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Environmental Justice Emerging Trends and Best Practices Guidebook

2. Public Involvement

Introduction

Federal regulations and requirements under the ISTEA, TEA-21, SAFETEA-LU, and NEPA require early and continuous public involvement. Effective community engagement addresses the needs of and incorporates input from a broad spectrum of interested parties including residents, businesses, and transportation system users. Within the context of a broad public involvement process, transportation agencies need to focus extra effort on outreach to and engagement of traditionally underrepresented populations.

Full and fair participation of all potentially affected communities is one of the three core environmental justice (EJ) principles. Ensuring the participation of traditionally underrepresented communities in the transportation planning process allows communities to identify the benefits and burdens associated with the proposed activity, and suggest alternatives to mitigate impacts based on their concerns. This input helps transportation agencies comply with another core EJ principle-avoid, minimize, or mitigate disproportionately high and adverse impacts. As demonstrated through context-sensitive approaches, the most effective community engagement processes incorporate a broad range of community input long before planning and project-level decisions are made.[31]

Trends in Public Involvement/Community Engagement

Many transportation agencies have developed a wide range of innovative public involvement strategies to break down the barriers to public involvement. Examples include public meetings at the offices of trusted community-based organizations (CBOs) or common gathering locations like malls or senior/community centers. Also, transportation agencies regularly tailor public service announcements, (PSAs), a conventional mass media strategy, to reach out to underrepresented communities by broadcasting announcements in multiple languages through language-specific media outlets.

Demographics of Internet Users

Percentage of Internet users by demographic details in national survey conducted by the Pew Research Center. Source: Pew Internet and American Life Project, 2009.
Internet Users
Total Adults 74%
Men 74%
Women 74%
Race/Ethnicity
White, Non-Hispanic 76%
Black, Non-Hispanic 70%
Hispanic (English- and Spanish-speaking) 64%
Age
18-29 93%
30-49 81%
50-64 70%
65+ 38%
Household Income
Less than $30,000/yr. 60%
$30,000-$49,999 76%
$50,000-$74,999 83%
$75,000+ 94%
Educational Attainment
Less than High School 39%
High School 63%
Some College 87%
College+ 94%
Community Type
Urban 74%
Suburban 77%
Rural 70%

While transportation agencies are encouraged to continue exploring innovations in emerging media and online tools, it is important that agencies also understand the limitations of high-tech tools and approaches. For example, although the Digital Divide is shrinking, it still exists to a degree. A national survey of adults conducted by the Pew Research Center's Internet & American Life Project finds that households at the lowest income and educational attainment brackets have limited access to the Internet. In addition, online activities amongst users vary significantly. The discrepancy suggests that despite the burgeoning options for sharing and receiving information, the simplest modes of online communication may reach the broadest audience: email for providing information and receiving comments, simple Web sites that maximize hits on search engines, and accessibility so hardware sophistication or Internet connectivity do not hamper use.[32] As such, agencies must not rely exclusively on the use of online tools for community outreach and participation.

Some agencies are exploring innovative advances in online technologies, particularly Web 2.0 (i.e., social media and social networking), to expand their outreach and engagement strategies. Examples of such efforts include those implemented by Bay Area Rapid Transit (BART), the Chicago Metropolitan Agency for Planning (CMAP), Denver's Regional Transportation District (RTD), and LA Metro:

CMAP organized interactive workshops during which participants used a scenario software tool and keypad polling to create their own detailed versions of 2040 and compare them with CMAP's proposed scenarios. This is a picture of the travelling kiosk used to get similar input from people who coud not attend the workshops.

Figure 8. Travelling kiosk

Source: Chicago Metropolitan Agency for Planning, 2010.

This is a picture of a travelling display of project map, which LA Metro used to gather input from the community in a variety of public locations.

Figure 9. Project map display

Source: Los Angeles, California Metro, 2010

By using traveling kiosks and online communications platforms like Facebook and YouTube, transportation agencies expand options for stakeholder participation: through an online interactive tool, users are encouraged to obtain information and provide input and feedback on meeting events and proposed meeting locations. This is an important development because community members have varying interests, access, and abilities to attend public meetings.[38] As such, the efforts to engage community members at their homes, worksites, or various neighborhood locations permits agencies to reach members of the public who are traditionally underrepresented at public meetings. These populations include, but are not limited to, low income, minority, Limited English Proficiency, youth (10-17 years old), young adult (18-35 years old), senior (65 years and older), and persons with disabilities populations.

Challenges

Effective public participation requires an organized, strategic, and culturally sensitive effort, since members of underrepresented or marginalized communities experience a variety of barriers to participation. For example, based on prior negative experiences working and interacting with public agencies and officials, individuals and communities are sometimes suspicious of an agency's outreach motives. Low income and minority communities also frequently experience language and literacy barriers, as well as differences in cultural mores and preferences in communication. In addition to these cultural barriers, accessibility for persons with disabilities can also pose major challenges to full community participation. Other common barriers include a lack of knowledge about the overall transportation planning process, an incomplete sense of the role and relevance of participation in the planning process, and skepticism that public comments and feedback have an impact on the outcome of planning processes.

Transportation agencies face additional challenges when implementing a participation process for a particular planning effort, including:

Case Studies

Case Study 1: Buford Highway (DeKalb County, GA)

Introduction

When DeKalb County, GA, announced the beginning of preliminary engineering on a sidewalk and streetscape plan to improve Buford Highway's appearance, the announcement generated a number of articles by pedestrian advocacy groups in the Atlanta Journal Constitution. The articles highlighted Buford Highway's pedestrian safety problems and questioned the use of funds for beautification rather than for improving pedestrian safety. Realizing that DeKalb County did not have resources available to address this larger undertaking, Georgia Department of Transportation (GDOT) proposed a joint initiative and provided additional funding to address Buford Highway's pedestrian safety issues.

When GDOT expanded the landscape improvement project to address pedestrian safety concerns, the new project design included a number of measures such as a continuous raised median to provide a refuge for pedestrians crossing Buford Highway at mid-block locations. When corridor merchants learned of these plans, many went to DeKalb County elected officials and expressed concerns that the median would limit left turns and restrict access to their businesses. Community advocacy groups identified similar median constructions on nearby Memorial Drive as a cause of that area's decline. Whether the decline resulted from the median improvements or other factors, many of the businesses on Memorial Drive had closed. DeKalb County officials advised GDOT that they would be unable to support the raised median concept without the backing of the merchants, and suggested that GDOT re-evaluate the design.

As part of the re-evaluation, GDOT initiated a public involvement process. Originally, the public participation effort called for a series of design charrettes, which are typically multiple-day, collaborative design workshops. However, the agency abandoned this idea due to the logistics of accommodating the wide array of communities (Latino, Chinese, Korean, and Vietnamese) and languages in the project area. In order to remedy issues and concerns brought forward by the community GDOT crafted an effective public participation process that was tailored to the cultural norms of each community., GDOT's contractor identified and surveyed community stakeholders, and using the information from the stakeholders, conversations with community members, anecdotes, and demographic information, designed two parallel public involvement plans. One of the plans aimed to engage Latino merchants and residents; the other targeted the Chinese, Korean, and Vietnamese community members. See further details on the two plans below.

Public Involvement Plans for Buford Highway

The following features were unique to the involvement plan for Latino merchants and residents:

  1. Language Related Consideration: GDOT asked principals of three elementary schools near the corridor if their students could take home translated information about the events to their parents who may not read Spanish or English.
  2. Location, Timing, and Giveaways at Survey Events and Public Information Open House: Two stores, Plaza Fiesta and Mercado del Pueblo, each hosted a survey event. Plaza Fiesta also hosted a public information open house. Both of these locations made the public feel safe to congregate and visit, had a family friendly atmosphere, and were convenient to transit.
    • Survey event and public information open house at Plaza Fiesta was held on a Sunday from 4:00 to 8:00 p.m., and the survey event for Mercado del Pueblos also was held on a Sunday from 2:00 to 6:00 p.m. Those times are when the stores draw the largest weekly crowds.
    • Giveaways, including soccer balls, were provided for children.

The following aspects were unique to the involvement plan for the Chinese, Korean, and Vietnamese merchants:

  1. Interview Meetings: GDOT set up interviews to survey business owners and operators. The surveys were conducted by appointment at the business locations convenient for the business owners/operators. Appointments were made by a trusted source-an individual that was well known in the community and by the business owners/operators.
  2. Location and Timing of Public Information Open House: The Center for Pan Asian Community Services hosted a public information open house on a Thursday from 10:00 a.m. to 7:00 p.m., at a location well known to the Korean, Chinese, and Vietnamese merchants, close to a subway stop and a bus stop, and able to accommodate a large crowd.
  3. Outreach and Invitations: Members of the Chinese, Korean, and Vietnamese communities considered newspaper advertisements and flyers too informal and not culturally appropriate for an invitation to a public information open house. Therefore, GDOT created a phone tree for each community.
    1. Interpreters telephoned community leaders, business owners and operators, friends and relatives who owned businesses and others in their individual communities to extend personal invitations to attend the public information open house.
    2. In turn, these individuals called others, who also called others. In this way, everyone reached received a personal invitation to attend.

A Korean interpreter interviews the operator of one of the largest Korean grocery stores in Atlanta.

Figure 10. A Korean interpreter interviews the operator of one of the largest Korean grocery stores in Atlanta.

Source: PBS&J, 2010

GDOT incorporated recommendations from the special event survey and interviews into the project design and prepared display boards for two public information open house events. The project display boards in each language (Chinese, English, Korean, Spanish, and Vietnamese) featured:

English poster showing the problems identified through the survey and GDOT's solutions to address them; GDOT also produced posters in Spanish, Chinese, Korean, and Vietnamese.

Figure 11. GDOT Poster

This large graphic display of the Buford Highway project used photographs of landmarks to orient the public rather than just text.

Figure 12. The Buford Highway project

Source: PBS&J, 2010

Comments received from the Plaza Fiesta and Center for Pan Asian Community Services public information open houses were analyzed and incorporated into the design plans. Phase I was completed in January 2007 and construction on Phase 2 is scheduled to begin in the summer of 2012.

Outcomes

The project was transformed from a sidewalk and streetscape beautification project into a more comprehensive project that also addressed improving pedestrian safety. Some of the concerns raised and design solutions to address those concerns are listed below.

Figure 13 is a picture of the construction signs that GDOT translated into Spanish.

Figure 13. GDOT Construction Signs in Spanish

Source: PBS&J, 2010

Lessons Learned

Incorporating stakeholders into the planning process is critical to developing culturally sensitive outreach and engagement events. Stakeholders located appropriate venues and times to meet with the target communities, identified interpreters that were well-known in the community, and provided materials and resources needed for the event. For example, the Plaza Fiesta representatives suggested the mall as a place to survey Latino customers on a Sunday between 4:00 and 8:00 p.m. because they knew more than 1,000 shoppers would be present. In addition, the mall provided four set-up spaces with tables and chairs, giveaways from mall merchants (e.g., toys, balloons, coloring books and crayons), eight bilingual interpreters, and translation of project materials into Spanish. A Latino member of the DeKalb County Police Force recommended small soccer balls for giveaways, since soccer is the national sport of Mexico.

Figure 14 is a picture of a GDOT representative and one of the bilingual interpreters (Spanish/English) distributing soccer balls at a public information open house.

Figure 14. GDOT Representatives

Source: PBS&J, 2010

In another example, for the Center for Pan Asian Community Services, a stakeholder identified critical cultural issues and proposed solutions to effectively engage community members. The center's executive director suggested surveying business owners/operators at their individual business locations to minimize inconvenience to them. The executive director knew that many business owners were concerned about interacting with Immigration and Naturalization Service and Internal Revenue Service personnel; therefore, it was imperative that owners/operators be contacted by someone they knew and trusted. The executive director agreed to provide Korean, Chinese, and Vietnamese interpreters who were well known within the corridor and business community. Each interpreter was responsible for making appointments with four business owners/operators, translating the survey, conducting the survey, and providing a summary of the survey results. In addition to the interpreters, a member of the staff from the Center for Pan Asian Community Services accompanied each interpreter. The center also agreed to translate project materials into each of the three languages.

CASE STUDY HIGHLIGHT

To serve Limited English Proficiency and low-literacy populations, the Buford Highway planners used multiple approaches, supplementing the conventional methods of making information available in multiple languages with visual aids, design considerations, and age-appropriate take home materials for school children. For example:

Case Study 2: Baltimore Regional Environmental Justice Toolkit (BREJTP)

Introduction

The BREJTP project in Baltimore, MD, was designed to explore a community-based, bottom-up approach to addressing EJ issues in the transportation planning process. The goals of the project included:

To implement these goals, the project devised a three-phase program. The first phase was a large-scale community outreach program to ascertain public concerns. The BREJTP project team conducted an intense public outreach effort to community groups and community leaders throughout the Baltimore region. Eight listening sessions were conducted from May 19, 2004 through June 9, 2004. After compiling the listening session findings, the project team conducted two community dialogues. The community dialogues were designed to allow participants to discuss EJ as it relates to transportation problems and to brainstorm solutions in small group breakout sessions. The breakout sessions were divided into four sub-group discussions. The BREJTP project team used these listening sessions to identify the key EJ concerns that the project would address.

The second phase, initiated in 2006, focused on developing analytical tools and methods for validating the range of EJ concerns articulated by underrepresented communities. Community participants from four selected communities worked with the project team to identify EJ concerns and potential causes, validate the community experience by quantifying impacts, and seek solutions. The EJ concerns were:

Members of the four communities worked with planning specialists and agency officials to study the causes and impacts of the EJ concerns raised. Community members actively participated in planning the studies and gathering the data. Technical specialists on the study team compiled the data and developed the appropriate analysis tools. With results of the analysis in hand, community members could weight near-term and long-term solutions, and work with agency planning and programming processes to implement the results. The BREJTP project team presented the validated findings to community members in a community workshop in 2008 and published and posted a report to the Baltimore Metropolitan Council Web site.[39] Additional reports are also available on the project Web site.[40]

The final phase, which is currently underway, is the development of practical, systematic, multi-user guidance on implementing a bottom-up approach for both practitioners and community members. This third phase envisions national dissemination of the toolkit for use in university curricula and practitioner training.

Outcomes

The listening sessions and community dialogues in Phase I of the BREJTP project identified a wide range of issues, implying that a broad base of analytical tools and measures would be required to validate the concerns identified and evaluating potential solutions. Investigations related to the four communities studied in Phase II confirmed that assessment. Each community required the BREJTP project team to assess available models and data sources and adapt existing models or develop new ones to complete the investigation.

As a result of the investigation, the BREJTP project team was able to confirm and in some cases, allay EJ concerns, help communities and transportation agencies address challenges identified, and suggest concrete follow-up actions. For example, MTA is locating hybrid buses at the Kirk Avenue bus yard instead of diesel fuel buses. In addition, new operational procedures are in place, and a new maintenance facility structure will replace the old structure. Another example is related transit access to Lexington Market. The BREJTP project team found that, despite reductions in bus service to the area, overall transit access to Lexington Market appears to have actually improved.

Scope of Analysis: Investigating Concerns of Four Communities in Baltimore, MD

Scope of analysis for the Kirk Avenue Bus Yard (Midway Community) included:

  1. Nature of bus operations
    • Scale of operations at Kirk Avenue and change in scale or nature of activity over time, in comparison with other MTA bus depots
    • Markets served by routes supplied by buses stored at Kirk Avenue; relevance to Kirk Avenue neighborhood
  2. Impact on neighborhood
    • Number of households/homes in proximity to the bus depot
    • Socio-demographic characteristics of households in surrounding vs. directly adjacent communities
    • Levels of home ownership, abandonments
    • Housing values, sale prices, turnover rates
    • Noise and pollution impacts
  3. Mitigation history and alternatives
    • Mitigation actions that have been taken by MTA: nature, timing, objective, effectiveness
    • Other actions suggested but not taken, and why
    • Potential impacts of proposed new facility

Scope of analysis for the Cherry Hill Community and Transit Access included:

  1. Assessment of changes in transit service
    • Nature of system changes when LRT system phased in
    • Change in route coverage and connectivity
    • Change in ease of access to transit within the community
  2. Impact of changes on regional accessibility
    • Comparison of areas reachable by transit within 30, 45, and 60 minutes of travel time before and after system change
    • Comparative travel times to favorite destinations
    • Assessment of whether changes in service orientation reflect redistribution of land use and opportunities in the region
    • Number of jobs within 30, 45, and 60 minutes of transit travel times before and after
  3. Changes in the community
    • Population: number, race, age, education, employment
    • Households: number, size, composition, income
    • Housing: number of units, size, ownership, vacancies, home values, rents
  4. Transit service delivery
    • Reliability (on-time performance, showing up for appointments)
    • Condition and cleanliness of equipment and facilities
    • Driver professionalism, competence, orderliness on buses

Scope of analysis for the West Baltimore "Highway to Nowhere" Community included:

  1. Characteristics of the communities in the U.S. 40 corridor
    • Segment the corridor into inner, middle, and outer corridor sections
    • Population size, characteristics of each segment
    • Housing condition, availability, home ownership
    • Changes over time
  2. Transportation conditions in the corridor
    • Daily vehicle traffic volumes, congestion levels
    • Transit service and ridership in the corridor
    • Pedestrian environment, walkability
    • Changes over time
  3. Benefits and burdens
    • Traffic congestion by segment, and origin of vehicle occupants
    • Vehicle emissions
    • Vehicle/pedestrian conflicts, accidents, injuries, fatalities
    • Changes in transit service (and accessibility) over time
    • Housing prices, vacancies, ownership adjacent to corridor

Scope of analysis for the Lexington Market Pedestrian Safety included:

  1. Assessment of nature, magnitude, and impact of changes in bus stops
    • Bus routes for which stop locations changed
    • Location of new stops, appraisal of impact on access (time, distance, exposure)
    • Communities served by these routes, route ridership, average boardings/alightings at Lexington Market
    • Characteristics of riders: race, age, gender, income, origin community, trip purpose, frequency
    • Stated effect on trip-making behavior
  2. Assessment of vehicle/pedestrian conditions and conflicts in market vicinity
    • Peak hour vehicle volumes on adjacent streets, particularly those which bus riders would need to cross to access the relocated bus stops
    • Comparable pedestrian volumes in market area
    • Pedestrian accident statistics
  3. Changes in regional transit accessibility
    • Change in accessibility to Lexington Market by transit, 1990 vs. 2000
    • Areas for which transit travel times have increased between 1990 and 2000

Source: U.S. EPA and FHWA, 2004.

Lessons Learned

Transportation agencies can demonstrate how community feedback and concerns impact project planning and design by adopting goal-oriented performance measures. These measures should reflect the concerns articulated by underrepresented communities so that the agency and community members can assess how the agency is doing relative to community concerns. From the experience of working with four communities, the BREJTP project team provides some examples of performance measures directly related to the concerns raised by the community.

The BREJTP project team also assessed at what stage in the planning process performance measures could be utilized. As cited in the EJ Toolkit Technical Document, the team envisioned four different applications:

Investigating programming activities, in which funding priorities and allocations are established, typically in conjunction with the regional Transportation Improvement Program.

The BREJTP project has published a report documenting the technical tools they employed for replication and adoption by interested transportation agencies. The project will also include these tools as part of the forthcoming procedures manual on a comprehensive community-based approach to EJ for transportation agencies and practitioners.

Community Driven Public Participation

Community Issues Community Driven Public Participation
Goal Objectives Performance Measure Measures
Job Access Economic Vitality and Competitiveness Encourage Employment Opportunities in Urban Communities Work opportunities within 15, 30, and 45 minutes by car and transit door-to-door.
Percent of transit dependent riders who can access jobs with 45 minutes of fixed route of transit
Maintenance Safety and Security (Motorized and Nonmotorized) Stop the Use of Old Equipment in Low Income Neighborhoods Percent and characteristic of out-of-service buses coming into an area Pedestrian/bicycle injuries and fatalities
Vehicle crashes
Age of fleet
Increased Accessibility Increase Accessibility and Mobility Options Access to Jobs Proximity to transit
Level of service
Accessibility to health care facilities
Accessibility to education facilities
Reduce Air and Noise Pollution Protect Environment, Conserve Energy, and Improve Quality of Life Clean Environment Air pollution concentrations
Incidence rates of respiratory disorders
Number of households exposed to noise
Asthma rates in communities adjacent to large transportation facilities
Improved Transit Route Structure Enhance Connectivity and Integration Across Modes for People and Freight Access to Shopping and Services Location improved per million passenger miles
Need Assessment Manage and Preserve Existing Transportation System Advocate for Project Funding to Improve Local Conditions Condition of roads and streets
Condition of sidewalks
Ratio of uncontested travel times between origins and destinations

Source: U.S. EPA and FHWA, 2004

Community Driven Public Participation

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 Nonmotorized Travelers
Pedestrian/bicycle injuries and fatalities C PL F PR DA   GIS  
Vehicle crashes C     PR DA   GIS  
Increase Accessibility and Mobility Options
Proximity to transit 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 origin/destination pairs by mode C PL       RM GIS  
Accessibility to regional educational institutions   PL F       GIS  
Average age/condition of buses by area served C   F   DA   GIS  
Protect Environment, Conserve Energy and Improve Quality of Life
Number of households living within X feet of busy highway C PL F PR DA   GIS  
Air pollution concentration by type of pollutant C PL   PR   RM GIS EM
Incidence 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 that use alternative fuels C PL F     RM GIS  
Percent of takings, household displacement, 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       RM GIS  
Manage Existing Transportation System for Maximum Efficiency
Percent of congested to uncongested 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 benefitting from new project or program   PL F PR DA   GIS  

Source: U.S. EPA and FHWA, 2004

LEGEND
C = Current Concern, PL = Planning, F = Programming, PR = Project, DA = Data Analysis, RM = Regional Travel Models, GIS = GIS-aided, EM = Emission Models

Conclusion

Community concerns are highly context specific and cannot be assumed or generalized across traditionally underrepresented communities. Transportation agencies may encounter multiple underrepresented communities within the same project area. Variations in the modes of transportation used may result in differing access to facilities and services and thus divergent needs. The populations may also have distinct cultural mores and preferences for communication that will require sensitively tailored public participation plans. As such, agencies need to explore a broad range of strategies to engage with and validate community concerns.

Community outreach should proactively engage underrepresented communities in their preferred settings, instead of expecting the community to come to the agency with feedback. Direct community outreach can enhance participation by visiting impacted community members, meeting one-on-one to solicit their feedback, holding special events, and convening meetings at non-traditional places. Innovations in technology can advance and extend agencies' outreach by offering community members who cannot participate in public meetings alternative options for obtaining information and providing feedback. However, technologically advanced outreach methods should not be used to the exclusion of other methods.

Transportation planners should address suspicion and skepticism directly by incorporating community concerns into planning and programming efforts. Transportation agencies must demonstrate how the concerns articulated by community members are explicitly addressed by project plans. Outreach materials should highlight community concerns as they have been articulated in the public participation process, and provide details about the agency's efforts to address community concerns and incorporate them into project plans and construction designs. These materials can be disseminated in a number of ways. As discussed in this chapter, agencies with an online presence use email newsletters, status updates on their Web sites, and videos. The Buford Highway case study created display boards of the revised plans featuring the measures adopted to address pedestrian concerns and exhibited them at open house information meetings. The BREJTP project team presented findings during community meetings at locations proposed by community members. They also included community members in the development and dissemination of the final report community members helped to develop. In addition to incorporating mitigation and improvement suggestions, agencies can also involve community members in analyzing the concerns that they raise. As demonstrated, community members can be involved in selecting appropriate metrics for validating their concerns, as well as in gathering data.

Updated: 12/19/2011
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