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MPO Environmental
Justice Report
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Introduction
In the wake of
new Federal guidelines on environmental justice that amplify Title VI
of the Civil Rights Act, growing attention has been placed on the need
to incorporate environmental justice principles into the processes and
products of transportation planning. In response to this important challenge,
Metropolitan Planning Organizations (MPOs) around the country have begun
developing methods to assess the impacts of their transportation plans
and planning processes on low-income and minority populations. One such
agency is the Mid-Ohio Regional Planning Commission (MORPC), the MPO
for the greater Columbus, Ohio, region.
In January 2000,
MORPC convened a task force to develop a process with which to assess
and ensure compliance of the agency's transportation planning efforts
with environmental justice requirements of Title VI. This process ultimately
contained four key steps:
- Identify and
map locations of low-income and minority populations.
- Identify transportation
needs of target populations.
- Document and
evaluate the agency's public involvement process.
- Quantitatively
assess benefits and burdens of transportation plans with respect to
target populations.
MORPC's efforts
are noteworthy for using analytical techniques and public involvement.
The agency effectively used Geographic Information Systems (GIS) mapping
to locate low-income and minority populations within the Columbus metropolitan
area. This information was incorporated into a travel-demand forecasting
model to assess the benefits and burdens of existing and planned transportation
system investments on target populations.
MORPC also undertook
significant steps to publicize its efforts and involve the public. The
task force that developed the review process represented public, private,
and nonprofit sectors. In addition, MORPC held an open house to provide
opportunities for public comments on the Draft Environmental Justice
Report following its release in March 2000. The entire draft report
was also posted on MORPC's web site, along with minutes from all five
Environmental Justice Task Force meetings.
Recent Federal
guidelines on environmental justice emphasize the need for MPOs to substantiate
self-certification of Title VI compliance. However, procedural and analytical
approaches for doing so remain largely unspecified. MORPC's efforts
in this regard may serve as a useful model for other MPOs facing the
same challenges.
Snapshot
of City of Columbus and MORPC Planning Area
Location
- Columbus
is the Ohio State Capital
- The Mid-Ohio
Regional Planning Commission (MORPC) includes Franklin County,
Delaware County, Pataskala (Licking County), Etna Township (Licking
County), Violet Township (Fairfield County), and Bloom Township
(Fairfield County)
Population:
1,049,666
Minority
population:
- City
of Columbus -- 25.5 percent
- MORPC
Region -- 17 percent
- Percent
of region's minority population living in City of Columbus --
84 percent
Median
household income:
- City
of Columbus -- $26,651
- MORPC
Region -- $31,353
Households
below poverty level:
- City
of Columbus -- 17.2 percent
- MORPC
Region -- 11.8 percent
- Percent
of region's population with incomes below the poverty level
and living in the City
of Columbus -- 63 percent
Source: 1990
U.S. Census Data
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Implementing
Title VI Requirements in Metropolitan and Statewide Planning
October
7th Memorandum
The Federal
Highway Administration (FHWA) and the Federal Transit Administration
(FTA) issued a memorandum, "Implementing Title VI Requirements
in Metropolitan and Statewide Planning," October 7, 1999.
The memorandum provides clarification for field offices on how
to ensure that environmental justice is considered during current
and future planning certification reviews. While Title VI and
environmental justice have often been raised during project development,
the law applies equally to the processes and products of planning.
The FTA and FHWA have concluded that an appropriate time to ensure
compliance with Title VI in the planning process is during the
planning certification reviews conducted for the Transportation
Management Areas (TMAs) and through the statewide planning finding
rendered at approval of the Statewide Transportation Improvement
Program (STIP). TMAs are MPOs for regions with populations of
200,000 or more.
The memorandum
recommends several questions be raised during certification reviews
to substantiate the basis upon which self-certification of Title
VI compliance is made. If it becomes evident that the self-certification
was not adequately supported, a corrective action to rectify the
deficiency is to be included in the certification report. The
entire memorandum is available online: www.fhwa.dot.gov/environment/ejustice/ej-10-7.htm.
During certification
reviews, MPOs are asked to address several important questions
related to:
- Overall
Strategies and Goals
- Service
Equity
- Public
Involvement
Below are
specific questions MPOs should be prepared to address about their
Overall Strategies and Goals:
Overall Strategies
and Goals
- What
strategies and efforts has the planning process developed for
ensuring, demonstrating, and substantiating compliance with
Title VI?
- What
measures have been used to verify that the multimodal system
access and mobility performance improvements included in the
plan and Transportation Improvement Program (TIP) or STIP and
the underlying planning process comply with Title VI?
- Has the
planning process developed a demographic profile of the metropolitan
planning area or State that identifies the locations of socioeconomic
groups, including low-income and minority populations as covered
by the Executive Order on Environmental Justice and Title VI
provisions?
- Does
the planning process identify the needs of low-income and minority
populations?
- Does
the planning process use demographic information to examine
the distributions across these groups of the benefits and burdens
of the transportation investments included in the plan and TIP
(or STIP)?
- What
methods are used to identify imbalances?
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The
MORPC Region
MORPC's planning
area includes Delaware County, Franklin County, and portions of Fairfield
and Licking Counties. Columbus, the Ohio State Capital, is located in
Franklin County.
Land development
patterns in the Columbus metropolitan area mirror those of other urban
centers during the past several decades. Since the 1960s, new development
has shifted away from the urban core in favor of outlying areas. New
suburban developments, both residential and commercial, have tended
to spring up along major freeways and arterials and are heavily oriented
toward automobile use.
The Columbus region
is growing rapidly. Estimates are that between 1990 and 1995, MORPC's
planning area added more than 50,000 households and 70,000 jobs. By
2020, MORPC predicts that the number of households will increase by
150,000 and the number of new jobs by 180,000. According to MORPC's
2020 Regional Transportation Plan, approximately three-quarters of the
anticipated residential development and two-thirds of the projected
nonresidential development will occur outside the I-270 outerbelt.
Data from the 1990
U.S. Census indicate that low-income and minority populations within
MORPC's planning area remain concentrated principally in the urban center.
Of the nearly 12 percent of the MORPC region's population living below
the poverty line, 63 percent of these individuals are located in the
City of Columbus. Likewise, while 17 percent of the population within
MORPC's planning area is minority, 84 percent of those individuals live
in Columbus.
What
Happened
In late 1999,
MORPC undertook a substantive review of the extent to which its
transportation planning activities met the requirements of Title
VI and environmental justice. The Federal Transit Administration
(FTA) and the Federal Highway Administration (FHWA) Administrators
issued a joint memorandum on October 7th, 1999, directing
regional and division administrators to consider environmental
justice requirements in the MPO planning certification review
process. The memorandum, however, defined no specific procedural
or analytical approaches for demonstrating
compliance. Thus, MORPC, like MPOs around the country, had considerable
discretion in developing methods to evaluate its planning programs,
policies, and processes.
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The U.S.
Department of Transportation recognizes MORPC as the official
transportation-planning agency for the mid-Ohio region.
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MORPC's first step
was to convene a task force to serve as an advisory group for the project.
Members of the task force came from MORPC's Citizen Advisory Committee,
Transportation Advisory Committee,
and the Columbus Area Transportation Coordination Program. The 12-member
group included representatives from municipal governments within the MORPC
planning area, Central Ohio Transit Authority (COTA), Ohio Environmental
Protection Agency, and several public interest groups. Two of the twelve
task force participants were members of target populations. Other members
were selected principally on the basis of their experience working with
low-income and minority populations. For example, COTA has worked with
the Franklin County Department of Human Services for several years on
the issue of access to jobs. As part of this effort, COTA mapped the location
of Temporary Assistance to Needy Families (TANF) recipients by census
tracts.
The Environmental
Justice Task Force met biweekly for three months, beginning in January
2000. During that time, members played a key role in helping MORPC define
the target population, identify the needs of the target population,
evaluate the agency's existing public involvement process, and develop
appropriate measures for gauging the regional burdens and benefits of
transportation system investments on the target population.
Three months after
the Environmental Justice Task Force's first meeting, MORPC held an
Open House on Environmental Justice to formally present the findings
of its Draft Environmental Justice Report and give citizens an
opportunity to ask questions and provide feedback. The open house was
held at MORPC's downtown Columbus office, a location accessible by transit
during the evening hours when the event was held. MORPC determined that
a central location would provide the best access for the greatest numbers
of low-income and minority residents. MORPC was confident that these
individuals would be comfortable coming to this location because the
agency had previously hosted activities directed toward low-income and
minority residents, which had been well attended. More than 50 people
attended the Open House. The proceedings were also broadcast on Channel
3, a local government-access network.
MORPC's Draft
Environmental Justice Report contained four principal areas of investigation
used to evaluate whether the agency's transportation planning efforts
met the letter and spirit of Title VI and the Executive Order on Environmental
Justice. The four principal areas of investigation involved:
The
Participants
The
Mid-Ohio Regional Planning Commission established an Environmental
Justice Task Force whose members represented:
- Central
Ohio Transit Authority (COTA)
- Ohio
Environmental Protection Agency
- Neighborhood
Empowerment Council
- Transportation
Resources, Inc.
- Sierra
Club, Ohio Chapter
- Franklin
County
- City
of Columbus
- City
of Delaware
- City
of Whitehall
- City
of Westerville
- City
of Upper Arlington
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I. Demographic
Profile. Identifying the size and location of low-income and
minority population groups is an important first step toward assessing
whether or not transportation system investments disproportionately
burden or fail to meet the needs of any segment of the population.
MORPC first reviewed the racial and ethnic and income-distribution
patterns provided by various 1990 U.S. Census data sets. After
screening the advantages and disadvantages of various data sets,
MORPC decided to use census data sets to prepare a demographic
profile of the central city and metropolitan area. Although 10
years old at the time, census data offered the advantage of providing
information at the census block group, the smallest geographic
unit available. In addition, census block groups correspond roughly
to Traffic Analysis Zones (TAZs), the level of geography used
in MORPC's travel-demand forecasting model. This became an important
consideration in subsequent phases of the analysis.
Using census
data, MORPC then calculated percentages of low-income and minority
populations for each TAZ within the planning area. At that point,
MORPC chose to establish "threshold" criteria for determining
whether or not a particular TAZ should be considered predominantly
minority or low-income. To make that determination, MORPC used
the regionwide percentages of minority and low-income residents
-- 17 percent and 11.8 percent, respectively. Any TAZ that met
or exceeded this threshold was considered by MORPC as predominantly
minority and/or low-income.
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Finally, MORPC
prepared GIS maps to provide a visual representation of the low-income
and minority populations. The maps revealed that TAZs with concentrations
of minority or low-income residents higher than the regional averages
were located predominantly in the central city. By contrast, areas outside
the I-270 outerbelt had very few concentrations of target populations,
although this periphery region was, and is expected to remain the principal
location of new job growth.
The mapping exercise
also assessed the number and location of zero car households and people
with disabilities. The report found that approximately 85 percent of
zero car households were concentrated in TAZs with relatively greater
numbers of low-income and minority populations. While members of the
Environmental Justice Task Force were generally aware of the issue,
the maps amplify and illustrate the problem of a potential spatial
mismatch between employment growth and population. The maps reinforce
one of the Report's findings that a principal challenge will be to devise
transportation solutions as well as land-use planning strategies capable
of addressing this problem.
Project
Chronology
January
2000
MORPC convenes Environmental Justice Task Force.
January-March
2000
Environmental Justice Task Force meets every 2 weeks. March
2000
MORPC releases Draft Environmental Justice Report.
March
2000
MORPC hosts Open House on Environmental Justice.
April
2000
MORPC's Policy Committee passes a resolution to include
the environmental justice assessment in the MORPC regional
transportation plan.
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II.
Identify Transportation Needs. In addition to establishing locations
of low-income and minority residents, a key element of Title VI
compliance in statewide and metropolitan transportation planning
is due consideration of the transportation needs of the target populations.
For MORPC, documentation of transportation needs was readily available.
Numerous reports had already been produced by MORPC, COTA, and a
number of other sources. For example, agencies represented on the
Environmental Justice Task Force had previously prepared a Job
Access and Reverse Commute Plan, which examined travel by TANF
recipients in Franklin County, studied transit-labor force accessibility
of central city residents, and established a regional transportation
coordination committee. COTA also maintains a census tract map with
overlays showing minority census tracts, transit routes, and major
destinations. Staff periodically sample census tracts and conduct
analysis comparing population segments with the quality and level
of transit service. In 1998 COTA submitted a Title VI report to
FTA that documented the results of its route performance monitoring
and demonstrated COTA's compliance with Title VI regulations. |
MORPC's methodology
for identifying the transportation needs of target populations for its
Draft Environmental Justice Report report drew chiefly upon existing
documentation supplemented by feedback provided by members of the Environmental
Justice Task Force. The needs identification section focused on shortcomings
within the Columbus-area public transit
system because of the heavy reliance on public transportation by low-income
and minority residents. MORPC identified several needs suggesting the
importance of improving public transportation:
- Greater transit
access to emerging employment centers, shopping, and other services
located in outlying areas.
- More responsive
reverse commute transit service from low-income neighborhoods to employment
centers with insufficient or nonexistent service.
- Safer, more
easily accessible and user-friendly transit facilities.
- Better transit
connections to reduce commute times.
- Transportation
systems that cross county lines and adequately serve low-income persons
in rural areas.
Target
Population Identification and Data
Consistent
with the direction of Executive Order 12898, MORPC identified
minority and low-income populations to analyze whether the agency's
programs, policies, and other activities had disproportionately
high and adverse human health or environmental effects. Other
special populations were added for analysis as well, including
minority populations in poverty, people with disabilities, and
zero car households.
- Defining
Target Population "Thresholds." Averages of regional
totals for various target populations were calculated. MORPC
concluded that using the break point at which areas fall above
or below the average for the study area alerts planners to special
areas of consideration when analyzing the effects of changes
to the transportation system.
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Target
Population Thresholds Used by MORPC for
Demographic Profile and Mapping
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Data
Set
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1990
Totals
for Study
Area
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Threshold
(percent
of total)
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Total
population
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1,049,656
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Total
households
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416,400
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Minority
population
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177,965
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17.0
percent
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Population
below the poverty line*
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122,389
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11.8
percent
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Minority
population below the poverty line*
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44,835
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25.2
percent
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Persons
with disabilities
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60,602
5.8
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percent
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Zero
car households
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9,404
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2.3
percent
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*Based on
1990 poverty guidelines issued by DHHS
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Distribution of Demographic Data to Traffic Analysis Zones
(TAZs). Census data sets providing information at the most
detailed geographic level available -- census block groups
-- were used. Data characteristics of the block groups were
applied to population and housing totals of the TAZs through
a conversion table in which TAZ boundaries were matched to
census block groups on a "best-fit" rule between
the two geographies.
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U.S.
Census Data Source. MORPC relied upon 1990 U.S. Census data,
which was available in the geographic detail most consistent
with their travel-demand forecasting model, the primary analytical
tool used to review the benefits and burdens of their transportation
planning efforts. More current administrative records about
the residential location of TANF recipients, child care facilities,
the locations of business establishments, and emerging and
suitable employment opportunities could be drawn upon to deepen
the needs assessment. As discussed previously, COTA and the
Franklin County Department of Human Services had undertaken
elements of such a research effort in the past several years
to map the location of TANF recipients by census tract for
bus transit planning.
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National
Poverty Guidelines. To identify low-income households, MORPC
drew upon national poverty guidelines issued by the U.S. Department
of Health and Human Services (DHHS), which vary by family
size. MORPC's analysis identified $12,674 as the poverty threshold
for a family of four in 1990, and indicated that the threshold
had risen to $16,000 by 1997. The latter figure was taken
from the March 10, 1997 Federal Register, part of a package
of legislative information that the Ohio Department of Transportation
provided to MORPC to use in environmental justice planning.
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Using
1990 Census data sets to prepare demographic profile maps of the central city
and target areas, MORPC was able to identify the geographic locations of minority
and low income residents.
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Demographic
profile maps were among those displayed at an Open House on Environmental
Justice.
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III. Evaluate
Public Involvement Efforts. MORPC institutionalized its commitment
to public involvement with adoption of the Public Involvement
Process (PIP) in January 1995. The PIP identified a set of procedures
to be consistently applied to incorporate public participation
in the transportation planning process. Foremost among these was
the creation of the Citizen Advisory Committee (CAC), an advisory
group that serves as the principal vehicle for public participation
in transportation planning activities. The CAC is composed of
citizens from all segments of the population including representatives
of low-income, minority, and transportation-disadvantaged populations.
An effort is made to maintain broad geographic representation
covering the municipalities, townships, and counties of the entire
MORPC planning area.
MORPC maintains
a list of organizations that it refers to when it needs to fill
vacancies on the CAC. The PIP specifically commits the CAC to
identifying and considering the transportation needs of low-income
and minority households.
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MORPC's evaluation
of its public involvement process identified a range of existing strategies
and opportunities for public participation, including public meetings,
task forces, a quarterly newsletter, direct mail, press releases, community
presentations, and citizen involvement on various committees. The evaluation
cautioned that low-income and minority residents typically become involved
in regional transportation planning only when issues arise that concern
them directly. The report recommended that MORPC do more to publicize
its activities among low-income and minority populations and make staff
available to give presentations at neighborhood meetings.
Implementing
Title VI Requirements in Metropolitan and Statewide Planning:
Public
Involvement
The October
7th memorandum directs FHWA and FTA staff to explore the MPO's
commitment to public involvement:
- Does
the public involvement process have an identified strategy for
engaging minority and low-income populations in transportation
decision making?
- What
strategies, if any, have been implemented to reduce participation
barriers for such populations?
- Has their
effectiveness been evaluated?
- Has public
involvement in the planning process been routinely evaluated
as required by regulation?
- Have
efforts been undertaken to improve performance, especially with
regard to low-income and minority populations?
- Have
organizations representing low-income and minority populations
been consulted as part of this evaluation and have their concerns
been considered?
- What
efforts have been made to engage low-income and minority populations
in the certification review public outreach effort?
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Does the public outreach effort use media (such as print, television,
radio) targeted to low-income or minority populations?
- What
issues were raised, how are their concerns documented, and how
do they reflect on the performance of the planning process in
relation to Title VI requirements?
- What
mechanisms are in place to ensure that issues and concerns raised
by low-income and minority populations are appropriately considered
in the decision-making process?
- Is there
evidence that these concerns have been appropriately considered?
- Has the
MPO or State Department of Transportation made funds available
to local organizations that represent low-income and minority
populations to facilitate their participation in planning processes?
Estimating
Baseline and Future Target and Nontarget Populations by Zone
MORPC concluded
that it was necessary to estimate the target and nontarget population
within each TAZ. However, the land use variables of their travel-demand
forecasting model considered only total population by TAZ for
their baseline (1995) and future years (2015). They needed a method
to estimate 1995 and 2020 target populations by zone.
MORPC used
a relatively simple and straightforward "constant share"
method to estimate poverty and minority populations. In estimating
the target populations by traffic zone, it was assumed that the
total regional percentage for each population would be the same
percentage as the 1990 census. For example, the regional percentage
in poverty in 1990 was 12 percent, and it was assumed that this
figure would remain constant for the 1995 population and the forecast
2020 population. MORPC decided to use this assumption because
the agency had no data available to support an alternative scenario.
The first
step was to apply the 1990 target population percentage in
each zone to the 1995 and 2020 total population
within each zone. However, because higher growth is occurring
in zones with lower than average target population percentages,
the total regional target population percentages were less than
the 1990 percentages. Uncorrected, this would provide a rather
misleading projection of the effects of growth.
The next
step, therefore, was to add the additional target population to
zones throughout the region in order to achieve the same regional
percentage as in 1990. This allocation relied upon the 1990 distribution
share of the particular targeted population. For example, assume
10,000 additional poverty population is needed to achieve the
same 12 percent as in 1990. If, in 1990, one TAZ had 1 percent
of the total poverty population, an additional 100 (10,000*.01)
poverty persons were added to the zone. During this process, steps
were taken to ensure that the total target population did not
exceed the total population of each zone.
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IV. Assess the
Benefits and Burdens of the Transportation System. The final step
MORPC completed in its environmental justice analysis was to examine
the agency's planning efforts to determine whether the benefits and
burdens of existing and proposed transportation system investments were
distributed equitably among target and nontarget populations within
the MORPC planning area.
MORPC, like any
transportation agency, was quickly confronted with the need to make
several important defensible assumptions regarding baseline and future
socioeconomic conditions, growth rates, and travel-demand forecasting
methods to assess the benefits and burdens.
Central to MORPC's
study plan was the agency's use of the travel-demand forecasting model
that it had used to prepare its Vision 2020 Transportation Plan.
This model employed land use and demographic information for each TAZ
within the MORPC planning area to forecast existing and future traffic
patterns and volumes on the regional transportation network. By expanding
the modeling process to take into account the distribution of target
versus nontarget populations within each TAZ, MORPC was able to estimate
the extent to which low-income and minority populations were equitably
served for each measure considered.
A major analytical
step in MORPC's benefits and burdens assessment involved identifying
a series of measures with which to compare the respective treatment
of target and nontarget populations in the planning process.
During the study process, MORPC distinguished between types of measures
and offered the following definitions:
- Population-based
measures best address the environmental justice definition in that
they provide information about members of the target population, regardless
of their location. Population-based measures also consider small pockets
of target populations within nontarget populations.
- Geographic-based
measures provide information specific to a geographic area (e.g.,
TAZ). Some information such as congested vehicle miles of travel can
only be reported for an identified geographic area. The data reported
within these areas are applicable to all of the populations
residing in the particular area. Thus, for an environmental justice
analysis, identifying the geographic area(s) of
interest is very important. The geographic area(s) should have higher-than-average
percentages of the target population and in total account for a large
majority of the target population.
- Visual-based.
In contrast to the measures above, some data cannot be boiled down
to comparisons. These can be classified as visual data, which are
usually presented in a map form.
MORPC considered
accessibility measures and travel measures and elected
to use both types of measures in the study. In the report, an example
of an accessibility measure is "number of jobs within 20 minutes."
Travel measures, such as the "average work trip length" or
"congested vehicle miles" are based upon an estimated pattern
of trip making.
MORPC was careful
to note that some measures can be either accessibility measures or travel
measures, depending on how they are calculated. For example, average
travel time to the central business district, if based on an estimated
pattern of trip making, would be
a travel measure. However, if it were calculated based on the average
travel times for trips downtown originating throughout the MORPC planning
area, it would be an accessibility measure.
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MORPC screened
and categorized potential measures for their immediate and future
application to environmental justice evaluations. The selected
measures included variables such as average number of accessible
job opportunities, average number of accessible shopping opportunities,
and average travel times for work and shopping trips.
For most
measures, estimates were calculated for four different scenarios.
The first scenario represented 1995 conditions. The next three
represented 2020 conditions under three different sets of transportation
system assumptions. The first was that only those projects currently
under construction were completed. The second assumed that only
projects in the current FY 2000-2003 Transportation Improvement
Program (TIP) were constructed. The final scenario assumed all
of the projects in the 2020 Plan were constructed.
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MORPC
estimated the average number of jobs within a desired travel time
available to various socioeconomic groups.
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The modeling process
did not reveal significant disparities in the distribution of benefits
and burdens of transportation system investments between target and
nontarget populations. For each measure considered, MORPC concluded
that low-income and minority residents were at least as well served
by existing and proposed investments as other segments of the population.
In addition, an analysis of the potential for displacement resulting
from the construction of major transportation projects during the next
20 years revealed no significant disparities in expected impacts upon
target and nontarget populations.
In April 2000,
based on the recommendations of its Citizen Advisory and Transportation
Advisory Committees, MORPC passed Resolution T-7-00, "Adoption
of Environmental Justice Assessment and Recommendations and Inclusion
in the MORPC Regional Transportation Plan." The resolution incorporated
the findings and recommendations of the Draft Environmental Justice
Report into the Transportation Plan and instructed staff to carry
out the recommended improvements. In addition, it encouraged member
jurisdictions to comply with environmental justice requirements when
reviewing, selecting, and submitting projects to MORPC for Federal funding.
Soon after, MORPC
began following up on specific recommendations made in the Report. During
summer 2000, MORPC began preparing a plan to increase participation
of target populations in the transportation planning process. In addition,
updates of the Regional Transportation Plan and future versions of the
TIP will contain sections on environmental justice that include revised
and updated versions of the analysis contained in the Draft Environmental
Justice Report. Year 2000 census data will be incorporated into
this analysis as soon as it becomes available.
MORPC continues
to work with transportation providers to ensure that the recommendations
outlined in the Report are implemented. For example, MORPC and the region's
transit provider COTA have translated analytical research and public
involvement activities into proactive initiatives, particularly in the
areas of job access. COTA has expanded and instituted new services and
invested and developed plans for transit center/transfer centers at
key nodes to support improved access to Empowerment Zones.
Average
Number of Job Opportunities Close: How MORPC Calculated the Measure
One of MORPC's
standard variables is the number of jobs by TAZ. This measure
estimates the average number of jobs within a specified travel
time. Discussion during the task force meetings addressed what
the appropriate time threshold should be to define a "close
job opportunity." A time threshold for auto travel was set
at 20 minutes. For transit, a doubling of the auto travel time
threshold (40 minutes) was selected. This was based upon a discussion
concluding that persons with multiple transportation options would
not likely ride public transit more than this length of time.
- First,
the model was used to estimate peak period auto travel times
and peak and off-peak transit travel times from each TAZ to
every other TAZ. This is commonly referred to as a travel-time
skim.
- Second,
for each TAZ based on the skim, the total number of jobs within
various travel times was calculated.
- Finally,
a weighted average number of jobs was calculated based on the
number of each population group within each TAZ.
Measures
Used to Assess Benefits and Burdens of Transportation
System Investments
Accessibility
Measures
- Average
number of accessible job opportunities
- Average
number of accessible home-based shopping opportunities
- Average
number of accessible nonshopping attractions, such as medical
appointments or banking
- Percent
of population close to a college
- Percent
of population close to a hospital
- Percent
of population close to a major retail destination
- Transit
accessibility to Columbus CBD
Travel
Time Measures
- Average
travel time for work trips
- Average
travel time for home-based shopping trips
- Average
travel time for nonshopping home-based trips
- Average
travel time for all home-based trips
- Average
travel time to Columbus CBD
Other
Measures
- Congested
vehicle miles of travel
- Highway
investments
- Displacement
from highway projects
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Most measures,
including transit accessibility, were compared for various transportation
investment scenarios.
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MORPC's
outreach program included an Open House on Environmental Justice
to present the Draft Environmental Justice Report and invite
citizens' comments and feedback.
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Effective
Environmental Justice Practices
MORPC's environmental
justice review process serves as an example of how one MPO comprehensively
evaluated the extent to which its regional planning efforts incorporate
the principles of Title VI and the Executive Order on environmental
justice. This review process illustrates a number of effective practices
for ensuring that environmental justice requirements are fulfilled:
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Technical
Advisory Groups and Public Involvement Techniques. MORPC engaged
the public and transportation service providers in carrying out
its environmental justice review process by convening a broad-based
task force to advise agency staff. This group not only provided
opportunities for public participation in the process, but it also
filled certain gaps in the knowledge and expertise of agency staff.
In addition, MORPC made efforts to publicize the review process
and seek public input by holding an Open House on Environmental
Justice, televising the proceedings, and making its Draft Environmental
Justice Report available on the agency's web site.
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GIS Mapping
of Target Populations. In identifying and mapping the locations
of target populations within the Columbus metropolitan area, MORPC
had to balance the need for current data against the need for data
that were usable in its travel-demand forecasting model. In the
end, MORPC used 1990 census data, a choice that will allow the model
to be easily updated once year 2000 census data become available.
Although more current administrative records data on employment
and establishments could be mapped by exploring a data-sharing partnership
with the State's employment office, the analysis was still able
to pinpoint the existence of a spatial mismatch between the locations
of new job growth in the outerbelt and the residential location
of low-income and minority populations.
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Use of
Accessibility and Travel Time Measures from MPO's Travel-Demand
Forecasting Model. In assessing the benefits and burdens of
transportation system investments on low-income and minority populations,
it makes sense for MPOs to use analytical methods with which they
have prior experience. MORPC's use of travel demand forecasting
shows how an existing model can be modified and applied to address
a different set of questions. In this case, a model developed to
estimate existing and future regional traffic patterns and volumes
was modified to predict how well current and proposed transportation
investments serve low-income and minority populations.
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Documenting
the Review Process. MORPC's Draft Environmental Justice Report
thoroughly documents the methodology developed to carry out the
agency's environmental justice review process. This is important
because the report identifies a clear set of procedures for assessing
future planning efforts from an environmental justice perspective.
Although some of these procedures will undoubtedly be modified as
refinements to the methodology are introduced, the report represents
an important baseline. It also represents a potential learning device
for MPOs elsewhere wrestling with the same issues.
Challenges
Ahead
Incorporating environmental
justice principles into regional transportation planning is an evolving
area of practice, and it is only natural that MPOs seeking to address
this mandate will encounter certain challenges. Some of the key challenges
MORPC faces concern the limitations of the data used by the agency to
carry out its analysis.
For example, MORPC's
use of 10-year-old 1990 census data to identify the locations of target
populations within the agency's planning area raises significant questions
about the accuracy of the information. While not inappropriate, using
this data places the burden on MORPC to update its analysis once new
census data become available.
Equally important,
it is often possible to cooperate with the State labor department, which
is responsible for keeping and reporting administrative establishment
employment and payroll data for the ES-202 program. This data set has
confidentiality restrictions that present challenges in precisely pinpointing
establishment locations. These limitations can frequently be overcome,
however, with proper handling of confidentiality concerns. No other
employment data set provides the ability to map emerging employment
centers and illuminate the challenges presented by a spatial mismatch
between job growth and population in such a timely and comprehensive
fashion.
MORPC's use of
travel-demand modeling to identify benefits and burdens of transportation
system investments also reveals certain data limitations. For instance,
the analysis concluded that target populations had access to at least
as many jobs as other groups, yet no effort was made to determine what
kinds of jobs these were and what percentage of them represented viable
employment opportunities for low-income and minority workers. Although
this type of information was not readily available to MORPC at the time
it was developing its environmental justice methodology, it is important
that such data limitations be acknowledged and addressed in future modeling
efforts.
Additionally, MORPC's
analysis of travel times and accessibility for public transit did not
consider frequency of service. All bus lines were assumed to have uniform
service, even if lack of evening or weekend service prevented individuals
using certain bus routes from accessing jobs or other destinations.
Shortcomings such
as these should not obscure the fact that MORPC has gone to great lengths
to assess
the benefits and
burdens of its transportation planning efforts, investing considerable
time and resources in developing a methodology, carrying out the analysis,
and documenting the process. Now, however, MORPC faces the additional
challenge of holding its findings up to further scrutiny and, finally,
incorporating the substance of the environmental justice review process
into its transportation planning efforts.
Lessons
Learned
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MPO staff
may not be intimately familiar with the transportation needs and
concerns of low-income and minority populations. MORPC's environmental
justice review process benefitted from the knowledge that Environmental
Justice Task Force members brought to the table.
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Methods for
evaluating equity in transportation planning may be constrained
by the absence of timely and appropriate data. MORPC's Draft
Environmental
Justice Report is by necessity a work in progress whose findings
and conclusions will need to be reassessed as new data sources become
available.
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MORPC's Draft
Environmental Justice Report is more than a summary of findings
from GIS mapping and the application of evaluation measures drawn
from a travel-demand forecasting exercise. The report gives an overview
of the public-involvement processes, partnerships, and other initiatives
undertaken by the MPO and its member agencies such as COTA. In so
doing, the overview clarifies how environmental justice requirements
are addressed in the overall regional transportation planning process.
For example, the report details the role of MORPC's Columbus Area
Transportation Coordination Program (CATCP), which was created to
assist in providing transportation to employers located in the outlying
areas that are not served by public transit. The CATCP planning
process provides a forum for addressing complex regional transportation
problems and forging workable partnerships to leverage the scarce
resource of individual agencies. The CATCP facilitates a dialogue
between private and public transportation providers, human service
agencies, planning agencies, citizen groups, and employers.
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Taking a first
step in a long journey, MORPC adopted a self-critical perspective
about its findings and outlined several next steps to improve both
its analyses and outcomes. In addition to exploring other methods
and noncensus data sources, MORPC concluded that further public
involvement outreach to both general and target communities would
better promote an understanding of needs. More consideration was
also required as to whether minority and disabled populations had
special needs to address. Finally, MORPC concluded that, despite
the strategic role of Columbus as a rail and freight hub, the agency's
consideration of environmental justice as it relates to rail and
truck freight needed to be more comprehensive and required further
investigation.
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MORPC recognizes
that considering Title VI/environmental justice issues is more than
a one-time exercise or occasional obligation; rather, it is a normal
part of its mission to be fully integrated into its transportation
planning and programming process. The agency further recognized
that establishing and monitoring performance measures such as the
ones discussed in this case study will prove beneficial in determining
whether the target populations have been treated fairly in transportation
programs and activities receiving Federal funds.
Implementing
Title VI Requirements in Metropolitan and Statewide Planning:
Service
Equity
The October
7th memorandum directs FHWA and FTA staff to ask MPO's about their
planning and analytical processes related to service equity:
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Does
the planning process have an analytical process in place for
assessing the regional benefits and burdens of transportation
system investments for different socioeconomic groups?
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Does
it have a data collection process to support the analysis
effort?
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Does
this analytical process assess the benefit and impact distributions
of the investments included in the plan and TIP (or STIP)?
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How
does the planning process respond to the analyses produced
and are imbalances identified?
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The
MORPC Draft Environmental Justice Report described activities
to address minority populations undertaken by COTA, the region's
transit agency, in coordination with MORPC.
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Evaluating
regional planning
from an environmental justice perspective
can't be a cookbook process. Different cities
have different issues and concerns. The process needs to be
tailored to local conditions.
-- Robert Lawler
Assistant Director of Transportation
Mid-Ohio Regional Planning Commission
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Benefits
from Environmental Justice in Decision Making
For Low-Income
and Minority Populations:
- MORPC's
environmental justice review process produced a set of conclusions
about the fairness of transportation access and travel in the
Mid-Ohio region based largely on a modeling process developed
by agency staff. By thoroughly documenting the review process
in its Draft Environmental Justice Report, MORPC opened
itself to the possibility of public scrutiny. Neighborhood groups
and other organizations now have the opportunity to review the
agency's findings, gauge them against their own experiences,
and respond accordingly.
- MORPC's
Draft Environmental Justice Report provides valuable
information on regional demographics, accessibility, travel
times, and highway investments for different segments of the
population that may be useful in research efforts or other undertakings
by neighborhood groups.
For the
MPO:
- MORPC
staff acquired a greater sensitivity to the demographic profile
and spatial patterns of low-income and minority populations.
This further clarified an understanding about the zones of employment
- growth
and residential development as well as possible avenues for
additional needed research and resources.
- The MORPC
staff became further engaged in a review of the transportation
needs and concerns of low-income and minority populations. By
working with Environmental Justice Task Force members from a
cross section of institutions and agencies, MORPC provided a
forum for exploring workable partnerships to discover opportunities
as well as improve access for target populations.
- MORPC
better understands how its transportation system and transportation
plans serve low-income and minority residents. Meaningful efforts
to incorporate the findings and recommendations of the report
into future planning efforts will strengthen MORPC's support
by target populations and better ensure that transportation
plans are broadly inclusive. Transportation planning efforts
that consider all segments of the population are more likely
to enjoy broad-based support. Conversely, projects and planning
efforts that ignore the concerns of certain groups may become
the subject of vocal opposition.
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References
Mid-Ohio Regional
Planning Commission, Draft Environmental Justice Report, March
23, 2000.
Vision 2020
Transportation Plan, Spring 1998. Minutes of Environmental Justice
Task Force meetings are available on the MORPC web site: www.morpc.org/trans/EnvirJust/envjust.htm
Contacts
Robert Lawler
Assistant Director of Transportation
Mid-Ohio Regional Planning Commission
285 E. Main Street
Columbus, OH 43215
(614) 233-4160
Bernice Cage
Principal Planner
Mid-Ohio Regional Planning Commission
285 E. Main Street
Columbus, OH 43215
(614) 233-4157
Marc Conte
State Program Coordinator
Sierra Club, Ohio Chapter
145 N. High Street, Suite 409
Columbus, OH 43215
(614) 461-0734
FHWA
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