TPB planners are working on a new approach to analyzing the region’s long-range transportation plan to satisfy long-standing federal Title VI requirements and Environmental Justice guidelines. These federal measures aim to protect minority and low-income populations from discrimination and disproportionate adverse impacts of federally funded programs.
At its January 18 meeting, the TPB discussed a draft of a map identifying areas with high concentrations of minority and/or low-income populations. The areas, which the TPB plans to call Equity Emphasis Areas, or EEAs, are Census tracts with higher concentrations of these groups.
The Equity Emphasis Areas map, once finalized, will be used to evaluate the impacts of the region’s Constrained Long-Range Transportation Plan (CLRP). It will also be able to be used by local jurisdictions assessing equity as part of their own initiatives. And it can open up broader discussions among planners, the public, and elected officials about the needs of transportation-disadvantaged populations to consider in the transportation planning process.
What are “Title VI” and “Environmental Justice?”
Title VI is a provision of the Civil Rights Act of 1964. It prohibits agencies or programs that receive federal funding from discriminating based on race or national origin. For the TPB this means that the CLRP must not have a disparate impact on these protected populations.
Related to this federal law is a 1994 Executive Order on Environmental Justice, which requires recipients of federal funds to analyze plans and programs for disproportionately high adverse effects on both low-income and minority populations. The Environmental Protection Agency, one of the federal agencies charged with enforcing the order, defines environmental justice as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of… laws, regulations, and policies.” Under these rules, the TPB must evaluate the CLRP to ensure that the “benefits” and “burdens” of the plan are distributed fairly.
Proposed changes to the TPB’s analysis methodology
In the past, TPB planners looked at broader regional changes in accessibility to jobs by transit and auto forecast for the horizon years of its long-range plans. While that analysis has helped highlight some key equity issues at a regional scale, TPB staff have proposed improvements to their evaluation methods—based in part on a scan of best practices from other metropolitan areas.
Among the best practices being adopted is identifying smaller, more specific geographic areas that have relatively high concentrations of low-income and minority populations, then comparing accessibility and mobility measures in these areas with the rest of the region. Another is to analyze more than access to jobs, including access to healthcare facilities, and educational institutions.
How the TPB’s Equity Emphasis Areas are being identified
To identify these geographic areas, staff are using demographic information from the U.S. Census Bureau’s American Community Survey to calculate the regional averages of low-income, African-American, Asian, and Hispanic or Latino populations as a share of the total population. Then they’re looking at each Census tract and comparing those percentages to the regional average.
Because the region has become majority minority—meaning that minority groups now make up a majority of the total population—staff will have to carefully set the thresholds for being considered an Equity Emphasis Area, ensuring that areas with the highest concentrations receive the designation.
Staff have so far consulted with a wide range of stakeholders in developing and refining the EEA methodology. One key group was COG’s Planning Directors Technical Advisory Committee, made up of the planning directors of all the region’s local jurisdictions. Staff also received input from the TPB Technical Committee, Citizens Advisory Committee, and Access for All Advisory Committee. More consultations are planned for February as staff continue to refine the map.
Next steps: Endorsing the map and analyzing the CLRP
The TPB will be asked at its February meeting to endorse the map of Equity Emphasis Areas. The endorsement was scheduled for January but was postponed a month to make final adjustments to the underlying methodology. (Read more about the postponement.)
Once the Equity Emphasis Areas have been endorsed, the TPB’s planners will analyze the 2016 CLRP Amendment, approved this past November, to assess transit and auto access to jobs, hospitals, and higher education institutions in Equity Emphasis Areas versus the rest of the region.