieved from: http://www.to2040.org/. MORPC. 2017. 2016–2040 Columbus Area Metropolitan Transportation Plan, Appendix 3, Environmental Justice Analysis. Retrieved from: http://www.morpc.org/wp-content/uploads/2017/12/MORPCTIP2018- 2021Appendix3EJ.pdf. Oregon Metro. 2016. Strategic Plan to Advance Racial Equity, Diversity and Inclusion. Retrieved from: https:// www.oregonmetro.gov/strategic-plan-advance-racial-equity-diversity-and-inclusion. PSRC. 2017. Guidance for Responding to the Transportation 2040 Prioritization Measures. Retrieved from: https://www.psrc.org/sites/default/files/2017_prioritization_guidance.pdf. Rogue Valley MPO. 2017. Rogue Valley Regional Transportation Plan, 2017. Retrieved from: https://www.rvmpo. org/index.php/ct-menu-item-13/regional-transportation-plan-rtp.