Environmental Justice Toolkit

Phase II of the Baltimore Region Environmental Justice in

Transportation Project

Prepared for

The U. S. Environmental Protection Agency in Conjunction with the

U.S. Department of Transportation Federal Highway Administration
Cooperative Agreement XA-83085801-3
Contract DTF1161-06-P-00106

2008
 Project Director and Principle Investigator
Glenn Robinson
Research Scientist, School of Engineering, Morgan State University

Sponsor
Baltimore Metropolitan Council – Transportation Planning Division

Institutional Support
School of Engineering and Institute for Urban Research, Morgan State University
Greater Baltimore Urban League
Environmental Justice Partnership, Inc
Johns Hopkins Center in Urban Environmental Health
Ohio State University - School of Public Health

Community Support
Miss Morton (Kirk Ave.)
Sister Jean, St. Ann’s Church (Kirk Ave. Bus Depot)
Art Cohen, Morgan State University (Historian, Highway to Nowhere)
Shirley Folks, Cherry Hill Public Housing Tenants Association
Diane Jones, Assistant Professor - Institute of Architecture and Planning, Morgan State University
Ruth Pitts, Cherry Hill Public Housing Tenants Association
Leon Purnell, Executive Director – The Men’s Center
Zelda Robinson, President - Westside Baltimore Coalition
Angela Wilkins, Graduate Research Assistant, Planning, Morgan State University (Cherry Hill)

Oversight Committee
Tony Brown, Maryland Transit Administration
Don Chen, Smart Growth America
Richard Lloyd, Morgan State University
Michael Mazepink, Peoples Homesteading Group
Dorothy Morrison, Maryland Department of the Environment
Paul Oberle, Maryland Department of Transportation
Carol Payne, Department of Housing and Urban Development
Dan Pontious, Citizens Planning and Housing Association
Andrew Sawyer, Maryland Department of the Environment
Scot Spencer, Annie E. Casey Foundation
Rich Stoltz, Center for Community Change

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 Acknowledgments

We would like to take this opportunity to thank the four community groups for their
fine work, the support they gave to this research, as well as their willingness to
continue to share their experience with us and with other communities. We wish them
the best as they strive to ensure accessible, affordable and reliable transportation for
people with disabilities, low incomes and others in their communities.

Also, we wish to express our appreciation to federal representatives for their support
as well, this includes: Victor McMahan (EPA), Sherry Ways (FHWA), and Gloria
Shepherd (FHWA). A note of thanks to an early contributor to this project, Rick
Kuzmyak, is also warranted.

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 Table of Contents
Acknowledgments........................................................................................................................................................................ ii
Table of Contents ....................................................................................................................................................................... iii
Executive Summary.................................................................................................................................................................... iv
About this Toolkit..........................................................................................................................................................................v
Chapter 1 ▪ Introduction............................................................................................................................................................ 1
Environmental Justice and Transportation ...................................................................................................1
What is the Problem? Symptoms of Environmental Injustice ...................................................................... 2
Who are the Key-Players? EJT Stakeholders.................................................................................................3
Chapter 2 ▪ A Framework for Addressing EJT Concerns.............................................................................................. 5
The Triage Process ........................................................................................................................................ 7
Chapter 3 ▪ A Guided Tour of EJT Analysis......................................................................................................................... 9
Phase 1: Community-Driven Intergovernmental Engagement and Cooperation.........................................9
Phase 2: Community Assessment and Citizen Input...................................................................................10
Phase 3: Information Gathering and Analysis.............................................................................................12
Phase 4: Developing a Community Profile..................................................................................................12
Phase 5: Drill Down to Assess the EJT Issues ..............................................................................................13
Phase 6: Being Heard (Communicating) .....................................................................................................14
Chapter 4 ▪ EJT Evaluation Tools, Procedures and Examples..................................................................................16
Demographic Profile ...................................................................................................................................16
Do Your Due Diligence ................................................................................................................................19
EJ Evaluation of Transportation Plans (Performance-Measures) ...............................................................19
Land-Use Impacts........................................................................................................................................20
Industrial/Commercial/Institutional ...........................................................................................................21
Revaluation .................................................................................................................................................21
Public Health Risk........................................................................................................................................22
Chapter 5 ▪ The Baltimore Experience...............................................................................................................................27
Case Study Report: Kirk Avenue Bus Yard...................................................................................................29
Case Study Report: Cherry Hill Issues .........................................................................................................30
Case Study Report: Lexington Market.........................................................................................................32
Case Study Report: US 40 Highway-to-Nowhere ........................................................................................34
Chapter 6 ▪ Conclusions ...........................................................................................................................................................36
Appendix A: Literature Review............................................................................................................................................41
Appendix B: Glossary ...............................................................................................................................................................64

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Executive Summary
The Baltimore Region Environmental Justice in Transportation Project (BREJT) is a collaborative
effort between the Morgan State University School of Engineering and the Institute for Urban
Research, Baltimore Metropolitan Council, John Hopkins Bloomberg Center for Urban
Environmental Health, the Greater Baltimore Urban League, and the Environmental Justice
Partnership, Inc. The second of two EJ efforts, is sponsored by the U.S. Environmental Protection
Agency (EPA) and the Federal Highway Administration (FHWA) to provide a systematic process
for the integration of environmental justice (EJ) into the transportation decision-making process
since there is no such approach currently in place.

BREJT’s goals are to advance the integration of EJ into the metropolitan planning process and to
help low-income and minority communities and their planning agents better understand and
more effectively deal with a wide range of urban transportation issues and problems. Since 2003,
BREJT has been listening to low-income and minority communities describe the impacts of
transportation on their environment and in their lives. BREJT utilized community stakeholders to
identify local concerns and potential remedies. The EJ toolkit was developed to address these
issues and to encourage government and communities to better work together to achieve sound
solutions when addressing EJ concerns related to transportation. It is a vehicle for addressing
community-based concerns through an informed public involvement process that is credibly
responsive to public input particularly from low-income and minority communities.

The toolkit provides a contextual framework, analytical tools, evaluation criteria, and performance
measures that can be used by metropolitan planning organizations (MPOs), communities, and
other stakeholders to avoid, minimize, or mitigate the social, economic, or environmental
consequences of the local, regional, and statewide transportation planning decisions.

Case studies of four Baltimore communities—Kirk Avenue, Cherry Hill, US 40 Highway–to-

Nowhere, and Lexington Market—are included to demonstrate the elements of EJ analysis. From
the Baltimore experience the clear message is that when communities are motivated, well
organized, and educated on the issues and options a sense of ownership is created that better
influences the project selection outcomes.

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About this Toolkit
This EJ toolkit is a guide to assist metropolitan planning organizations (MPOs), communities, and
other stakeholders avoid, minimize, or mitigate the social, economic, or environmental
consequences of transportation projects and policies. It is designed to help determine the extent of
environmental justice and transportation (EJT) issues in low-income and minority communities
(EJ communities).

This toolkit includes six chapters that provide a framework to better understand environmental
justice (EJ) issues related to transportation projects (existing and new) and methods to define,
analyze, evaluate and document such findings. Throughout the toolkit, examples of four
Baltimore communities are used to demonstrate how tools can work to identify and reduce EJT
concerns.

Chapter 1 introduces EJ and its relevance to transportation. Common symptoms of environmental

injustice and insight from the BREJT project are provided. Stakeholders and their roles in
transportation projects are detailed.

Chapter 2 explains the contextual framework for addressing EJT concerns. It also introduces the
triage process created from the BREJT and instructs why and when to use it.

Chapter 3 outlines the six phases of any EJT process that are helpful for engaging key-players in
the decision making process. A community driven model frames EJT issues so local community
groups and MPOs can successfully engage one another in the transportation process.

Chapter 4 contains a “recipe” for intervention, information access and analysis. This chapter
includes a description of the nuts and bolts of creating committees, generating plans, and
identifying milestones for EJT analysis and evaluation.

Chapter 5 presents case studies from four Baltimore communities where BREJT employed the
strategies in this toolkit.

Chapter 6 concludes the toolkit and provides reflection on the BREJT process and how
improvements to EJT are possible.

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Chapter 1 ▪ Introduction
Environmental Justice and Transportation
Environmental Justice (EJ) ensures that all people—regardless of race, color, national origin, or
income—are able to benefit from environmental protection. It is fundamentally about fairness
toward the disadvantaged and often addresses the exclusion of the disabled and racial and ethnic
minorities from decision-making processes. It is rooted in Title VI of the 1964 Civil Rights Act that
required the elimination of discrimination in federally-funded activities. The official regulatory
introduction of EJ came about in 1994 with Executive Order 12898 entitled “Federal Actions to
Address Environmental Justice in Minority and Low-Income Populations.” This executive order
urged federal agencies to take more aggressive actions to eliminate inequities associated with the
planning, operation and development of infrastructure improvements.

The federal government has identified EJ as a critical element in the transportation planning
process. The Federal Highway Administration and the Federal Transit Administration issued a
joint memorandum in 1999 titled “Implementing Title VI Requirements in Metropolitan and
Statewide Planning.” This affirmed that compliance with Title VI is required, and non-compliance
would mean that all federal funding for the region could be withheld. Over time, the federal
government has created increasingly specific requirements for non-discrimination and
environmental protection, but states can decide how to implement them. If they do not follow
these directives they risk losing their federal money, which is usually a sizable share of their
transportation funding.

The Department of Transportation (DOT) promotes the principles of EJ in its programs, policies,
and activities. The principles of environmental justice are to 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; to ensure the full and
fair participation by all potentially affected communities in the transportation decision-making
process; and to prevent the denial of, reduction in, or significant delay in the receipt of benefits by
minority and low-income populations.1

While federal regulations now exist that identify principles of EJ, the legal system recognizes no
universally accepted definition of EJ and its standing as an enforceable right has been tested
through the court system with mixed outcomes. It has only been since 1997 that plaintiffs began
winning EJ cases, which did not require proof of intent. As a result, planning organizations are
obliged to treat EJ communities equally in terms of the opportunities afforded them for
meaningful public participation—they should have opportunities equal to those of the most
“important” stakeholders. Indicators such as travel time, accessibility, number of trips, emissions,
noise, and congestion are but a few of the measures which can typically be used to discern
whether government funded projects conform to existing law.

1U.S. Department of Transportation, Federal Highway Administration, An Overview of Environmental Justice, Available
online at: http://www.fhwa.dot.gov/environment/ej2000.htm

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What is the Problem? Symptoms of Environmental Injustice
Environmental injustice occurs when vulnerable communities lose control of their surroundings.
This happens to communities when they lose population, lose land value, when development
pressures lead to land-use changes, or when their voice is left out of decision-making processes.
Often, environmental injustice is documented in communities where low income and minority
residents rely on transportation systems and where there is a perception that system benefits are
not fairly distributed. While it is possible for non-residents to observe environmental injustice,
symptoms are often defined by community members and vary according to location. Noise, air
quality, exposure to odors, and safety are among several potential environmental risks that are
cited as concerns of citizen groups. Location matters because exposure to these problems varies
according to community proximity; neighborhoods adjacent to an airport experience different
concerns than those near a freeway. Citizens experience symptoms of transportation-related
environmental injustice when they:
 Do not benefit from funding for improved accessibility, faster trips, and congestion relief;
 Suffer disproportionately from poor transportation design: air pollution, noise, traffic
congestion, crashes, etc.;
 Have to pay more (higher transportation taxes or higher fares) than others in relation to
the services that they receive;
 Endure transportation designs that are not contextually sensitive to pedestrians, cyclists,
and the disabled.
Identifying the symptoms of environmental injustice involves direct engagement between
community leaders, advocacy groups, and citizens. In case studies performed in Baltimore, BREJT
sponsored a community dialogue among low-income and minority participants that identified
approximately 100 issues that influence EJ scenarios (Figure 1).2

Figure 1: Community Identified Issues

2 November 4, 2004, Community Dialogue, Morgan State University

2
During the event, participants engaged one another in small group breakout sessions and revealed
their concerns about environmental injustices they experience. Overall, the concerns cited were
related to air pollution and congestion, access to jobs, access to health care, poor bus service, and
fairness in transportation funding.

Who are the Key-Players? EJT Stakeholders

Stakeholders are the people, organizations, and agencies that have a reason to care about EJT
problems. Some of these groups may be directly affected by a project, such that their standard of
living is reduced or they experience negative health outcomes. Other groups may need to comply
with local, state, or federal regulations. Regardless of the reason, there are several groups that
have a stake in most EJT problems.

Neighborhoods and Communities

Every EJT problem includes a group of people directly affected by the outcome of a project. For
instance, a bus depot or a new road may be built in close proximity to residential dwellings,
causing unintended outcomes such that the residents are adversely affected. These neighborhoods
and communities are often made up of low-income and minority residents. Historically, these
groups rely heavily on transit and experience greater separation from jobs and other needed
services and activities as patterns of growth and development favor the relocation of employers,
shopping and health providers away from the center city to outlying areas. Much less is known
about their discretionary travel patterns, which are important factors for better understanding
needs and the rationalization of funding priorities.

Local Government Agencies

Cities and counties make decisions about transportation projects, including road construction,
repair, and maintenance, streetscapes, bicycle and pedestrian facilities, and transit lines. They
work with other local jurisdictions to plan and prioritize transportation projects, yet they manage
those that occur within their boundaries. Impacts to EJ communities are not always considered
during the planning phase of projects. However, local politicians do participate in the planning
process and should be contacted by their constituents on issues of concern as soon as possible.

Transit Providers
Transit providers operate and maintain bus, subway, rail, and other mobility services throughout
local communities. Within any region, there may be several transit providers and they may be
government entities or private corporations or a combination of the two. They work with state and
local jurisdictions to identify optimal routes for their services. EJ communities often rely on transit
but often get overlooked when decisions are made. For example, the Cherry Hill neighborhood in
Baltimore was the recipient of light rail service. However, the addition of light rail came along
with a reduction in bus service to the community. As a result, accessibility to services declined
and a portion of the residents moved out of the community.

Metropolitan Planning Organizations (MPOs)

Metropolitan planning organizations or MPOs are regional policy-making bodies that are
responsible for adopting long-range transportation plans every four years that identify how their
respective region intends to invest in the transportation system. They are overseen by a board of

3
officials from the jurisdictions in the region they serve; the board may be composed of elected
officials that receive input from citizen advisory committees, a director, and technical staff. MPO’s
are also responsible for administering a public participation process that provides meaningful
opportunities for affected individuals and communities to influence transportation decisions.
They are required to comply with Title VI, in addition to any other EJ-related policies put in place
by federal, state, or local governments. Typically MPO’s:
 Have analytical tools to measure transportation program compliance with Title VI.
 Identify residential, employment, and transportation patterns of all residents in their
regions, including low-income and minority populations, to identify and address needs
and assure that benefits and burdens of transportation investments are fairly distributed.
 Have a public involvement processes that eliminates participation barriers and engages
minority and low-income populations in transportation decision making.

State Departments of Transportation

State Departments of Transportation (DOT), or State Highway Administrations, manage the
network of roadways within a specific state. They also participate in regional planning and
implementation efforts, write regulations, initiate programs and policies, and administer grants
for application within their boundaries. Like MPOs, they are subject to the compliance
requirements of Title VI and other EJ regulations. They may even have EJ policies applicable
within their agency and external rules for organizations they do business with. Though these
conditions are in place, EJ issues still arise and it is important that concerns be addressed directly
to the State DOT.

Federal Agencies
Federal agencies administer programs and revenue sources that impact local transportation
projects. While there are many agencies that have transportation-related programs, it is not likely
that any are directly involved in implementing the projects after funding has been released. Three
agencies deal directly with EJT issues: the U.S. Environmental Protection Agency (EPA), the
Federal Transit Administration (FTA), and the Federal Highway Administration (FHWA). EPA
and its state counterparts set the rules about environmental pollution, while FHWA and FTA
provide guidance on Title VI and EJ concerns in transportation planning. Although they do not
necessarily participate directly in local transportation project implementation, they do deal with EJ
problems by addressing complaints from communities and individuals that are brought to their
attention.

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Chapter 2 ▪ A Framework for Addressing EJT Concerns
The best possible place to be is to have ongoing communications between all communities about
their transportation needs and their local elected officials. After all of the needs are determined,
communities would be involved in the difficult process of deciding how limited dollars are spent.
Once decisions are made with public input communities would remain engaged with
implementing agencies on how projects are planned and so forth. Short of that process working
perfectly, some communities experience issues that they believe are EJ in nature. This framework
addresses how communities and planning organizations can address those communities that feel
they have been left out or simply mistreated in the process.

Once an issue arises, a successful EJT endeavor begins with community engagement. BREJT’s
experience revealed that communities are more motivated and better able to work toward a
solution when they are educated on relevant issues, solutions and options; believing that they
have a better chance of influencing the implementation of projects that have a positive local
impact. In contrast to traditional transportation projects that tend to be hierarchical in nature and
are limited to a few agencies, working from a bottom-up framework is more responsive to the
needs and concerns of affected communities and plays an important role toward implementing
sound solutions. This approach can also improve analysis methods for addressing issues of
concern through the public involvement process which should lead to more community-relevant
action from decision-makers.

Community driven public participation in each of the Baltimore case studies demonstrates that
bottom-up participation, because it involves or responds to local concerns are more likely to result
in the active involvement of EJ communities. When contrasted to the perception of top-down
public participation approaches and/or strategies, which are perceived by low income and
minority communities to be less likely to result in actual, meaningful participation because of
mistrust and suspicion. Yet, such an approach requires a two-way communication strategy
because communities are not likely to know how to initiate contact with a transportation agency
and the planners themselves may be uncertain about whom to contact in a community group.

The framework illustrated in Figure 2 identifies a bottom-up, step-wise method for approaching
EJT issues; it is a collaborative model that promotes feedback between transportation planners and
EJ communities. The initial step involves identifying the EJ community affected by the
transportation project. Local residents are the best source of problem identification, so outreach by
the planning agency should be initiated. During the outreach process, it is important to identify
the full-extent of the affected population and define the concerns and desired outcomes of the
community. An initial attempt at problem screening occurs at this point to better understand the
issues from a neighborhood perspective. It is important that the individual or community group
communicate their concerns to the implementing agency, such as a transit agency, local planning
department, highway department, or MPO. In instances where there is more than one affected
community, it is equally important that the neighborhood or community groups seek each other’s
support and knowledge to address the areas of concern. When the community perceives that they
are experiencing inequity in the delivery of a public good or service they will likely be in need of
additional information and/or analysis during this phase of the framework. As a result of
identifying the issues, the transportation agency and the community can determine what potential

5
short-term impacts will occur within the affected community. In some cases this may involve
having solutions or alternatives already in hand. If an agreement or consensus is achieved, then
the project can move to the standard review process. If there is uncertainty as to whether short-
term impacts exist, then it is necessary to revisit problem identification. A third option occurs
when disagreements persist or if there is no clear solution; in this case, a triage process is initiated.

Issues Preempt/React

COMMUNITY Outreach Scale Simple/Complex

Severity Near/Long term

No Potential Unsure
short-term
impacts?

Yes
Get more input Dialogue w/agencies
Standard
Review Triage Process Perform analysis Document process
Process
Seek solutions

No Technical Unsure
analysis
needed?

Yes

Specify performance
criteria

ANALYSIS
Obtain/Review Existing Data
TOOLBOX
Perform More Detailed Interviews
Simple
Conduct Focus Group

Apply Sketch Planning Methods

Regional Travel Model Applications

Apply Traffic Simulation Tools

Enhance GIS Tools, Population Synthesis

Advanced
New Tools and/or Special Studies

Report
Yes Outcomes No/Unsure
suggested acceptable?
actions

Figure 2: Public Participation and Analysis Framework

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The Triage Process
When problems cannot be resolved in the previous steps, it is recommended that a screening
committee, or similar body, needs to come together to examine the EJT problem in more depth, or
merely from a different perspective. This group is the EJT Triage Committee and should consist of
non-traditional stakeholders, or key organizations that have a bearing on EJT issues and with the
clout to accomplish politically sensitive actions.
The Triage committee should consist of organizations/individuals with influence and the ability
to get things done (Figure 3) and will vary with each region that implements such a group.
Diverse representation and independent status (one vote per member) will allow it much greater
freedom to pursue EJ concerns. The EJT Triage Committee will develop an agenda, lead analyses
and evaluations, and make recommendations for solutions to EJT problems. It will review
information obtained through the outreach process, and assess what to do with the information or
take action (dismiss, recommend, additional research or forward to agency of responsibility). The
committee will develop criteria to ensure that decisions will be made about how the EJ concern or
issue will be treated, especially in relation to its history, urgency and extent.

Public
Health
Institution
Local State
Government DOT

Urban Triage
Academic Committee MPO
Institution

Business
Group Non - Profit

Community
Group

Figure 3: Potential Triage Committee Members

If it is determined that the EJ concern needs to be addressed in a relatively short timeframe,

actions may include toolkit analysis (see Chapter 3), mediation, or legal action, as appropriate.
Otherwise, the standard review process can be initiated or a particular action or remedy can be
arrived at by consensus.

Important questions are expected to arise in the creation of this group, its composition, and its
authority. Given the many tasks and functions linked to the EJT Triage Committee, it might be
expected that there would be a high level of activity. The corresponding concern would be
whether its members would have the time to participate in all of these activities, and financially

7
how this group’s activities would be supported. Under full deployment, the Committee will
either have to maintain very stringent rules in selecting the issues it examines, or have sufficient
resources (in-kind, grant or endowment) to acquire supplemental assistance from staff or
consultants; thus the critical need to ensure that communities are engaged in the planning process
over time to avoid these types of concerns.

Once technical analysis is complete and solutions have been suggested by either the Triage
process or by consensus, performance measures or criteria must be set. Analysis will help
determine whether the outcomes of the process are deemed acceptable. If the acceptability of an
outcome remains in question, the EJ analysis framework needs to go back to the Triage Process
where it can be re-evaluated along with any new information generated. Otherwise, the process
can continue on to the Planning Board or other decision-making body for adoption.

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Chapter 3 ▪ A Guided Tour of EJT Analysis
This chapter builds on the framework presented in Chapter 2 by providing a detailed process for
identifying EJT concerns and analyzing them to determine potential short-term impacts or to build
consensus around a solution. All of the phases are meant to be inclusive of both the EJ
communities and the transportation agency responsible for administering the project. BREJT used
this process in each of the four case studies with positive results. Six phases are identified that
move an EJ concern toward a solution:

Phase 1 - Community-Driven Intergovernmental Engagement and Cooperation

Phase 2 - Community Assessment and Citizen Input (Identify the Local Problems)
Phase 3 - Information Gathering and Analysis (Due Diligence)
Phase 4 - Developing a Community Profile (Analytical)
Phase 5 - Drill Down to Evaluate the EJT Issues (Evaluation)
Phase 6 - Being Heard (Communicating)

Phase 1: Community-Driven Intergovernmental Engagement and Cooperation

Community planning activities are shaped by local needs, priorities and circumstances. Thus,
local community leaders are encouraged to form some type of committee or team that will
consistently meet to examine the EJ issue and assure that the community’s needs are being met
through the process. Members should prepare to serve as project advocates while effectively
communicating EJ concerns to the transportation agency or MPO. Specifically, two things need to
be done: (1) a team leader must be identified for each group, as well as appropriate supporting
cast for facilitation and note-taking, and (2) identify at least five appropriate community members
for team participation. Form a strategy at the project team meeting as to how these tasks will be
accomplished. In the case of BREJT, a Transit Service Case Study Team comprised of nine
members was formed. Members consisted of active community members, public health workers
familiar with environmental issues and an individual from the Baltimore City Mayor’s Office.

It should be noted that the committee needs to continue to function through the completion of the
project. Specifically, in phases 2, 3, and 4, the committee should determine a meeting schedule:

 In phase 2, the committee should meet multiple times, or on average three meetings or
sessions, to adequately come up with issues identification.
 During the third phase, the committee should meet enough times to address each stage of
the information-gathering process.
 In phase 4, the committee will interact with the transportation agencies involved in the
project.

Prior to this step, however, some organizational work must be done in order to ensure the best
possible participation outcome with the community. The committee needs to develop a needs
profile to enable community stakeholders (government agencies as well as, community leaders,
organizers and planners) to define EJT concerns or problems, understand how they occurred,
assess who is impacted and determine what can be done to fix or resolve the problems. BREJT
conducted a community dialogue to achieve this and used flip charts and sticky dots to allow

9
participants the ability to identify their main concerns. For example, participants were given two
sets of sticky dots. One dot was placed on their most important issue and one dot on their most
important topic. When compiled, the case study team recognized similarities in the concerns and
developed a needs profile as a result. The basic ground rules for conducting the community
dialogue are:

1.) Each person gets a chance to talk,

2.) Allow others to finish before you speak,
3.) Listen with an open mind and with respect,
4.) Seek to understand, rather than to persuade, and
5.) Keep comments short

Of special note, in this section it is not our intent to say that “government” initiated public
participation is undesirable. To the contrary it is required and quite desirable as a tool for
meaningful interaction when addressing EJ issues that are initiated by the government. As shown
in Table 1, who and how this process starts are of critical importance. Typically the top down
public participation process is initiated at the bequest of the government with the objective of
targeting particular community organizations and churches in high-risk areas to get input. As
shown in the literature public participation is seen as an activity that is initiated by government
sponsored agencies. Through the eyes of low income and minority community residents this
process is often viewed suspiciously and not designed to address community based concerns and
issues. On the other hand, a bottom up approach to participation, when initiated by high risk
communities is more likely to get community involvement in the interest of seeing that remedies
are implemented in their best interest.

The art of knowing what, when, and how to ask for equitable environmental justice in
transportation improvements is both evolutionary and iterative and is neither well defined nor
linear. It is believed that an important characteristic of a successful environmental justice program
is that it be dynamic, i.e., that it allow for “cycles” of involvement, information exchange,
education, analysis of alternatives and their tradeoffs, and ultimately closure – where the
stakeholders are witness to and feel ownership in the final outcome. Since, the types of issues that
arise in EJ deliberations are typically not clear-cut the process of problem identification,
understanding, and resolution involves multiple iterations of sifting through multiple variables
and tradeoffs.

Phase 2: Community Assessment and Citizen Input

During this phase, the community planning committees are encouraged to create an initial
timetable of three meetings. The objective of the first meeting is to develop a broad agenda.
Everyone gets chance to give input about visions, concerns, and priorities. Then it’s up to the team
to work through these priorities over the long term to ultimately make the project successful.

The objective the second meeting is to better define project goals and vision. You should leave the
meeting with a solid draft of a project description that clearly details what you are trying to
achieve. Between the second and third meeting, draft and approve a document that states the
agreed upon vision and goals. By the third meeting, an agreement should reach its final form and
be ready to be signed by all of the project team members. Everyone on the team should be present
to sign the document together and to commit to the agreement.

10
Table 1: Level of Public Involvement
Case Study Name/Location Impetus* Focus Topics and Effective Practices Stakeholder Involvement

Bottom Up/Top
Collaborative

(Urban/Rura

Learned and
Deliberative

Transportati

Minority/Lo
Responsibilit
Adversarial

Geography

w Income,
Outcomes
Response

on Mode/

Agency of
Lessons
Driver

Latino
Asian,

Down
Black,
l)

y
Verona Road & West Beltline Needs Assessment Study CB Yes Yes Highway (U) Public Involvement State DOT B,A,LI TD
(Madison, WI), Ex. 1
Jobs Access and Reverse Commute Planning (Northern NJ), GOV Transit (R,U) Data sources, GIS, Analytical Methods, MPO, Transit M,LI TD
Ex. 2 MPO regional coordination Agency, HHS
East-West Expressway EIS Statement (Durham, NC), Ex. 3 CB Yes Highway (U) Title VI complaint, housing of last State DOT, B,LI TD
resort, mitigation and enhancements, City, Local
collaborative plans Community
Southern California Regional Transportation Plan (Los GOV Yes Yes Yes Highway, Data sources, analytical techniques, MPO M,LI TD
Angeles Region), Ex. 4 Transit (U) benefits/burdens, alternative dispute
resolution

Cypress Freeway Replacement Project (Oakland, CA), Ex. 5 CD Yes Yes Highway (U) Project development, right of way, State DOT B,LI BU
public involvement, mitigation and
Fruitvale BART TOD Project (Oakland CA), Ex. 6 CD Yes Yes Transit (U) Partnerships, enhancements Transit Agency H,B,A,LI BU
MPO Environmental Justice Report (Columbus, OH), Ex. 7 CD Yes Yes Highway, Data sources, analytical techniques MPO H,B,LI TD
Transit (U)
South Park Avenue Improvement Project (Tucson, AZ) Ex. 8 CB Yes Yes Bike/Ped, Partnerships, enhancements, context City DOT, H,LI TD
Transit (U) sensitive design, public involvement FTA, HUD
South Carolina Route 72 Environmental Assessment GOV Yes Yes Yes Highway (R) Community impact assessment, public State DOT B,LI TD
(Calhoun Falls, SC), Ex. 9 involvement
Environmental Justice & CRCOG’s Transportation Planning GOV Yes Highway, Community impact assessment, public MPO B,A,LI TD/BU
Program, Ex. 10 Transit (U) involvement
Metropolitan Atlanta Rapid Transit Authority (MARTA), CB Yes Yes Highway, Housing, Transit, Accessibility MPO, Transit B,A,LI TD
Ex. 11 Transit. Authority
Housing (R)
Conflict of Public Policies: Hope VI. vs. PRWORA, Chicago, GOV Yes Highway, Housing Housing B,A,LI TD
Illinois, Ex. 12 Transit (U) Authority
Public Involvement in the MIS) Process, Denver, Col, Ex. 13 GOV Yes Yes Housing (U) Government Initiated Outreach Public Transit District N TD/BU

Notes: CB Community Based, CD Community Driven, Gov. Federal, State, Regional or Local
*Terry L. Cooper, Thomas A. Bryer, Jack W. Meek, Collaborative Governance Initiative, Citizen, PAR, Supplement to Volume 66, Centered
Collaborative Public Management

11
This not only helps affirm team members’ commitment to the success of the project, but in case of
staff or political leadership turnover helps subsequent team members or decision makers
understand what has already been agreed to.

Phase 3: Information Gathering and Analysis

Analysis of EJ issues attempts to identify and measure inequalities that are associated with the
traditional planning model. Transportation habits about low-income and minority individuals are
not as well known as they should be and are generally left out of traditional transportation
planning. For a variety of reasons, it is likely that unique characteristics of this population’s
transportation needs and patterns are not well known, and this is an important disadvantage
when trying to better account for these needs in the transportation planning or funding process.
Difficulty in accessing employment and other basic services is a problem magnified by lower rates
of vehicle ownership and public transportation systems that are not well suited to serving reverse-
flow travel patterns. Thus, travel patterns should be determined and it is recommended that a
travel diary be administered to the EJ community (unless the EJ concern is unrelated). This phase
can be broken down as follows:

 Conduct an initial screening that includes capturing information on travel patterns of the
EJ community residents.

 Test whether projects benefits are disproportional (three basic steps are required)

1. Identify affected populations,

2. Estimate the environmental and transportation impacts of the project, and
3. Perform data analysis (proximity, statistical).

Phase 4: Developing a Community Profile

If the EJ issue under study is likely to have a major impact on a community, a profile of the EJ
community should be developed to serve as a baseline against which various sorts of social and
economic effects can be assessed, measured or verified. Construct a comparison trend analysis
table using available data sources (Table 2). This data may be obtained from the MPO, or by
accessing data sources on the Internet, such as the Census Bureau and Departments of Economic
Security. Of course, the source will vary according to the type of data needed. Developing a
community profile enables the EJ community and transportation planners to visualize the extent
of the problems, understand how they occur, assess who may be impacted, and determine what
can be done to fix or resolve the problems. This involves establishing whether or not various
communities will be affected by the transportation project.3

3Jill Alge, MPH in Environmental Health Sciences, Dr. Buckley- Academic Advisor, Dr. Crawford-Second Reader, The
Ohio State University, January 2, 2008, Glenn Robinson, Morgan State University, School of Engineering, January 2, 2008

12
Table 2: EJ Trend Data Table

Category 2000 - 2030 Metrics

Geographic Census Transportation Political Neighborhood Corridor Regional
Unit Tract Analysis Zone Jurisdiction
Population Age Household Public Health Employment Ethnicity
Demographics Sex Size Characteristics
Income
Income Median Persons Below Median
Non- the Poverty Household
Family Level Income
Household
Income
Housing Family Vacant Multiple Units, Owner and Percent Median
Characteristics households Occupied, Average rooms Renter Owner- Value of
Owner- per unit Occupied Occupied Owner
Occupied, Units Units Occupied
Renter- with a Units
Occupied Mortgage
Educational 25 years Less than high High school Junior College Four Advanced
Attainment and more school graduate College Degree
Degree
Travel Transit Auto Travel Mode
Characteristic Dependant Ownership

Phase 5: Drill Down to Assess the EJT Issues

Once citizen input is gathered and information about travel patterns and a community profile
have been compiled, there needs to be an assessment conducted.4 The drill down assessment
process will:
1. Assess the general health of community,
2. Identify community perceptions associated with transportation impacts, and
3. Define community and intergovernmental interactions.
This is a process of discovery and helps to better understand how to avoid planning decisions that
may negatively impact low-income and minority groups. It is also a good time to frame the issues
by asking these questions: What was done?, Who was impacted?, How did it happen?, What was
the role of government and private sector?, and, What do you want done to fix the problem?

Analysis Levels
This involves establishing whether or not various communities will be affected by the
transportation project. Screening should be done at two scales—regionally and at the
neighborhood scale. Table 3 identifies methods showing three levels of detail for screening EJT
community problems. They include: GIS buffer analysis, reviews of existing community resources,
site visits, focus groups and public meetings. NCHRP Report 532 identifies three analysis levels
for evaluating EJ issues. Generalizing from guidance provided by Report 532, the set of tools and
procedures associated with the three degrees of application detail are summarized below.

4Community Assessment Survey, www.BREJT.org, Dr. Tim Buckley The Ohio State University, April, 2007 and Glenn
Robinson, Morgan State University April 2007.

13
Table 3: Drilling Down

Initial Screening Moderate Detail Most Detailed

•Assembly and review of
existing data or forecasts;
•Published reports and
tables;
•Creation or analysis of
maps;
•Visual (field) inspections;
•Simple surveys,
interviews, or focus groups.
•Standard four-step regional
transportation planning model;
•Use of GIS to create maps for
locating projects or impacts in
relation to population subgroups at a
TAZ or census tract level;
•Corridor traffic flow simulation
models and analyses;
•Transportation emissions
forecasting models;
•Physical measurement of noise,
pollution, runoff impacts;
•Visual preference surveys;
•Formal surveys or operational data
collection.
•Enhanced travel
forecasting models
(including activity-based
methods);
•Population synthesis and
household micro
simulation approaches
using detailed GIS;
•Pollution surface models
to gauge air pollution
exposure;
•Regression or other
advanced statistical
analysis methods to isolate
and quantify contributing
factors.

At the initial screening level define the affected area, stratify the population by ethnicity and
income, compare the general population and analyze past impacts against archived census data
and local knowledge. Likewise at the moderate and most detailed levels of analysis more
elaborate tools can be used to identify EJ impacts of improvement plans on affected populations.
This is critical when measuring the special transportation needs of low-income groups against
other income groups, inner city areas and suburban areas. Also, proximity data analysis is an
important drill down analysis tool because it analyzes the activity space within which at-risk
populations typically move about. This analysis will be keyed to a concise set of measures or
indicators that are revealing in gauging and comparing impacts (a.k.a., benefits and burdens) on
the target population. Probable indicators would include the following: total jobs available within
(1) 30 minutes, (2) 45 minutes, (3) 1 hour by (1) transit, (2) auto/highway to (1) white households,
(2) African American households, and (3) other [Hispanic, Asian] households by (1) over or (2)
under the poverty line.

Phase 6: Being Heard (Communicating)

All too often community arguments are based on qualitative arguments. Strong presentations can
happen by using some basic quantitative analysis components as depicted below in Table 4. The
implied sets of tools and procedures shown above were used in BREJT’s case studies which are
discussed in the following section. Generate a report to present at a public hearing and include
these characteristics: frame solutions, analyze demographic and land-use trends and patterns, and
define perceived deficiencies and demonstrate impacts. This report should act as a companion to
the issues related to public health and accessibility.

14
 Things to Discuss Level of Detail
Identified Issues History and Background
Controlling Policies and Programs
Agency Technical Documentation
Areas of Impact (Neighborhood, Corridor, Region, etc)
Framed Solutions Land Use of the area of in question (Commercial,
Industrial, Residential)
Population Demographics
Analyzed Trends and Patterns Transit Dependency
Auto Ownership
Number of Trips
Impact Analysis Retail Manufacturing, Service Employment
Social Services
Route Coverage
Service Frequency
Perceived and Demonstrate Proximity to Car and Truck Traffic
Impacts Incidence of Respiratory Aliment
Incidence of Cancer
Noise and Air Pollution
Table 4: Drilling Down

Recommendations are another way to be heard. BREJT conducted a workshop to look at the
community concerns in detail. Results identified actionable steps that may prevent injustices from
occurring:

 Instituting a quality control/customer service feedback system to improve accountability;

 Bringing about a more interactive and informed public participation process where the
public is meaningfully informed and brought into the planning process when it is still
possible to influence decisions;
 Providing better information and data for planning and, in particular, information on
which communities had the greatest transportation needs; and
 Determining the amount of funding directed to those communities who depend on those
transportation services, and how those services might be improved.

15
Chapter 4 ▪ EJT Evaluation Tools, Procedures and Examples
This chapter is the toolbox for performing analysis on the EJ issues and communities. Several of
the tools presented here were used in the BREJT case studies.

Demographic Profile
Demographics refer to the characteristics of the residents of a community. This is an important
type of data because it can show the baseline conditions of an EJ community before a
transportation project is initiated and again after. It can also be used to perform comparisons
against affected and non-impacted communities. Steps involved in gathering and analyzing
demographic data are:

1. Identify targeted neighborhoods by census tract, block group, zip code or another
geography with well-defined boundaries;
2. Select neighborhoods with a specific racial/ethnic composition;
3. Select neighborhoods with a specific poverty level;
4. Select neighborhoods with significant share of households with no vehicles;
5. Identify the geographic area impacted by governmental action.

Where is the impact? Is it at the neighborhood, community, regional or corridor? Once the impact
area boundaries are determined, a band measurement analysis can be performed using the
following widths or arc within ¼, ½, or one mile from the facility analysis. This can be done
through visual observation or you can use online GIS tools or contact your MPO for assistance.

Surveys are another method to capture demographic data and are particularly useful when the
neighborhood geography does not match a pre-defined source of data. Meaning, certain data
sources only report data for specific geographic areas. It is reasonable to expect that some
community boundaries do not overlap with these pre-defined datasets. The following categories
are examples of demographic data needed to develop a community profile:

 Sex
 Race
 Number people in household
 # of Children less than 18 in household
 Education
 Age
 Employment

Surveys should also be used to determine the nature and extent of the EJ concerns in a
community. The following questions were asked in the BREJT case study for the Kirk Avenue Bus
Depot:

These questions ask about your opinions as to the noise, air pollution, and economic impact of the
Kirk Avenue Bus Depot on your household and community.

16
Think about how noise from the bus depot affects you and your family.

1.) The noise from the bus depot is bad for the health of my family and me.
Strongly Agree
Agree
Either Agree or Disagree
Disagree
Strongly Disagree

2.) The noise from the bus depot is stressful to my family and me.
Strongly Agree
Agree
Either Agree or Disagree
Disagree
Strongly Disagree

3.) The noise from the bus depot is annoying to my family and me.
Strongly Agree
Agree
Either Agree or Disagree
Disagree
Strongly Disagree

Think about how air pollution from the bus depot affects you and your family.

1.) The air quality from the bus depot is bad for the health of my family and me.
Strongly Agree
Agree
Neither Agree nor Disagree
Disagree
Strongly Disagree

2.) The air quality from the bus depot is stressful to my family and me.
Strongly Agree
Agree
Neither Agree nor Disagree
Disagree
Strongly Disagree

3.) The air quality from the bus depot is annoying to my family and me.
Strongly Agree
Agree
Neither Agree nor Disagree
Disagree
Strongly Disagree

17
Think about other ways that the bus depot affects you and your community.

1.) The bus depot has a bad affect on the value of my home.
Strongly Agree
Agree
Neither Agree nor Disagree
Disagree
Strongly Disagree

Think about your interaction with the Maryland Transportation Authority (MTA) related to the
bus depot.

1.) On average, how many times per week do you complain to the MTA about the bus depot?
0
1-2
3-4
5-7
8 or more

2.) The MTA is responsive to my complaints about the bus depot.

Strongly Agree
Agree
Neither Agree nor Disagree
Disagree
Strongly Disagree

The following questions will help us to understand your transportation-related activities.

1.) What is your primary mode of transportation?

Walk
Bike
Auto
Bus
Rideshare

2.) On average, how many round trip bus rides do take per week?

None
1-5
6-10
11-15
16 or more

18
3.) On average, how many round trip bus rides do take per week?

None
1-5
6-10
11-15
16 or more

1.) How many vehicles are there within your household?

0
1
2
3
4 or more

2.) What types of vehicles do you own?

(Circle all that apply)
None
Car
Truck
SUV
Motorcycle

Do Your Due Diligence

Due diligence suggests that the community has conducted a sufficient amount of research to know
the history of the area. Information on transportation, land-use impact models and procedures
and information on results—“What is analyzed and its impact” is available through the MPO, the
DOT, and at the public library or on the Internet. A method to ensure that there is minority
representation on local and regional transportation committees is to get policies on transportation
committee membership and assess minority membership on policy and technical committees—
calculate the number of minority members and compare to city regional minority population
percentage. If the percentage difference is, less than 10 percent ask for greater representation.

EJ Evaluation of Transportation Plans (Performance-Measures)

In general, transportation projects are evaluated using performance metrics for their effectiveness
(how well a proposal meets its objectives), efficiency (the cost of a project relative to its benefits)
and equality (how equal are the burdens and benefits spread across geographic, income, racial
and ethnic lines). Table 5 provides guides for using performance measures to evaluate equity.

To better understand and frame community-based issues and to inform the decision-making
process we recommend that goal-oriented performance measures be used to focus how
investments in the transportation system impact on low-income and minority communities and
that objective - oriented metric measures show how improvement plans enhance transportation
system performance in terms of accessibility gains associated community strategies.

19
Land-Use Impacts
Land use characteristics include zoning, building type, condition, and height. These factors impact
the quality of life in a community. Information on long and short-range land-use plans are
available at regional and city planning agencies. Land use maps that affect low-income and
minority neighborhoods are particularly important. Documentation on the number of dilapidated,
deteriorated structures provides the data to calculate the percentage of these structures in the
neighborhood.

a. # dilapidated structures/total community structures = percentage

b. # deteriorated structures/total community structures = percentage
c. Trend Analysis—5-10 year period

Table 5: Measuring Equity

Community
Issues Community Driven Public Participation
Goal Objectives Performance Measures
Job Access Economic Vitality Encourage Work Opportunities within 15, 30 and 45 minutes
and Competitiveness Employment by car and transit door-to-door. Percent of
Opportunities Urban transit-dependent riders who can access jobs with
Communities 45 minutes by fixed route of transit
Maintenance Safety and Security Stop the Use of Old Percent and characteristic of out of service buses
(Motorized and Equipment in Low coming into and area.
Non) Income Pedestrian/bicycle injuries & fatalities
Neighborhoods Vehicle Crashes, Age of Fleet
Increased Increase Access to Jobs Proximity to transit
Accessibility Accessibility and Level of Service
Mobility Options Accessibility to health care facilities
Accessibility to educational facilities
Reduce Air and Protect Clean Environment Air pollution Concentrations, Incidence rates of
Noise Pollution Environment, Respiratory disorders, Number of Households
Conserve Energy exposed to noise. Asthma rates in communities
and Improve Quality adjacent to large transportation facilities,
of Life
Improved Enhance Access to Shopping Number of fatalities
Transit Route Connectivity and and Services locations improved per million passenger miles
Structure Integration Across
Modes for People
and Freight
Need Manage and Advocate for project Condition of roads and streets
Assessment Preserve Existing funding to improve Condition of side walks
Transportation local conditions. Ratio of uncontested travel time between origins
System and destinations
Funding Equity Local Fairness in Transit Per Capita Transportation expenditures
Regional Funding Per Capita Operating Expenses
Statewide Number of fatalities
Identity of user who benefit
Locations improved per million passenger miles

20
Industrial/Commercial/Institutional
Acquire plans/maps that show industrial/commercial/institutional development from the city
and regional planning agencies. To compare, sort the information by census tract, traffic analysis
zones, and zip codes for minority and low-income neighborhoods. Industrial / commercial /
institutional structures may be calculated as follows.

Industrial Gross Square Feet of Floor Space (include parking)/Total Gross Square Feet
Space in Neighborhood/Community = Percentage

Revaluation
Let’s take a look a look at the residential, traffic, transit usage and trip patterns.

Residential -The following data is required to prepare a comparison table/ranking. Single

Family, Two Families, Multi-Families, Townhouse, Condominiums, Manufactured, Demolition.
Information can be obtained by review of U. S. Census data, city planning, and regional planning
documents for both residential and non-residential development activity. Acquire program
construction/demolition schedules from the city-housing agency.

Traffic Data—Detailed information is needed for two purposes: to analyze existing problems and
to develop mathematical models for forecasting travel. The most common units for measuring
travel are as follows:

 Traffic Volume (on a road segment)

 Person Trip and Vehicle Trip
 Passenger Vehicle Trip and Commercial/Freight Trip
 Person Miles Traveled and Vehicle Miles Traveled

This data is available at the MPO and is constructed in tabular format specifically in Traffic
Analysis Zones (TAZ). The data can also be refined to corridors. This data should be analyzed
using the trend concept and will show the travel patterns (existing) on a particular facility or area.
The information is often used with travel surveys to forecast future travel behavior. Calculations
of the following may be required:

# Persons x Avg. Trip Length x # of trips = Person Miles Traveled

# Vehicles by Type x Avg. Trip Length x # of trips = Vehicle Miles of Travel

Transit Dependency— Transit dependency is defined as persons who either have no driver’s
license and/or no automobile. This information can be used to evaluate what mode and
investment should be made into the transit system. Areas with high transit dependency
characteristics should have more dollars per capita invested in transit. Obtain information to
assess transit dependency through transit agency surveys or regional travel surveys. The
following calculation is how to determine per capita invested in transit.

Dollars spent on indirect miles in connection/# persons in service area ¼ mile of transit
route = per capita invested in travel

21
Auto Ownership—Calculating auto ownership can be obtained directly from the 2000 Census
data, and Regional Travel Surveys. Simply perform a trend analysis in the neighborhood or
community.

Trip Table/Traffic Volume—This data can be obtained in the following manner and should be
analyzed at the neighborhood, community, and corridor levels. Trip table data will show trip
purpose as well as the number of origin/destination/zonal pairs. Traffic volume data will
indicate various levels of services on the street and highway network. Capacities and level of
service are closely related and often are easily confused. While capacity is a measure of demand
that a roadway facility can potentially service. Level of service is a measure of the operating
conditions, the Highway Capacity Manual list operating conditions A-F. This data can be obtained
from Regional Planning Agency, and the City Department of Public Works. Simply stated LOS
Conditions D, E, F, indicate a problem with traffic flow and should be stated as a problem that
needs investigation. The travel impact at these LOS levels is: Increase air pollution, Highway
travel cost, Increase congestion, longer travel times and reduced accessibility.

Public Health Risk

There is a growing recognition among public health, planning, and transportation professionals
that land-use and transportation planning decisions can have a substantial impact on the public’s
health. The evidence relating a decision’s environmental effects to potential adverse health effects
is clear.

Table 6: Public Health Matrix5

Category Proximity Traffic Health Exposure Metric Reported Effects 95%
and Density Effects with Positive CI
Citation Assessed Associations

Respiratory 550 ft 5,500 - Prevalence ADT Asthma Related 1.10-

English et.al 9,000 of Asthma Distance to Doctor Visits
Residence

Asthma 200 m ≥% Heavy Asthma ADT Asthma Hospital 1.13-

Lin et al. Trucks Hospital Distance Admissions 3.29
Admissions to
Residence

Mortality K 100 m N/A Cohort Residential Cardiopulmonary 1.09

et al. Freeway or Mortality Distance to Mortality – 3.52
50 m Urban Freeway and
Roads Urban Road

Adverse 500 m 93,000 Preterm Residential Preterm 1.03 -

Birth vehicles Delivery Distance to Delivery 1.65
Outcomes per day Freeway

5
Nancy Kipp, NIH, 2007

22
Air Quality—The detrimental effects of poor air quality are numerous. The following calculations
can be used to determine the amounts of Hydrocarbons and NOx, a generic term for a group of
highly reactive gases, all of which contain nitrogen and oxygen in varying amounts. Nitrogen
oxides form when fuel is burned at high temperatures, as in a vehicle engine combustion process.
The results of the calculations below will give you an indicator of the air quality in the
neighborhood and community.

3.26 grams x Vehicle Trips = o.36 grams x Vehicle Miles Traveled = Hydrocarbons (HC)
1.56 grams x Vehicle Trips = 0.71 grams x Vehicle Miles Traveled = Nitrogen Oxides (NOx).

Incidence of Respiratory Ailments –Respiratory ailments are an ongoing EJ concern in urban

communities. It is important to examine the potential links between high respiratory ailment rates
in a neighborhood or community to the air pollution created by emissions from buses and trucks.
The local Department of Health should be able to provide incidents of respiratory ailments (e.g.
asthma) by number of cases and rates (e.g. per 100,000 population) within the geographical
boundaries defined by the department. This data can be overlaid with Census 2000 data or zip
codes to determine if there is a potential negative affect on the specific areas under analysis. In
addition, neighborhood and community organizations can be solicited to identify persons in the
neighborhoods and communities who are challenged by respiratory conditions.

Influence on Cancer-There are various Cancer Risk / Exposure Cancer Incidence

determinants for cancer, however, a Identification of
Identification of
polluted environment can exacerbate the Chemical Carcinogens Environmental Cancers

symptoms of persons diagnosed with MD Cancer

Exposure
cancer. In particular, trachea, bronchus, and By Source and Route Cancer Prevention Mortality Rates
Priorities
lung cancer are vulnerable to deleterious Cancer Potency
MD Cancer
effects of polluted air. The local Department Weight of Evidence Incidence Rates

of Health is charged with maintaining by Cancer Spatial Analysis

Of Cancer Cases
number of cases and rates (e.g. per 100,000 Risk

population) the number of incidences of Risk-Based Surveillance-Based

trachea, bronchus, and lung cancer within Cancer Incidence Cancer Incidence

their prescribed geographical boundaries.

Figure 4
This information can be overlaid with
Census 2000 data or zip codes and compared to other areas to determine if there is a possible link
of pollution to incidences of cancer and in the specific areas being analyzed.

Strategies for the prevention of environmental cancer can be evaluated using a dual approach
considering the spatial distribution of both cancer risk and incidence as depicted in Figure 4. The
juxtaposition of the geographical distribution of mobile source-related ambient carcinogenic air
toxic concentrations with cancer rates may inform prevention priorities. This approach is limited
to the use of publicly available data.

Although the primary concern among communities impacted by traffic relates to the nature and
extent of the health threat, the actual health threat that can be attributed to air pollution from
traffic is a difficult thing to directly assess. Challenges to being able to directly assess traffic
related community health impacts include the following.

23
  Multiple Sources. Traffic is not the only source for the noise and air pollution that
impacts communities and therefore, it can be difficult to attribute health effects
experienced by communities to any single source. For example, some of the same
pollutants that are produced by traffic are also produced by auto body shops, tobacco
smoke, or gas stoves.
 Multi-factorial Diseases. The cause of health effects observed within communities such as
cancer, asthma, or cardiovascular disease are multi-factorial, i.e. traffic-related air pollution
may contribute, but is likely not the sole cause. The incidence rates for these diseases are
relatively high so that it is difficult to detect the expected small increase attributed to
traffic-related air pollution.
 Statistical. Considering the two points above, communities may be too small to provide
sufficient statistical power to tease out the influence of traffic.

Given these limitations, two related approaches are available to communities to help understand
the health threat (Figure 5). The first examines the nature and extent of traffic-related air pollution
exposure within the community. The second approach assesses the health risk from the estimated
or measured exposure.
For census tracks across the United States, the
Environmental Protection Agency has estimated air
toxics exposure and risk from source categories
including traffic. These data may be useful to
communities to compare their traffic-related air
pollution risk to other source categories or other
census tracts across the U.S. These data are publicly
available as a part of EPA’s National Air Toxics
Assessment (NATA) for the years 1990, 1996, and
1999 can be at http://www.epa.gov/nata/.
Figure 5. Exposure and Risk to Bridge the Gap of
Community Health Concern

The exposure research is clear in identifying four primary and interrelated determinants of
community exposure to traffic related air pollutants.

1) Temporal variables of varying scale including time of day (e.g. rush hour), day of week
(e.g. weekday versus weekend), and season.
2) Roadway proximity. Pollution levels drop exponentially with distance from the roadway
source. Therefore, proximity of the roadway to the community is an important risk factor.
3) Roadway traffic level and class. The air pollution source strength is directly proportional
to the traffic density and is influenced by vehicle fleet characteristics including engine
type, fuel, age, and size.
4) Meteorology. Air pollution concentrations are strongly influenced by meteorological
factors that affect fate, transport, and dilution including wind speed, wind direction, and
mixing height. In addition, source emissions are influenced by temperature and relative
humidity.

24
The temporal variability is determined by commuting patterns resulting in differences from
weekends to weekdays and within a weekday, due to morning and afternoon rush hour
(Chetwittayachan et al. 2002; Nielsen 1996; Sapkota and Buckley 2003). Of particular public health
relevance are assessments based on measurements that are time-resolved and that consider the
multitude of mobile source emissions. Time-resolved measurements are informative in both
assessing the health hazard as well as the source contribution (Gilliland et al. 2005). When these
methods are linked with appropriately timed health outcome studies, it is possible to link specific
source categories to health outcomes (Hopke et al. 2006; Thurston et al. 2005).

National Air Toxics Assessment - As a part of the National Air Toxics Assessment (NATA)
program, US-EPA has conducted national scale assessment of various hazardous air pollutants
(HAPs), using a Gaussian dispersion model. The model - Assessment System for Population
Exposure Nationwide (ASPEN) provides national annual estimates of ambient concentration of
various air toxics for the base year 1996, with spatial resolution down to the census tract level
(Caldwell et al. 1998; Woodruff et al. 2000). In deriving the ambient concentration, the model takes
into account several important determents of air pollution including discharge rate & height,
location of discharge, wind speed & direction, atmospheric decay, deposition and secondary
formation (User Guide for ASPEN, EPA-454/R-00-017). These data can be used to estimate
cancer risk at the spatial resolution of the census tract or scaled up to spatial scales relevant to the
available cancer data (e.g. county).

In our dual assessment of air toxin risk and cancer incidence, smoking prevalence is also
considered because of its important contributory role in the development of cancer. Estimates of
county-level current smoking prevalence among adults (≥18 years) can be obtained from survey
data (State of Maryland Department of Health and Mental Hygiene 2001).

Cancer Incidence Data - A weight of evidence review was conducted to identify those cancers
with epidemiological evidence of associations with environmental and/or occupational
exposures. Occupational studies provide the strongest evidence of the association between
chemical exposure and increased cancer risk. Based on this analysis (or criteria), seven cancer
sites were identified including: 1) bladder (Silverman et al. 1986), 2) kidney (McCredie and
Stewart 1993), 3) liver (Forman et al. 1985), 4) lung (Blot et al. 1983), 5) leukemia (Rinsky et al.
1987), 6) non-Hodgkin’s lymphoma (Persson et al. 1989), and 7) multiple myeloma (Rinsky et al.
1987). For each of these sites, age-adjusted cancer incidence rates are potentially available with
appropriate approvals that protect the confidentiality of data.

County-level cancer risk, incidence, and smoking prevalence can be analyzed using a variety of
approaches. First, their geographical distribution can be assessed via mapping using
ESRI®ArcMap™8.2. Second, the distribution of risk can be compared to incidence graphically.
Lastly, a 2x2 table can be used to group spatial units that are above (high) and below (low) the
median for risk and incidence while at the same time taking smoking prevalence into account.

Noise Pollution- Noise, the effect of noise on people can be substantial and stressful. Therefore,
transportation related noise impact can range from annoyance to stress related illnesses. Noise
can interfere with communication and concentration, an example being that noise diminishes the
ability of students to learn in a classroom environment (Seep et. a. 2000). Noise can cause sleep

25
deprivation, and stress, contribute to high blood pressure and heart disease (Sandberg and Ejmont
2000, Fra, 1998, and Lee and Fleming 2001). The measurement of noise as an indicator of
transportation impact is generally expressed as an amplitude measurement, which indicates
volume. To the right is the range and impact of audible sound on the human ear. The question of
noise impact should be brought to the attention of local government, usually the Department of
Public Works. In addition, most communities have noise ordinance laws, which can be enforced.
Communities can also measure noise themselves or retain the services of a noise engineer. The
measurements are obtained over a period of time; it is recommended that an environmental
performance noise check is conducted using electric condenser microphone that provides
improved reliability over standard condenser microphones.

Table 7: Noise Levels

db A) Quiet suburban Highway traffic 300 feet Train horn—200 Threshold of

Scale6) neighborhood from hearer (60) feet from hearer hearer
(40) (100) (135)

6
Handbook of Transportation Engineering, 2004; Ed. Meyer Kutz, McGraw Hill, New York, New York

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Chapter 5 ▪ The Baltimore Experience
BREJT conducted four case studies in the Baltimore region, all in Baltimore City. This chapter
reports the results of the case studies, including: the issues that would be explored in each case
study and the information that we recommend be compiled before we take the case study
recommendations back to the community work groups. This information is to illustrate possible
approaches to EJT in other regions.

Congestion and Environment: Will focus on the impacts and mitigation opportunities associated
with the Maryland Transit Administration’s Kirk Avenue bus depot. This study is also viewed as
a platform for addressing the “neighborhood” level of problem.

Public Involvement: It is proposed that this study area focus on public involvement with
transportation issues in the US 40/Red Line corridor extending through west Baltimore. This
study will investigate how the public has been involved in planning decisions made in relation to
the Red Line, their level of satisfaction, and parallels that may be drawn with earlier corridor
efforts such as the “highway to nowhere”. It will also consider state and city efforts to generate
support for TOD development around the West MARC rail station. This study will be the
platform for investigating the “corridor” level of transportation impact.

Quality and Adequacy of Transit Service: Focused on issues stemming from transit service
changes at Lexington Market, but will extend to broader issues regarding integrity of transit
service and the design of Lexington Market to successfully function as a regional transit hub and
pedestrian center. This study will also provide the platform for “regional” impact.

Quality and Adequacy of Transit Service II: During the course of Project Team discussions,
concerns were raised as to the ability of the project to address the issues of transit service raised by
the Cherry Hill community. Cherry Hill is in many ways an exemplary minority/low-income
community that has had its transit service changed or curtailed in significant ways, and found its
ability to generate interest in solving its problems to be limited and frustrated. Knowing the
desire of this particular community to be heard and seeing transit service at the neighborhood
level as an important toolkit application, the initial strategy was to try to incorporate Cherry Hill
into the Lexington Market case study. As such, it would be investigated from the standpoint of
“what happens on the origin end” of the trip when routing and service are changed to a key
destination such as Lexington Market. The Project Team felt that this treatment by association
with Lexington Market was too diffuse to assure a comprehensive, head-on study of this area’s
concerns. The result was the decision to make Cherry Hill into a separate fourth case study, while
also maintaining a “family” connection to the transit service changes at Lexington Market. A brief
summary of how each case study was framed is shown in Table 8.

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Table 8: Physical Community Profiles

Questions To Ask Cherry Hill Kirk Avenue Lexington Market US 40

Overall Access to and from
Transportation Issues Interstate
Pedestrian & bicycles
barriers Safety
Substandard intersection
interchange
Noise Barriers Pollution from busses Intercity mobility
Air Quality Diesel exhaust Regional mobility
Public Participation Removal of bus stops Safety
Age of Facility Increased walking
distances
Suitability

Annapolis/Waterview Proximity to
neighborhoods
Narrow and obstructed
with utilities
Regional Access I-95 & McComas Greenmount Avenue All Points CBD Route 40, I-95, I-
Points I-95 & Hanover Harford Road 295, MLK.
Boulevard
I-895 & Potee Loch Raven Boulevard
I-295 & Waterview
Pedestrian Activity Cherry Hill Light Rail Kirk Avenue Citywide Schools
Generators Station Automotive body Shopping
Westport Light Rail shops

Main Traffic Street Waterview Avenue Kirk Avenue Eutaw Street Edmonson Avenue
(Minor Cherry Hill Avenue 25th Street Paca Street Monroe Street
Arterials/Collectors)
Hanover Street/Potee Route 40 Fulton Avenue
Impacted Middle River Homewood Avenue Appleton Mid-Town
Communities West Port Bartlett Avenue Harlem Park Edmondson

Midtown Harlem Park

Orowso
What Government Economic Development Inner City Bus Facility TOD TOD
Wants Enhanced Transit Access Reduced Operating Reduce CBD Red Line
Points Cost Congestion Economic
Market Priced Housing Development
What the Community Better transportation Keep Homes Improve Transit & Better
Wants Better transit services Find Land Use Transportation transportation

Low income affordable Clean Environment Low income, Better transit

housing for residents of affordable public services
Community Cohesion
public housing housing Community
Bus Facility Moved Cohesion
Economic
Development
Impact Measures Land use impacts Accessibility Individual Analyze
Direct, indirect, secondary Select link analysis accessibility to accessibility using
and cumulative effects (VMT and VHT) Lexington Market select link analysis
(based on Traffic & Time, distance, and Crime statistics and traffic flow
population forecast population proximity data
Employment accessibility analyses Collect data from
and service accessibility adjacent
communities.

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Case Study Report: Kirk Avenue Bus Yard
The Midway Community is one in which residential and industrial uses collide. The Kirk Avenue bus
yard has been a point of contention between the surrounding community and the Maryland Transit
Administration (MTA) for some time. The primary complaints have to do with the impact of noise and
emissions from bus operations on the community and its residents. The bus yard is located between
industrial land to the north and east and residential neighborhoods to the west and south, that seem to
have somewhat receded over time. What is not clear is the extent to which the operations at the Kirk
Avenue bus yard have directly caused the decline of the neighborhood.

Community Concerns
 Residents complain that the noise levels at the bus yard are too high and are causing
physiological health impacts.
 There are concerns about the impacts of engine idling on residents’ respiratory health. A
number of residents have asthma and some have died of cancer.
 The bus yard is too close to homes. The Kirk Avenue bus yard is 1 of 3 MTA bus yards located
in or near residential areas.
 Residents are concerned about the impact of the bus yard on property values, as the bus yard is
perceived as having a negative impact upon the community.
 Quality of life has declined for many residents due to an inability to fully use their homes
because of exhaust and noise. Examples cited were: Not being able to open windows in rooms
facing bus yard; No one with any respiratory problems can sleep in the back rooms; and No
backyard cookouts.
 Community representatives have appealed to the MTA on numerous occasions to address these
conditions but feel their concerns are not being resolved or at time, even considered.

Analysis and Findings

Bus Operations:
 In terms of daily pullouts, the Kirk Avenue bus yard is the 2nd largest MTA bus facility.
 All 4 of MTA’s bus yards have had a significant decrease in bus pullouts between 1997 and
2007; however Kirk Avenue has experienced the largest decrease (22.5%).
 Some of the bus routes leaving from Kirk Avenue directly serve the Midway Community. Of
the 12 bus routes that leave the Kirk Avenue bus yard, 4 are within a 1/2 mile radius of Kirk
Avenue and 2 are within 1 mile.

Community Impacts:
 Noise pollution noted at bus yard: Announcements over loud speakers, Engines running
throughout day and night, Repairs and servicing.
 Recorded noise levels exceeded Baltimore City ordinance levels during both day and night,
nearly every day tested. Noise levels were higher during night hours, especially on weekends.
This could affect residents’ health (loss of sleep, high levels of stress, etc).
 Although the daily average of air pollution didn’t exceed the federal standard, the 2 week
average indicates that the annual standard may be exceeded.
 The effects of air pollution put residents at an increased risk for adverse health effects. Related
illnesses and doctor/hospital visits were documented and mapped.

29
  Property values are lower in the 1/4 mile residential areas surrounding the bus yard,
particularly given the houses are larger units than those in the surrounding area.

Assessment and Recommendations:

 MTA is currently responding to the community’s concerns with some mitigation measures (all
new hybrid buses are located at the Kirk Avenue bus yard rather than diesel fueled buses, new
operational procedures have been put in place, a new structure is replacing the old structure,
etc).
 The community should have ongoing, structured, negotiations with MTA regarding near-term
and long-term strategies that will begin to provide some relief from the impacts which are
substantially attributed to the bus yard.
 The community should ask the MTA for a clear statement of the likely impacts of the new,
planned facility and pursue mitigation for impacts from construction and implementation of the
new facility.

Tools Used in this Case Study:

 Residents maintained a Diary of concerns, that was made available to the team
 Community meetings
 Map of bus routes
 Socio-demographic profiling
 Homeownership and property value analysis
 Map of reported illnesses and health concerns
 Indoor and outdoor air pollution measurements

Key Policy Questions

 Should damage assessment fees be considered for transportation systems that
disproportionately impact communities?
 Scaling upwards, how can the overall EJ concern of minorities be addressed within the existing
transportation system? What practical solutions can be implemented?
 How can future transportation systems be designed in a way to facilitate movement while
minimizing distributional economic, environmental and health outcomes across communities?

Case Study Report: Cherry Hill Issues

The Cherry Hill community is located in the southern section of Baltimore City, south of the Inner
Harbor/Central Business District of Baltimore City. The Cherry Hill community was established in the
late 1940’s when the Housing Authority of Baltimore City chose it as a site of a federal project for
African American war workers migrating from the South. In those days of segregated housing, no
neighborhood in the city was available for an influx of African Americans. Today , Cherry Hill is a
mostly residential area with apartment complexes, row houses, and public housing projects. Some of
the public housing has been demolished leaving large tracts of land in the middle of the community
that can be redeveloped in the future.

Community Concerns
 Residents feel there are too few buses

30
  The buses do not run on schedule
 Bus stops, shelters, sidewalks are poorly maintained
 Paratransit vehicles are poorly equipped
 Drivers are impolite
 As a poor community, residents are highly dependent on transit
 People miss appointments or are left stranded
 Employers see Cherry Hill residents as unreliable
 Complaints go unanswered

Analysis and Findings

Impact of Changes on Regional Accessibility:

 Decreased transit access overall
 Major areas of east Baltimore are inaccessible within 1 hour of travel time
 Access to substantial areas of northeast Baltimore are no longer reachable without at least one
hour of travel time
 Light rail service has improved travel time to jobs in the BWI corridor
 Overall access to jobs for transit dependent households in Cherry Hill has declined

Community Profile and Changes:

Between 1990 and 2000 there was a marked change in the size of the Cherry Hill Regional Planning
District (RPD). Here are some of the findings:
 Overall population declined 21.1%, with the largest population decrease among whites (-46.8%)
with the largest increases among non-whites (+77.8%) and Hispanics (+99%).
 There was a 12.9% decline in the number of households
 The largest decreases in households were seen among married couples with children
(-51.4%)
 Single person households increased by 15.8%
 By age, the largest decreases were seen among 18 to 44 year olds (-31.7%) and in children under
5 (-29.6%)
 The total reduction in housing was 9.3%, but percent change in vacant homes increased by 113%
 The number of employed residents fell by 28.6% and the unemployment rate was 15.5% of total
labor force – well above the national average

Assessment and Recommendations

 An initial review shows the Cherry Hill community has experienced deferential treatment with
regard to transit service, however additional investigations should be undertaken to quantify
and legitimize residents’ claims. Recommended studies and actions are listed below.
 Consider developing an independent monitoring and assessment program to document
community concerns regarding both transit and paratransit services.
 Implement a process to report back to the community about the status of investigations into
complaints, including any changes implemented as a result.
 Create a community advisory board.

31
  Establish that the reductions in bus services after the Light Rail service that began in 1992 were
not part of a much larger, system wide reduction in services due to financial restrictions

Tools Used in This Case Study

 A Listening Session
 Maps showing changes to transit travel times
 Regional travel model analysis
 Population, housing, and employment statistics
 Map of available transit in area

Key policy questions

 In the face of decline in bus service quality and frequency, what is the associated impact on
community socio-economic performance?
 What lessons can be learned from the Cherry Hill study to integrate in transit service decisions
regarding the socio-economic impacts of route decisions?
 How can the socio-economic concerns of communities be addressed through participatory
public transportation system decision making process?

Case Study Report: Lexington Market

Lexington Market is a major commercial destination in downtown Baltimore, providing fresh produce,
meats, seafood, and a variety of vendors selling items in a large, historic building. The market is not
only a major tourist attraction, but also a mainstay for a large portion of Baltimore’s minority
community, who prize its selections, freshness and tradition. Beginning in 2001, the City of Baltimore
Police Department, the Market Authority, and the MTA introduced a set of controversial changes when
they moved the stops for several of the bus routes.

Community Concerns
 The public felt it had been marginalized and left out of the decision-making process
 Commercial interests were given preference over community well-being
 Shoppers complained they had to walk longer distances to connect with buses
 The public expressed concerned about exposure to vehicle exhaust as they walk to buses
 Pedestrians have to navigate busy traffic to visit the market or transfer between transit services.

Analysis and Findings

Changes in Regional Transit Access:

 Historically, a large number of the city’s minority and low-income residents have traveled to
the market by public transportation
 Improvements in transit access to the market are seen in the communities to the north and west
of the market. A significant improvement was also noted for Westport residents (-11 minutes).
 In general, due to the addition of Metro and light rail, a much higher percentage of the region is
within a 1-hour travel window of Lexington Market in 2000 over 1990.
 The net effect of the added rail services seems to have improved transit access to the market.

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Transportation statistics:

 The crosswalks at Lexington Street are not signalized. The crosswalks supports major
pedestrian traffic made up of visitors and transit users.
 A 1996 City of Baltimore traffic report documents that 600 to 800 vehicles travel every hour
along Eutaw Street in front of Lexington Market. This amounts to one vehicle every 4 to 6
seconds, making crossing without a signal difficult and dangerous.
 Pedestrian counts taken at the same time show over 500 pedestrians crossing Eutaw Street.
Given the narrow sidewalks, these high volumes of pedestrians and vehicles make for
congested conditions.

Assessment and Recommendations

 Some hardship may have been visited upon riders to Lexington Market as a result of the
movement of bus stops. However, further information is needed to assess the actual impacts.
 What is evident is the community was not included in the decision-making process of moving
the bus stops. This “issue of process” is more a concern from an environmental justice
perspective than the movement of the stops themselves, since they show a lack of consideration
for an inclusive process. Recommend the following:
o Research ways to improve decision-making process
o Implement improved process for notifying and involving transit riders of proposed
changes to bus stops
 Due to high traffic volumes, pedestrian safety remains a concern for both transit riders and
visitors. Recommend the following to address these concerns:
o Collect updated traffic counts to determine current safety issues between pedestrian and
vehicle traffic.
o Identify and evaluate alternatives to improve pedestrian safety and access.

Tools Used in This Case Study

 Community meetings
 Measure vehicle and pedestrian traffic volumes
 Study changes to travel times

Key policy questions

 What are potential distributional impacts of transit stop changes on minorities and low income
riders?
 How can potential community concerns with transit stop changes be addressed through a
participatory public hearing?
 What are the long-term impacts of transit changes on users and long-term uses?
 How do transit changes impact local businesses through impact on volume of passengers to a
particular location?

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Case Study Report: US 40 Highway-to-Nowhere
The “Highway to Nowhere” is a massive section of roadway that begins on the western edge of
downtown Baltimore and heads due west out of the city as part of US 40 through the neighborhoods of
Poppleton, Harlem Park, Lafayette Square and Rosemont. Once the starting point of an ambitious plan
to connect I-95, as it passes through Baltimore, with I-70, which terminates at the Baltimore Beltway (I-
695) in the west, the highway would have been called as I-170. However, the plan ran out of
momentum and support before it could proceed beyond the railway line, and thus it remains to this
day–almost 30 years after it was opened to traffic – a grade-separated superhighway that is only 1.4
miles long.

Community Concerns
 The Highway to Nowhere is a ditch that cut the community into two halves.
 The creation of the Highway to Nowhere led to a decline in property values and in increase in
abandoned buildings.
 There has been an increase in crime, especially drug-related.
 The city and state have allowed the area to decay over the last 30 years and nothing significant
has been done to help correct the mistake of the highway.
 Residents fear being displaced again when new improvements are introduced.

Analysis and Findings

Demographic Characteristics and Changes:
 In the 3 main communities affected by the Highway to Nowhere (HTN), significant shifts in
population were noted: a 67% decline in the central area and an 80% decline in the eastern area
from 1950 to 2000, and a 39% decline in the western area from 1960 to 2000.
 From 1940 to 2000, Baltimore’s White population fell 70%, while its Black population more than
doubled (rising 253%).
 The HTN corridor is mostly comprised of minority families with low-to-moderate incomes,
many earning less than $30,000 per year.
 Residents living closest to the eastern end of the HTN have a median-income of less than
$15,000 per year.
 Residents of the hard-hit eastern section also show signs of economic and social distress:
o 48% of residents over 25 have less than a high school education
o 43.3% are living below the poverty level
o 28% of housing is vacant
o 57% of homes are occupied by renters.
o 15% of homes are owner-occupied.

Congestion, Air Quality, and Transit:

 Some portions of the HTN corridor show congestion, particularly where the “expressway”
ends.
 Fulton and Monroe Streets also experience congestion, as they are major arteries bringing
substantial traffic through the west Baltimore neighborhoods.
 A substantial amount of traffic on the HTN comes from outside Baltimore City. This traffic
stream is growing each year – daily volumes have increased by 24.5% just since 2000.

34
  The principal population subgroups that use the HTN corridor appear to be of a very different
socio-economic mix than those live along the corridor.
 Along the 1.4 mile HTN corridor, daily production of emissions equal 39.2 tons a year of
Hydrocarbons and 26.9 tons a year of NOx.
 Bus transit service is good in the corridor, with MTA bus routes No. 10 and 40 providing
frequent east - west from downtown to Social Security, and various cross-routes providing
north-south connection.
 There is access to a commuter train, but no local rail transit in the corridor. However, the
proposed Red Line would occupy or parallel the US 40 right-of-way along much of its length.

Assessment and Recommendations

 It is clear that the communities in the W. Baltimore neighborhood adjacent to the HTN have had
a difficult time. The dislocation of several thousand residents left the remaining African
America homeowners and communities struggling to sustain a proud past.
 The HTN remains 30 years later as a daily reminder for residents of “planning gone wrong.”
 The local residents bear the burden of 36,000 vehicles a day passing through their communities,
generating an estimated 1/4 ton of ozone-producing pollutants each day, while the commuters
from Baltimore, Howard, Frederick and even Montgomery Counties have the benefit of access.
 A significant community planning effort is needed to address the disproportionate burden that
is borne by this predominately low-income, minority community.
 Baltimore City and the MDOT have initiated planning processes in West Baltimore related to
the Red Line transit project and West Baltimore MARC station improvements. It will be key for
residents to work closely together with planners to ensure community needs are met as
planning moves forward on these two projects.

Tools Used in This Case Study

 Map congestion levels
 Regional travel forecasting model
 Review of U.S. Census data

Key policy questions

 An assessment of the distribution of opportunities and burdens of proposed road projects needs
to be communicated to communities to generate public support. What are the mechanisms
through which proper information on the distribution of the impacts associated with new road
projects be communicated to communities?
 How do transportation planners and decision-makers integrate potential economic and
environmental distributional impacts of transportation systems?
 How can communities be engaged and well-informed to make choices about transportation
routes in and near their communities?

35
Chapter 6 ▪ Conclusions
This toolkit attempts to provide particular guidance on the selection of the appropriate analysis tools
and measures or analysis procedures. During the course of this project we have concluded that
effective environmental justice analysis requires that the user first frame the problem to determine
what sets of measures are most appropriate for its investigation (in relation to benefits and burdens)
and then assess how those measures will be used and interpreted (especially distributional
considerations).

In developing the framework of analysis for our toolkit we believed that there was a need to address a
wide range of demands with the limited guidance available from the existing body of studies and
guidebooks. We also believe that there are aspects of the transportation EJ analysis and problem
resolution process that are not effectively dealt with in the existing body of information and that this
body of information informally constitutes guidance to practitioners and agencies.

Pondering the range of problems and concerns that emerged from the Phase I Listening Sessions and
Community Dialogue, and later by Phase II and the completion of a comprehensive literature review
and the development of four case studies, the BREJT team developed a framework analysis tool with a
range of drill down analysis capabilities.

The following observations of system gaps are factors that shaped the development of this toolkit.

 That public outreach and involvement is extremely important for disadvantaged groups to
have a greater say in the planning and decision-making process. Special efforts must be made to
reach, inform and involve them. To be credible, that involvement should be continuous through
the planning process, early enough to have an impact on the outcome, and there must be a
mechanism to ensure closure.

 That agency fragmentation may have a lot to do with the inability to have a particular problem
properly addressed or acted upon, since the full authority for the problem may not fall within the
jurisdiction of a single agency.

 That there really is no step-by-step guidance offered (or intended) by any of the federal
regulations or directives on EJ, which means that there are no established protocols for conducting
EJ assessments and, hence, each federal-aid recipient is free or responsible for its own approach.

 In particular, there are no guidelines on what variables are critical and should be included in
appraising benefits and burdens. Studies are evolving toward a greater use of outcome measures
such as accessibility to jobs and opportunities, but whether or how this is done is left to the
discretion of the respective agency, and may be determined by either data limitations or local policy
norms.

 That different measure, analysis techniques and responses should be indexed to the level of the
problem at hand, with allowance for use of more simplistic methods when the circumstances would
not benefit from greater detail or accuracy, but where more informative methods are brought into
play when the nature of the issue demands them.

36
  That analytic tools, data and capabilities are highly variable across the many agencies that
engage in environmental justice evaluations and problem solving.

 That correct understanding and definition of “the problem” is 9/10ths of the task of identifying
the correct analysis approach and, ultimately, the solution. This places great weight on the process
of problem diagnosis and recommendation for further action.

 That every problem or assessment of equity or proportionality in benefits or burdens involves

“tradeoffs” to all parties; effective solutions must involve compromise which comes from informed
awareness of the relevant benefits and burdens and their distribution.

 That the technical elements and the public involvement elements in an EJ process should be
interconnected and reinforcing; in other words, the design of the analysis should not left wholly in
the domain of technicians nor should the public involvement process be denied critical information,
even if it is complex (or potentially controversial).

Ability to Influence Decision-Making

We have also concluded that agency fragmentation may have a lot to do with the inability to have a
particular problem properly addressed or acted upon, since the full authority for the problem may not
fall within the jurisdiction of a single agency. Closely tied to this is the paramount question of how
minority, low-income and other disadvantaged groups are truly able to gain access to “the system” and
trust it to hear their concerns and to get things done. In most areas, the process of defining needs and
setting planning and project priorities is a closely held privilege.

Triage Process: In the best of all possible worlds, ongoing outreach and community input would
address many concerns of low-income and minority communities. Next, in response to complaints
regarding a particular issue could be undertaken with the assistance described in the toolkit. In the end,
some issues appear intractable, run counter to prevailing policies, or may require substantial capital to
mitigate. Therefore a final step in the process is recommended that serves to provide an outlet to
communities that have been rebuffed by “the system”, and this is the Triage process.

Several factors limit the EJ population’s ability to seek remedy for EJ concerns or to ensure adequate
representation in the decision-making process. One important factor may be the fragmented network
of organizations authorized or equipped to address these issues. For example, the regional MPO may
have difficulty speaking out to raise concern about an issue with transit service, or with planning or
land use decisions in a local jurisdiction. Moreover, the single agency would probably find it difficult
to recommend a particular type of investigation or response if that response had implications for
responsibility outside of the agency. For this reason we have engineered an EJT Triage process at the
center of our framework as an institutional strategy for accomplishing collaboration among all the key
players, and as an advocacy group for the EJ community. We see this entity as comprised of sufficient
expertise and authority to be able to direct an analysis or investigation that will be broad enough to
appropriately deal with the critical underlying factors in the given problem, and not simply those
which are pertinent to the particular agency. We believe such a collaboration could be an effective way
of not only bringing more expertise and resources to bear on a complex EJ problem, but reduce the
exposure or risk of any given agency in having responsibility for recommending or implementing an
action.

37
Performance Measures, Analytic Tools, and Distributive Impacts
NCHRP reports 8-36(11) and 532 are excellent resources on the concept of benefits and burdens,
measures which can be used to quantify those elements, and technical assistance on availability and
use of analytic tools and data. NCHRP 532 even attempts the important next step of suggesting when
the use of particular tools and measures is most appropriate, i.e., at what level of the planning process.
These reports (which build upon the initial benchmark efforts of the Atlanta Benefits and Burdens
study) offer substantial aid to practitioners (chiefly planners and modeling specialists) on the tools for
performing EJ analysis.

There are also issues in how the analytic capabilities are used. As a primary example, most regional
planning agencies have GIS capability, and most are now attuned to use of GIS tools to perform buffer
analysis showing the location of target populations in relation to transportation system features or
service envelopes. However, the use of GIS as a serious planning tool is still largely in the early stages.
When combined with population synthesis techniques and household micro-simulation methods, GIS
can be a powerful tool for analyzing impacts and their distribution across discrete population
segments. NCHRP 8-36(11) and Report 532 should help greatly in illuminating these capabilities, but
practicing agencies will still have to be acquainted with the need and benefit of making the effort to
embellish and apply them in this manner.

38
Table 9 Performance Measures by Planning Goal Area

Performance Measures Application Analytical Method

Economic Vitality and Competitiveness
Accessibility to regional jobs C PL F RM GIS
Accessibility to entry-level/semi-skilled jobs PL F RM GIS
Employer accessibility to workers PL F RM GIS
Number of jobs by type and location PL DA GIS
Business receipts by location PL DA GIS
Property values by location
Safety and Security for Motorized and non-Motorized
Travelers
Pedestrian/bicycle injuries & fatalities C PL F PR DA GIS
Vehicle Crashes C PR DA GIS
Increase Accessibility and Mobility Options
Proximity to transit by type (bus, rail, etc.) C PL F PR RM GIS
Level of service (headways, days/hours of service C PL F PR DA RM GIS
Average travel times for selected O/D pairs by mode C PL RM GIS
Accessibility to regional educational institutions PL F GIS
Accessibility to regional healthcare facilities PL F GIS
Average age/condition of buses by area served C F DA GIS
Protect the Environment, Conserve Energy, and Improve
Quality of Life
Number of households living with X-feet of busy highway C PL F PR DA GIS
Air pollution concentration by type pollutant C PL PR RM GIS EM
Incidence rates of respiratory disorders C PL DA GIS
Number of households exposed to noise exceeding X-
decibels C PL PR DA RM GIS
Number of households living within X-feet of a bus
terminal C PL DA GIS
Percent of buses servicing area which use alternative fuels C PL F DA GIS
Percent takings, household dislocations, access restrictions PL F PR DA GIS
Enhance Connectivity and Integration Across Modes
Number of transfers required for transit trips between
select origin/destination pairs C PL RM GIS
Percent of travel time accounted for by transfers in select
origin/destination pairs PL F RM GIS
Manage Existing Transportation System for Maximum
Efficiency
Percent of congested to un-congested travel time between
select origin/destination pairs PL RM GIS
Preserve the Existing Transportation System
Condition of roads and streets PL F DA GIS
Condition of sidewalks PL F DA GIS
Funding Equity
Transportation capital expenditures per capita PL F PR DA GIS
Transportation operating expenditures per capita PL F PR DA GIS
Identity of users benefiting from new project or program PL F PR DA GIS
C=Current Concern, PR=Project, PL=Planning, F=Programming, DA=Data Analysis, RM=Regional Travel Models, GIS=GIS-Aided, EM= Emission Models

39
Pollution Exposure and Human Health
Finally, we draw issue with the fact that the most central and urgent tenant of environmental justice
overall – protection of human health – is not part of current EJ evaluations or included in the guidance.
This is perfectly understandable, since the state of the practice in EJ evaluation is still attempting to
reach an acceptable level of analytical competence while the analysis of health effects raises the
capabilities bar to still another level. As earlier discussed, two elements must be in place in order for a
health determination to be feasible: (1) data and analytic methods which can relate pollutant
concentrations in a particular location, and (2) statistical relationships that connect pollutant exposure
with incidence of particular health problems.

To date, health impacts have been overlooked because of (perceived) shortcomings in each of these
areas. However, based on the guidance on Air Quality evaluation in Chapter 3 of NCHRP Report 532,
new methods seem to be emerging that would make it possible to depict pollutant concentrations at a
finite geographic level through creation of “pollution surfaces”. This GIS-based methodology
combined with ever-increasing evidence from medical research on the pollution exposure-health link;
make it possible to begin to assess health consequences of transportation plans or projects. Our
proposed research and development of an EJT Toolkit will address these presumed deficiencies in EJ
guidance in the following ways:

Public Outreach and Involvement: This toolkit builds on the Phase I screen of regional EJ issues to
build a collaborative process with the community through development of the toolkit. Specifically,
several of the identified issues were selected as projects for study and resolution in Phase II, where we
worked interactively with the community in developing the analytic and institutional responses. The
community was at the table with us as we undertook to better understand the concern, identify and
assess its underlying causes (and history), and conduct the necessary data assembly and analysis to
fully understand the nature and impact of the concerns. The public worked directly with us as we
investigated alternative solutions, assessed tradeoffs, and developed a plan for implementation. These
problem-solving vignettes were documented as case studies, intended to relate the thinking behind, as
well as the outcomes, of the process. We then drew upon this practical and comprehensive experience
in developing the toolkit.

40
Appendix A: Literature Review
Introduction
A basic premise motivating development of the proposed Environmental Justice in
Transportation (EJT) Toolkit is that there is an outstanding need for a practical toolkit to
effectively address environmental justice concerns and requirements and to blend EJ into the
metropolitan planning and decision-making process. Environmental justice is a bold policy
objective of the Federal Government to bring about fairness and equity to disadvantaged
populations who might otherwise not be fully represented in societal decisions about funding
priorities, or able to affect the implications of those decisions on their mobility, health, or quality
of life. That work is still needed to advance this objective is confirmed by the outcomes of
Baltimore Region Environmental Justice and Transportation Project community meeting, held in
December 2004 at Morgan State University; where members of the region’s minority and low-
income communities were engaged at the neighborhood and regional level in a dialogue unique
to the Baltimore region to gain input on the whole ranges of concerns held by the affected
community. The identified concerns ranged from issues as immediate as the quality of bus
service in poor neighborhoods to exposure to transportation pollution, to patterns in regional
transportation funding. Each of these concerns were compelling because of their importance to
the community, the multiple dimensions to the problem, and the fact that the community had not
found a way to work within the “system” to find a solution.

While federal statutes and regulations delineate procedural steps for incorporating EJ
requirements into the planning process, those directives provide no practical or systematic
guidance on how a comprehensive EJ program or evaluation should be done. While the absence
of hard rules and guidance provides important flexibility to implementing agencies, it also
invokes a level of conjecture as to what a proper EJ process or analysis should look like. It is
argued that there is no single source that an interested party can look to for assistance in
negotiating this complex process. In the absence of such guidance, it is further argued that
implementing agencies have to do more primary research on their own, leading to trial and error
methods, or worse, an EJ analysis or process that falls short of its potential.

It is believed that an important characteristic of a successful environmental justice program is

that it be dynamic, i.e., that it allow for “cycles” of involvement, information exchange,
education, analysis of alternatives and their tradeoffs, and ultimately closure – where the
stakeholders are witness to and feel ownership in the final outcome. This process is neither well
defined nor linear. However, the types of issues that arise in EJ deliberations are typically not
clear-cut, but involve multiple variables and tradeoffs, and also multiple iterations of the process
of problem identification, understanding, and resolution. Effective guidance, therefore, must
reflect this evolutionary and iterative nature.

The need for a toolkit is both aided and made uncertain by the growing number of case studies
and research reports on EJ. In the course of developing our proposal to construct an EJT Toolkit
under Phase II of the Baltimore Region Environmental Justice and Transportation (BREJT)
project, we have conducted a preliminary review of the literature to establish whether our
premise is valid. This paper summarizes our review of what we believe to be the key studies and
reports that have been produced to date on environmental justice in transportation. In particular,
we have reviewed EJ case studies that have been published by FHWA or FTA, or that have been
sponsored by these agencies and their documentation made available on the respective websites.

41
We have also reviewed a more recent set of overview studies and handbooks that begin to fill the
gap on the “how to” part of EJ. Most of this work is excellent and serves a valued role in the
library on this evolving subject, and most should be incorporated in any future guidance activity.
To make clear our purpose, this review is to ascertain whether the type of comprehensive
approach we are suggesting already exists in substantial whole or part. This document is
organized as follows: Section II lists and summarizes a number of studies that represent profiles
of existing practice. They are essentially documents built around case studies, and their value is
in illustrating how particular areas approached particular EJ initiatives, thus providing a model
for others that may be in need of considering similar initiatives. Section III then examines a
series of key research studies or guidebook efforts with objectives of providing more generalized
directions on different aspects of environmental justice, ranging from community involvement
through analytic methods and measurement. Section IV addresses the specific area of health
impacts. While environmental justice has always maintained that human health is one of the
most critical concerns, EJ studies and guides have invested comparatively little time on this
complex subject. Since we are proposing to include health impacts among the key elements of
our Toolkit, we summarize in Section IV the treatment of human exposure and health both in the
existing EJ literature as well as feature studies that exist that would be drawn upon to
incorporate this element into the Toolkit. Finally, Section V provides an overall summary of the
findings from this review in relation to what we believe is needed in the way of comprehensive
guidance on environmental justice in transportation.

Examples of Current Practice

Environmental Justice and Transportation Case Studies7
The FHWA and FTA jointly published this compendium of case studies to provide support to
others engaged in EJT studies or assessments. The expressed intent of the booklet is “to put
environmental justice at the center of transportation decision making”, and to demonstrate that
“when properly implemented, EJ principles can improve all levels of transportation decision-
making – from the first thought about a transportation plan through project development, right-
of-way, construction, operations and maintenance”. The premise is that “pursuing
environmental justice is not a simple task, but one that stretches the imagination of the
transportation agency, calling upon the practitioner to explore new methods and new
partnerships”. It further possible that “eliminating discrimination, and the appearance of
discrimination, often requires probing analysis of transportation issues, broad-based community
outreach, and a particular sensitivity to the needs [sic] of people who have not traditionally been
participants in the decision-making process”.

The case study booklet illustrates how 10 different areas independently approached EJ aspects in
a variety of planning, project or impact resolution contexts. The intent is to present a “story” of
how a given area recognized an EJ problem or need and dealt with it – usually documenting the
process from beginning to end in an attempt to illustrate the “learning curve” for the given
agency. The essential characteristics of the 10 case studies are illustrated in Table 10. Clearly, the
studies cover a wide range of planning activities, setting, techniques used and organizations
involved. The examples in the booklet provide assurance as to how agencies, practitioners,

7
Federal Highway Administration & Federal Transit Administration, Transportation & Environmental Justice Case
Studies. US Department of Transportation, Pub. No. FHWA-EP-01-010 (December 2000).

42
others have faced similar problems or circumstances and developed an approach to deal with it.
There are good insights in this book on public participation methods, analytic approaches, and
institutional mechanics, all of which add to the knowledge base and awareness of the dimensions
of environmental justice. The limitations of the case study booklet as “guidance” are:
 The examples are somewhat random in topic coverage, and while interesting, require the
user to ascertain which studies and which aspects they find relevant.
 It is not always clear that the path chosen by the particular case study is either optimal or
inclusive of all important considerations, nor that they necessarily reached an effective
solution.
 This guidance requires the user to try to decide how much of the particular process to
replicate in their respective situation.

43
 Table 10: Summary of FWHA Case Studies

Case Study Name/Location Type Activity EJ Cat. Research Topics Type of Stakeholder

Impact

Effective

Geography (Urban/Rural)
Project Develop./NEPA

Minority/Low Income,

Transportation Mode
Black, Asian, Latino
Public Involvement

Native American,

Agency Involved
ROW Evaluation

Topics and
Community
Planning

Hispanic

Practices
Assess.
Verona Road & West Beltline Needs Assessment X X B,A,LI Early public involvement U Highway State DOT
Study (Madison, WI)
Jobs Access and Reverse Commute Planning X M,LI Data sources, GIS, Analytical Methods, R,U Transit MPO, Transit
(Northern NJ) MPO regional coordination agency, HHS
East-West Expressway EIS Statement (Durham, X X X X B,LI Title VI complaint, housing of last resort, U Highway State DOT, City,
NC) mitigation and enhancements, Local Community
collaborative plans
Southern California Regional Transportation Plan X M,LI Data sources, analytical techniques, U Highway, MPO
(Los Angeles Region) benefits/burdens, alternative dispute Transit
resolution
Cypress Freeway Replacement Project (Oakland, X X X X X B,LI Project development, right of way, public U Highway State DOT
CA) involvement, mitigation and
enhancements
Fruitvale BART TOD Project (Oakland CA) X H,B,A,LI Partnerships, enhancements, public U Transit Transit Agency
involvement
MPO Environmental Justice Report (Columbus, X X H,B,LI Data sources, analytical techniques U Highway, MPO
OH) Transit
South Park Avenue Improvement Project (Tucson, X H,LI Partnerships, enhancements, context U Bike/Ped, City DOT, FTA,
AZ) sensitive design, public involvement Transit HUD
Cordes Junction Interchange Environmental X X X N Tribal consultation, cultural resources R Highway State DOT
Assessment (Yavapai County, AZ) assessment
South Carolina Route 72 Environmental X X X X B,LI Community impact assessment, public R Highway State DOT
Assessment (Calhoun Falls, SC) involvement

44
Two of the case studies in the FHWA/FTA compendium with a high degree of applicability to
the type of toolkit contemplated in the EJT framework are Southern California’s (SCAG)
regional plan update, and Mid-Ohio’s (MORPC) environmental justice assessment. Both are
reviewed separately below.

Southern California Association of Governments (SCAG): “Community Link 21”8

The Southern California Association of Governments’ (SCAG) 1998 update of its Regional
Transportation Plan (RTP) became a national example of the methods and processes for
assessing the benefits and burdens of a regional transportation plan. The 1998 RTP, known as
CommunityLink 21, developed and adopted performance indicators that gauge the social and
economic effects of transportation investment decisions on the region’s minority and low-
income populations. SCAG’s initial RTP (long range plan) update was faulted for inadequate
treatment of equity and accessibility issues. A coalition of groups led by Environmental Defense
claimed that the plan offered few benefits to those living below the poverty line, and that SCAG
had failed to meaningfully involve low income and minority communities in the planning
process. Under threat of a lawsuit, SCAG revised its process in several important ways to better
serve low-income communities:

 It recommended a transit restructuring strategy to better serve low-income

communities.
 It incorporated a transportation equity performance indicator in their plan
evaluationprocess.
 It employed the measure of accessibility with a new emphasis toward differentiating
impacts by transportation mode, income group and ethnicity.
 It examined parity between the tax burden shouldered by individual income groups and
then developed a method to assess the distribution of transportation benefits along the
same lines.

As a result of these efforts, SCAG was able to earn the support of EDF, and the resulting RTP
was hailed for “bringing transportation equity to the planning table.”

Lessons Learned
In terms of the value of this case study for comprehensive EJ guidance, we note the following
contributions (as summarized in Table 11):

 Use of accessibility as a key measure of transportation performance

Explicit consideration of benefit/burdens disparities in relation to both existing and
proposed transportation investments
 Active incorporation of these findings in the regional planning process and subsequent
plan updates
 Emergence of the MPO as a regional forum for debating EJ issues and concerns

8
Southern California Association of Governments, “CommunityLink 21, Regional Transportation Plan: Equity and
Accessibility Performance Indicators.” Transportation & Environmental Justice Case Studies. US DOT Pub. No.
FHWA-EP-01-010 (December 2000).

45
However, the following are areas where the case study may not provide sufficient guidance:

 The public participation process was engineered “after the fact”, with some interesting
new techniques only beginning to be tested at the time of the case study’s preparation.
 Not clear how the EJ population was materially involved in the actual drafting of the
revised RTP.
 The 10-member Peer Review Committee had no community members
 Analytic tools employed were unremarkable
 Health impacts not considered

Mid-Ohio Regional Planning Commission (MORPC): Environmental Justice Report9

In response to the October 1999 joint memorandum from the Federal Transit Administration
(FTA) and the Federal Highway Administration (FHWA) directing that environmental justice
compliance be made part of the MPO certification process, MORPC undertook a comprehensive
review of its transportation planning activities to ensure its compliance with Title VI. The
review was built around four steps:
 Mapping the locations of minority and low-income populations
 Identifying the transportation needs of the targeted population
 Documenting the public involvement process
 Quantifying the benefits and burdens of existing and proposed transportation plans

MORPC’s first step was to convene a 12-member task force to serve as an advisory group for
the process, including members from local governments, the transit agency, the state
environmental agency, several public interest groups and two members of the target
community. The committee played a key role in helping define the target population, identify
its needs, evaluate the public involvement process, and develop measures to assess benefits and
burdens. MORPC used a combination of census block data, the regional travel model (TAZ
level aggregation) and GIS to profile and map the target population. Transportation needs were
ascertained from existing studies, and focused chiefly on bus transit access. A series of
accessibility and travel time measures were developed to assess benefits and burdens of
alternative transportation system investment plans (2020 no-build, 2020 current TIP, and 2020
full RTP improvements). From this assessment MORPC determined that its low income and
minority residents were at least as well served by existing and proposed investments as other
segments of the population. In April 2000, based on recommendations of its Citizen Advisory
and Transportation Advisory Committees, MORPC adopted the Environmental Justice
Assessment into its regional transportation plan, and presumably satisfied the USDOT’s
certification requirements.

Lessons Learned
Value of this case study for EJ guidance purposes would be in the following areas (as
summarized in Table 2):

9
Mid-Ohio Regional Planning Commission, “MPO Environmental Justice Report.” Transportation &
Environmental Justice Case Studies. US DOT Pub. No. FHWA-EP-01-010 (December 2000).

46
  Creation of a diverse 12-member regional EJ Task Force to steer the process, including 2
community members
 Use of accessibility and travel time measures to assess benefits and burdens in relation
to both existing and future transportation opportunities
 Use of GIS methods to help locate and map EJ populations, and subsequently to
incorporate these data in regional travel model runs

The following are areas where the information in the case study is in doubt as guidance:

 Actual public participation process was minimal and not worthy of replication: it was
after the fact and involved only one community Open House with 50 attendees. It is
unclear what community input derived from this process.
 Transportation needs were extracted from existing studies and/or model runs, and did
not involve the public. Major focus was on connecting EJ urban populations with
decentralizing job opportunities, and particularly through reverse commute bus service.
 Accessibility measures and analytic tools used are fairly primitive. It appears that they
compare accessibility for EJ groups by transit within a 40-minute acceptable time
envelope with 20-minute envelope for regular population. Hence, they conclude no
existing or future disparities in benefits.
 Long term continuing spatial mismatch between people in jobs is cited as an issue but
not raised outside the chosen accessibility measures/assessment. Speaks to the narrow
range of vision adopted by study.
 Health impacts not considered

Capitol Region Council of Governments (CRCOG): EJ Challenge Grant Project10

CRCOG was one of four agencies selected in 2001 to participate in a federal Environmental
Justice Challenge Grant program. These grants were for the purpose of allowing each agency to
assess how well their transportation planning programs were meeting the goals and
requirements of Title VI and to identify ways to improve involvement of minority communities
in those programs. The CRCOG process had three objectives: (1) to develop a current profile of
the region’s minority and low-income communities; (2) to find ways to increase public
involvement in all phases of the planning process; and (3) to develop quantitative methods for
use in assessing whether the target community is receiving a fair share of the region’s
transportation benefits or burdens. CRCOG’s documentation of its work unabashedly notes
that its emphasis was much more on developing a process-oriented strategy and improving the
involvement of the minority and low-income community in the planning process than on
developing quantitative methods for assessing transportation needs, benefits and burdens. In
that vein, it would appear that CRCOG made significant efforts to involve the public in its
process, to the extent of dropping an early strategy to run the entire process with a single
committee to on that relied instead on a series of community workshops. These were located in
different areas at different times and each addressed a different set of questions dealing with
some aspect of the regional planning process. Considerable insights were gained with respect
to methods of outreach and involvement, ways to communicate information, needs and

10
Capitol Region Council of Governments, “Environmental Justice & CRCOG’s Transportation Planning
Program”, Environmental Justice & Title VI Challenge Grant, Hartford, CT (December 2002).

47
concerns, and areas of the planning process most in need of improvement. A particular goal of
CRCOG in its evaluation was to identify ways to increase the involvement of the target
population in core decision-making activities, like project selection, TIP development, and
update of the regional long range plan. To increase the odds of this happening, CRCOG
recommended two key organizational changes: (1) formation of an Environmental Justice
Advisory Board to advise the decision-making Transportation Committee, and (2) appointment
of an Advisory Board member as a voting member of the Transportation Committee. CRCOG
did investigate and attempt some improvements to its quantitative methods, but admitting that
this was not a prime area of interest, most of the outcomes were at the definition and
recommendation stage.

Lessons Learned
Value of this case study for EJ guidance purposes would be in the following areas (as
summarized in Table 10):

 Significant experimentation with public outreach methods and good success in getting
input of transportation needs and ways to improve the planning process
 (Proposed) Creation of an EJ Advisory Committee to advise the voting Transportation
Committee on EJ issues bearing on planning and programming decisions
 (Proposed) Inclusion of a member of the EJ Advisory Committee as a voting member on
the Transportation Committee
 Extensive use of GIS methods help locate and map EJ populations, coupled with
definition of thresholds (i.e., what constitutes minority or low-income)
 Development of analysis methods and measures to evaluate Equity in both the short-
term TIP and in the long-term regional transportation plan. Used GIS to co-locate target
populations and transportation projects to determine equity in project funding; used
regional travel model to develop accessibility measure for LRP

The following are areas where the information in the case study is in doubt as guidance:

 Much of what is in the documentation is in the way Action Plan recommendations; they
are interesting and ambitious recommendations but it is not clear how many have
actually been implemented and with what effect
 An aversion over “complex” technical measures steered the study away from measures
like accessibility, although they came back to adopt it in their recommendations.
Unfortunately, the only accessibility measure they used in the study was access to jobs
by transit for zero-car households (from pre-existing work), so there is no real sense for
whether the near term or long term plans achieve equity
 The short term measure – percent of TIP investments vs. percent EJ population – is not
an outcome oriented measure of performance, and may be tainted also by the inclusion
of transit subsidies in the cost accounting for the EJ population
 Health impacts not considered

48
Case Studies in Environmental Justice and Public Transit Title VI Reporting11
This study was jointly funded by TCRP and the National Center for Transit Research at the
University of South Florida for the purpose of identifying examples of environmental justice
solutions and Title VI reporting and implementation that demonstrate commitment to equitable
distribution of public transportation resources. In an earlier study by NCTR, Title VI reporting
was identified as a tool for assessing the impacts of transportation decisions, particularly as
related to environmental justice.

This is one of the comparatively few EJ case studies emanating from the transit sector, and
hence has value in taking a slightly different view of EJ requirements. A theme echoed in the
study is that persons of color and with low incomes tend to walk, bike and use transit more
than the general population, are more likely to be victims of auto-pedestrian incidents, and are
more likely to be affected by decisions that direct transportation resources into suburban
highway improvements over urban transit. The study suggests that five topics encapsulate
many of the facets of environmental justice issues in transportation: (1) justice in decision
making; (2) the geographic placement of transportation facilities; (3) public transit access to
government services; (4) equity in transportation investments; and (5) transportation, land use,
economic development, and social equity.

The study is built around five case studies, each of which provides an example of actions taken
by transit agencies to respond to environmental justice and Title VI concerns, and documents
techniques used to achieve community buy-in and support. Four of the case studies entail
metropolitan areas (Atlanta, Chicago, Denver and Miami), while the fifth is a national
assessment of EJ issues facing native Americans and Alaskans. The study report concludes with
a section on “Suggested Guidance” for transportation agencies addressing civil rights and
environmental justice issues, which includes the following elements:
Improving agencies’ public outreach and involvement efforts

 Providing access to the decision making process at all levels, from the MPO long range
planning process through service delivery and maintenance.
 Impacts associated with the siting of transportation facilities, with goals for ensuring
equitable distribution of benefits and burdens.
 Fragmented government authority problematic in dealing with multi-faceted problems
 Equity in transportation investments, and financial and other implications of these
investments
 Disconnect between land use and transportation decisions and authority
 Use of Title VI program guidelines to support collection of data which supports
identification of minority/low-income populations and analysis of service standards
and policies in these areas.
 Consideration of the differential effect of cuts in bus service, routing changes, location
and maintenance of stations and equipment on minority populations, who are more
likely to be impacted.

11
Ward, B. Case Studies in Environmental Justice and Public Transit Title VI Reporting. University of South
Florida, National Center for Transit Research. Final Report, TCRP J-06, Task 47 (Sept. 2005).

49
The value of this study as a guidance tool is primarily in its shaping of issues and practices that
relate to transit and non-motorized transportation, both of which have greater impact on the EJ
community. This would be important in the areas of public involvement, access to the decision-
making process, and awareness of differential impacts. Where this study may fall short in its
guidance potential is that it has relatively little information on specific performance measures,
analytic approaches, and step-by-step guidance on process.

Existing Research Studies and Technical Assistance Guides

Atlanta Transportation Benefits & Burdens Study12
This project was the result of a 1997 agreement between the USDOT and a coalition of non-
government agencies (Environmental Defense, Southern Organizing Committee for Economic
and Social Justice, and Georgia Coalition for a People’s Agenda) to conduct a study of
environmental justice in the Atlanta region. The work was to be performed in two phases – a
Phase 1 assessment of public participation followed by a Phase II assessment of the distribution
of transportation benefits and burdens on minority and low-income populations. Phase I was
completed during 1999 and 2000, tied to the solicitation of comments and opportunities for
change in participation in the 2000 Regional Transportation Plan update. FHWA’s Office of
Human Environment, its Office of Metropolitan Planning, and FTA’s Office of Planning
participated in this review, for which the Phase I report13 concluded that the Atlanta Regional
Commission needed to be more proactive in engaging minority and low-income populations,
better documenting their public involvement activities, increasing their capacity to sustain
outreach to local communities, and removing institutional and logistical barriers between the
public and decision makers.

The main purpose of Phase II of this study was to evaluate quantitative measures of
transportation benefits and burdens for minority and low-income populations in the Atlanta
region. This work was done by private consultants contracted by FHWA using a framework
that first established a baseline of current distributions of benefits and burdens, which were
then compared with conditions likely to occur over the next 25 years due to demographic trends
and transportation investments. Given the timing of the study, 2000 Census data were not yet
available so the researchers were forced to assemble information from various sources
representing different points in time from 1990 to 2000. Therefore the approach used was to set
up a template representing “current conditions” which could be updated when new data
became available or in relation to future scenarios for RTP updates. Two different groups of
participants were used to comment on the work: a Review Panel that ensured that the analyses
produced clear and understandable information, and a Technical Committee that determined
whether the work was technically reliable and consistent with good practice. Both groups had a
diverse membership that included government agencies, non-profit interest groups, and EJ
community advocates.

Phase I served to solicit the community’s input on appropriate benefits and burdens to measure.
The study team recognized that it didn’t have the tools or data to address all the questions that

12
USDOT, FHWA, FTA, Transportation Benefits & Burdens in the Atlanta Region, Final Draft, May 2002
13
USDOT Office of Civil Rights. Assessment of Environmental Justice and Public Involvement in the Atlanta
Metropolitan Area”. Phase I Report (April 2000).

50
were raised, and that no single measure would provide a complete answer. It was clear that the
dimensions of geography, demographic characteristics, transportation system attributes and
model data would have to be synthesized from different sources, levels of aggregation or even
points in time in order to portray travel patterns or impacts by race, ethnicity and income. GIS
was the key tool used for this synthesis, and for presenting the information in understandable
formats.

Given the focus of the Phase II study effort on “measures”, and the objective of FHWA to
identify measurement tools that could be used in a variety of planning scenarios, RTP updates
or focused planning studies, the research team evaluated a rather lengthy list of measures. Each
of these measures was derived from the Phase I outreach process, including input from both the
community and transportation agencies. The key measures that were recommended by the
study were:
 Population within walking distance of transit
 Percent of employment accessible within 60 minutes by transit for lower income groups
 Average congested travel time by income
 Potential impact to historic areas

Other measures that were evaluated included: transit load factors (as surrogate for service
quality); effect of congestion on neighborhood safety; quality of transportation system
maintenance; proximity of population to point source emissions (represented by bus yards);
proximity to mobile source pollution (population near major highways as proxy); effect of
taking property for transportation on community cohesion; distribution of crashes; incidence of
transportation costs. For each measure the study documented:
 Description and importance of the measure
 Measurement tools
 Lessons learned/areas for further consideration
 Important technical considerations
 Alternative approaches not taken, and why

Lessons Learned
Value of this case study for EJ guidance purposes would be in the following areas (as
summarized in Table 10):

 The major value of this study is that of a technical aid in understanding the challenge of
defining and measuring benefits and burdens, and in particular trying to effectively
measure these commodities (performance measures) in relation to the impacted
populations.
 Starts addressing the issue of tradeoffs – what is benefit to one may be a burden to
another. Question is how to balance.
 Provides assistance in identification, appraisal and manipulation of data (how to work
in an imperfect information world, although some issue as to how the Atlanta situation
compares to other areas)
 Health impacts are approached, with good reference information

51
The following are areas where the information in the case study is in doubt as guidance:

 While this is a comprehensive list of measures, it is not particularly an exhaustive or

well-categorized list. It does not link particular issues with appropriate measures.
 No lesson on how this came out of the regional planning process, or even if the
recommendations will find their way into use. It was done for, not by, the locals (with
their participation but difficult to ascertain ownership)
 A practical consideration in the value of this study is that – to our knowledge -- a final
Phase II report has never been released. Since the study was completed in 2002, this
raises the question of whether the study or its findings have been accepted by the
sponsoring agencies.

NCHRP Project 8-36(11): Technical Methods to Support Analyses of Environmental Justice

Issues 14
This project was undertaken as a special study for AASHTO’s Standing Committee on Planning
to provide assistance to state DOTs, MPOs, transit agencies and others attempting to address
environmental justice requirements in planning and project studies. The primary focus was on
identifying and developing an inventory of technical approaches that could be in both systems-
level and corridor/subarea planning to quantify benefits and burdens and their distribution
across individual population groups. To perform this review, the study both articulated and
offered interpretation for the array of existing environmental justice laws and policy directives,
and also collected information on current practice and challenges from a large number of
practicing agencies. Based on interviews with 15 state DOTs, 21 MPOs, and three transit
agencies, the study determined that there is considerable uncertainty among agencies as to the
appropriate level of analysis that is necessary, the correct mix of public involvement and
technical analysis, and the manner in which environmental justice should be treated during
systems planning. The existing practice review confirmed that the approaches in use for project
planning are much better defined and accepted than they are for statewide or regional systems
planning.

The report describes methods, including examples, for defining and identifying population
groups, conducting public outreach and involvement, defining measures of benefit and burden,
defining disproportionate impacts, and responding to environmental justice issues. Its primary
strength, however, is in its description of methods for identifying and examining the
distribution of risks, benefits and burdens. It provides both a solid overview of the definitions
of benefits and burdens, and the procedures for assessing disparate benefits. Lists of each type
of measure are provided, along with descriptions on how they may calculated, agencies which
have used the measures and their experiences. An emphasis is placed on currently available
methods that can be applied immediately without further research, but the study also makes
note of other methods that are currently in use which may be valuable in environmental justice
applications, but which are not being routinely applied in that context.

14
Cambridge Systematics, Inc. Technical Methods to Support Analysis of Environmental Justice Issues. NCHRP
Project 8-36(11) (April 2002).

52
Lessons Learned
As a guidance tool, NCHRP 8-36(11) has considerable value in the following areas:
 Improving understanding of the legal issues driving environmental justice evaluations,
and the guidance given or not given by the various statutes and directives.
 Offering a sense of what other transportation and planning agencies are doing to
address EJ in their different levels of planning and project activities.
 An inventory of and orientation to measures of benefit and burden, their meaning, value
and methods of computation.
 Solid grounding in the definition and assessment of disproportionate impacts.

Where NCHRP 8-36(11) falls somewhat short in its guidance is in the following areas:
 Illustrating application and actual use of these measures in real world situation
 Incorporation of public outreach and involvement
 Nuance of introducing these measures within the institutional planning and decision-
making process.

CalTrans: Desk Guide -- Environmental Justice in Transportation Planning and

Investments15
The purpose of the Desk Guide is to provide those involved in making decision about
California’s transportation system (public agencies, concerned citizens, community-based
organizations concerned citizens, community-based organizations, and elected officials) with
information and examples of ways to promote environmental justice. In section 5 of the Desk
Guide it states that there are “only a few resources providing guidance on assessing the
distribution of transportation project impacts on low-income and minority population”. While
the Desk Guide covers the full breath of regulatory, procedural, and technical issues, it does not
provide detailed guidance or background in any specific area. Rather, each section of the Desk
Guide points to resources (reports, papers, guidance documents, Internet sites, etc.) that provide
greater detail for interested readers. Table 11 summarizes the types of information that are
included in this reference guide, by individual chapter. The value of the Desk Guide in the
guidance area would seem to be as a convenient reference guide.

15 California Department of Transportation, Desk Guide, Environmental Justice in Transportation Planning and

Investments. Division of Transportation Planning, Office of Policy Analysis & Research (January 2003).

53
Table 11: Desk Guide Highlights

Ch. Focus Highlights

1 Impacts Economic, Social and Environmental Impacts (Air pollution, Noise and
Water)
2 Legal and Historical Beginnings, Title VI of the Civil Rights Act, Title VI Application
regulatory to Transportation in the Los Angeles MTA Lawsuit, Changes in the VI
context Enforcement.
3 How public Developing Agency-Specific Environmental Justice Policies, Training and
agencies Education, National Highway Institute Courses, Establishing a Citizens’
incorporate Advisory Committee, Need for Citizens’ Advisory Committees, Roles for
environmental Citizens’ Advisory Committees and Environmental Justice and Public
justice issues Involvement (Attitude, Active Engagement, Public Information Materials,
into their Language, Effective Public Meetings and Operating Support for
planning Community-Based Organizations)
processes
4 When and how Overview of the Long-Range Transportation Planning Process, Defining
environmental Population Groups (Regulatory Definitions and Current Practice in
justice issues California) Data Sources (U.S. Census, The American Community Survey,
can be National Household Transportation Survey and Statewide Integrated
addressed Traffic Records System) and Non-Traditional Public Data Sources.
Developing Vision, Assessing Needs and Identifying Investment
Alternatives, Involving the Public Early to Generate Real Alternatives,
Using Community Groups In Needs Assessment., Performance Measures
(Accessibility, Employment Accessibility, Access to other Activities, Travel
Time, Transportation Service Provision, Other Performance Measures,
Evaluating Disproportionate Impacts (Spatial Distribution versus Area
Wide Analysis, Travel Models and Key Assumptions and The use of GIS
and Mapping)
5 How Defers to Technical Methods to Support Analysis of Environmental Justice
environmental Issues, NCHRP Project 8-41, Effective Methods for Environmental Justice
justice relates to Assessment (Forthcoming at the time of this publication) and
transportation Environmental Justice and Transportation Investment Policy
6 Application Public Participation: Arterial corridor Needs Assessment in Madison,
highlights of Wisconsin, Road Widening in Calhoun Falls, south Carolina, Intersection
various Rebuilding in Yavapia County, Arizona. Assessment Methods: Southern
techniques California Association of Governments 2001 Regional Transportation Plan,
Metropolitan Transportation Commission 2001 Regional Transportation
Plan, Association of Bay Area Governments (ABAG) Livability Footprint
Equity Analysis, Regional Transportation Planning in Columbus, Ohio

54
Environmental Justice and Transportation: A Citizens Handbook16
The Citizens Guide was written with the general public in mind. It provides introductory detail
for investigating and advocating environmental justice and transportation issues. Its intent is
help those who are new to the transportation planning and decision making process influence
how environmental justice is incorporated into decisions about transportation policy and
projects. It provides a basic orientation to environmental justice and the legal requirements for
its inclusion in the transportation planning process identifies steps in the planning process
when citizen involvement is particularly effective, and provides suggestions on how
environmental justice can be incorporated in a project. The Citizen’s Guide appears to be a
valuable resource for the layperson, and as guidance instrument would appear to have its
greatest value in relation to the EJ community itself. This guide can help educate the
community or its advocates on how to engage the planning process and have an impact.

NCHRP Report 532: Effective Methods for Environmental Justice Assessment17

NCHRP Report 532 is a guidebook designed for planning practitioners in state DOTs, MPOs,
and local planning agencies who must consider environmental justice impacts in planning,
programming, and implementing transportation projects. It presents as a step-by-step guide
that provides technical assistance in selecting appropriate methods of analysis for calculating
any of a number of relevant impacts. While intended primarily as a planning guide, it is also
promoted as an educational resource on the concepts, tools and procedures currently employed
for assessing environmental justice issues in the context of transportation planning decisions.
The guidebook is a continuation of research begun in project 8-36(11), focusing more on the
modification of existing methods and developing new methods that are needed. The methods in
the handbook are organized by topic in order to facilitate use by practitioners in assessing EJ
issues within specific application categories. The categories included are:

 Air quality
 Hazardous materials
 Water Quality and drainage
 Safety
 Transportation user effects (primarily accessibility)
 Community cohesion
 Economic development
 Noise
 Visual quality
 Land prices and property values
 Cultural resources

Each of these categories is presented as a stand-alone chapter with the following information
included:

16
Institute of Transportation Studies (ITS), Environmental Justice and Transportation: A Citizens Handbook.
University of California at Berkeley (2003).
17
Forkenbrock, D.J. and Sheeley, J. NCHRP Report 532: Effective Methods for Environmental Justice Assessment.
Transportation Research Board (2004).

55
  Overview of the measure: the effect being addressed and why it would have EJ
implications
 State of the practice: how the effect is evaluated by the profession and used for EJ
 Selecting an appropriate method of analysis: guidance on which method to use for
particular situations, scaled to level of focus and type of decision pending
 Methods: discusses each alternative method in detail
 Resources: cites articles, book and other sources with additional, more detailed
information
 References: lists the sources that used in compiling the chapter

The Guidebook also provides a basic foundation on the essentials of environmental justice, its
place in the planning process, the concepts of benefits, burdens and distributive effects, and the
basic challenges facing planning professionals. There is a separate chapter dealing with the
identification of “protected populations”, including a summary and assessment of the many
different data sources, tools and methods which have been used. The appendices include more
detailed information on EJ requirements and case law, as well as detailed sections on how to
use GIS systems and Decennial Census data to evaluate EJ issues.

Although it bears a lot of similarity to NCHRP 8-36(11) in its coverage, NCHRP Report 532
stands as an important addition to the library of guidance on environmental justice. Its primary
value as a guidance tool is to aid technical specialists and planning practitioners in selecting the
most appropriate methods for their particular analysis. Of considerable value in this regard is
the attempt to scale the analysis tools selected to the geographic scale and precision needs of the
particular issue, which may be different, based on the stage of the planning process and the
gravity of the issue under consideration. Where Report 532 may be deficient in providing EJ
guidance is in the following areas:

 It does not attempt to address public involvement or how this information may be
relevant to interaction with the public – it assumes that this is the domain of the larger
planning process
 It does not deal with the how or why of where these measures are appropriate or
important to be considered – it assumes that these directives will come out of the larger
planning process

56
Table 12: Coverage of Key Environmental Justice Elements in Source Studies
Public Participation
Methods
Broad spectrum of public
participation examples
FHWA involving needs assessment
and reaction.
Case
Studies
Employed ADR process to
arbitrate positions; no special
SCAG RTP public involvement during
Update (1998) 1998 update but created
several channels for next plan
MORPC EJ Held one Open House 3
Compliance months into process – not clear
Report (2000) what real input to process
Most intensive aspect of
process; Adopted work shop
CRCOG EJ format to increase reach and
Challenge Grant coverage of topics
(2002)
USF EJ & Title VI By example through case
Case Studies studies
(2005)
Implementation Body/
Process
Varies
10-member Peer Review
committee formed to
challenge process, but no
community members & not an
implementation body
Created 12-member EJ Task
Force as advisory committee –
diverse membership, 2
community members
Involving EJ population in
planning process and decision
making a prime concern;
Recommended an EJ Advisory
Board plus inclusion of one of
its members on the
Transportation Committee
Articulates importance of
involvement in the entire
planning an decision making
process
Performance Measures
Accessibility, highway
investment analysis &
minority displacement caused
by highway projects.
Jobs accessibility
Opportunities accessibility.
Equity – percent of hours
saved vs. percent of total
expenditures (by income
group
Various accessibility
measures;
Travel times;
Congestion, fiscal,
displacements
Job opportunities access by
transit for single car
households; other measures
proposed
Issues raised which can be
translated into critical
performance measures
57
Analytical
Tools
Regional travel models;
GIS; Census data.
Primarily regional travel
model using TAZ level
aggregation (no GIS); HBW
travel only
Census data, regional travel
model, GIS used to map
population & estimate
accessibility measures
Combination of GIS
techniques and regional travel
model; Spent considerable
time defining target areas and
establishing thresholds
Not covered
Analysis of Distributive
Impacts
Demographic breakout
by income, age and proximity.
Explicit consideration of
benefit distribution from
existing and planned
transportation investments by
mode, race and income
Compared performance of
existing & planned systems on
poor & minority vs. overall
Used GIS to layer TIP projects
on Target areas & determine
equitable share of funding
For LRP, used travel models to
develop measures of
cumulative travel time and
access to jobs
Issues raised shine light on
types of analyses which
should be done
Table 13: Coverage of Key Environmental Justice Elements in Source Studies (continued)
Public Participation
Methods
Phase 1 was an evaluation of
existing efforts by ARC:
Atlanta EJ basically lots of
Benefits & recommendations on how &
Burdens Study where to improve;
(2002)
Phase II did not have direct
public input, but
representation on the 2
oversight committees
NCHRP Overview of the need to define
and identify population
Project groups; Good general
8-36(11) discussion of public
involvement techniques
(2002)
Desk Full chapter on types of public
involvement, techniques,
Guide committees (primarily via
(2003) reference)
ITS Citizens What to do guide. How to
respond to community needs.
EJ&T Handbook Involving everyone.
(2003)
NCHRP Not a coverage item
Report 532
(2004)
Implementation Body/
Process
Two committees formed to
oversee work on measures in
Phase II: Review Panel to
ensure results were relevant
and understandable, Technical
Committee to ensure results
were technically sound.
However, an academic study
with no attempt to integrate
results into the planning
process yet
Not covered
Discusses need for & function
of Citizens Advisory
Committees; where in
planning process issues can be
raised
Details how the transportation
planning process works and
key steps in which to get
involved
Not a coverage item
Performance Measures
Long list of measures studied
– good information on their
function & value;
Four key measures selected:
1. Walking distance to transit;
2. Jobs access-ability by transit;
3. Avg. congested travel time;
4. Potential impact to historic
areas
Inventories and details lists of
measures of benefits and
burdens;
Calculation methods described
Extensive citations on
performance measures via
reference
Provides a good generalist’s
overview on types of
measures, how they are used,
why they are important
11 different categories of
measures covered, with
guidance on use scaled to the
type of analysis & setting
58
Analytical
Tools
Had to synthesize data from
multiple sources, using GIS to
do the spatial relationships
Covers both tools in existing
use and potential use: GIS,
regional travel models, census
& other data sources; also
household microsimulation
Defers to upcoming NCHRP
8-41 report on Technical
Methods to Support Analysis
of EJ Issues
Not addressed
A multitude of common and
less common methods linked
to each type of measure and
analysis approach
Analysis of Distributive
Impacts
Benefits & burdens evaluated
for most of the measures,
particularly the key measures
Some concern about focus on
income over minority status;
Also some concern about
using “history” to explain how
things got this way?
Describes benefit & burden
measures and discusses
conduct of disproportionate
benefit analysis in some detail
Citations for evaluating
disproportionate impacts;
suggests SCAG, ABAG, MTC
and MORPC RTP efforts as
examples
Discusses concept of benefits
and burdens, how it must be
dealt with in the
transportation planning
process
Covered in the background
sections but not in the
development of measures of
deployment of tools
Environmental Justice and Human Health
One of the major “missing links” in environmental justice studies and analytic capabilities is the ability
to evaluate the relationship between transportation activity and human health. Developing
transportation-related indicators to measure public health impacts is actually a requirement under Title
VI. While transportation may impact health in many ways, for example vehicle/pedestrian conflicts,
noise and exhaust odors, one very tangible connection is through transportation’s contribution to poor
air quality. Poor air quality has a detrimental effect on persons with asthma or other pulmonary health
problems, children and the elderly. An ever-increasing body of empirical research is able to
demonstrate an epidemiological link between the proximity of exposure to air pollution concentrations
and higher incidence rates of a variety of health abnormalities. Not surprisingly, there is also a body of
evidence which indicates that minority and low-income populations tend to live and work closer to
sources of air pollution than does the general population, and hence face greater health risks.18,19,20

Chapter 3 of NCHRP Report 532 provides the most current and comprehensive review of the role of air
quality in environmental justice assessments among current guidance materials. It is particularly on
point in laying out the issues, the tools and the challenges with regard to air quality impacts. It points
out that transportation-related air pollution’s effect on communities can occur in two primary ways:
 Through increased ground-level concentrations of pollutants like carbon monoxide (CO) or
particulate matter (PM) caused by motor vehicle traffic and congestion
 Atmospheric concentrations of ozone and particulate-causing pollutants like VOCs, NOx, SOx,
and also CO.

From an environmental justice perspective, the methods for dealing with either type of effect are not
especially good. The ground-level effects are analyzed using hot-spot or micro-scale techniques which
relate vehicle activity levels at roadway intersections with readings at pollution measurement receptor
sites. While the models are fairly accurate at creating this linkage between activity and receptor
reading, they are not able to project what concentrations are or will be in non-receptor areas, e.g., along
sidewalks or inside neighborhoods. And for the measurement of atmospheric pollutants, the standard
regional air quality models used for transportation conformity and addressing NAAQS standards do
not provide geographic distinctions; rather, they are obliged to assume that distributions are uniform
across large areas. Hence, the ability of standard tools and data to tie transportation activity to
pollution concentrations in particular geographic areas – i.e., those with EJ populations – is very
challenged. What these methods also do not allow for is accounting for any cumulative effect on health
of pre-existing activity and pollution concentrations.

Second, however, is the fact that none of the methods presented directly address the causal connection
between vehicle generated pollution and health effects, such as asthma or cancer rates. Report 532
notes that the assessment of health effects is an emerging field of research, and because this type of
research is very time and resource intensive and requires considerable expertise in health and

18 Forkenbrock, D.J. and Sheeley, J. Chapter 3, p 60 cites Bullard 1996 and Bryant and Mohai 1992.
19 Green R.S., Smorodinsky, S., Kim, J.J., McLaughlin, R., and Ostro, B. 2004. “Proximity of California Public
Schools to Busy Roads”, Environmental Health Perspective, 112:61-66 (2004).
24 Gunier, R.B., Hertz, A., Von Behren, J., and Reynolds, P. “Traffic Density in California: Socioeconomic and

Ethnic Differences Among Potentially Exposed Children”. J Expo Anasis Environ Epidemiol 13:240-246. (2003).

59
epidemiology, the evaluation of health effects would be beyond all but a few extreme EJ/transportation
situations. Hence, methods are not included in the guidebook, although references to several
exposure-based EJ studies are provided.

The first of the two problems – ascertaining pollutant concentrations in particular areas – may find an
interesting solution in the “pollution surface” concept introduced as the fourth method in Chapter 3 of
Report 532. This creation of a pollution surface makes it possible to estimate pollution concentrations
within particular geographic sub areas of a region. Two different approaches are described for creating
a pollution service – model-based methods and statistical methods.

Model-based methods estimate emissions based on roadway geometry, traffic volumes and vehicle
fleet emissions characteristics. A prototype model known as MEASURE (Mobile Emission Assessment
System for Urban and Regional Evaluation), supported by the EPA, is described as an example of a
model-based approach. Although the MEASURE model is built in a GIS framework which allows it to
not only produce more accurate estimates of emissions than conventional MOBILE6 approaches it is
not widely used outside of the research community. However several of its components have been
incorporated into the development of EPA’s Move model replaces Mobile 6. The Move model like its
predecessor Mobile 6 can be integrated with GIS technologies to provide better spatial and temporal
resolution of the emissions and be sensitive to how changes in transportation system design can affect
the emissions rates.

Statistical models predict pollution surfaces by fitting regression models to observations at monitoring
sites based on known values for predictor variables such as land use, population, and vehicle miles
traveled. Because monitoring networks are sparse, Report 532 advises that a larger monitoring
network and a larger number of samples over time will yield a more accurate model.

Assuming that the approach of creating a pollution surface proves to be a more accurate and
responsive way to estimate pollution concentrations imposed on specific geographies or populations,
the second part of the health impacts equation is the link between concentrations and health. Whereas
Report 532 suggests that this research area is too complex or not quite ready to incorporate in an EJ
evaluation, the presence of Johns Hopkins University and affiliate Dr. Timothy Buckley on the BREJT
team lead us to believe that we are much closer to making the tie with health than may be perceived.
This is evidenced by the large and growing number of credible studies on the subject, ranging from
non-specific outcomes of mortality (Finkelstein et al. 200421) to more specific effects including injury
(Kumanyika, 200122), obesity (Frank et al. 200423), cancer (Pearson et al. 2000; Knox, 200524),
cardiovascular (Bigert et al. 200325), and a range of respiratory effects (Brunekreef et al. 1997, Wjst et al.
199326), (Weiland et al. 1994, Friedman et al. 200127). Parallel public health studies suggest that this

21
Finkelstein MM, Jerrett M, Sears MR. Traffic air pollution and mortality rate advancement periods. Am J Epidemiol. 2004 Jul
15;160(2):173-7.
22
Kumanyika SK. Minisymposium on obesity: overview and some strategic considerations. Annu Rev Public Health.
2001;22:293-308.
23
Frank LD, Andresen MA, Schmid TL. Obesity relationships with community design, physical activity, and time
spent in cars. Am J Prev Med. 2004 Aug;27(2):87-96
24
Pearson et al.. “Distance-Weighted Traffic Density in Proximity to a Home Is a Risk Factor for Leukemia and Other
Childhood Cancers”. Journal of Air and Waste Management Association 50:175-180. (2000); Knox EG. Oil combustion and
childhood cancers. J Epidemiol Community Health. 2005 Sep;59(9):755-60
25
Bigert C, Gustavsson P, Hallqvist J, Hogstedt C, Lewne M, Plato N, Reuterwall C, Scheele P. Myocardial infarction among
professional drivers. Epidemiology. 2003 May;14(3):333-9.
26
Brunekreef, Hoek, Goldbohn, Fischer, van den Brandt. “Association Between Mortality and Indicators of Traffic-Related Air
Pollution in the Netherlands: A Cohort Study”. Lancet, 360 (9341): 1203-9. (2002)
60
health threat is disproportionately borne by racial minority and socio- economically disadvantaged
subpopulation groups (Green et al. 2004; Gunier et al. 2003; Apelberg et al. 200528). A brief profile and
citation for some of these key studies is provided below.

Air Pollution from Busy Roads Linked to Shorter Life Spans for Nearby Residents29: Dutch researchers
looked at the effects of long-term exposure to traffic-related air pollutants on 5,000 adults. They found
that people who lived near a main road were almost twice as likely to die from heart or lung disease
and 1.4 times as likely to die from any cause compared with those who lived in less-trafficked areas.
Researchers say these results are similar to those seen in previous U.S. studies on the effects of long-
term exposure to traffic-related air pollution. The authors say traffic emissions contain many pollutants
that might be responsible for the health risks, such as ultra-fine particles, diesel soot, and nitrogen
oxides, which have been linked to cardiovascular and respiratory problems.

Truck Traffic Linked to Childhood Asthma Hospitalizations: A study in Erie County, New York
(excluding the city of Buffalo) found that children living in neighborhoods with heavy truck traffic
within 200 meters of their homes had increased risks of asthma hospitalization. The study examined
hospital admission for asthma amongst children ages 0-14, and residential proximity to roads with
heavy traffic30.

Pregnant Women Who Live Near High Traffic Areas More Likely to Have Premature and Low Birth
Weight Babies: Researchers observed an approximately 10-20% increase in the risk of premature birth
and low birth weight for infants born to women living near high traffic areas in Los Angeles County.
In particular, the researchers found that for each one part per million increases in annual average
carbon monoxide concentrations where the women lived, there was a 19% and 11% increase in risk for
low birth weight and premature births, respectively31.

People Who Live Near Freeways Exposed to 25 Times More Particle Pollution: Studies conducted in the
vicinity of Interstates 405 and 710 in southern California found that the number of ultra-fine particles in
the air was approximately 25 times more concentrated near the freeways and that pollution levels
gradually decrease to near normal (background) levels around 300 meters, or 990 feet, downwind from
the freeway. The researchers note that motor vehicles are the most significant source of ultra-fine
particles, which have been linked to increases in mortality and morbidity. Recent research concludes
that ultra-fine particles are more toxic than larger particles with the same chemical composition.

27
Weiland SK, Mundt KA, Ruckmann A, Keil U. (1994): Self-reported wheezing and allergic rhinitis in children and traffic
density on street of residence. Ann Epidemiol. 4(3):243-7
28
Green RS, Smorodinsky S, Kim JJ, McLaughlin R, Ostro B. 2004. Proximity of California public schools to busy roads.
Environ Health Perspect 112:61-66; Gunier RB, Hertz A, Von Behren J, Reynolds P. 2003. Traffic density in California:
Socioeconomic and ethnic differences among potentially exposed children. J Expo Anal Environ Epidemiol 13:240-246;
Apelberg, B. J.; Buckley, T. J.; White, R. H. Socioeconomic and racial disparities in cancer risk from air toxics in
Maryland; Environ. Health Perspect. 2005, 113, 693-699
29
Hoek, Brunekreef, Goldbohn, Fischer, van den Brandt. (2002). Association between mortality and indicators of traffic-
related air pollution in the Netherlands: a cohort study. Lancet, 360 (9341): 1203-9
30
Lin, Munsie, Hwang, Fitzgerald, and Cayo. (2002). Childhood Asthma Hospitalization and Residential Exposure to State
Route Traffic. Environmental Research, Section A, Vol. 88, pp. 73-81.
31
Wilhelm, Ritz. (2002). Residential Proximity to Traffic and Adverse Birth Outcomes in Los Angeles County, California,
1994-1996. Environmental Health Perspectives. doi: 10.1289/ehp.5688
61
Moreover, the researchers found considerably higher concentrations of carbon monoxide pollution near
the freeways32.

Asthma More Common for Children Living Near Freeways: A study of nearly 10,000 children in
England found that wheezing illness, including asthma, was more likely with increasing proximity of a
child’s home to main roads. The risk was greatest for children living within 90 meters of the road33.

Children Living Near Busy Roads More Likely to Develop Cancer: A 2000 Denver study showed that
children living within 250 yards of streets or highways with 20,000 vehicles per day are six times more
likely to develop all types of cancer and eight times more likely to get leukemia. The study looked at
associations between traffic density, power lines, and all childhood cancers with measurements
obtained in 1979 and 1990. It found a weak association from power lines, but a strong association with
highways. It suggested that benzene pollution might be the cancer promoter causing the problem34.

Emissions from Motor Vehicles Dominate Cancer Risk: The most comprehensive study of urban toxic
air pollution ever undertaken shows that motor vehicles and other mobile sources of air pollution are
the predominant source of cancer-causing air pollutants in Southern California. Overall, the study
showed that motor vehicles and other mobile sources accounted for about 90% of the cancer risk from
toxic air pollution, most of which is from diesel soot (70% of the cancer risk). Industries and other
stationary sources accounted for the remaining 10%. The study showed that the highest risk is in urban
areas where there is heavy traffic and high concentrations of population and industry35.

Proximity of a Child’s Residence to Major Roads Linked to Hospital Admissions for Asthma: A study
in Birmingham, United Kingdom, determined that living near major roads was associated with the risk
of hospital admission for asthma in children younger than 5 yrs of age. The area of residence and
traffic flow patterns were compared for children admitted to the hospital for asthma, children admitted
for non-respiratory reasons, and a random sample of children from the community. Children admitted
with an asthma diagnosis were significantly more likely to live in an area with high traffic flow (>
24,000 vehicles/ 24 hrs) located along the nearest segment of main road than were children admitted
for non-respiratory reasons or children form the community36.

EPA’s Hot Spot Exposure Assessment Program

In addition to the above studies from the medical and academic research field, the EPA Office of
Transportation and Air Quality (OTAQ) has established a monitoring plan to assist regulatory agencies
in the development of models to accurately identify and assess personal exposures to air toxics in
microenvironments. The emphasis of this monitoring plan is to quantify the impacts from mobile
source- generated toxics. A number of studies have been or are currently being conducted by the EPA
and other environmental agencies to assess personal exposures to air toxics. OTAQ plans to participate

32
Zhu, Hinds, Kim, Sioutas. Concentration and size distribution of ultrafine particles near a major highway. Journal of the
Air and Waste Management Association. September 2002. Zhu, Hinds, Kim, Shen, Sioutas. Study of ultrafine particles
near a major highway with heavy-duty diesel traffic. Atmospheric Environment. 36(2002), 4323-4335
33
Venn et al. (2001). Living Near A Main Road and the Risk of Wheezing Illness in Children. American Journal of
Respiratory and Critical Care Medicine. Vol. 164, pp 2177-2180
34
Pearson et al. (2000). Distance-weighted traffic density in proximity to a home is a risk factor for leukemia and other
childhood cancers. Journal of Air and Waste Management Association 50:175-180.
35
South Coast Air Quality Management District. Multiple Air Toxics Exposure Study-II. March 2000
36
Childhood Asthma Hospitalization and Residential Exposure to State Route Traffic, Shao Lin, Jean Pierre Munsie,
Syni-An Hwang, Edward Fitzgerald and Michael R. Cayo, Bureau of Environmental and Occupational
Epidemiology, New York State Department of Health, Troy, New York, 12180
62
 in a number of these studies to specifically investigate impacts from mobile sources in select
microenvironments. This literature review identifies and summaries the:
 Baltimore Traffic Study, 2001 – 2003
 Los Angeles School Bus Exposure Assessment, summer 2001- spring 2003
 Fresno Asthmatic Children’s Environment Study (FACES)

The objectives of these studies have in common the intent to demonstrate particular aspects of the
public health and transportation linkage at various spatial scales (regional, local near road, local Bus
Stops, inside and outside bus cabin, neighborhood/local and indoor mobile trailers. Together the
results of these studies further demonstrate the association that pollution from mobile source emissions
has on health.

Table 14: EPA’s Hot Spot Exposure Assessment Program

Objectives
Baltimore37 Assessment of mobile source impacts on indoor and outdoor air
pollution concentrations of PM and gaseous toxics in a home and a
school located in an ambient hot spot location. Assess exposures
by comparing continuous, fixed-site measurements with the time-
course, sensitivity and specificity of biomarkers among volunteer
subjects occupying the fixed-site row home. Characterize the
exposure distribution and investigate the health effects of mobile
source-related air pollution among inner-city asthmatic children.
Associations among environmental exposures and biomarkers
used to identify and quantify the exposure levels. Temporal and
spatial variability of air toxics, including multiple
microenvironments (in-home, in school, near roadway); source
apportionment of mobile source-generated contaminants for
outdoor, indoor, and personal measurements.
LA38 Quantify in-vehicle, outside vehicle, near vehicle (bus stop), and
ambient exposures to diesel exhaust. Identify specific scenarios
and factors that lead to the highest air pollutant exposures of
children while commuting on diesel school buses or waiting at bus
stops. Obtain measurements of in-bus and near-bus pollutant
concentrations during normal school bus operations across the full
range of anticipated conditions. Comprehensive vehicle
characterization: fuel analysis, vehicle/engine information,
tailpipe emission characterization, assessment of high emitters,
with emphasis on obtaining measurements during operations
expected to lead to realistic high-end exposures and assessment of
effects of control technology (diesel retrofits).
FRESNO39 Study of the effect of air pollution on 450 asthmatic children.
Examines short-term effect of daily air pollution on the symptoms,
medication use, and lung function of these children and the
longer-term effect on the progression of asthma. Assess temporal
and spatial distributions of particulate matter (PM), including
toxic components, at multiple microenvironments including
homes (~100), schools (~25), and near roadways. Associations
among environmental exposures and adverse health effects for
asthmatic children Temporal and spatial variability of air toxics,
including multiple microenvironments (in-home, in-school, near
roadway); source apportionment of mobile source generated
contaminants for outdoor, indoor, and personal measurements.
Analyzed
Airborne Particulate Matter (PM),
Polycyclic Aromatic Hydrocarbons (PAHs),
PM2.5 Metals by ICP-MS, EC/OC,
Aldehydes by fluorescence, VOCs by
GC/MS, Nitrogen Oxides (NO2), Carbon
Monoxide (CO); Meteorological Station
(temperature, wind speed/direction,
humidity); Traffic volume, speed, type,
pattern by video analysis; Atmospheric
boundary layer by LIDAR.
Obtain measurements of in-bus and near-
bus pollutant concentrations during normal
school bus operations across the full range
of anticipated conditions. Comprehensive
vehicle characterization fuel analysis,
vehicle/engine information, tailpipe
emission characterization, assessment of
high emitters, with emphasis on obtaining
measurements during operations expected
to lead to realistic high-end exposures and
assessment of effects of control technology
(diesel retrofits).
Particle Matter (mass, metals, ions,
elemental and organic carbon), Polycyclic
Aromatic Hydrocarbons (PAHs) - gas and
particle phase; Nitrogen oxides Ozone,
Environmental tobacco smoke (ETS);
Biological agents include Endotoxin, Pllens,
and Fngal Spores in the air, and Endotoxin
and Allergens in house dust.

37
EPA Hot Spot Exposure Assessment Program
38
Hot Spot Exposure Assessment Program
39
Hot Spot Exposure Assessment Program
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Appendix B: Glossary
Barrier Analysis - A more sophisticated use of GIS is Barrier analysis. This is used to estimate how
many people are likely to experience problems accessing their neighbors or community activity
centers as a result of a transportation change. Transportation projects that widen roads or increase
traffic may create barriers to community cohesion by diminishing access to neighbors or
neighborhood resources. This type of analysis requires several types of digital data including
information on demographics, the street or transportation network, facilities that are important
activity centers, and local community landmarks. A limitation of barrier analysis relates to its data
requirements. Because micro level data may not be available, larger units of analysis may
excessively generalize changes in travel time, safety and distance.
Buffer analysis - A buffer is an area of a specified width that surrounds one or more map features. This
is best used as a screening tool to determine if social or economic effects actually are likely in the
predicted impact area before proceeding with a more in-depth analysis.
Case study (comparison analyses) - The value of case studies is that one can learn from the experiences
of others who may have addressed issues similar to those one is currently facing. Although it may
be difficult to find case studies that are very similar to a particular set of circumstances, general
lessons may be transferable.
Environmental Justice (EJ) - Environmental justice assures that services and benefits allow for
meaningful participation and are fairly distributed to avoid discrimination
Evaluation of Alternatives - A synthesis of the information generated by an analysis in which
judgments are made on the relative merits of alternative actions.
Financial analysis - Estimating costs, establishing a revenue baseline, comparing revenues with costs
and evaluating new revenue sources.
Focus groups - Focus groups, interviews and surveys are a good means of acquiring information about
residents’ values, attitudes, and day-to-day travel needs. In the early stages of the research they can
provide insights into preferences and priorities; later, they are a means for gauging reactions to
estimated effects. One of the most productive uses of surveys and focus groups is to learn about the
types of trips and the destinations that are important to various types of community residents.
Another use is to assess which social and economic effects are considered most important or serious
within the community. A general problem with these approaches is ensuring full participation
from community members.
GIS (Geographic Information System) - Geographic Information System (GIS) technology should be
used for effective review and evaluation of environmental justice issues. The ability to juxtapose
layers of demographic information onto layers which detail the transportation system (or other
prominent physical or socioeconomic feature) makes it possible to directly link transportation or
travel-related information with the areas and people who are affected by it. The good news is that
GIS applications are popping up on the internet to support these analysis activities.
Long-Range Transportation Plan (LRTP) - A document resulting from regional or statewide
collaboration and consensus on a region or state's transportation system, and serving as the
defining vision for the region's or state's transportation systems and services. In metropolitan areas,
the plan indicates all of the transportation improvements scheduled for funding over the next 20
years.
Micro-simulation - Travel modeling techniques forecast travel by modeling a set of actual or synthetic
individuals or households that represent the population. A full micro-simulation of a population is
yet to be commonly implemented in practice due to computational requirements. The advantage of
this approach is that travel patterns, and therefore travel benefits of transportation improvements,
can be tracked across any population characteristic that is included in the sample of persons
modeled.

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Metropolitan Planning Organization (MPO) - Regional policy body, required in urbanized areas with
populations over 50,000, and designated by local officials and the governor of the state. Responsible
in cooperation with the state and other transportation providers for carrying out the metropolitan
transportation planning requirements of federal highway and transit legislation.
Performance Measures - Indicators of how well the transportation system is performing with regard to
such things as average speed, reliability of travel, and accident rates. Used as feedback in the
decision-making process
Programming Prioritizing proposed projects and matching those projects with available funds to
accomplish agreed upon, stated needs
Spatially-Based Analysis - This method compares the distribution of impacts among spatial units,
which can be classified by characteristic, for example low-income, or predominately minority
ethnic. Spatially based analyses to assess the impacts of transportation policies on disadvantaged
groups can include the following steps:
 Identify disadvantaged groups
 Identify disadvantaged geographical areas using census data
 Identify degrees of disadvantage in each geographic area
 Identify the location of important public services and destinations
 Evaluate transportation plans according to how they affect accessibility between disadvantaged
communities and important destinations
Stakeholder - Person or group affected by a transportation plan, program or project. Person or group
believing that are affected by a transportation plan, program or project. Residents of affected
geographical areas.
Travel demand Modeling - Travel demand models are usually constructed to estimate the benefit of a
change to a region as a whole. Travel demand modeling involves a series of mathematical models
that attempt to simulate human behavior while traveling. Model output should show total changes
in travel times and travel patterns expected to result from a transportation project as they would
affect low-income or minority residents of affected communities.
Travel diaries - Travel diaries are a means of gathering information about the origins, destinations and
modal choices of particular groups of people. Data can then be aggregated and presented in
various forms including mapping and descriptive statistics. Although they are effective at
providing detailed behavioral data, travel diaries are time-consuming and expensive to administer
and rely upon the participant completing them accurately
Title VI - Title VI of the Civil Rights Act of 1964, prohibits discrimination in any program receiving
federal assistance.

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