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15 Findings and Applications The organization of this chapter follows the chapters and steps of the guide. It begins with a foundation section discussing public involvement and proceeds through the five-step equity analysis framework: (1) identifying populations, (2) assessing needs, (3) measuring impacts, (4) determining whether impacts are disparate, and (5) mitigating inequities identified by the analysis. The recommended approaches and practices described in the guide have been studied and applied in various ways, but this project is the first to bring all the aspects together into a simple, practitioner-focused, five-step framework. In this chapter, each section discusses the reasons for including the associated step, the state of the practice, the best practices discovered during the research, recommended approaches, and open challenges and research questions. The literature review (included as Appendix A in this volume) provides details on regulatory requirements and the findings from the research teamâs scan of the state of the practice. The final version of the reference guide (published as Volume 1 of TCRP Research Report 214) provides more details on the best practices and recommended approaches for each step. Many researchers and some MPOs use the phrase communities of concern as an inclusive term to describe populations required under Title VI and EJ and other populations that may be being analyzed. The phrase appears in the literature review and was used in the draft guide. Upon reviewing the draft guide, however, the panel and the research team agreed to change the language for two reasons. First, the phrase communities of concern can be interpreted as suggest- ing that something is wrong with low-income and minority individuals. Like the needy or the handicappedâother phrases no longer in common useâcommunities of concern can perpetuate patronizing stereotypes about individuals who, for purposes of analysis, have been grouped into various socio-economic classifications. One such stereotype is that such individuals are less capable of participating effectively in civic life. Second, the word communities suggests discrete, geographically defined groups. Effective analysis of the needs and concerns of underserved pop- ulations should apply not only to particular geographic areas, but to all persons who fall within the social and economic classifications specified by federal laws and directives. Based on additional research and feedback received from the panel, the research team adopted the following terms for the guide and this report: â¢ Required populations and required population groups are terms that refer to the population groups for which analyses are required to comply with federal laws and guidance relating to Title VI and EJ. These population groups include minority and non-minority racial/ethnic populations, low-income and non-low-income populations, and LEP populations. â¢ Underserved persons refers more broadly to any person of a population group that may face particular accessibility barriers or mobility challenges, whose needs would be relevant to C H A P T E R 3
16 Equity Analysis in Regional Transportation Planning Processes analyses of equitably distributed benefits and burdens of transportation services and invest- ments. Required populations may fall into this broader category, as may other populations such as older adults or persons with disabilities. â¢ Underserved communities refers to geographic areas or neighborhoods in which under- served persons live. This term acknowledges the practicality and usefulness of mapping neighborhoods as part of equity analysis and transportation planning. As emphasized in the guide and in this report, such mapping is most effective when it is conducted in conjunction with an effective public engagement effort that continues throughout the equity analysis process. â¢ Equity stakeholders refers to individuals and organizations that represent the interests of underserved populations. These stakeholders include, for example, people who identify with one or more of the required population groups, and people that work with underserved populations who can provide knowledgeable insights about their needs and concerns. â¢ Disadvantaged refers to specific types of unfavorable circumstances. Per federal law, socially disadvantaged persons include persons who have been subject to racial or ethnic prejudice or cultural bias within American society because of their identification as members of particular groups without regard to their individual qualities. Economically disadvantaged persons refers to socially disadvantaged individuals whose ability to compete in the free enterprise system has been impaired due to diminished capital and credit opportunities. Lay the Foundation with Public Engagement Many of the resources reviewed, including guidance from both the FHWA and the FTA, emphasize the need for engaging with underserved persons throughout the process of conduct- ing an equity analysis. Guidance generally recommends that MPOs engage early and often with underserved persons throughout the planning process. Public engagement is a critical component of equity analyses. Beyond notifying underserved persons about the plan or project in question, public engagement provides a way for MPOs to create equity analyses that are meaningful to the underserved persons the analyses are intended to benefit. Equity indicators and analyses attempt to evaluate something that is inherently difficult to measure, and in any analysis many subjective decisions will go into developing the assumptions and methodology. Engaging with local equity stakeholders early in the process and throughout the process can help agencies determine reasonable thresholds, prioritize what characteristics and criteria are included in each measurement, and establish some legitimacy for the subjective elements of the process. State of the Practice The research team did not comprehensively review MPOsâ public participation plans, which outline agenciesâ outreach approaches in general terms. Instead, the literature review focused on documentation of public engagement within MTP/TIP equity analyses. For purpose of this study, it was important to identify how the broad range of strategies and policies were applied specifically to the MTP and the TIP. Many MPOs have described in detail how the agency has collected information on the needs of underserved persons (e.g., by documenting the number of meetings held in underserved communities) and documented the practices the agencies use to engage underserved persons (e.g., providing materials in different languages or holding meetings outside of working hours); however, existing documentation reviewed by the research team did not always make clear how the input from underserved persons influenced the equity analysis or other aspects of agency decision making.
Findings and Applications 17 Best Practices and Recommended Approaches Public involvement is recommended throughout each step of the equity analysis process. It is important to note that the outreach options available to agencies include all levels of effort and expense. Agencies can include outreach and feedback with underserved populations as part of their other public involvement activities, and standing committees of underserved persons or related stakeholders can be an invaluable resource for helpful critiques and validation of the agencyâs assumptions, methods, and findings. To ensure that underserved personsâ input is received and used, agencies should adopt performance measures to capture their level of engagement, document the feedback received, and document how that feedback influenced the agenciesâ equity analysis or other aspects of agency decision making. The two volumes of TCRP Research Report 214 (the guide and this report, including the literature review) provide options and recommended practices that relate directly to conducting an equity analysis. For additional examples of effective practices for public involvement and, in particular, for engaging underserved persons, practitioners are encouraged to consult the robust literature available from federal agencies, TRB, and non-governmental organizations. Open Challenges and Research Questions Most agencies employ targeted strategies to engage equity stakeholders in the planning process, but often the connections between the input and the decision-making process are not clearly described. Some agencies interviewed expressed concerns about the resources required to conduct a NEPA-level equity analysis and public engagement campaign as part of long-range plans and programs. They did not seem aware that the planning regulations are intentionally less prescriptive and detailed than the NEPA regulations. Agencies are advised to consult FHWA resources such as the Planning and Environmental Linkages Toolkit (www.environment.fhwa. dot.gov/env_initiatives/pel/implementation.aspx), Environmental Justice Reference Guide (https://www.fhwa.dot.gov/environment/environmental_justice/publications/reference_ guide_2015/fhwahep15035.pdf), and PlanWorks (https://fhwaapps.fhwa.dot.gov/planworks). Step 1: Identify Populations for Analysis Equity analyses seek to compare impacts experienced by different population groups. To conduct this comparative analysis, agencies must identify distinct segments of the population. At a minimum, agencies are required to identify locations and characteristics of the populations specified in Title VI (and, by extension, E.O. 13166), and E.O. 12898. Title VI requires the consideration of the needs and concerns of all persons served by the agency, inclusive of all races, ethnicities, and national origins. Reinforcing Title VI, E.O. 13166 requires agencies to ensure full access to the decision-making process by individuals who do not speak, read, or write English, while E.O. 12898 requires agencies to consider the needs and concerns of individuals from specific minority populations and of low-income individuals. The comparative analysis of benefits and burdens required by E.O. 12898 does not extend to the population specified in E.O. 13166, but planners must identify and consider the needs of LEP populations and those covered under EJ and protected under Title VI to fully achieve equity in transportation decision making. To conduct a comparative analysis of any kind, the analysis must study a population of interest and a relative control population to which the population of interest will be compared. In equity analyses, this would mean, for example, that when an agency evaluates impacts on
18 Equity Analysis in Regional Transportation Planning Processes minority persons, the agency must gather the same data for non-minority persons so the agency can compare the results produced in relation to each of the two population groups. State of the Practice MPO equity analyses generally do cover the required populations: minority persons, low-income households, and LEP persons. MPOs also frequently include other underserved populations, such as persons with a disability, zero-vehicle households, and older adults. Other populations that may be studied less frequently included female heads of households, young persons, single-parent households, rent-burdened households, veterans, foreign-born persons, and adults without a high school diploma. These analyses usually rely on the U.S. Census Bureauâs American Community Survey (ACS) data to identify the relevant populations, but some agencies have developed local databases. Agencies differed somewhat in how they defined âlow-income.â Some followed the U.S. Department of Health and Human Services (DHHS) poverty guidelines, as recommended by U.S. DOT EJ guidance. Others adopted definitions based on the regional median income or in relation to the national poverty guidelines (e.g., 200% of the DHHS poverty guidelines). Most of the MPOs identified the total number of persons within the different required popu- lations, but their needs assessments and comparative impact analyses almost always limited the focus to geographic areas that the agencies designated as having high concentrations of the required populations (e.g., minority areas, low-income areas, or LEP areas). Nearly all of the MPO plans reviewed followed the same basic process: 1. Collecting data on different population groups at a particular geographic scale (census tract, block group, or TAZ); 2. Setting a numerical threshold for what constitutes a âsignificantâ concentration of each population group; and then 3. Identifying the tracts, block groups, or TAZs where the percentage of people or households in a given population group exceeds the threshold. Not all MPOs whose plans were reviewed explained their basis for setting thresholds, but of those that did, most used the regional average. For example, an agency might use the regional average concentration of minority persons as a threshold and then declare that all census tracts exceeding that threshold are âminority tracts.â The agencyâs analysis then considered only the populations of those tracts as the minority populations for the needs assessments and impact analyses. Although the relative percentages of different populations in different areas is a useful indicator for understanding what areas might need attention from an equity lens, the use of a bright-line threshold is not endorsed by federal agencies. The commonly used approach of limiting the analysis of a population to those who reside in a given âzoneâ raises several issues: â¢ When an agency limits its equity analysis to only the geographic areas (e.g., census tracts) that meet a predetermined threshold, it runs the risk of overlooking the experiences of underserved persons that live in other areas. As an alternative to this approach, the MORPC attaches minority status and income level data to TAZs so that it can run assessments for all persons in required populations. â¢ When the thresholds are based on the concentration of underserved persons, the analysis risks overlooking relatively diverse areas that have high numbers, but not high percentages, of underserved persons. In Bismarck, North Dakota, the Bismarck-Mandan MPO mitigates this problem by generating thematic population distribution maps of all underserved persons.
Findings and Applications 19 â¢ The areas that fall just to either side of a threshold (e.g., a TAZ with 19% minority persons next to a TAZ with 21% minority persons in a study with a concentration threshold of 20%) may be very similar demographically and may experience very similar impacts from the transportation system or agency activities. If these similar areas are used in the comparative analysis, the analysis might not capture disparate impacts or DHAE that may exist among areas that are more dissimilar in their demographic makeup, such as an area with 1% minority persons compared to an area with 99% minority persons. A few agenciesâamong them the Atlanta Regional Commission (ARC), the Metropolitan Area Planning Agency (MAPA) of Omaha, Nebraska, and Council Bluffs, Iowa, and the Metropolitan Transportation Commis- sion (MTC) serving the San Francisco Bay area of Californiaâavoided this problem by setting their thresholds at a standard deviation away from the median. â¢ Using the regional average as a threshold could result in large swaths of the region falling within the threshold. This can make it difficult for agencies to pinpoint issues or to set invest- ment priorities. Agencies including the ARC, the Baltimore Regional Transportation Board, the Delaware Valley Regional Planning Commission (DVRPC), the Puget Sound Regional Council (PSRC), and the Southern California Association of Governments (SCAG) have avoided this problem by creating indices that help them identify areas with multiple indicators of potential disadvantage. â¢ If an agency does not document its rationale for selecting a threshold, the selection can appear arbitrary to constituents, which may reduce equity stakeholdersâ willingness to engage in the process. Best Practices and Recommended Approaches Rather than rely on the use of bright-line thresholds to categorize entire TAZs or census block groups, the guide recommends that agencies start by studying the complete regional distribution of underserved populations. Options for doing so include using heat maps that assign color gradations to levels of underserved population percentages across geographic areas; dot-density maps to show the numbers of underserved persons in each area; and attaching demographic information to TAZs in the travel-demand model. The research revealed that a few agencies use these approaches rather than relying on bright-line thresholds (e.g., the Bismarck- Mandan MPO and the MORPC). The general process that MPOs use to add demographics to travel-demand models at the TAZ level is summarized in the following steps: 1. Download demographic data from ACS; 2. Create TAZ equivalency table; 3. Develop forecasts for population groups within TAZs; 4. Conduct quality control review; 5. Refine assumptions. After understanding the regional distribution, the guide recommends identifying high- priority areas that have high percentages and high numbers of each of the population groups selected for analysis. Threshold concentrations, such as the regional average or one standard deviation from the mean, can be helpful indicators for identifying high-priority areas, but agencies are encouraged to work with equity stakeholders to gather input and feedback to ensure that the most appropriate areas are included. The review of the state of the practice revealed that several agencies use index approaches to identify high-priority areas, and the guide provides a brief overview of this approach. These index approaches risk washing out the analyses necessary for complying with Title VI and EJ guidelines by commingling the analysis for required populations with other population groups; for this reason, the guide does not delve into providing complete instructions for creating
20 Equity Analysis in Regional Transportation Planning Processes such an index. The indices are useful for identifying areas with many types of underserved popula- tions and can be used to supplement the required analyses. Practitioners interested in using index approaches can find more information in the literature review (Appendix A to this report). Open Challenges and Research Questions Some MPOs may be not meeting Title VI and EJ requirements fully in their equity analyses. The project team found instances of MPOs that did not include LEP populations in their MTP or TIP analyses, though they may have addressed LEP populations in a separate docu- ment such as a Title VI policy or public participation plan. MPOs that use indices to define their areas for analysis run the risk of inadequately accounting for required populations if indices are not structured so that areas with required populations (low-income, minority, or LEP) are always included and the significance of their presence is not diluted by the presence of other indicators. Creating a demographic analysis that is both inclusive and meaningful is a challenging pro- cess. An inclusive analysis covers a larger number of population groups and/or encompasses more communities. A meaningful analysis focuses on those populations with the greatest need to support a clearer determination of disparate impacts. The research teamâs review suggests that defining underserved communities such that they cover most of a region might not support a meaningful analysis. On the other hand, defining the locations and numbers of required populations too narrowly can lead to results that overlook important concerns affecting persons outside of the identified EJ zones. The best practice is to study the locations and characteristics of required populations in more than one way, andâmost importantlyâto work with equity stakeholders to develop a meaningful, complete depiction of underserved persons for analysis. The research also investigated options for understanding demographic change as regions deal with gentrification, increased immigration, and other potential changes in the makeup and distribution of underserved persons. A few very high-capacity agencies are beginning to develop approaches to these questions. In the San Francisco Bay area, for example, the MTC is identifying the locations of rent-burdened households. Nonetheless, the research team chose not to include instructions for these approaches in the guide for three reasons: 1. They seemed to be used primarily by MPO host agencies acting outside of their function as a transportation agency (e.g., regional councils conducting affordable housing or sustainable development plans); 2. They are just starting to take hold in a few agencies and require more development before being recommended to a wider audience of transportation practitioners; and 3. They seemed to require a high level of technical capacity, whereas the guide has been designed to focus on methods that are accessible to MPOs of all technical capacities. Given the state of the practice, the research team chose to prioritize the basics of a meaning- ful equity analysis rather than going into all the possible options. That said, these emerging experiments to incorporate broader equity-related analyses into transportation plans could be a valuable subject for further research. Step 2: Identify Needs and Concerns The MPOs studied for this project typically conducted the Step 2 analysis by mapping and analyzing data to understand the accessibility and mobility needs of underserved persons. This process generally involved overlaying data on equity indicators with the location of underserved persons to determine which issues were particularly prevalent in underserved communities.
Findings and Applications 21 Many of the agencies also conducted targeted public involvement activities to gain qualitative insights on issues such as institutional barriers to civic participation. The agencies that involved equity stakeholders in the Step 2 process also tended to engage them in later stages, such as determining appropriate measures for assessing disparate impacts (Step 3 and Step 4) and identifying strategies to improve outcomes (Step 5). The indicators that were used by MPOs in assessing needs differ in two important ways from the performance measures used for later stages such as impact analysis. First, needs assessment indicators can be broader in scope than traditional planning and programming performance measures, capturing issues such as housing costs or access to healthy food that are of high importance to underserved persons. These issues can be difficult to address via transportation strategies alone, but examining these indicators for a broad-based needs assessment can help an MPO to later select related indicators for the impact analysis and to identify strategies for improving conditions for underserved persons. Second, because a needs analysis involves measuring current conditions rather than estimating future impacts, an MPO can collect data on indicators in the context of a needs assessment that they may not be able to predict in an impact analysis, such as vehicular crashes. The literature review discusses several relevant indicators for accessibility, transportation options, affordability, and health and safety (see Appendix A). These needs assessment measures can be used to identify regional equity gaps, which an MPO can then use to develop new performance measures and strategies for closing those gaps. State of the Practice Most agencies complete some form of the Step 2 needs assessment. For example, many of the agencies studied created maps showing the existing transit system and walk buffers around the transit stops. The agencies then overlaid these maps over their equity areas. The literature review covers these approaches in greater detail (see Appendix A). Some agencies described steps they took to ask underserved persons about their needs, but the research team frequently could not find documentation of the specific needs that were identified through this process. Few MPOs, however, document the ways in which the needs identified during Step 2 are ultimately addressed in plans or programs. The Step 2 needs assessment often stands alone, disconnected from the impact analyses (Step 3 and Step 4) and strategies (Step 5). Failing to visibly link the findings of Step 2 to planning and programming decisions puts the agency at risk of non-compliance with Title VI and EJ requirements, and it can make equity stakeholders feel that their participation in the process of identifying needs was not meaningful. Best Practices and Recommended Approaches The approaches to identifying needs seemed to generally apply either at the regional level or at the neighborhood scale. The topics addressed at the regional scale are similar to those considered at the local scale, but local-level efforts require a greater level of detail. The research team determined that the most meaningful approach was to identify big-picture regional issues first, and then delve into more localized areas for which additional investigation may be warranted. For example, if regional comparison of travel times among different popula- tion groups reveals longer commutes associated with TAZs that have high concentrations of low-income households, a localized assessment could be conducted to cross-reference local transit routes with the origin-destination patterns stemming from those TAZs. The results could help the agency identify transit service gaps that may be contributing to the unusually long commute times.
22 Equity Analysis in Regional Transportation Planning Processes Regardless of the scale of analysis, a robust needs assessment requires input from equity stakeholders. Agencies must employ public involvement techniques to engage stakeholders in critical tasks such as identifying issues of interest; assessing exposure to the existing burdens of the transportation system (e.g., environmental and safety risks); understanding the receipt of benefits of the transportation system (e.g., access to destinations); and validating the agencyâs findings. Some of these needs assessments are conducive to producing the comparative analyses discussed in Step 3 and Step 4 to understand whether there are disproportionate differences in the experiences of differing population groups (e.g., numbers of pedestrian fatalities in under- served communities versus their relative control communities). Others (e.g., transit travel sheds around grocery stores in relation to underserved communities) might not lend themselves as easily to comparative analyses but can help an agency identify indicators to use for assessing their impacts or needs to address in their plans and programs. Still other methods might be useful for both stages (the needs assessment and the impact analysis). The Memphis Urban Area MPO conducted a transit gap analysis (Step 2) that focused on underserved communities where travel times by transit far exceeded travel times by auto- mobile (i.e., current needs). The agency analyzed how transit routes and extensions in their plan would improve the transit travel times in those areas (Step 3) and found several gaps that the proposed improvements did not bridge. The MPO then investigated and recommended transit improvements (Step 5) that could improve access from those underserved communities to major employment areas (Memphis Urban Area MPO 2016). Open Challenges and Research Questions The research team noticed some uncertainty among practitioners (and some researchers) as to the difference between the indicators of needs (Step 2) and the indicators of impacts from agency activity (Step 3). For this project, the researchers assumed that needs assess- ments capture existing benefits and burdens that have resulted from past agency actions (e.g., higher rates of asthma among low-income persons living near congested freeways) whereas impact analyses measure potential benefits and burdens that the agencyâs future actions could affect (e.g., scenarios depicting the potential numbers of jobs accessible to different population groups given alternative transportation investment packages). The agency ideally uses the information from both types of indicators (Step 2 and Step 3) to identify strategies that can help to address current gaps and that mitigate or avoid negative potential future results (e.g., programming increased safety countermeasures in underserved communities). New research could be conducted to develop and encourage the use of a more standardized approach to (1) selecting indicators of current needs and indicators of potential impacts, (2) applying them together toward a robust understanding of distributions of benefits and burdens (Steps 3 and 4), and (3) developing mitigation strategies (Step 5). The research would review existing literature, case law, and agency guidance. One possible approach would be to convene a discussion group or conduct a broader survey of researchers, practitioners, equity stakeholders, and policymakers to attempt to develop a recommended or standardized approach. Step 3: Measure Impacts of Proposed Agency Activity During this step, MPOs assess proposed plans, programs, or projects to determine whether the anticipated benefits and burdens would be equitably distributed between populations of underserved persons (e.g., minority persons, low-income persons) and the rest of the
Findings and Applications 23 population. The assessment process involves selecting indicators of impacts, measuring the changes in selected indicators given a scenario (e.g., a package of proposed investment for the long-range plan), and comparing results for underserved persons (e.g., low-income persons) to results for all other âcontrolâ populations (e.g., all other income cohorts). If the agencies find that the result of an impact analysis for any underserved population group differs from its respective control population, then the agency must determine whether the difference is disparate or generates DHAE (Step 4). To comply with Title VI and EJ requirements, agencies need to take a comprehensive view in selecting indicators of impacts. Impacts include not only explicit burdens (e.g., increased exposure to congestion-related mobile source pollution), but also, as specified in E.O. 12898, the âdenial of, reduction in, or significant delay in the receipt of benefitsâ (e.g., decreasing transit service coverage in an area with low-income populations while increasing it in an area with higher-income populations). A fuller description of the relevant regulations and guidance can be found in Appendix A. As is the case with each step of the analysis process, input from underserved persons and equity stakeholders is essential for selecting indicators and for identifying impacts that might not be adequately assessed using the available indicators. No indicator or suite of indicators will capture the full range of potential impacts, and all analysis methods have their strengths and weaknesses. Agencies should be clear with stakeholders and decision makers about the meaning of the analyses, acknowledging what the selected indicators can measure, and what they cannot measure. State of the Practice To conduct an impact analysis for a plan or program, many MPOs overlay maps of proposed projects on maps of the locations of the required populations identified in Step 1 (typically, TAZs or other geographic âEJ zonesâ that meet an agency-specified concentration such as a standard deviation from the regional average). These analyses usually conclude that the impacts are equitably distributed if the project locations are equitably distributed. This relatively simple approach can provide a broad-brush picture of potential equity implications, assuming that the Step 1 maps of underserved populations are sound. That said, simple proximity to a transportation project is not, in and of itself, an indicator of either benefit or burden. If part of a new limited-access freeway is located in an EJ zone, for example, the simple conflation of project location with net benefit would support a finding of benefit to that zone. Limited-access freeways tend to benefit regional traffic more than local traffic, however, especially if no interchange is located in or near the underserved community. Further- more, these types of facilities can increase exposure to noise, air pollution, and associated health risks. If a Step 2 needs assessment has identified existing concerns of this nature in the underserved community, the new project might exacerbate the problem. The findings should be examined at some deeper level before conclusions are drawn. Toward this end, some agencies differentiate types of investments and associated actions, which can help to substantiate a finding of net benefits or burdens. For example, a map of proposed highway construction projects could identify where rights-of-way are likely to be needed in order to determine the potential for a disparate level of takings in underserved communities. In addition to mapping project locations, some MPOs map the distribution of invest- ment dollars. If a segment of a new roadway touches an EJ zone, for example, some agencies allocate 100% of the estimated project cost toward the estimated level of benefit to under- served personsâin some cases, even if very little of the new roadway is actually located in
24 Equity Analysis in Regional Transportation Planning Processes the underserved community. Although mapping the distribution of investment dollars is a straightforward, replicable activity, the conclusions could be questionable for the same reasons as for the project location analyses. To refine an impact analysis of proposed investment costs, agencies can allocate monies on a per capita basis, taking into account all the persons in all the locations served by the project, rather than counting 100% of a project cost toward a sum total of EJ benefits when the project only partially affects required populations. About half of the MPOs in the study used a travel model to compare forecast outcomes of plans and programs (e.g., commute travel times and distances) for underserved populations compared to outcomes for control populations. Of the agencies that forecast outcomes, most were using a geographic-based approach that compares the outcomes for designated EJ TAZs to the outcomes for other TAZs. These studies can be useful if the Step 1 logic of designating EJ TAZs is sound. Best Practices and Recommended Approaches A strategy to counter potential errors that could result from all-or-nothing allocations of benefits to EJ zones is to associate impacts with types of populations rather than with types of zones. One MPO studied for this project (the MORPC) used a population-based approach instead of the typical geographic-based approach to study the impacts of forecast outcomes from the travel-demand model. Using this approach, the agency did not categorize TAZs into different types. Rather, for each demographic group being analyzed, the outcomes for each TAZ contributed to the production of a regional outcome based on that TAZâs share of the regionâs population for that group. This approach is described in detail in the guide and is well documented in the equity appendices to the MORPCâs plans and programs. On a related note, the research team learned from another study about two much smaller MPOs (in Licking County, Ohio, and Northwest Indiana) that used (and documented) the population-based approach to forecast the equity impacts of their plans. During interviews with the MORPC, the agency suggested that any MPO with a travel-demand model could adopt a similar approach, whether the model is supported in house or by other staff such as DOT planners or private contractors. During the pilot testing phase of the study, two agencies (the MARC in Kansas/Missouri and the DRCOG in Colorado) reviewed the MORPC approach described in the draft Volume I guide and conducted peer-to-peer discussions with the MORPC. The MARC successfully conducted a population-based analysis using the instruc- tions in the guide, and the DRCOG provided thoughtful questions while preparing to apply the approach in the future. The research team updated the guideâs instructions to reflect feedback received from both MARC and DRCOG staff. All the methods studied for conducting the Step 3 analysis pose some potential risks and shortcomings. Relatively simple methods, such as allocating 100% of proposed project invest- ment costs to the benefit of required populations whenever a portion of the project touches an EJ zone, may be based on debatable assumptions such as a one-to-one correlation between a projectâs proximity and its benefits. More sophisticated methods, such as comparing forecast outcomes among differing population groups, require a little more technical capability to conduct and interpret. Regardless of the approach used to measure impacts, agencies always should work with equity stakeholders to validate, refine, or change key assumptions and findings about the level to which given projects and investments may confer benefits and burdens. Open Challenges and Research Questions Transportation impact analyses of all sorts measure outputs (e.g., roadway level of service, multimodal connectivity, and other indicators of system performance) as well as outcomes
Findings and Applications 25 (e.g., commute times, accessibility to destinations, and other indicators that reflect the expe- rience of system users). When it comes to equity analyses, outputs include indicators such as the numbers and dollar amounts of transportation investments located in areas with high concentrations of underserved populations, whereas outcomes include indicators such as comparative commute times and distances. A robust equity analysis would, ideally, examine a range of outputs and outcomes, but almost all of the MPOs studied for this project measure only outputs. One key challenge, therefore, is to encourage more MPOs to adopt multiple approaches that examine both outputs and outcomes. Output analyses should capture the fact that simple proximity of a project or investment to an underserved community does not necessarily confer benefits or burdens upon that community. The impacts may differ depending on the amount, types, and locations of investments relative to the travel needs of the people in these areas. Among MPOs that measure outputs, some analyses differentiate the types of projects, which can help the agency to relate the assessment of benefits and burdens more closely to the needs and characteristics of underserved popula- tions. An outcomes analysis would further support a meaningful determination of benefits and burdens. Outcomes analyses should include performance measures that capture travel by all modes, particularly transit, which is an important mode for many low-income persons and other underserved populations, and also the subject of in-depth Title VI and EJ requirements. Step 4: Determine Whether Impacts Are Disparate or Have DHAE Federal guidance requires a comparative analysis to determine whether the required popula- tions are receiving comparable benefits and burdens of MPO plans and programs, including the cumulative impact of historical patterns of investment. Prior sections of the guide and this report have discussed options for measuring these benefits and burdens for each population group under current conditions (Step 2 for needs) and under the agencyâs planned activities (Step 3 for impacts). Once agencies have collected all the data for Steps 1â3, they are likely to observe differences. How does the agency then determine whether those differences are disparate or disproportionate? No one-size-fits-all approach exists, but the agency can use some quantitative approaches, supplemented (as in all the steps of an equity analysis) with qualitative information collected from equity stakeholders. State of the Practice Of the equity analyses reviewed for this study, none found a disparate or disproportionate impact. A few agencies prepared tables or line graphs comparing impacts or conditions for differing populations under a variety of scenarios (e.g., the current conditions, existing and committed projects for the forecast year, and the planâs scenario for the forecast year), and concluded that no disparate impacts or DHAE existed, but did not necessarily describe a specific rationale for that finding. Most of the documents studied for this project did not quantify the Step 3 impacts in enough depth to support a detailed Step 4 determination of potential disparities. The most common practice was to create a map of projects, overlay the project map on a map of EJ zones, and determine that projects are equitably distributed, with little documentation to describe the analysis or support the findings. If no impacts have been identified in Step 3, an agency
26 Equity Analysis in Regional Transportation Planning Processes understandably would not allocate resources toward conducting a Step 4 assessment to quantify levels of disparity. This state of the practice is not particular to the agencies reviewed for this project; the research team found similar results from a scan for another project that involved 100 MPOs and all state DOTs. One possible reason for a lack of Step 4 findings is that potential disparate impacts were identified and resolved before the development of the final plan or program, but the team did not find detailed descriptions of agency processes to this effect. Best Practices and Recommended Approaches To determine whether their activities generate disparate impacts, MPOs should first review data collected in Steps 2 and 3 to identify differences among population groups in terms of their needs and concerns with respect to agenciesâ outputs and outcomes, both existing and forecast. Displaying this data in tables and graphs helps decision makers and stakeholders visualize how impacts are distributed among population groups. After digesting the information developed through Steps 2 and 3, MPOs should use quantita- tive analysis techniques, such as benchmarking, statistical significance, and location quotients, to identify potentially disparate impacts that may warrant additional investigation. For example, a location quotient can be used to determine secondary outcomes of transportation investments (e.g., the risk of asthma for underserved populations in proximity to a new freeway expansion, which can be assessed using existing research on air quality, pollutant exposure, and census data on the distribution of underserved populations). Quantitative screening is a necessary component of a Step 4 analysis of disparate impacts, but it is not sufficient without qualitative methods that integrate supplemental information and stakeholder feedback to validate or challenge the findings, and to understand whether those differences are experienced by underserved persons as disproportionate adverse effects and/or as denials or delays of benefits. The guide provides open-ended questions that MPOs can use to gather supplemental information from equity stakeholders to enrich the agencyâs understanding of potential impacts, and to set the stage for Step 5, exploring causes and developing mitigation strategies to address current or potential disparities. Open Challenges and Research Questions Agencies are clearly in need of additional guidance about how to identify differences and how to determine whether those differences are disparate or disproportionate. The guide developed from this research recommends some approaches that the research team has observed in practice, but additional research and guidance on this issue would be helpful. For example, a wide body of case law is now available relating to Title VI, some of which relates to transportation and some of which is from other sectors of public decision making. Transportation practitioners could learn a great deal from a synthesis of Title VI case law, including results that discuss approaches by other sectors. Step 5: Develop Strategies to Avoid or Mitigate Inequities If an impact analysis reveals that a plan or project has a disproportionate impact on under- served persons or communities, the MPO must examine alternatives that mitigate these impacts and incorporate or discuss these alternatives in their final decisions. Whether or not disparate impacts or DHAE are identified in a Step 4 analysis, some MPOs commit to specific activities toward prioritizing equity in their plans and programs. These
Findings and Applications 27 proactive approaches can help to address the needs found in the Step 2 analysis, and help to avoid the possibility of disparities arising or deepening. State of the Practice MPOs rarely identify disproportionate impacts at their planning or programming levels. A few plans and programs mentioned mitigation actions that had been taken in relation to major projects due to disparate impacts or DHAE identified during a NEPA review or as a result of a lawsuit under Title VI. These mitigation actions tended to be project-specific, such as improving pedestrian connections as part of a road-widening project. When agencies find disparities, the Step 5 process encompasses a closer investigation of why the disparity is occurring, which supports the development of mitigation strategies. For example, the MARC identified that most pedestrian fatalities were occurring in underserved communities. To understand the possible connections between agency decisions and this situation, the MARC analyzed the geographic distribution of safety funding (a measure of the agencyâs outputs). Upon observing that the funds were primarily benefiting high-capacity communities, the agency considered why, and noted that the funds were distributed in grants for which the community members must have the time and ability to apply. To remedy the disparities, the MARC began to develop strategic outreach and safety countermeasures toward underserved communities that were experiencing the high rates of fatalities. Over the long run, these efforts would be expected to help reduce the disparity in safety outcomes. Many MPOs have adopted broad-reaching equity goals and undertaken planning and decision-making strategies that are clearly intended to improve equity in the region. These actions generally seem to be proactive rather than reactive, and agencies usually do not document any specific disparate impacts or DHAE that these activities are designed to resolve. Best Practices and Recommended Approaches The first step toward developing effective strategies is to adopt a clearly stated policy and measurable goals toward improving equitable access to transportation benefits and decision- making processes. This top-level directive enables staff to spend resources on more robust analyses and engagement efforts with equity stakeholders. Many agencies have adopted policies or goals, some of which are supported by measurable objectives, along with strategies. A few agencies conduct performance assessments to measure the effectiveness of their strategies. If disparate impacts or DHAE are identified anywhere in the spectrum of Steps 2 through 4, agencies can use the Step 5 process to pinpoint countermeasures (as demonstrated by the MARCâs safety funding prioritization strategy) and to adopt proactive approaches toward improving equity considerations throughout transportation planning, programming, and decision-making processes. These approaches may include goals to direct the overall strategic direction of the agencyâs activities and strategies, such as project selection criteria that address the needs of underserved persons and communities. Agencies also can strive to increase representation from underserved populations on advisory committees, to increase the amount and quality of input from underserved persons in agency decision making, and to improve the documentation of analysis methods and responses to identified needs and to existing or potential disparities. Open Challenges and Research Questions Transportation agencies face a variety of challenges when developing and implementing effective strategies to improve equity in planning, decision making, and system performance.
28 Equity Analysis in Regional Transportation Planning Processes Agencies that adopt an overarching policy goal relating to equity can still have difficulty in making substantive changes to agency decision-making processes and outcomes. Some agencies that include equity in project selection criteria, for example, simply award points for projects in underserved communities, regardless of whether the project promises to deliver specific benefits that address a documented need or concern expressed by the affected populations. Many agencies identify public involvement and stakeholder engagement strategies such as increasing diversity in advisory groups and participation in outreach activities. Implementing these strategies effectively and monitoring success can be challenging. Some underserved popu- lations are reluctant to engage in civic decision making due to a distrust of government officials, and/or a lack of community capacity to devote the necessary time and resources to meetings and communication. These kinds of barriers are not taken down overnight. Agencies must make long-term commitments and measure success incrementally to achieve objectives such as building trusted relationships and providing hands-on support (such as leadership training programs) to increase the capacity of underserved persons to advocate their interests and needs effectively.