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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
×
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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Suggested Citation:"Appendix A - Literature Review." National Academies of Sciences, Engineering, and Medicine. 2020. Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview. Washington, DC: The National Academies Press. doi: 10.17226/25886.
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A-1 A P P E N D I X A Literature Review Completed August 1, 2017 Introduction and Executive Summary About This Project The goal of this research project was to develop a reference guide that identifies and describes how metropolitan planning organizations (MPOs) can effectively analyze and address equity and environmental justice in long-range planning and programming processes, meeting both the legal requirements of Title VI and the needs of underserved or underrepresented communities successfully and efficiently within an MPO’s responsibilities and capacity. A strong transportation system provides everyone who lives in a community with access to economic opportunities such as jobs or schools and to destinations that are vital to health and livability, such as grocery stores and healthcare. Transportation projects can also endanger nearby residents’ safety, health, and quality of life by increasing traffic volumes or speeds, increasing pollution, or bisecting communities. Historically, low-income and minority communities have borne a disproportionately high share of the burdens of the transportation system and a low share of the benefits. In implementing Title VI of the 1964 Civil Rights Act and federal environmental justice (EJ) policies that stem from Executive Order 12898 (1994), transportation agencies aim to prevent this situation. Title VI and EJ require transportation agencies to identify communities of concern (COCs), analyze whether transportation projects have a disparate impact on these communities, and if so, either demonstrate that these impacts are unavoidable or identify ways to mitigate them. Though the requirements of Title VI and EJ vary, there is extensive overlap between the two policies, and transportation agencies usually submit a single equity analysis of a plan or project designed to satisfy both sets of requirements. This project focuses on equity analyses of regional transportation plans and projects. Metropolitan planning organizations (MPOs) are responsible for long-term transportation planning and for programming federal transportation funds in U.S. urban regions where 50,000 or more people occupy two or more jurisdictions. Every 4 years, MPOs create metropolitan transportation plans (MTPs) that outline a 20-year (or greater) vision for the transportation system, accounting for all of the current and proposed transportation investments to be supported by estimated funds from federal, state, and local sources. To implement the MTP, the MPO adopts and regularly updates a short-term Transportation Improvement Program (TIP), which lists and designates funding for all regionally significant transportation projects to be moved forward during a period of 4 or more years. In accordance with Title VI and EJ requirements and policies, MPOs must conduct equity analyses of the MTP, the TIP, and other plans and projects that they develop.

A-2 Equity Analysis in Regional Transportation Planning Processes A thorough regional equity analysis can take a holistic approach to equity that may be missing from other stakeholders’ assessments. For example, a transit agency may conclude that new transit service benefits a predominantly African-American neighborhood, and a state department of transportation (DOT) may conclude that a freeway expansion in the same community produces negative impacts. MPOs must plan for all transportation modes, and a regional equity analysis provides an opportunity to examine projects side-by-side to weigh their aggregate benefits and burdens. Regional equity analyses can be challenging for the same reasons that they are important. MPOs must account for a range of communities and stakeholders with different needs and goals, and for multiple overlapping projects that have different modes or different scales, which can make it difficult to come to a concrete conclusion about whether a plan produces disparate impacts, much less identify steps to mitigate these impacts. Adding to these challenges, federal guidance on regional equity analyses for long-range planning is much less detailed than is guidance on conducting analyses for specific transportation projects that are in the development process. About This Report This literature review was the first substantive report from this Transit Cooperative Research Program-funded project. It covers the state of the practice of regional equity analysis, and it identifies challenges and best practices for further consideration during the remainder of the project. The purpose of the literature review is to ensure that our work is grounded in the state of the practice and identify potential areas of focus for the rest of the project. TCRP is focused on research related to public transportation, which is central to meeting the needs of many traditionally underserved populations. For this project, we are addressing regional transportation equity analyses in general terms rather than focusing specifically on how MPOs analyze transit. This is in part because MPO planning is by nature multimodal, and MPOs usually do not undertake detailed equity analyses of transit or other modes. Transit agencies must, by regulation, conduct equity analyses at the operational or street project level. A sound, regional multimodal equity analysis not only captures the benefits of transit, but also other actions that support transit use, such as improving pedestrian access to transit station areas, or pricing congestion to support transit use, as well as potential tradeoffs between investing in transit and in other modes. We do identify specific steps that MPOs can take to ensure that their equity analyses capture the benefits and burdens of transit, and anticipate focusing on these steps further as the project progresses. We selected 25 MPOs representing metropolitan areas of different sizes distributed throughout the United States, and we reviewed the equity analyses relating to their MTPs and TIPs, as well as equity analyses of other plans and projects and supplementary documents about the equity analysis process, such as Title VI programs. We also reviewed research, guidance, and reports on Title VI and EJ compliance, as well as examples of equity analyses from non-MPO transportation agencies and advocacy groups that can serve as potential sources of best practices for MPOs. We organized our discussion into four key steps of an equity analysis: 1. Demographic analysis: MPOs use demographic data to identify communities of concern (COCs)—those with high proportions of low-income households, minorities, and other traditionally underrepresented populations. 2. Needs assessment: MPOs conduct outreach and collect data to understand the needs of COCs. 3. Impact analysis: MPOs assess plans and projects to determine whether benefits and burdens are equitably distributed between COCs and the population in general. 4. Taking action: If the impact analysis reveals that a plan or project has a disproportionate impact on underserved communities, MPOs must examine alternatives that mitigate these impacts. The following section summarizes our findings with respect to the four steps listed above.

Literature Review A-3 Summary of Findings Table A-1 summarizes the key components of each step in equity analysis and the state of the practice among the MPOs reviewed. Table A-1. Summary of key components and state of the practice for each equity analysis step. Step Components State of the Practice Demographic Analysis Collecting data on relevant population groups Defining communities of concern (COCs) using thresholds All MPOs reviewed consider low-income and minority groups in their demographic analysis, and many include other groups as well. Most MPOs take a similar approach to using demographic data to identify concentrations of traditionally underrepresented population groups. There is less consistency with respect to how MPOs define COCs. MPOs use different thresholds to define COCs and some weight or aggregate data on different population groups to define a more focused set of COCs. Needs Assessment Public engagement with COCs Mapping and analyzing needs in COCs Almost all MPOs reviewed documented their public outreach efforts. Some MPOs map existing needs in COCs. Some tools are available to support these analyses. Few MPOs document how outreach or analysis informs their MTP/TIP or the subsequent steps in their equity analysis. Impact Analysis Selecting indicators Comparing impacts between COCs and other communities Determining whether plans result in disproportionate impacts Most MPOs analyze output measures in their equity analyses; some also analyze outcomes. The MPOs reviewed had not identified a disparate impact in their MTP/TIP, but the reason for this ubiquitous lack of findings is unclear. If an MPO adjusts its processes to mitigate potential impacts before adopting the MTP/TIP, it would be helpful to document that process in order to avoid the implication that no potential impacts were ever identified. MPOs use several different methods when comparing results that vary in format, comparison population, and baseline population. Taking Action Determining that disparate impacts are unavoidable and/or identifying mitigation measures Taking proactive steps to integrate equity throughout the planning process We found no examples of MPOs identifying mitigation measures. Some MPOs are taking proactive approaches, including prioritizing equity in project selection, creating equity advisory committees or community liaisons, supporting stakeholders in equity analyses, and improving public participation. The research statement for this project focused on the indicators that MPOs use in their equity analyses. However, an overarching finding from our literature review is that conducting a successful equity analysis requires a holistic approach that considers not only which

A-4 Equity Analysis in Regional Transportation Planning Processes indicators are used but also which communities are the focus of the equity analysis, how these communities’ needs are identified and addressed, and how the results of analyses inform decision making. MPOs that select best-practice indicators without considering these other steps may not provide adequate information to support a determination of disparate impact and may run increased risk of complaints or lawsuits. Table A-2 summarizes the key issues that we identified through our literature review, as well as potential best practices to address these issues. Table A-2. Summary of key issues and potential best practices. Step Key Issue Potential Best Practices Demographic Analysis Some MPOs are not meeting Title VI and EJ requirements in their demographic analyses. Ensure that populations with limited English proficiency (LEP) are included in equity analyses. If using indices to define COCs, structure them so that all areas with significant concentrations of low-income, minority, and LEP populations are always included as COCs. It can be challenging to create a demographic analysis that is both inclusive and meaningful. Consider the characteristics and needs of specific population groups that reflect the region’s characteristics when defining thresholds and indices. Needs Assessment Few MPOs document how the needs that they identify through outreach and analysis are addressed in their plan. Document not just the process of outreach, but also the findings and how these findings support the analysis and the broader decision-making process, including funding decisions. Map current conditions and needs in COCs, and identify projects or performance measures based on results. Impact Analysis Many MPOs are analyzing either outputs or outcomes in their equity analysis instead of doing both. Include indicators that capture both the outputs of a plan (i.e., the distribution of projects or funding) and the outcomes (i.e., long-term impacts on transportation behavior and access). Some analyses do not account for the fact that different project types produce different benefits and burdens for COCs. Break projects/funding out by type/mode when analyzing outputs. Use performance measures that capture travel by all modes when analyzing outcomes. It is unclear what constitutes a disparate impact. Adopt a policy defining disparate impact and disproportionate burden and create associated guidance on how to identify them. With respect to the last step, taking action, we found that very few of the MPOs within the sample identified disparate impacts, so it is difficult to characterize the state of the practice with regard to the final step.

Literature Review A-5 Candidates for Follow-up Interviews As a follow-up to the literature review task, the project team planned to interview up to 15 transportation agencies to better understand their approach to regional equity analysis and the opportunities and challenges they see to improving their analyses. We proposed to start by interviewing contacts from 10 MPOs that represented metropolitan areas of varying sizes across Table A-3. Recommended interviewees. Agency (MPO) State Population Rationale for Selecting Atlanta Regional Commission (ARC) GA 4,818,000 Conducted nuanced discussion of project distribution, used best-practice outcome measures, held workshop series on equity. Denver Regional Council of Governments (DRCOG) CO 2,827,082 Adopted equity policy, educates COC members on engagement via Transit Alliance Citizens’ Academy. Madison Area Transportation Planning Board (MATPB) WI 434,438 Small MPO with nuanced discussion of project impacts on equity and measures to mitigate disparities. Memphis Urban Area MPO TN, MS 1,077,697 Medium-sized MPO that conducted transit gap analysis, incorporated equity into project selection criteria, and engaged COCs in analysis. Metropolitan Area Planning Agency (MAPA) NE, IA 285,407 Small MPO that used interesting output/outcome indicators and incorporated equity into project selection criteria. Metropolitan Transportation Commission (MTC)* CA 7,150,828 Conducted thorough outcome-based equity analysis, expressed discontent with disparate impact standard, convened Regional Equity Working Group, developed grant-funded plan focused on regional equity. Mid-America Regional Council (MARC) MO, KS 1,895,535 Medium-sized MPO that conducted detailed analysis of funding distribution and safety. Mid-Ohio Regional Planning Commission (MORPC) OH 1,426,183 Medium-sized MPO that used innovative approaches to displaying results of the equity analysis. Oregon Metro* OR 1,499,844 Currently updating equity analysis with input from a stakeholder committee. Wichita Area MPO KS 518,985 Small MPO that just adopted a comprehensive EJ program. *The MTC serves the San Francisco Bay Area in California and the Oregon Metro serves Portland, Oregon, and the surrounding area. The team will determine how best to fill the remaining five interview slots after conducting the initial 10 interviews, drawing either on agencies recommended by interviewees or potential the United States, each of which demonstrated some types of best practices and/or innovative approaches during our literature review. Table A-3 lists these MPOs and our rationale for selecting them.

A-6 Equity Analysis in Regional Transportation Planning Processes alternate interviewees identified during our research. The final section of this report contains additional information on alternates, as well as the interview questionnaire. Structure of This Report The next section discusses our process for conducting the literature review, and the following section gives a general overview of Title VI and EJ guidance and regulations. Next, four sections describe in depth the relevant regulations, state of the practice, and key issues with respect to each of the steps listed above. The final section of this appendix describes the research team’s proposed next steps for interviewing MPOs to collect in-depth information about how they conduct equity analyses. The report also contains a summary of MPO MTPs and TIPs we reviewed and a list of the other sources that we drew upon in our review. Review Process We began by creating a list of 60 diverse MPOs based on our knowledge of performance-based Small (Under 200,000) Medium (200,000–999,999) Large (1,000,000–2,999,999) Very Large (3,000,000–18,000,000) Figure A-1. MPOs included in the literature review. planning (Grant et al. 2013). From this list, we selected 25 MPOs representing regions across the United States with a range of population sizes. Population size served as a rough proxy for differing levels of staff and technical capacity and service area types (e.g., small urban, large metropolitan). See Figure A-1 for a map of the MPOs surveyed and Table A-4 for a list of these MPOs and the populations of the regions they serve.

Literature Review A-7 Table A-4. List of MPOs reviewed. Agency (MPO) Service Population Atlanta Regional Commission (ARC) 4,818,000 Baltimore Regional Transportation Board 2,685,000 Bismarck-Mandan MPO 100,000 Charlotte County-Punta Gorda MPO 161,000 Chicago Metropolitan Agency for Planning (CMAP) 8,455,000 Chittenden County RPC 157,000 Community Planning Association of Southwest Idaho 581,325 Delaware Valley Regional Planning Commission (DVRPC) 5,626,318 Denver Regional Council of Governments (DRCOG) 2,827,082 East-West Gateway Council of Governments (EWGCOG) 2,571,327 Madison Area Transportation Planning Board (MATPB) 434,438 Memphis Urban Area MPO 1,077,697 Metropolitan Area Planning Agency (MAPA) 285,407 Metropolitan Council of the Twin Cities (Met Council)* 2,906,684 Metropolitan Transportation Commission (MTC)* 7,150,828 Mid-America Regional Council (MARC) 1,895,535 Mid-Ohio Regional Planning Commission (MORPC) 1,426,183 Nashville Area MPO 1,494,356 North Central Texas Council of Governments (NCTCOG) 6,417,630 Oregon Metro* 1,499,844 Puget Sound Regional Council (PSRC) 3,690,866 Rogue Valley MPO (RVMPO)* 167,859 Southern California Association of Governments (SCAG) 18,051,203 Valdosta-Lowndes MPO 79,176 Wichita Area MPO 518,985 *The Met Council serves the Minneapolis–Saint Paul region in Minnesota; the MTC serves the San Francisco Bay Area in California; the Oregon Metro serves Portland, Oregon, and the surrounding area; and the RVMPO serves the urbanized areas of Jackson County, Oregon. For the selected MPOs, reviewers scanned the TIPs and MTPs and related materials for equity analyses, and they gathered information on the demographic indicators used, methods for measuring impacts, and whether a disproportionate impact was found. The template used to collect this information and a table summarizing the results appear under the heading “MPO Survey Template and Summary of Results” at the end of this appendix. This section summarizes the MTPs and TIPs that we reviewed in the course of this project, including the size of the MPO region, the type of plan, the demographic factors considered, the

A-8 Equity Analysis in Regional Transportation Planning Processes indicators used to assess impacts, the tools and data used to assess these indicators, and how the indicator results were presented. Other non-MTP/TIP resources from MPOs are discussed in the next section. Some MPOs also have Title VI, public participation, or LEP plans. We also reviewed selected Title VI, LEP plans, and public participation plans. Our review also covered several other resources: Title VI and EJ guidance from FHWA, FTA, and EPA; Case law related to Title VI; Guidance and analyses of transportation equity by advocacy groups; Research and reports assessing the state of the practice with respect to transportation equity; and Fair Housing Equity Assessments (FHEA) prepared by MPOs that received transportation- related HUD-DOT Sustainable Communities Regional Planning Grants. FHEAs were required to have information on both housing and transportation equity issues, and took a more comprehensive look at equity than transportation agency equity analyses typically do. The “Resources Reviewed” section of this document provides a summary of all of the MPO MTP/TIPs reviewed and an annotated bibliography of the full list of resources reviewed. Challenges in Interpreting Regulations and Guidance Lack of specificity: The FTA Title VI and EJ circulars, which are the most detailed sources available on conducting equity analyses, do not contain a high level of detail on how MPOs should conduct these analyses. The circulars do include a significant amount of detail on analyzing individual transit projects, particularly service or fare changes, specifying contents of demographic maps, defining COCs, discussing metrics and thresholds that can be used to identify disparate impacts, and providing examples from transit agency analyses, but not all of this guidance is applicable to MPOs. For example, the Title VI Circular discusses cases in which transit ridership or service population would be appropriate metrics to use when analyzing different types of transit service changes. However, regional plans include multiple projects and are multimodal, so they typically use a single set of performance measures that apply across different project types. Overlapping and sometimes inconsistent review and guidance: Unlike the FTA, the FHWA requires that Title VI programs include EJ compliance elements. This has been an issue of discussion among recipients who receive both FHWA and FTA funds, including MPOs, because it can make it difficult to submit a single program that satisfies both sets of requirements. Both the FTA and the FHWA have been working to develop a streamlined process. Furthermore, state DOTs are responsible for monitoring the Title VI compliance of the MPO for activities for which the MPO is a sub-recipient of state-allocated FTA funds, and state agencies may have slightly different processes that reflect additional requirements. MPOs play multiple roles: A Regional Transportation Plan (RTP) or a TIP typically deals with many different federal funding sources. For example, MPOs may be direct recipients of some FTA funds (i.e., responsible for operating public transportation and leading Title VI analysis of public transportation projects), or they may be designated or primary recipients for other sources (i.e., responsible for documenting that funding is equitably distributed and for monitoring sub-recipients for Title VI compliance). It can be challenging to keep these overlapping requirements straight and meet all of them in the context of a comprehensive MTP or TIP. MPOs need to support stakeholders’ equity analyses: Under Title VI, MPOs are required to support member agencies’ equity analyses as requested, and member agencies may need different information and guidance depending upon the types of projects they pursue. For instance, service and fare equity analyses under Title VI require transit providers to analyze ridership survey data and do detailed mapping of transit routes (4702.1B, Chap. IV). Though MPOs may not directly

Literature Review A-9 operate transit, more detailed analysis of planned transit routes and data in a regional equity analysis can help support public transportation providers in their region. Similar consideration might be given to helping transit agencies or local transportation agencies prepare for the EJ component of National Environmental Policy Act (NEPA) analysis for major transportation projects. The FTA requires transit providers to analyze the equity impacts of siting facilities such as operations centers and administrative facilities, but has provided limited information on how to do so. MPOs may need to interpret this limited guidance or help stakeholders do so. Because of these challenges, MPOs may struggle to understand what is required of a regional equity analysis. As we discuss below, MPO practice varies widely. The aim of this project is to clarify some of the choices that MPOs face and identify best practices to provide clearer direction. Demographic Analysis In the first step of an equity analysis, MPOs use demographic data to identify communities with high proportions of low-income households, minorities, and other traditionally underrepresented populations. They typically define a set of neighborhoods that have significant concentrations of one or more of these groups. These communities, which we generally refer to in this document as communities of concern (COCs), become the focus of a regional equity analysis. Guidance produced by the FTA and other federal agencies includes extensive guidance on what data sources to use and recommendations for how to apply these data to identify COCs. Conducting a demographic analysis generally involves two steps: defining and collecting data on the relevant population groups, and defining COCs based on this data. It is important to note that the term communities of concern was dropped from use by the study team after the completion of this literature review in 2017. The TCRP H-54 panel determined that the phrase carried unnecessary implications, and was not comfortable with continuing to endorse its use. The subsequent reports (Volumes 1 and 2 of TCRP Research Report 214) rely upon value- neutral language such as required populations or specifically refer to the categories named in regulations, such as low-income populations and minority populations. Relevant Population Groups Relevant Regulations and Guidance The protected categories of individuals under Title VI differ but overlap with those protected under E.O. 12898. Title VI protects on the basis of “race, color, and national origin (including individuals with limited English proficiency),” which overlaps with the order’s protection of minorities.1 E.O. 12898 adds protection of low-income2 individuals. FHWA’s Title VI program incorporates the protected classes of both Title VI and E.O. 12898 but also extends coverage to offer protection on the basis of disability, age, and sex (FHWA 2015) to incorporate other statutory protections.3 The FTA’s circulars on Title VI and EJ both require MPOs begin their analysis with an identification of the relevant COCs, and the EJ Circular gives detailed recommendations on how to “create a residential demographic profile,” which are summarized here (FTA 2012b): Identify data sources. Determine the appropriate scale, which should include the entire population affected by the plan or project, not just those adjacent to a project location. For MTPs, they recommend a system-wide evaluation. For TIPs, the geographic area may be smaller and can be the same scope as would be used in a NEPA process.

A-10 Equity Analysis in Regional Transportation Planning Processes Determine whether an EJ population is present. This determination should not be solely based on population size because there can be a disproportionate impact even when the COC is small in population. Rather, the analysis will need to compare impacts among different population groups. Identification of the COCs might require community outreach to determine appropriate areas and communities to include in the analysis. State of the Practice All of the MPOs we reviewed examined minority and low-income households (and/or households in poverty). Table A-5 summarizes other population groups included in various MPO analyses for MTPs, TIPs, or other key reports such as Title VI or Coordinated Human Services Transportation plans. Table A-5. Population groups (other than minority and low-income) included in MPO equity analyses. Population Group MPOs Including this Group in Their Analysis LEP* Baltimore Regional Transportation Board, DVRPC, Memphis, Met Council, MTC, Nashville, NCTCOG, Oregon Metro, SCAG (10) Persons with a disability (or mobility limitations)** Baltimore Regional Transportation Board, DVRPC, Met Council, MTC, MARC, Mid-Ohio, Nashville, NCTCOG, PSRC, SCAG (10) Zero-vehicle households Baltimore Regional Transportation Board, DVRPC, Madison, MAPA, MTC, MARC, Mid-Ohio, Nashville, NCTCOG, SCAG (10) Older adults** Baltimore Regional Transportation Board, DVRPC, MTC, MARC, Mid-Ohio, Nashville, Oregon Metro, PSRC, SCAG (9) Female head of household DVRPC, Nashville, NCTCOG Young persons Oregon Metro, SCAG Single-parent households MTC Rent-burdened households MTC Veterans MARC Foreign-born population SCAG Individuals w/o H.S. diploma SCAG * Required under Title VI guidance ** Included in FHWA guidance MPOs that do not consider the population groups noted as required or included in Table A-5 run the risk of non-compliance. All equity analyses we reviewed used American Community Survey (ACS) data to identify these groups, and MPOs were generally consistent in how they defined these groups. One notable exception was “low-income,” which was defined either as households earning below the regional median income or individuals in poverty status. The former definition is more inclusive than the latter, given that poverty status is defined based on national data, and both incomes and cost of living are usually higher than the nationwide average in metropolitan areas. A broader question arises with respect to how many different characteristics to consider in an equity analysis. Including a greater number of population groups can give MPOs a broader

Literature Review A-11 perspective on equity issues, but it can also make an analysis much more complex to conduct and interpret. MPOs’ approach to defining COCs based on the concentration of different population groups also affects the inclusiveness and complexity of the analysis, as we discuss below. Defining COCs Relevant Regulations and Guidance Title VI and EJ guidance is clear on which demographic characteristics must be considered in an equity analysis, but it is less clear on how to identify areas with significant populations of these groups. The FHWA and U.S. DOT EJ Orders define a minority or low-income population as “any readily identifiable group of minority and/or low-income persons who live in geographic proximity, and, if circumstances warrant, geographically dispersed/transient persons of those groups (such as migrant workers, homeless persons, or Native Americans) who will be similarly affected by a proposed FHWA/DOT program, policy, or activity” (FHWA 2015, FTA 2012b). The FTA EJ Circular’s instructions for determining the presence of an EJ population emphasize that the particular size of a given population is not the sole determining factor, and recommends identifying the relevant populations through community outreach (FTA 2012b). State of the Practice Setting Thresholds Most MPOs geographically define COCs with significant concentrations of the population groups discussed above in order to analyze impacts on COCs in their equity analysis. Nearly all of the MPO plans that we reviewed followed the same basic process for doing so: collecting data on different population groups at a fine scale (census tract, block group, or traffic analysis zone [TAZ]), setting a numerical threshold for what constitutes a “significant” concentration of each population group, and then identifying the areas where the percentage of people or households in a given population group exceeded the threshold. Not all MPOs whose plans we reviewed explained their basis for setting thresholds,4 but of those that did, most used the regional average. Table A-6 summarizes the different methods for setting thresholds used by the MPOs reviewed that documented their process. Table A-6. Thresholds used in defining COCs. Threshold definition MPOs using this threshold Regional average Baltimore Regional Transportation Board, DVRPC, DRCOG, Memphis, MARC, MORPC, Nashville, NCTCOG, Oregon Metro (9) Standard deviations ARC, MAPA, MTC Regional median Baltimore Regional Transportation Board, CMAP 1.5 times the regional average Madison Percentile groupings Bismarck-Mandan MPO, MORPC

A-12 Equity Analysis in Regional Transportation Planning Processes Aggregating or Weighting Population Groups Setting and applying thresholds allows MPOs to identify all areas with significant concentrations of each population group that they are considering. Some stop after that step and use those areas as COCs in the further steps of their equity analysis. However, this approach can leave MPOs with multiple sets of COCs, or create a situation where COCs cover the majority of the region, as shown in Figure A-2. Source: Memphis Urban Area MPO (2016), Figure 4 Figure A-2. Map of COCs considered in Memphis Urban Area MPO’s FY 2017–2020 TIP. MPOs can take two approaches to focus their equity analysis or target areas with greater needs: 1. Weighting: Some MPOs further focus their analysis on COCs with higher concentrations and/or a greater number of population groups. This can be done by using the non-binary options for defining thresholds noted in Table A-6, such as standard deviations or percentile groupings, to rate the concentration of population groups, or by rating areas based on the number of population groups that exceed a threshold. 2. Indexing: Some MPOs define COCs as areas that contain significant concentrations of a certain number of the population groups considered. Table A-7 summarizes examples of MPOs that used one or both of these approaches.

Literature Review A-13 Table A-7. Examples of MPOs using weighting or indexing to define COCs. MPO Name of Method Description ARC Equitable Target Area Index Tracts ranked by standard deviations for poverty and minority to determine areas of greatest concern Baltimore Regional Transportation Board Vulnerable Population Index Tracts ranked from 0 (having no COCs above regional concentration) to 7 (having 7 COCs5 above regional concentration) DVRPC Degrees of Disadvantage or Indicators of Potential Disadvantage Tracts ranked from 0 (having no COCs above regional concentration) to 7 (having 7 COCs6 above regional concentration) MTC COCs Tracts with significant concentrations of: 1. Low-income AND minority OR 2. Any 4 or more of vulnerable populations7 PSRC Aggregate Population of Interest Analysis Tracts ranked depending on how many of the COCs it qualifies for (0–4 out of poverty, minority, elderly, or disabled) SCAG COCs Tracts falling in the upper one-third in the region for concentrations of minority and low-income households In its Equitable Target Area (ETA) Index, the ARC demonstrates the steps by which an MPO can apply indexing (Figure A-3). The ARC uses two steps to identify the areas at the most disadvantage: • Identify 1, 2, and 3 standard deviations to describe tracts’ concentrations of poverty or minority populations, and • Combine the poverty and minority scores to develop an index of non-ETA, medium, high, and very high. Poverty Category Race Category ETA Index 1 1 Very High 2 High 3 2 1 Medium 2 3 3 1 Non-ETA 2 Source: Reproduced from ARC (2018): The Atlanta Region’s Plan— Transportation, Appendix J, “Equitable Target Area Methodology” Figure A-3. ARC ETA Index categories. The ETA allows the ARC to focus on COCs that face more severe disadvantages when a more targeted analysis is warranted, as shown in Figure A-3. Areas rated as medium in the ETA Index contain 22% of ARC’s population, but areas with the very highest disadvantage have just under 5% of the population.

A-14 Equity Analysis in Regional Transportation Planning Processes Source: ARC (2018) Figure A-4. Percentage of the Atlanta region’s population in each ETA category. Summary of Findings All MPOs reviewed consider low-income and minority groups in their demographic analyses, and many include other groups as well. Most MPOs take a similar approach to using demographic data to identify concentrations of traditionally underrepresented population groups. There is less consistency with respect to how MPOs define COCs. MPOs use differing thresholds to identify areas with significant concentrations of underserved persons, though regional averages are commonly used. Some MPOs weight or aggregate data about different population groups to focus their analyses on COCs with the greatest need. Key Issues Some MPOs may be not meeting Title VI and EJ requirements in their demographic analyses. We found instances of MPOs that did not include LEP populations in their MTP/TIP analyses, though they may have addressed LEP populations in a separate plan. MPOs that use indices to define COCs run the risk of inadequately accounting for key population groups if indices are not structured so that areas with high concentrations of required populations (low-income, minority, or LEP) are always included as COCs. It can be challenging to create a demographic analysis that is both inclusive and meaningful. An inclusive analysis covers a larger number of population groups and/or uses lower thresholds to define significant concentrations when identifying COCs. A meaningful analysis focuses on a more limited number of COCs with the greatest need to support a clearer determination of disparate impact. Our review suggests that defining COCs such that they cover the majority of a region does not support a meaningful analysis. MPOs need to holistically consider which population groups they include and the thresholds and indices they use when defining COCs to make sure that they include all relevant population groups without designating the majority of their region as a COC. Needs Assessment The FTA requires that MPOs’ Title VI programs include a description of procedures for identifying and considering the mobility needs of minorities in their planning processes. We see MPOs achieving this in two ways: (1) conducting public engagement to gain insights on their equity needs (e.g., institutional barriers) and (2) mapping and analyzing data to understand needs in COCs. These activities can help with determining what measures are most appropriate for use

Literature Review A-15 in assessing disparate impacts and can also help identify strategies to improve outcomes for COCs. This section discusses both approaches to public engagement. Public Engagement Relevant Regulations and Guidance Many of the resources we reviewed, including guidance from both FHWA and FTA, emphasize the need for public participation to conduct outreach to and identify the needs of COCs. In general, guidance recommends that MPOs engage early and often with COCs throughout the planning process. With respect to equity analyses, public engagement is a critical component in notifying disadvantaged communities about the plan or project in question, but it also provides a way for MPOs to create equity analyses that are meaningful to the COCs that these analyses are intended to benefit. Equity indicators and analyses are attempting to evaluate something inherently difficult to measure, and many subjective decisions will go into developing the assumptions and methodology. Engaging with local stakeholders early in the process and throughout the process can help determine reasonable thresholds and prioritize what characteristics and criteria are included in each measurement, which will help establish some legitimacy for the subjective elements of the process. State of the Practice Our literature review focused on documentation of public engagement contained within MTP/TIP equity analyses; we did not conduct a comprehensive review of MPO public participation plans that more generally outline outreach approaches. Many MPOs describe in detail how they collected information on the needs of disadvantaged communities, for example by documenting the number of meetings held in COCs or practices that were used to engage COCs (e.g., providing materials in different languages, holding meetings outside of working hours). Examples include: The Memphis Urban Area MPO engaged with COCs in the preparation of the MTP by conducting meetings in collaboration with community partners; defining the meetings’ goals to educate COCs about the role of the MPO and MTP and to discuss issues unique to COC populations; and soliciting feedback through online and paper surveys (Memphis Urban Area MPO 2016a). The Metropolitan Council of the Twin Cities (Met Council) determined that Somali, Spanish, and Hmong were the most common non-English languages used in their region. To better engage these LEP populations, the Met Council hired staff speaking those languages, translated materials into each language, and worked with representatives of each LEP community to distribute information verbally (Met Council 2016). The Baltimore Metropolitan Council (the host agency for the Baltimore Regional Transportation Board, which is the region’s MPO) “uses its demographic analysis to identify areas of concern to focus outreach efforts, including community festivals, a parking day (where parking lots are used as a place to discuss transportation issues), and other locations through the city such as fresh food drops, food markets, malls, and train stations” (Lane et al. 2016). However, few MPOs described what they learned or how they incorporated these lessons into their MTP/TIP or the associated equity analyses. Examples of MPOs that more fully described how they used public engagement to identify needs include:

A-16 Equity Analysis in Regional Transportation Planning Processes In California, San Francisco’s MTC created the Regional Equity Working Group (REWG), which is made up of members of the Regional Advisory Working Group (representatives of local and regional governing agencies) and MTC’s Policy Advisory Committee. The Policy Advisory Committee consists of 27 area residents, 9 appointed by county commissioners representing communities of color and EJ and low-income issues, and another 9 appointed to represent seniors and persons with disabilities (MTC 2016). The REWG identified priority equity concerns, recommended equity performance measures, and provided input on the definition of COCs and the method of analysis (MTC 2013). In Oregon, the Rogue Valley MPO (RVMPO) conducted a Transportation Needs Assessment for Traditionally Underserved Populations (low-income, minority, young persons, and senior populations). To reach these populations, they asked 22 organizations (including the school district, housing authority, and department of human services) serving them to distribute a five-question survey that asked for their demographic information and to identify barriers to their transportation. Responders fully represented the desired demographics. Based on the responses, RVMPO determined that lack of access to public transportation was a major impediment and that it would be necessary to expand transit service both geographically and temporally to assist these populations (RVMPO 2014a). In Columbus, Ohio, an EJ committee identified equity issues that were not initially a focus for the MPO, including impacts from heavy trucks, safety and security, and the physical condition of infrastructure (Suhrbier et al. 2002). Mapping and Analyzing Needs In addition to engaging COCs, MPOs can analyze and map data to learn about the needs of COCs. This generally involves overlaying data on equity indicators with the location of COCs to determine which issues are particularly prevalent in COCs. The indicators used in assessing needs are different from those that are used as performance measures in the next step, impact analysis, in two ways. First, these indicators can be broader in scope than RTP/TIP performance measures, capturing issues such as housing costs or access to healthy food that are of high importance to COCs. These issues can be difficult to address via transportation strategies alone, but examining these indicators can still help MPOs identify strategies to improve conditions in COCs or qualitatively relate RTP/TIP performance measures to the issues that matter most to COCs. Second, because needs analysis involves measuring current conditions rather than estimating future impacts, MPOs can collect data on indicators in the context of a needs assessment that they may not be able to model in an impact analysis. These needs assessment measures can be used to identify gaps in regional equity, and MPOs can then add strategies to their plans to address these gaps or include performance measures that capture the extent to which these gaps have been closed. In the past several years, several tools have become available to help identify needs in COCs. These include resources from the FHWA, the Brookings Institution, other transportation research institutions; national data tools such as the Center for Neighborhood Technology’s (CNT) Housing + Transportation Affordability Index (CNT 2017), EPA’s Environmental Justice Screening and Mapping Tool (EJSCREEN) (U.S. EPA 2017), and the PolicyLink National Equity Atlas (PolicyLink 2016); and advocacy-led Regional Equity Atlases for Portland (1000 Friends of Oregon n.d.), Los Angeles (Reconnecting America 2013), and Denver (Reconnecting America 2012). Measures for assessing community needs include measures relating to accessibility, transportation options, affordability, and health and safety. Below we discuss data resources that are available to support measures in each category and identify examples from MPO practice.

Literature Review A-17 Accessibility COCs often do not have equal access to destinations or travel times as non-COCs. Access to jobs is the most common measure of accessibility, but some resources take a deeper look at modes or jobs that might be a better fit for COC members. For example, research from Brookings analyzes accessibility to low-skill and middle-skill industries by transit, and the Denver Regional Equity Atlas looks at access to jobs requiring less than a college degree. Some resources use more traditional measures of mobility as proxies for measuring accessibility; for example, the National Equity Atlas includes information such as average commute times by race or ethnicity. Long commute times suggest a lack of nearby employment opportunities. Several MPOs analyze accessibility to jobs and other destinations for COCs by measuring travel times, buffers around transit stops, or how many destinations are accessible by transit within a given travel time. Two examples are: The Charlotte County-Punta Gorda MPO, which has a Community Facilities Inventory that identifies major trip generators and community-oriented employers, such as parks, libraries, schools, and hospitals (CCPGMPO 2015a); and The ARC, which overlays its maps of COCs with travel-time buffers around services: 60-minute access to grade schools, higher education, hospitals, and libraries, and 30-minute access to grocery stores (ARC 2015). Some MPOs are already using these assessments to identify gaps to fill and how to fill them: The Memphis Urban Area MPO conducted a transit gap analysis focused on COC areas where travel times by transit far exceeded travel times by automobile. The agency analyzed how transit routes and extensions in the MTP would improve the transit travel times in those areas, and they found that there were several gaps that the currently identified projects didn’t bridge. The MPO then explored additional connections that could improve access from these COCs to major employment areas (Memphis Urban Area MPO 2016). Madison’s MTP calculates in-vehicle transit time to a sample of destinations. It recognizes that the transit travel time is significantly longer than by solo driving, and it recommends improved service for COCs, including bus rapid transit (BRT) and a low-fare express bus to the periphery when rebalancing of vehicles is needed (MATPB 2012). Many MPOs are capable of modeling accessibility to jobs under future scenarios, and include accessibility-related performance measures in their impact analyses as well. However, land use decisions about where to locate homes relative to jobs and other destinations have a significant impact on accessibility, and some MPOs may feel that they have limited ability to influence accessibility because they do not have land use authority. Transportation Options COCs are likely to have more limited transportation options available than non-COCs, and MPOs can identify these gaps. This includes identifying where zero-car households live, measuring mode shares by geography, and assessing how accessible and usable transit or active transportation facilities are. These measures are commonly used in advocacy data sources on equity; for example the Portland [Oregon], Los Angeles, and Denver Regional Equity Atlases all assessed active transportation mode shares, and some also included measures of suitability for walking or bicycling. A few of the MPOs in our review looked at current transportation options in COCs. The ARC (2016) and EWGCOG (2015a) each mapped ½-mile or 1-mile buffers around transit stops overlaid with their COCs to identify which COCs lacked access to transit. Many MPOs are capable of analyzing access to transportation options under future scenarios, and include related performance measures in their impact analyses.

A-18 Equity Analysis in Regional Transportation Planning Processes Affordability Some resources attempt to compare the full costs of living in a given location. Most prominent is the Housing and Transportation Affordability Index (H+T Index) developed by the Center for Neighborhood Technology (CNT) and now hosted by the U.S. Department of Housing and Urban Development (HUD). MPOs that received Sustainable Communities grants conduct fair housing and equity assessments (FHEAs) that include collecting data on housing and transportation costs for COCs. However, few MPOs are able to analyze future housing or transportation affordability in their impact analyses because doing so involves complex modeling. Health and Safety Many resources also look at existing health and safety conditions in COCs. For example, the Portland Regional Equity Atlas provides data on vehicle collisions and curb cuts at transit stops. The U.S. EPA’s Environmental Justice Screening and Mapping Tool (EJSCREEN) displays a number of environmental indicators, such as the concentrations of various air pollutants and proximity to different types of polluters, as well as indices that measure exposure to environmental risks among low-income and minority groups (U.S. EPA 2017). Some regional equity atlases track health outcomes such as rates of obesity, pre-term births, asthma, diabetes, and cardiovascular disease (1000 Friends of Oregon n.d.). All of these indicators illuminate how the built environment affects health, but few MPOs are able to estimate the impact of a plan or project on health and safety. Summary of Findings Almost all of the MPOs reviewed documented their public outreach efforts. Some MPOs map existing needs in COCs. Several tools are available to support these analyses. Key Issues Few MPOs document how the needs that they identify through outreach and analysis are addressed in their plan. Not only does this create a risk of non-compliance with Title VI and EJ, but it also creates a risk that community members may feel their participation in a plan is not meaningful if their input is not addressed. Impact Analysis During this step, MPOs assess plans and projects to determine whether benefits and burdens are equitably distributed between COCs and the population in general. This assessment typically involves selecting and analyzing performance measures, comparing results between COCs and other communities, and determining whether there is a disparate impact on COCs. Of the 25 MPOs for whom TIPs and MTPs were reviewed, 21 performed some kind of assessment of impacts of the TIP and/or MTP.

Literature Review A-19 Indicators for Measuring Impacts Relevant Regulations and Guidance MPOs need to evaluate negative and positive effects of their programs and plans and “the totality of significant individual or cumulative human health or environmental effects” (E.O. 12898). A comprehensive analysis will consider short-, medium-, and long-term benefits and burdens, potential imbalances in benefits and burdens, and “the cumulative effect of a decision in combination with past actions and all other reasonably foreseeable future actions” (FHWA 2015). These adverse effects or impacts do not just include the negative impacts but also the “denial of, reduction in, or significant delay in the receipt of benefits” (E.O. 12898). Title VI and EJ guidance recommends that MPOs analyze both the outputs of a plan (i.e., the distribution of projects or funding) and the outcomes (i.e., long-term impacts on transportation behavior and access) to determine whether COCs receive an equitable share of benefits and burdens. The federal regulations and guidance recommend a broad range of outcomes to consider in the EJ and Title VI analyses, but do not provide specific guidance on which to use. Benefits and burdens named in the U.S. DOT EJ Order, FTA Title VI Circular, and FHWA EJ Guidance include: Burdens Bodily harm Pollution of air, water, or soil Destruction or disruption of Man-made or natural resources Aesthetic values Community cohesion or economic vitality, including access to schools, parks, medical facilities, and religious institutions Public and private facilities and services Vibration and noise Adverse employment effects Displacement of persons or businesses Traffic congestion Reductions in parking or access to transit A denial of, reduction in, or delay in receipt of benefits Benefits Reductions in travel times Reductions in congestion Improvements in safety outcomes Increases in options for travel Asset management activities The FTA EJ Circular describes a process for determining what impacts to include rather than being prescriptive about which to include. Because opinions can vary as to what is a burden or a benefit, the circular recommends asking the affected populations identify adverse effects and benefits.

A-20 Equity Analysis in Regional Transportation Planning Processes State of the Practice In the TIPs and MTPs we reviewed, we found most MPOs measured their outputs, such as the distribution of projects or costs. Many (but not all) MPOs also looked at how performance outcomes varied across COC and non-COCs across different scenarios (see Table A-8). Table A-8. Indicators Used in TIPs and MTPs. Indicators Used MPOs Using Project Distribution ARC, Baltimore Regional Transportation Board, CMAP, COMPASS, DVRPC, DRCOG, MATPB, MARC, MORPC, Nashville, Oregon Metro, PSRC, Wichita (13) $ Cost Distribution ARC, MAPA, MARC, MORPC, Oregon Metro, SCAG (6) % Cost Distribution MAPA, MORPC Outcomes (e.g., jobs and destinations within 30-min. drive or 60-min. transit trip) Baltimore Regional Transportation Board, CMAP, DRCOG, Met Council, MTC, MARC, MORPC, NCTCOG, SCAG (9) Among the MPOs we reviewed, the most common approach was to map the distribution of projects and/or funding relative to CoCs and determine whether CoCs receive an equitable share of funding. These analyses typically assumed that all projects produce equal benefits in the communities where they are located, which is not necessarily true. For example, a new transit line will benefit people who do not own automobiles, whereas a new freeway could negatively impact the community in which it is located by fragmenting the built environment and exposing residents to pollution while producing benefits for drivers from other communities who travel along the freeway. As the ARC noted in its MTP: “the mere expenditure of funds on transportation projects within the physical boundaries of a community is certainly not a perfect indicator of how well the plan addresses needs and balances burdens and benefits fairly across the Region.” Some MPOs, such as the Baltimore Regional Transportation Board and the DRCOG, accounted for this variation by breaking out projects by mode or category to separate projects that are likely to benefit COCs from those that aren’t. Of the 21 MPOs that had conducted an impact analysis, nine looked at the outcomes of a plan or project for CoCs compared to the outcomes for the general population. Analyzing impacts is more complex, and typically requires travel modeling and other detailed analysis techniques. The MPOs we reviewed that conducted outcome analysis generally had enough technical capacity to calculate multimodal measures, but MPOs with less staff capacity may need guidance or technical assistance to do so. Those that took this approach examined a variety of indicators related to access to transportation options, access to destinations, affordability, health, and other topics. As is the case with analyzing outputs, the most compelling examples are those that account for the fact that different project types have different impacts on COCs. This typically involves using multimodal performance measures that capture the modes that disadvantaged communities are most likely to rely upon, for example, analyzing the impact of a plan on travel times to work via all modes rather than focusing on vehicle congestion. It can also involve defining measures that address the needs of COCs as identified during the needs assessment phase. A complete listing of all of the indicators used in the equity analysis for the plans that we reviewed appears in Table A-12, which is provided at the end of this appendix.

Literature Review A-21 Some best-practice examples include: The MTC has a wide variety of measures, but two indicators that are particularly relevant to equity are housing and transportation affordability and displacement potential (MTC 2013); The MARC measures the percentage of jobs within one-half mile of transit, the percentage of jobs reachable by transit within 90 minutes, and the presence of transit near COC areas (MARC 2015a); The MORPC measures the number of jobs and other destinations within a 20-minute auto trip or a 40-minute transit trip; and transit accessibility to the central business district for various COC populations (MORPC 2016); and The NCTCOG measures the number of jobs accessible within 60 minutes by transit (NCTCOG 2016a). Comparing Impacts Relevant Regulations and Guidance Federal guidance requires a comparative analysis to determine whether COCs are receiving comparable benefits and burdens of MPO plans and programs (FHWA 2012, FTA EJ Circular, FTA 2012a and 2012b). MPOs’ analyses need to compare impacts on COCs to impacts on a control population so that they can evaluate whether impacts are disproportionate or disparate. According to FHWA, “Fair distribution of the beneficial and adverse effects of the proposed action is the desired outcome” (FHWA 2015). The FTA requires that MPO analyses include: Maps showing the distribution of funds compared to the percentage of minorities by tract or block group; and An analysis of impacts to determine whether there are any disparate impacts based on race, color, or national origin (FTA 2012a). State of the Practice The MPOs reviewed used a variety of approaches to compare impacts in COCs and other areas. Key factors differentiating these approaches include: Format: Most MPOs present tables summarizing impacts for COCs compared to other communities. Other MPOs provide maps in addition to or in lieu of tables, particularly when showing the distribution of projects and funding. Maps are better for illustrating the distribution of impacts, but less conclusive as a basis for comparative analysis. Comparison population: Some MPOs compare impacts on COCs to impacts on the population in general, while others use the non-COC population as a basis for comparison. Other MPOs only focus on impacts in COCs and do not compare these to impacts in non- COCs, which could constitute a violation of the regulations listed above. Baseline scenario: To identify the change in outcomes due to a plan, MPOs must compare performance measure results under the plan to baseline results. Some MPOs use current conditions as a baseline, but others use a future no-build scenario. Some MPOs also present results for alternative planning scenarios, which can help identify mitigation measures if alternatives produce significantly better outcomes for COCs than the adopted plan. For output measures, such as distribution of projects or project funds, we summarized individual measures. A sample of commonly used outcome measures is also provided in Table A-9. Table A- 12 (at the end of this appendix) provides more details on the array of output and outcome measures used by each agency interviewed.

A-22 Equity Analysis in Regional Transportation Planning Processes Table A-9. MPO methods for comparing impacts. Method for Comparing Impacts MPOs Using the Method Outputs Map of projects overlaid on map of COCs ARC, Baltimore Regional Transportation Board, COMPASS, DVRPC, MTC, Nashville Map of projects overlaid on map of COCs, but with projects categorized into different types Baltimore Regional Transportation Board, DRCOG, Oregon Metro, Wichita8 Map of projects overlaid on map of COCs and employment clusters CMAP Maps of net negative impact9 and net positive impact10 projects overlaid on COCs Madison Table showing number and % of COC/non-COC tracts that have a project (highway and transit separate) DVRPC Table showing number of projects in COCs versus non-COCs ARC Table showing % of projects (separated into 8 types11) in COCs versus non COCs PSRC Table showing $ spending on projects in COCs versus non-COCs ARC, MAPA, MARC, Oregon Metro Table showing % spending on projects in COCs versus non-COCs MAPA, MORPC Table showing % of spending on projects by mode and EJ population, normalized by mode share MTC Table showing $ transit spending per capita for COCs and non-COCs MTC Table showing $ spending per capita for COCs and non-COCs MARC Table showing $ spending per capita per acre for COCs and regionally Oregon Metro Outcomes Table comparing levels of transit performance for COCs and non-COCs MARC12 Table comparing performance outcomes for COCs and non-COCs under plan and current scenarios Baltimore Regional Transportation Board, MTC, SCAG Table comparing performance outcomes for COCs under plan and no-build scenarios CMAP Table comparing performance outcomes for COCs under current conditions and plan scenarios DRCOG, Met Council Table comparing performance outcomes for COCs and non-COCs under current conditions, no-build future, and plan future MORPC, NCTCOG In the next section we present some illustrative examples of different comparative approaches from the MPOs reviewed.

Literature Review A-23 The PSRC’s TIP demonstrates an option analyzing the distribution of different project types across COCs containing significant concentrations of different population groups (Figure A-5). This allows for a nuanced look at the distribution of projects with different equity impacts across areas with varying levels of need. PSRC concludes, “most project improvement types are fairly equally distributed across the different categories, particularly in census tracts that surpass between one and three EJ regional thresholds. The improvement types with fewer projects represented, such as Highway Capacity Improvement, Vehicles/Equipment and Other, are less evenly distributed, but given the small number of these projects that seems a logical outcome.” Source: PSRC (2014), Table 3 Figure A-5. PSRC TIP analysis showing distributions of project improvement types by thresholds surpassed (by project type and COC level). A table showing results from the MTC’s Plan Bay Area equity analysis demonstrates how an MPO might compare how a plan affects performance outcomes across different population groups (Figure A-6).

A-24 Equity Analysis in Regional Transportation Planning Processes Equity Performance Measure Target Population 2010 2040 (Baseline Forecast) 2040 (Plan Bay Area) 1 Housing and Transportation Affordability Percentage of income spent on housing and transportation by low- income households Low-Income Households 72% 80% 74% All Other Households 41% 44% 43% 2 Potential for Displacement Percentage of rent-burdened households in high-growth areas Communities of Concern n/a 21% 36% Remainder of Region n/a 5% 8% 3 Healthy Communities Average daily vehicle miles traveled per populated square mile within 1,000 feet of heavily used roads Communities of Concern 9,737 11,447 11,693 Remainder of Region 9,861 11,717 11,895 4 Access to Jobs Average travel time in minutes for commute trips Communities of Concern 25 26 26 Remainder of Region 27 29 27 5 Equitable Mobility Average travel time in minutes for non-work-based trips Communities of Concern 12 13 13 Remainder of Region 13 13 13 Source: MTC (2013), Table 26 Figure A-6. MTC Plan, Results of Plan Bay Area equity analysis, 2010–2040. Determining Disparate Impacts/DHAE Relevant Regulations and Guidance The U.S. DOT EJ Order defines a “disproportionately high or adverse effect” as one that: “is predominately borne by a minority population and/or a low-income population, or will be suffered by the minority population and/or low-income population and is appreciably more severe or greater in magnitude than the adverse effect that will be suffered by the non-minority population and/or non-low-income population” (FHWA 2012). According to the FTA Title VI circular, MPO Title VI programs shall “determine whether there are any disparate impacts based on race, color, or national origin” (FTA 2012a). To allow agencies flexibility in determining the impacts, the guidance deliberately does not identify specific quantitative thresholds. The closest thing to a quantitative standard that can be found in federal guidance is in EPA’s Toolkit for Assessing Potential Allegations of Environmental Injustice, which recommends identifying “statistically significant differences between the two groups in one or more measures” (U.S. EPA 2004).

Literature Review A-25 Because MPOs can end up in court for failure to comply with Title VI, case law also provides some basis for defining disparate impacts. The current standard, as set by the United States Supreme Court in Alexander v. Choate, has interpreted Title VI only as prohibiting intentional discrimination. Prior cases set a more inclusive standard for defining disparate impacts. In 1994, the NAACP and a group of plaintiffs sued the Los Angeles County Metropolitan Transportation Authority (MTA) for violations of Title VI, and MTA had to enter into a costly court-ordered consent decree in 1996 to change its investment and service priorities (FHWA/SCAG 2017). Although the current case law standard for defining disparate impacts is narrow, only applying to intentional discrimination, most federal agencies’ standards bar discriminatory impact (Baida State of the Practice The 21 MTP/TIP equity analyses that we reviewed did not find a disparate impact of their plan or program. This is not to say that none of the equity analyses revealed inequities, but rather that vagueness in the Title VI and EJ guidelines for MPOs, the high number of performance measures and community types included in some equity analyses, the long-term and comprehensive nature of these plans, and the lack of consistency in how different MPOs conduct analyses and present results all combine to make it challenging to discern what exactly constitutes a disparate impact. Some of the MPO plans that we reviewed highlighted the challenges that MPOs face in determining disparate impact. For example, RVMPO looked at planned projects for the next 25 years within these areas, as well as the total 20-year investment amount per household and per capita to determine whether the COCs were receiving a proportional amount of funding. Based on the information shown in Figure A-7, the report concluded that “investment ratios appear favorable to areas containing very high concentrations of seniors, minorities, and younger persons, but not to low-income areas” (RVMPO 2016). However, the RVMPO stopped short of calling this a disparate impact, nor did it identify mitigation measures. Source: RVMPO (2016), Table 3, covering 2013–2038 Figure A-7. RVMPO table showing regional transportation planned investments in COCs. 2003). MPOs should expect that U.S. DOT will use a higher standard than that set by the courts, and we have noted frequently in this review that U.S. DOT requires that there not be disparate impacts.

A-26 Equity Analysis in Regional Transportation Planning Processes In its TIP analysis, the MTC said its understanding of regulatory requirements was that a disparate impact must be statistically significant. The MTC’s results did not show disparate impacts, but the agency did not reveal how it analyzed statistical significance in the TIP (MTC 2016). Their MTP used a transit investment analysis that divided the transit investment per capita non-minority populations and, thus, not disparate (2013). The analysis found a slightly higher share of investments for minority and low-income populations than their share of trips and VMT in the region, but apparently not at a significant level. Research also highlights the challenges that MPOs face in identifying disparate impacts. MPO and state DOT participants at an AASHTO-sponsored peer exchange on EJ “noted challenges with the interpretation of disproportionate impacts and indicated that there is a lack of national consistency in impact determinations” (Lane et al. 2016). Martens and Golub (2014) reviewed 10 MPO plans, none of which identified a disparate impact. They found that these plans did not state the MPOs’ standard for defining a disparate impact, though all appeared to go beyond the Supreme Court’s legal interpretation that an impact is disparate only if it is intentional. The examples discussed in this section illuminate several questions about what constitutes a disparate impact: How significant do impacts need to be to be considered disparate? For example, one analysis revealed that commute times for COCs, which currently average 30 minutes, increase by 1 minute compared to current conditions, whereas they do not change at all for the general population. How extensive do the impacts need to be to be considered disparate? Some equity analyses include several different performance measures and/or analyze results separately for different communities (e.g., assessing impacts on transit service for both low-income communities and minority communities). Some of the analyses we reviewed showed disparities for a single community type (for example, underinvestment in low-income communities, but not in areas with high concentrations of minorities, senior, or youth). Others revealed disparities with respect to one performance measure out of multiple measures considered. What baseline should be used to measure disparate impacts? Some MPOs compare outcomes under a plan to current conditions, some compare them to a future no-build or business-as-usual scenario, and some do both. In one example we reviewed, COCs saw a disparate impact in travel time to work relative to the future business-as-usual scenario, but not relative to the current scenario. What is the standard for defining a disparate impact? Many COCs face a history of systemic disinvestment. Should the goal of an MPO’s equity efforts be to undertake no intentional actions to further harm these communities, to ensure plans cumulatively produce equal benefits for COCs and the rest of the population, or to restore COCs following past injustices? Most MPOs appear to adhere to the second standard, but few make it explicit. The FTA does not require MPOs to adopt a policy on what constitutes a disparate impact (unless they operate a transit service), but does require disclosure of impacts. In the absence of such a policy, some of the cases above could be considered disparities and could be the subject of a Title VI complaint. We suspect that few MPOs have adopted such a policy because their analytical process and performance measures evolve with each MTP/TIP update, leaving them little information with which to set standards in a way that does not risk either overlooking disparate impacts/DHAE or flagging small differences as significant. in minority COCs by the non-minority transit investment per capita. They concluded that the share of transit funding benefiting minority populations was not significantly different from funding for

Literature Review A-27 Summary of Findings Most MPOs analyze output measures in their equity analyses; some also analyze outcomes. The MPOs reviewed did not identify a disparate impact. MPOs use several different methods when comparing results that vary in format, comparison population, and baseline population. Key Issues Many MPOs are analyzing either outputs or outcomes in their equity analysis instead of doing both. Title VI and EJ guidance recommends taking both approaches, and both provide complementary information about how MPOs can remedy disparate impacts/DHAE. Most MPOs that analyze outcomes have higher levels of staff and technical capacity, which suggests that technical capacity could be a barrier to analyzing outcomes for smaller MPOs. Some analyses do not account for the fact that different project types produce different benefits and burdens for COCs. Output analyses should capture the fact that impacts on equity are not proportionate to the amount of funding spent in a community but vary for different project types. Outcome analyses should include performance measures that capture travel by all modes, particularly transit, which is an important mode for many traditionally underserved populations and also the subject of in-depth Title VI and EJ requirements. MPOs may not clearly understand what constitutes a disparate impact/DHAE. Though some of the equity analyses we reviewed did reveal disparities, none identified a disparate impact or DHAE by the standards identified in the Title VI and EJ guidance. Taking Action If an impact analysis reveals that a plan or project has a disproportionate impact or DHAE on underserved or underrepresented communities, the MPO must examine alternatives that mitigate these inequities and potentially incorporate these alternatives into their final decision. In addition, some MPOs take more general or proactive steps to prioritize equity in planning and programming processes. Mitigate Disparate Impacts/DHAE Relevant Regulations and Guidance According to the FTA Title VI Circular, if MPOs find disparate impacts they must make determinations as to whether there is a legitimate justification for the policy that produces a disparate impact or whether there are alternatives that could lessen the discriminatory impact. U.S. DOT Order 5610.2(a)—the DOT EJ Order—identifies a process to engage in if disproportionately high or adverse effects are found. First, the MPO should consider mitigation, enhancements, and benefits accruing to COCs that would offset the adverse effect. The MPO also needs to consider how their approach in COC areas compares to that in non-COC areas, including the design and mitigation. If the MPO still finds a disproportionately high or adverse effect, the DOT EJ Order says the action may not be carried out unless additional mitigation or alternatives are “not practicable.” To determine whether an alternative or mitigation strategy is not practicable, MPOs must consider “the social, economic (including costs) and environmental effects of avoiding or mitigating the adverse effects.”

A-28 Equity Analysis in Regional Transportation Planning Processes If there is not a way to reduce the effects to not be disproportionate, the FHWA will not approve the activity unless a substantial need exists for the activity, based on the general public’s interest and the alternatives would either have impacts as severe or increase costs extraordinarily (FHWA Environmental Justice Reference Guide). State of the Practice Across the study, MPOs were not seen taking steps to mitigate or avoid disparate impacts, as the equity analyses had not originally identified disparate impacts. Although the MATPB did not make a finding of disparate impact in its MTP per se, it did describe a separate EJ analysis for a major state road expansion that will have a negative impact on a COC and associated mitigation efforts, and also recommended ongoing mitigation (MATPB 2012). Mitigation measures undertaken by transit agencies under Title VI may also be relevant for MPOs. For example, in the Los Angeles Metropolitan Transportation Authority (MTA) Consent Decree previously described, the MTA agreed to several mitigation measures (FHWA/SCAG 2017): Long-range plans, major capital projects lists, and annual budgets will have a section specifically addressing the needs of transit-dependent persons; [The agency will] improve consultation with riders to improve services, and add bus routes to activity centers and areas with many jobs; and [The agency will] develop a comprehensive program for bus system improvements, including reducing overcrowding and improving security, bus stop quality, and service efficiency. Proactive Approaches The best practices for EJ require the full integration of EJ considerations into the entire transportation planning and programming process instead of leaving it as a separate analysis (Suhrbier et al. 2002). Many MPOs are aware of that and want to improve their EJ practices for altruistic reasons and to streamline project delivery by reducing controversies. MPOs are still struggling with how to put EJ fully into practice, including how to ensure meaningful COC participation throughout the process (PolicyLink 2013, Aimen and Morris 2016, Sanchez and Wolf 2005). This section discusses some of the best-practice examples of proactive approaches to addressing equity. These approaches are not explicitly related to equity analysis nor to Title VI and EJ compliance. However, any member of the public can file a Title VI complaint against MPOs, and taking proactive approaches can demonstrate an MPO’s commitment to improving equity to concerned members of the public. Prioritize Equity in Funding Decisions Equity performance measures are just one element of a fully implemented, performance-based planning and programming approach. By introducing equity considerations early in the process, the public involvement and technical analysis can influence plan development and project selection to improve equity outcomes (Suhrbier et al. 2002). The FHWA 2015 EJ Reference Guide suggests incorporating EJ into the development of MTPs, project selection and prioritization processes, and all phases of project development. It recommends that MPOs “consider” including EJ in the project prioritization process, a concept which this literature review will address in the section on integrating the results of equity analyses into institutional decision making.

Literature Review A-29 In our review of MPO equity analyses, we found that several MPOs look at the distribution of funding and/or break it down by types of projects and into per capita spending. If the analysis of performance measure outcomes reveals that the COCs are having worse outcomes on a measure (e.g., safety), then an equitable performance-based approach would allocate funding to those areas to improve safety outcomes. Although our review did not focus on this, we identified several MPOs that started using project selection criteria related to equity. Table A-10 summarizes these examples. Table A-10. Summary of MPO approaches to prioritizing equity in project selection. Selection or Prioritization Criteria13 MPO One metric reduces the score of a project if it adds lanes in an EJ area Charlotte County MTP Points for transit system expansion projects serving a COC DVRPC MTP Weight given to projects “benefiting”14 a COC tract DVRPC (PA TIP) Points awarded depending on the degree to which a project in a COC improves access to opportunities EWGCOG (TIP) For projects adjacent to EJ areas, points added or subtracted depending on net positive or negative impacts to adjacent communities15 Memphis (TIP) Points earned for having more benefits for COCs RVMPO (MTP) Advisory Committees COCs can participate from the visioning stage of the Long-Range Plan to the final stages of project development, and advisory committees are one way of ensuring continued engagement (NCHRP 2016, PolicyLink 2013). Active advisory committee participation improves a COC’s confidence and trust that they are not simply a part of the listening sessions but are indeed a part of the decision-making process (PolicyLink 2013). These advisory committees can be used to help identify relevant performance measures, to help gather community input, to help make decisions Community Liaisons MPOs can establish a network of contacts and advocates in COCs. For example, the SCAG maintains a community database of contact information for each local subregion so that they know to whom they can reach out to gauge the needs and interests of that area. The SCAG regularly updates the lists so that it can adequately inform active citizens and organizations about upcoming workshops and other community meetings and discussions (FHWA/SCAG 2017). Partnerships with Other Agencies MPOs feel they have limited ability to address EJ and equity concerns because they have “limited roles in project development, locally funded projects, and maintenance activities,” but many are working with their local partners to improve equity across the region (NCHRP 2002). When confronted with an issue outside of its jurisdiction, the SCAG identifies the appropriate on projects to fund, and to help monitor progress (U.S. EPA 2008, NCHRP 2016, PolicyLink 2013). Several MPOs have formed EJ advisory committees and found that they increased credibility and engagement with stakeholders and improved decision making (NCHRP 2002).

A-30 Equity Analysis in Regional Transportation Planning Processes agency who would be able to address the issue. The MTC works with the county agencies that manage congestion to help ensure adequate public involvement during their project prioritization process. The Pima Association of Governments in Tucson, Arizona, trains local agencies on outreach methods and technical aspects of EJ to incorporate in their project development. The Indianapolis MPO hosts lunches over which community members can connect with staff at the city transportation department and transit agency (Lane et al. 2016). Improve COC Participation in Planning Processes In addition to using public participation to inform equity analyses, Title VI and EJ guidance generally recommends that MPOs engage with members of traditionally underserved communities throughout the planning process. FTA requires that MPOs document their processes for conducting outreach to minorities and LEP populations, and there is extensive guidance and research on conducting effective outreach to COCs, which we summarize below: It is advisable to start by getting to know the community by gathering information that will help improve outreach. Questions to consider include: Where do community members live, work, and spend leisure time? What languages do they speak? What types of media do they use? What are their barriers to participation, and what would make them more likely to participate? Additional steps that agencies can take to improve outreach include: Recruiting outreach coordinators and public involvement officers with diverse backgrounds and ties to the affected communities, and Establishing trust by getting to know the community and having a presence there even when you don’t need something. Agencies also can establish partnerships with local COC leaders. Helpful steps include: Meeting informally first with community groups and COC leaders to get advice and feedback on your approach; Attending meetings of community groups and faith-based organizations to present the proposed plan and solicit feedback; Building capacity of local COC leaders to serve as liaisons between you and the community; and Keeping a database of contact information. For example, the SCAG maintains a community database of contact information for each local sub-region so that they know who to reach out to gauge the needs and interests of that area. The SCAG regularly updates the lists so that it can adequately inform active citizens and organizations about upcoming workshops and other community meetings and discussions (FHWA/SCAG 2017). Potential allies include churches, bus drivers’ unions and other labor organizations, Native American tribal organizations, schools, minority business associations, libraries, public health clinics, civic associations, EJ associations, legal aid providers, tenant associations, community and social service organizations, civil rights organizations, senior citizens groups, disability rights groups, tenants’ rights advocates, or any non-profit organizations that are already effectively engaged with the target COCs. Establishment of advisory committees can ensure COC participation from the visioning stage of the Long-Range Plan to the final stages of project development (Aimen and Morris 2016, PolicyLink 2013). Active advisory committee participation improves COCs’ confidence and trust that they are not simply a part of the listening sessions but are indeed a part of the decision-making

Literature Review A-31 process (PolicyLink 2013). These advisory committees can be used to help identify relevant performance measures, to help gather community input, to help make decisions on projects to fund, and to help monitor progress (EPA guidance, Aimen and Morris 2016, PolicyLink 2013). Agencies can use both traditional and non-traditional means of outreach. For example, they can: Use a variety of media sources that include digital and social media, mailings to the affected area, flyers at community events, ads in community newspapers, and radio announcements; Staff a booth at existing community events to provide and solicit information; and Consider conducting a community impact assessment. Outreach materials and content can be tailored to suit the audience. Agencies can: Get feedback from local partners on what types of approaches will be more effective for their constituents; Consider facilitation approaches to overcome any historic distrust of government activities; Consider ways to tailor the tone of in-person presentations to the culture and expectations of the community (e.g., some audiences may be put off by the appearance of government officials in three-piece suits, whereas other groups expect formal dress as a sign of respect); Translate written materials and provide interpreters at public meetings; Use graphics and other non-verbal means for conveying the message to audiences that might have low levels of literacy or not speak English as their primary language; and Use an open house format or small group discussions for public meetings so that participants can engage in discussions with staff members about the project or plan. To eliminate barriers to active participation in the process, agencies can: Establish 24/7 access to information and comment opportunities; Encourage input through many means, including simple in-person, paper, or online surveys; Select meeting locations that are easily accessible (by transit, walking, bicycling, and for those with ADA needs) in the community; Schedule the meetings for a variety of times and days to accommodate different work schedules; Record meetings and make the videos easily available online with a means for providing feedback (because many interested individuals may be unable to attend meetings in person); Plan for a variety of meeting types to suit different needs; Provide childcare and food/refreshments at meetings; and Set up a satellite office in the community (for large projects). To evaluate the effectiveness of public engagement approaches, agencies can: Define performance measures and goals; Start with number of meetings in COC areas, number of attendees, and number of comments, but acknowledge that these measures do not necessarily reflect meaningful engagement; Ask the community for help defining success; Document how COC feedback differed from the general population and how the plan or program in question evolved in response to that feedback; and Describe actions taken to resolve any controversies that arose, including how the information was summarized and shared with decision makers or technical committees. Next Steps In the next task of this project, we planned to interview up to 15 transportation agencies to better understand their approach to regional equity analysis and the opportunities and challenges they see to improving their analyses. We began by interviewing contacts from 10 MPOs that represented metropolitan areas of varying sizes across the United States, all of which had emerged as best-

A-32 Equity Analysis in Regional Transportation Planning Processes practice examples of equity analysis during the literature review. Table A-11 lists the MPOs; the states in which they are located; the populations of the regions they serve; the proposed agency contacts, by title (typically the person in charge of equity analysis or the planning manager, if an equity-specific contact was not available); and the research team’s rationale for selecting each. Table A-11. Recommended interviewees. Agency (MPO) State Population Served Contact Title Rationale for Selecting Atlanta Regional Commission (ARC) GA 4,818,000 Principal Planner Conducted nuanced discussion of project distribution, used best-practice outcome measures, held workshop series on equity. Denver Regional Council of Governments (DRCOG) CO 2,827,082 Regional Planning and Development Director Adopted equity policy, educates COC members on engagement via Transit Alliance Citizens’ Academy. Madison Area Transportation Planning Board (MATPB) WI 434,438 Transportation Planning Manager Small MPO with nuanced discussion of project impacts on equity and measures to mitigate disparities. Memphis Urban Area MPO TN, MS 1,077,697 Title VI Coordinator Medium-sized MPO that conducted transit gap analysis, incorporated equity into project selection criteria, and engaged COCs in analysis. Metropolitan Area Planning Agency (MAPA)* NE, IA 285,407 Transportation and Data Manager Small MPO that used interesting output/outcome indicators and incorporated equity into project selection criteria. Metropolitan Transportation Commission (MTC)* CA 7,150,828 Director of Planning Conducted thorough outcome-based equity analysis, expressed discontent with disparate impact standard, convened Regional Equity Working Group, developed grant-funded plan focused on regional equity. Mid-America Regional Council (MARC) MO, KS 1,895,535 Director of Planning and Environment Medium-sized MPO that conducted detailed analysis of funding distribution and safety. Mid-Ohio Regional Planning Commission (MORPC) OH 1,426,183 Associate Planner Medium-sized MPO that used innovative approaches to displaying results of the equity analysis. Oregon Metro* OR 1,499,844 Equity Program Manager Currently updating equity analysis with input from a stakeholder committee. Wichita Area MPO KS 518,985 Principal Planner Small MPO that just adopted a comprehensive EJ program. *The MAPA serves the region of Omaha, Nebraska and Council Bluffs, IA; the MTC serves the San Francisco Bay Area; and the Oregon Metro serves the region around Portland, Oregon.

Literature Review A-33 The research team planned to determine how best to fill the remaining five interview slots after conducting the initial 10 interviews. We planned to ask each of the interviewees listed in Table A-11 about potential additional contacts, either from other MPOs or among stakeholders within their regions that are pursuing best practices in or have interesting perspectives about equity analysis. We also considered reaching out to some additional transportation agencies, which included both best-practice MPO examples from the literature review and transit agencies with experience in equity analysis that could apply to MPOs. These additional agencies were: • Charlotte County-Punta Gorda MPO (Florida), • DVRPC (Delaware), • EWGCOG (Missouri), • Met Council (Twin Cities) (Minnesota), • PSRC (WA), • Portland TriMet (Oregon), • Santa Clara Valley Transportation Authority (California), and • Southeastern Pennsylvania Transportation Authority. The research team also developed a list of questions to draw upon during the interviews. This list would serve as a general guide to the topics we wanted to cover, but we intended to tailor the interviews to each agency, prioritizing the most relevant questions from the list and asking specific follow-up questions regarding the documents that we reviewed. The basic questions were as follows: • What is your agency’s role with respect to planning and operating the transportation system? Does your agency have any additional functions beyond the typical MPO long-term planning and programming roles? • Are there challenges, issues, or concerns that your agency is particularly focused on addressing when it conducts an equity analysis of the MTP/TIP? • How many staff work for the MPO? How many staff are exclusively dedicated to equity- related activities? What other resources are being used to address equity and measure equity impacts? • Are you familiar with FTA and FHWA guidance on Title VI and EJ? If so, do you find this guidance easy to follow when conducting equity analyses, or are there areas where you need clarification? • How do you define COCs within your service area? Do you feel that your definition of COCs supports a meaningful, inclusive equity analysis? • How do you identify the needs of low-income and minority populations? How do you incorporate these needs into your equity analysis? • What public participation approaches have you found effective in engaging underserved or underrepresented communities? What approaches haven’t worked so well? • How are you engaging rural areas in your planning process, such as small communities and unincorporated areas that may be interspersed throughout the metropolitan region? • How do you select the indicators that you use to measure equity impacts? • What data and tools do you use to analyze these indicators? Do you feel that these data and tools are adequate? • Are there indicators that you or your stakeholders would like to be able to capture, but are currently unable to? • Does your agency have a policy defining what constitutes a disparate impact? If so, please describe it. If not, how would you identify a disparate impact? • Have you, the public, or the federal government found that any decisions your agency has made resulted in a disparate impact on disadvantaged communities? If so, how did you resolve it? For example, did you revise the plan or program before final adoption? Have any of the other transportation agencies in your region made a finding of disparate impact?

A-34 Equity Analysis in Regional Transportation Planning Processes • Have you revised a plan or program before adoption based on a potential impact? What happened during that process? • How familiar are staff at your agency with Title VI case law? • Has your agency adopted policies or goals related to equity or environmental justice? • How does your agency address equity in funding decisions or project selection criteria? • Can you describe your agency’s working relationships with transit agencies, local governments, and other stakeholders? How do these relationships affect your approach to equity? Are transit agencies active on your agency’s technical committees or policy boards? How do you engage transit agencies in planning for multimodal networks, accessibility, and connectivity? • What are your current and upcoming activities relating to planning and equity analyses? Are there any opportunities for pilot testing our draft guidance in support of your efforts? • Are there stakeholders within your region or other MPOs that you recommend we interview? MPO Survey Template and Summary of Results Table A-12 summarizes the MTPs and TIPs that we reviewed in the course of this project, including the size of the MPO region, the type of plan, the demographic factors considered, the indicators used to assess impacts, the tools and data used to assess these indicators, and how the indicator results were presented. Other non-MTP/TIP resources from MPOs are discussed in the next section.

Table A-12. Agencies studied. Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Atlanta Regional Commission (ARC) The Atlanta Region’s Plan: Equitable Target Areas (2016) 4,818,000 MTP Low-income Minority Project distribution Distribution of financial commitments GIS Census ACS Overlay map of project locations onto map of COCs Compare number of projects and costs for all projects in COCs to costs for projects outside Atlanta Regional Commission (ARC) 2016–2021 TIP (2015) 4,818,000 TIP None were Baltimore Regional Transportation Board Maximize 2040 (2015) 2,685,000 MTP Low-income Minority Jobs and destinations within 30 min. drive, 60 min. transit trip GIS Census ACS Tour-based travel- demand model Compare results for COCs and non-COCs under two future scenarios: baseline and preferred alternative Baltimore Regional Transportation Board 2017–2020 TIP 2,685,000 TIP Low-income Minority LEP Disability Elderly Carless household Project distribution GIS ACS Overlay map of project locations onto map of COCs Bismarck-Mandan MPO Long-Range Transportation Plan (2015) 100,000 MTP Poverty Minority Project distribution GIS ACS Overlay map of project locations onto map of COCs Bismarck-Mandan MPO 2017–2020 TIP 100,000 TIP Poverty Minority Project distribution GIS ACS Overlay map of project locations onto map of COCs Charlotte County- Punta Gorda MPO (CCPGMPO) Long-Range Transportation Plan (2015a) 161,000 MTP None were (continued on next page)

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Charlotte County- Punta Gorda MPO (CCPGMPO) FY16/17–FY20/21 TIP (2015b) 161,000 TIP None were Chicago Metropolitan Agency for Planning (CMAP) Go To 2040 MTP (2010) 8,455,000 MTP Low-income Minority Distribution of projects, households, and highway/rail Number of jobs accessible by auto (in 45 min.) or transit (in 75 min.) GIS ACS Overlay map of COCs, new and existing highways and rail projects, and employment clusters Evaluation of a build and no-build scenario % change in number of jobs accessible from EJ areas Chicago Metropolitan Agency for Planning (CMAP) 2014–2019 TIP 8,455,000 TIP Low-income Minority Number of jobs accessible by auto and transit GIS ACS Assess % change in number of jobs accessible within given transit time Chittenden County RPC 2013 Chittenden County ECOS 157,000 MTP None were Chittenden County RPC 2017–2020 TIP 157,000 TIP None were Community Planning Association of Southwest Idaho Communities in Motion 2040 (2014) 581,325 MTP None were Community Planning Association of Southwest Idaho 2017–2021 TIP 581,325 TIP Low-income Minority Distribution of projects GIS ACS U.S. Census Map project locations and COCs

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Delaware Valley Regional Planning Commission (DVRPC) Connections 2040 Plan for Greater Philadelphia (2014) 5,626,318 MTP Households in poverty Carless households Minority Disability LEP Elderly Female head of household Distribution of projects GIS U.S. Census Map project locations and COCs Delaware Valley Regional Planning Commission (DVRPC) – covering areas in Pennsylvania 5,626,318 TIP Households in poverty Carless households Minority Disability LEP Elderly Female head of household Distribution of projects DVRPC Indicators of Potential Disadvantage EJ Analysis Tool ACS Map of projects to identify low-disadvantage and high-disadvantage census tracts without any TIP projects Delaware Valley Regional Planning Commission – covering areas in New Jersey 5,626,318 TIP Households in poverty Carless households Minority Disability LEP Elderly Female head of household Distribution of projects ACS Map of projects overlaid with COCs Denver Regional Council of Governments (DRCOG) 2035 Metro Vision Regional Transpor- tation Plan (2011) 2,827,082 MTP Minority Low-income Distribution of projects Transit accessibility: Share of population with 100K jobs within 55-min. transit ride U.S. Census Traffic analysis zones (TAZs) GIS Map of projects overlaid with COCs Compared transit access to jobs in 2010 to plan’s horizon year Denver Regional Council of Governments (DRCOG) 2016–2021 TIP 2,827,082 TIP None were (continued on next page)

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented East-West Gateway Council of Governments (EWGCOG) Connected 2045 Long- Range Transportation Plan (2015a) 2,571,327 MTP None were East-West Gateway Council of Governments (EWGCOG) 2017–2020 TIP (2015b) 2,571,327 TIP None were Madison Area Transportation Planning Board (MATPB) 2035 RTP (2012) 434,438 MTP Minority Households in poverty Carless households Distribution of projects Transit travel times ACS Map of projects overlaid with COCs Qualitative transportation project analysis, including maps of projects likely to have negative and positive impacts Travel-time analysis of COCs to a sampling of destinations Madison Area Transportation Planning Board (MATPB) 2017-2021 TIP 434,438 TIP Minority Low-income Carless households Distribution of projects and transit service ACS GIS Map of projects overlaid on COCs Narrative discussion of expected positive/negative impacts Memphis Urban Area MPO 2040 Regional Transportation Plan (2016a) 1,077,697 MTP Minority Low-income LEP Mode to work by EJ communities EJ communities in relation to transit and non-motorized networks ACS GIS Travel-demand model Scenario analysis Transportation- disadvantaged analysis compared proposed investment in EJ communities compared to overall regional investment for highway capacity, transit, and bike/pedestrian projects

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Memphis Urban Area MPO 2017–2020 TIP (2016b) 1,077,697 TIP Minority Low-income LEP Distribution of projects ACS GIS Map of projects overlaid on COCs Metropolitan Area Planning Agency (MAPA) – covering Omaha, NE, and Council Bluffs, IA MAPA MTP 285,407 MTP Minority People in poverty Carless households Funding within EJ areas Funding within transit shed Metro Transit funding Distribution of projects GIS ACS % of funding in EJ areas compared to total funding, normalized by the % of the population living in EJ areas Metropolitan Area Planning Agency (MAPA) – covering Omaha, NE, and Council Bluffs, IA FH2017 TIP 285,407 TIP Minority People in poverty Carless households Funding within EJ areas Funding within transit shed Metro Transit funding Distribution of projects GIS ACS % of funding in EJ areas compared to total funding, normalized by the % of the population living in EJ areas Metropolitan Council of the Twin Cities (Met Council) Thrive 2040 (2014) 2,906,684 MTP Minority Low-income LEP Disability Distribution of projects Jobs within 30 min. by transit/auto ACS GIS Regional Travel Model Map of projects overlaid on map of COCs Highway and transit accessibility of plan compared to current Metropolitan Council of the Twin Cities (Met Council) 2017–2020 TIP (2016) 2,906,684 TIP None were (continued on next page)

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Metropolitan Transportation Commission (MTC) – covering San Francisco Bay Area Play Bay Area 2035 (2013) 7,150,828 MTP Low-income Minority Elderly LEP Carless households Disability Single-parent households Rent-burdened households % income spent on housing and transportation % of rent-burdened households in high- growth areas Average VMT per populated square mile within 1,000 feet of heavily used roadways Average travel time for commute trips and non-work-based trips Distribution of projects U.S. Census CA Dept. of Finance population projections Association of Bay Area Governments (ABAG) population, household, employment, housing, and land use forecasts MTC Travel Model UrbanSim Bay Area Travel Survey Bay Area Transit Passenger Demographic Survey Performance measures for COCs compared against the rest of the population under three different scenarios (current, baseline, plan) Map of projects overlaid on map of COCs Metropolitan Transportation Commission (MTC) – covering San Francisco Bay Area 2017 TIP Investment Analysis (2016) 7,150,828 TIP Low-income Minority Elderly Share of investments by mode and COC $ of Transit investments per capita ACS Public User Micro Sample (PUMS) CA Household Travel Survey Bay Area Transit Demographics Survey Compare share of investments to share of trips by mode for each population group Map of projects overlaid on map of COCs Mid-America Regional Council (MARC) Transportation Outlook 2040 (2015a) 1,895,535 MTP Minority Low-income Transit access: % of jobs within ½ mile of transit, total jobs in employment core, % jobs within 90-min. by transit; average headways; hours of service Local transit agency service data GIS Mapped performance measure results Compared headway and service hours between COCs and non-COCs

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Mid-America Regional Council (MARC) 2016–2020 TIP (2015b) 1,895,535 TIP Minority Low-income Disability Older adults Veterans Carless households Distribution of projects and funding Safety performance outcomes GIS Travel-demand model Calculate spending on projects that are in COCs to non-COCs Count the number of projects serving particular policy goals, including safety Compare safety performance in COCs to non-COCs Mid-Ohio Regional Planning Commission (MORPC) Metropolitan Transportation Plan (2016) 1,426,183 MTP Minority Low-income Disability Elderly Carless households Number of jobs, shopping, non- shopping opportunities within 20-min. by car and 40-min. by transit % population with a college, hospital, or major retail destination within 20-min. car or 40-min. transit ride Average travel time Transit access to CBD Congested VMT during peak hours Distribution of projects and investments ACS Tour-based travel model Comparing expected performance outcomes for COCs and non-COCs under current, no-build, and plan scenarios Map of projects overlaid on COCs Tabular summary of funding in and not in COCs Mid-Ohio Regional Planning Commission (MORPC) 2016–2019 TIP (2015) 1,426,183 TIP Minority Low-income Disability Elderly Carless households Number of jobs, shopping, non- shopping opportunities within 20-min. by car and 40-min. by transit % population with a college, hospital, or major retail destination within 20-min. car or 40-min. transit ride Average travel time Transit access to CBD Congested VMT during peak hours Distribution of projects and investments ACS Tour-based travel model Comparing expected performance outcomes for COCs and non-COCs under current, no-build, and plan scenarios Map of projects overlaid on COCs Tabular summary of funding in and not in COCs (continued on next page)

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Nashville Area MPO Middle Tennessee Connected 2016–2040 RTP (2016) 1,494,356 MTP Minority Carless households Poverty Disability Female heads of household Elderly LEP Distribution of projects U.S. Census List of projects that overlap with areas having high concentrations of at least 3 COCs Nashville Area MPO 2017–2020 TIP 1,494,356 TIP None were North Central Texas Council of Governments (NCTCOG) Mobility 2040 (2016a) 6,417,630 MTP Minority LEP Disability Female heads of household Low-income Carless households Number of jobs accessible within 60–90 min. by transit Mobility: average LOS and average travel time ACS GIS Scenario analysis comparing results of COCs and non-COCs Narrative discussing expected negative/positive impacts of projects in COCs North Central Texas Council of Governments (NCTCOG) 2017–2020 TIP (2016b) 6,417,630 TIP None were Oregon Metro – covering Portland, OR, region 2014 Regional Transportation Plan 1,499,844 MTP Young persons Older adults Minority LEP Low-income Distribution of projects Distribution of investments U.S. Census Regional spatial analysis boundary Map of projects (by category) overlaid on map of COCs Transportation investments per person per acre in COCs compared to the regional average Oregon Metro – covering Portland, OR, region 2015–2018 TIP 1,499,844 TIP Young persons Older adults Minority LEP Low-income Distribution of projects Distribution of investments U.S. Census Regional spatial analysis boundary Map of projects (by category) overlaid on map of COCs Transportation investments per person per acre in COCs compared to the regional average

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Puget Sound Regional Council (PSRC) Transportation Plan 2040 (2014) 3,690,866 MTP None were Puget Sound Regional Council (PSRC) 2017–2020 TIP (2016) 3,690,866 TIP Low-income Minority Elderly Disability Distribution of projects ACS GIS Count and % of projects (by project category) in COCs versus not in COCs. Rogue Valley MPO (RVMPO) – covering areas in Jackson Valley, OR EJ and Title VI Plan (referenced in 2013– 2038 RTP) (2012) 167,859 MTP None were Rogue Valley MPO (RVMPO) – covering areas in Jackson Valley, OR 2015–2018 TIP (2014) 167,859 TIP None were Southern California Association of Governments (SCAG) 2016 RTP/SCS (2016) 18,051,203 MTP Low-income Minority Disability Foreign-born LEP Elderly Children Individuals without a high school diploma Carless households Reductions in travel time and distance Geographic distribu- tion of investments Access to jobs, shop- ping, parks, natural lands, and schools w/in 1-mile, 30-min. auto, or 45-min transit Noise and traffic exposure ACS GIS (SCAG Land Use dataset, CPAD California Statewide Integrated Traffic Records System) Google Earth Traffic Model Emissions Data (ARB, SCAG transportation model) Compare performance outcomes of baseline and plan scenarios for COCs to regional outcomes Southern California Association of Governments (SCAG) 2017 TIP (2016) 18,051,203 TIP None were (continued on next page)

Agency and Plan Name Regional Population MTP/ TIP Demographic Factors Used to Define COCs Indicators Used to Assess Impacts Tools and Data Used How Indicators Are Presented Valdosta-Lowndes MPO 2040 Transportation Vision Plan (2014) 79,176 MTP None were Valdosta-Lowndes MPO 2015–2018 TIP (2014) 79,176 TIP None were Wichita Area MPO Move 2040 Long- Range Transportation Plan (2015) 518,985 MTP Minority Low-income Distribution of projects GIS Qualitative discussion of potential costs and benefits of projects Map of projects (by project type) overlaid with COCs Wichita Area MPO 2015 TIP Amendment (2014) 518,985 TIP Minority Low-income Distribution of projects GIS U.S. Census Map of projects (by project type) overlaid with COCs

Literature Review A-45 Resources Reviewed Research and General Resources 1000 Friends of Oregon, Ecotrust, and Futurewise. n.d. Regional Equity Atlas, [online], Available at: http://regionalequityatlas.org (as of June 13, 2017). The Regional Equity Atlas is a research project for the Portland, OR, metro area that measures and visualizes equity in the region across a number of indicators. The project has also developed a toolkit to help other regions develop their own atlases. The toolkit includes descriptions of steps for selecting indicators and engaging stakeholders. Aimen, D., and A. Morris. 2016. NCHRP Report 710: Practical Approaches for Involving Traditionally Underserved Populations in Transportation Decisionmaking, Transportation Research Board of the National Academies, Washington, D.C., Available at: http://www.trb.org/Publications/Blurbs/166872.aspx. This study discusses a wide range and detailed summary of strategies, tools, and practices related to the involvement and participation of COCs in transportation decisionmaking. Baida, H. A. 2003. NCHRP Legal Research Digest 48: Civil Rights in Transportation Projects, Transportation Research Board of the National Academies, Washington, D.C., 2003. Available at: http://www.trb.org/Publications/Blurbs/152856.aspx. This report discusses civil rights issues affecting minority groups during public transportation planning and the legal actions that can be undertaken when transportation planners discriminate against minorities and violate laws. CNT. 2017. The Housing and Transportation (H+T®) Affordability Index, Available at: http://htaindex.cnt.org (as of June 13, 2017). The Center for Neighborhood Technology (CNT) conducts research and develops tools in the area of urban sustainability. CNT has developed the Housing + Transportation Affordability Index, a web-based tool that assesses affordability across a number of measures. The H+T Index attempts to capture the true cost of housing by considering location efficiency which impacts transportation costs. The H+T Index website includes a searchable map that displays Index assessments for all U.S. locations. Community Indicators Consortium. n.d. Community Indicators Consortium website. Available at: http://www.communityindicators.net/home (as of June 13, 2017). The CIC encourages collaboration and shares information and tools on community indicators and performance measurement at the local level. The website contains databases of community indicator projects and resources. Fan, Y., et al. 2011. Impact of light rail implementation on labor market accessibility: A transportation equity perspective. SSRN. Available at: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1736206. This study assessed the impacts of the new light rail line in the Twin Cities, Minnesota, on equity. The researchers measured job accessibility for different wage levels to assess if the light rail improved access for workers and matching types of employment. FHWA. 2006. How to Engage Low-Literacy and Limited-English-Proficiency Populations in Transportation Decisionmaking, Federal Highway Administration, February 2006. Available at: https://www.fhwa.dot.gov/planning/publications/low_limited/webbook.pdf. This report discusses how to assess the needs of and customize outreach for low-literacy and LEP populations. FHWA. 2012. Update to ‘Actions to Address Environmental Justice in Minority Populations and Low-Income Populations,’ Federal Highway Administration, May 2012, Available at: https://www.fhwa.dot.gov/environment/environmental_justice/ej_at_dot/orders/order_56102a/. This is a detailed summary of key updates and revisions issued to the Department of Transportation Order 5610.2(a) Actions to Address Environmental Justice in Minority Populations and Low-Income Populations including clarification analysis and role of environmental justice (EJ) in transportation planning and definition of minority. FHWA. 2013. Developing Environmental Justice in NEPA: Detailed Presentation. 2013. Federal Highway Administration. Available at: https://www.fhwa.dot.gov/environment/environmental_justice/resources/ej_and_nepa/detailed_presentation/ (as of June 13, 2016). This resource presents an overview and assessment of environmental justice (EJ) and NEPA reviews in transportation using 10 case study projects. FHWA. 2015. Environmental Justice Reference Guide, FHWA-HEP-15-035, Federal Highway Administration, April 2015 [online] Available at: https://www.fhwa.dot.gov/environment/environmental_justice/publications/reference_guide_2015/index.cfm. Consolidates existing guidance relating to Executive Order 12898, Federal Actions to Address Environmental Justice

A-46 Equity Analysis in Regional Transportation Planning Processes in Minority Populations and Low-Income Populations (Executive Order 12898), the U.S. Department of Transportation (U.S. DOT) EJ Order 5610.2(a), and the FHWA EJ Order 6640.23A to assist staff at FHWA, State DOTs, and MPOs to comply with those existing orders. FHWA. 2016. Developing and Advancing Effective Public Involvement and Environmental Justice Strategies for Rural and Small Communities, Federal Highway Administration, September 2016, Available at: https://www.fhwa.dot.gov/environment/environmental_justice/publications/effective_strategies/index.cfm. This study reviews six MPOs and the state of the practice for engaging the public particularly environmental justice (EJ) groups in transportation decision-making. FHWA. 2017a. Developing Environmental Justice Case Studies: CommunityLink 21, Regional Transportation Plan: Equity and Accessibility Performance Indicators. Federal Highway Administration [online]. Available at: https://www.fhwa.dot.gov/environment/environmental_justice/case_studies/case4.cfm (as of June 13, 2017). A case study summarizing why and how SCAG began incorporating equitable performance measures into their Regional Transportation Plan. Reasons why include to avoid threatened litigation under Title VI. FHWA. 2017b. Developing Environmental Justice Case Studies: MPO Environmental Justice Report for Mid-Ohio Regional Planning Commission. Federal Highway Administration. Available at: https://www.fhwa.dot.gov/environment/environmental_justice/case_studies/case7.cfm; (as of June 13, 2017). A case study summarizing Mid-Ohio Regional Planning Commission’s efforts to identify and assess requirements of environmental justice (EJ) groups in compliance with Title VI. FTA (2012a), Title VI Requirements and Guidelines for Federal Transit Administration Recipients, FTA Circular 4702.1B, October 1, 2012 FTA (2012b), Environmental Justice Policy Guidelines for Federal Transit Administration Recipients, FTA Circular 4703.1B, August, 2012 Forkenbrock, J. D., and E. G. Weisbrod. 2009. NCHRP Report 456: Guidebook for Assessing the Social and Economic Effects of Transportation Projects, Transportation Research Board of the National Academies, Washington, D.C., Available at: http://onlinepubs.trb.org/Onlinepubs/nchrp/nchrp_rpt_456-a.pdf. This guidebook provides social and economic measures for transportation projects, rather than focusing on traditional measures of system performance for users of transportation systems (e.g., travel time, safety, operation costs). The report includes 11 types of social and economic impacts of transportation systems and methods for measuring those impacts. Four social and economic effects were considered: community cohesion; economic development; traffic noise; and visual quality. Full report in two parts available here: https://www.edrgroup.com/library/multi-modal/guidebook-for-assessing-social-a-economic- effects-of-transportation-projects.html HUD. 2017. The Fair Housing Equity Assessment. U.S. Department of Housing and Urban Development. [online]. Available at: https://portal.hud.gov/hudportal/HUD?src=/program_offices/economic_development/place_based/fhea (as of June 13, 2017). The Fair Housing Equity Assessment (FHEA) was a requirement under a U.S. HUD Sustainable Communities Regional Planning Grant. The FHEA identifies regional housing disparities to identify opportunities for improving access to opportunity. The FHEA includes an overview of the historical and cultural context; analysis of racial segregation, poverty, and access to opportunity; and recommendations for advancing fair housing and equity. Grant, M., et al. Performance-Based Planning and Programming Guidebook, Federal Highway Administration, September 2013. This detailed guide summarizes the state of the practice and offers step-by-step instruction in performance-based planning and programming, under which agencies make decisions based on defining and analyzing progress toward quantitative outcomes. Lane, L., et al. 2016. Practitioners Peer Exchange Environmental Justice Roadmap, American Association of State Highway and Transportation Officials, Available at: http://environment.transportation.org/pdf/2016_environmental_justice_peer_exchange/ejrm_1_v6.pdf. This report discusses the Environmental Justice Roadmap identifying key focus areas including the role and state of the practice for environmental justice (EJ) and collaboration across different agencies in transportation decision-making. Martens, K., and A. Golub. 2014. A Fair Distribution of Transportation Benefits: Interpreting Civil Rights Regulations for Transportation Investment Programs. Working Paper. 2014. https://drive.google.com/file/d/0B3t2rQGsCSW- dGFDVW5JT3I0UFk/view. Discusses 4 possible standards for determining whether impacts are disparate and reviews and categorizes the standards in use by the 10 largest MPOs. The paper particularly focuses on measures of accessibility and how accessibility may vary among COCs and non-COCs.

Literature Review A-47 Morris, A., and L. Fragala. 2016. NCHRP Synthesis 407: Effective Public Involvement Using Limited Resources, Transportation Research Board of the National Academies, Washington, D.C., Available at: http://www.trb.org/Publications/Blurbs/163992.aspx. This report summarizes a survey of agency perspectives on effective and cost-effective strategies and implementation techniques for public participation in the transportation projects. It includes a literature review and results of a survey of 26 agencies, most of which only have rudimentary processes in place for public involvement. The report then recommends an approach for involving the public. National Neighborhood Indicators Partnership, List of National Data Sets with Small-Area Data, 2017, Available at: http://www.neighborhoodindicators.org/library/catalog/list-national-data-sets-small-area-data. This is a list of public datasets compiled by the Urban Institute from federal and nonprofit sources that have data on small areas (point-level, census tracts, zip codes, etc.). The Excel spreadsheet contains basic information and links to the websites where the data is posted. PolicyLink. 2013. The Community Engagement Guide for Sustainable Communities. Available at: http://www.policylink.org/sites/default/files/COMMUNITYENGAGEMENTGUIDE_LY_FINAL%20%281%29.pdf. This document presents benefits of and guidelines for meaningful community engagement, including measures of success. PolicyLink. 2016. National Equity Atlas, PolicyLink and the USC Program for Environmental and Regional Equity, 2016, Available at: www.nationalequityatlas.org. The Atlas is a tool to provide and summarize data related to equity for policy and decision makers. The Atlas breaks down data along a number of demographic, equity, and economic indicators. It also aims to ensure transparency and open access, and makes all of its data and methodologies available for download. Ramey, C. 2015. America’s Unfair Rules of the Road: How our transportation system discriminates against the most vulnerable. Slate. February, 2015 [online]. Available at: http://www.slate.com/articles/news_and_politics/politics/2015/02/america_s_transportation_system_discriminates_aga inst_minorities_and_poor.html. A news article reporting on the results of a FOIA request to reveal Title VI complaints made to the FHWA. Summarizes the legal status, gives an overview of the different types of complaints, and gives in- depth interviews and personal stories relating to several cases. Reconnecting America. 2012. Denver Regional Equity Atlas, Available at: http://www.reconnectingamerica.org/resource- center/online-tools/map-room/denver-regional-equity-atlas/ (as of June 14, 2017). This website includes the background and summary material for Denver’s Regional Equity Atlas. The Atlas maps a number of equity measures, including transportation measures, over a range of demographic groups of interest as a visual and quantitative assessment of location and equity. Reconnecting America. 2013. Los Angeles Equity Atlas. Available at: http://reconnectingamerica.org/laequityatlas/20131101- laequityatlas-final.pdf (as of June 14, 2017). This website describes and documents Los Angeles’ Regional Equity Atlas. The document describes Los Angeles’ desired outcomes across all categories, including transportation and housing. The Atlas maps a number of equity measures over a range of demographic groups of interest as a visual and quantitative assessment of location and equity. Sanchez, T. W., and J. F. Wolf. 2005. Environmental Justice and Transportation Equity: A Review of Metropolitan Planning Organizations. Brookings Institution. Washington, DC. Available at: https://www.researchgate.net/profile/ Thomas_Sanchez/publication/230820724_Environmental_justice_and_transportation_equity_A_review_of_ metropolitan_planning_organizations/links/0fcfd50b5a04eda5a4000000.pdf. Reviews MPOs, and social equity issues related to their planning activities and political representation with a focus on 50 large MPOs. 3 “dimensions of this issue are reviewed: (1) efforts targeted at assessing the fairness of planning outcomes and promotion of social equity, (2) citizen participation in MPO processes, and (3) analysis of the extent to which MPO boards under-represent social, economic, ethnic/racial groups.” Relies on existing research but also “presents results of a recent survey to examine types of equity planning conducted by MPOs, forms of public participation efforts, as well as geographic representation of voting board members.” Reviewed MPO’s TIPs, MTPs, and state plans looking for “language codifying enforcement or monitoring of: (1) civil rights, (2) environmental justice, (3) social justice, (4) transportation equity, and (5) citizen participation activities.” Also reviewed racial/ethnic balance of the MPO boards compared to the regions they serve. Suhrbier, J. H., et al. 2002. NCHRP 08-36/Task 11: Technical Methods to Support Analysis of Environmental Justice Issues, Transportation Research Board of the National Academies, Washington, D.C., Available at: http://apps.trb.org/cmsfeed/TRBNetProjectDisplay.asp?ProjectID=1318. The report reviews the legal framework for environmental justice issues in transportation and discusses the state of the practice of technical approaches to the analysis. Includes ideas for data to supplement GIS and census data.

A-48 Equity Analysis in Regional Transportation Planning Processes Tomer, A., et al., 2011. Missed opportunity: Transit and Jobs in Metropolitan America, Brookings Institution, Washington, D.C., [online]. Available at: https://www.brookings.edu/research/missed-opportunity-transit-and-jobs-in- metropolitan-america/. The Brookings Institution conducted an analysis of transit access in the 100 largest metropolitan areas in the United States. The researchers analyzed data from 371 transit providers to measure employment accessibility via transit travel time in those areas. They also identify factors that affect how well transit serves to connect people to jobs, including land use patterns and how residents and employers choose their locations. Tomer, A. 2012. Where the Jobs Are: Employer Access to Labor by Transit. Washington, DC: Brookings Institution, Available at: https://www.brookings.edu/research/where-the-jobs-are-employer-access-to-labor-by-transit/. An update to the previous Brookings study, analyzing data from transit providers in the 100 largest metropolitan areas in the United States. The study found that while three-quarters of all jobs in those areas have transit service, only 27% of workers can access those jobs within 90 minutes by transit. The suburbanization of jobs has made it more challenging for transit to connect people to employment. U.S. EPA. 2008. Environmental Justice Collaborative problem-solving model, U.S. Environmental Protection Agency, Washington, D.C., [online]. June 2008, Available at: https://www.epa.gov/communityhealth/environmental-justice- collaborative-problem-solving-model. This report summarizes a collaborative problem-solving model using a seven- step approach that can be utilized for engaging COCs. It also identifies benefits of engaging the public. U.S. EPA. 2004. Toolkit for Assessing Potential Allegations of Environmental Injustice, U.S. Environmental Protection Agency, 2004, https://www.epa.gov/sites/production/files/2015-02/documents/ej-toolkit.pdf. U.S. EPA. 2017. Environmental Justice Screening and Mapping Tool. U.S. Environmental Protection Agency, Washington, D.C., [online]. Available at: https://www.epa.gov/ejscreen (as of June 13, 2017). A web-based mapping tool combining environmental and demographic indicators. The tool uses nationally consistent and publicly available data sets to display EJ Indexes, which are the combined environmental and demographic indicators. MPO Resources (Other than MTPs and TIPs) Metropolitan Council of the Twin Cities (Met Council) Corridors of Opportunity, Metropolitan Council. Available at: http://www.corridorsofopportunity.org/(as of June 6, 2017). Developed through the Partnership for Regional Opportunity for the Corridors of Opportunity project, the Community Engagement Team (CET) aimed to transform community engagement in the Twin Cities to ensure that COCs (low- income, communities of color, immigrant communities, and persons with disabilities) are empowered and equipped to participate in transit planning processes. Choice, Place, and Opportunity: An Equity Assessment in the Twin Cities Region, Metropolitan Council, March 2014. Available at: https://metrocouncil.org/Planning/Projects/Thrive-2040/Choice-Place-and-Opportunity.aspx. Developed as part of a Sustainable Communities Regional Planning Grant from U.S. HUD. Provides an overview of regional equity and access to opportunity and how these metrics should inform public policy and regional planning. As a result of this assessment, the Met Council plans to address equity through its investments in housing and travel choices, housing affordability along transit routes, and robust community engagement. Hoyt, S. 2013. Transit, More than a Ride: Trusted Advocate Pilot Project Evaluation, April 2013 District Councils Collaborative of Saint Paul and Minneapolis and Metro Transit. Available at: http://www.funderscollaborative.org/wp- content/uploads/2016/04/Trusted-AdvocateProjectEvaluation.pdf. Evaluation of a pilot project to increase participation by underrepresented communities in a study of the effectiveness of transit along a corridor in preparation for a new light rail line. Although quantitative data was limited, the report describes the process and examples of how it influenced agency decision making. Title VI Program In Compliance with FTA Circular 4702.1B, Metropolitan Council, January 2017. Available at: https://metrocouncil.org/About-Us/What-We-Do/Office-of-Equal-Opportunity/Discrimination-Complaints/Public- Service-Discrimination/Discrimination-and-Title-VI.aspx. The Met Council’s Title VI Program provides an overview of the MPO’s Title VI activities. Updated every three years, the report focuses on Met Council’s response to FTA Circular 4702.1B (because Met Council is also a transit operator) and provides a summary of activities occurring at the MPO to meaningfully engage with COCs and mitigate impacts.

Literature Review A-49 MTC Evaluation of the Plan Bay Area Public Outreach and Participation Program, Metropolitan Transportation Commission, December 2013, Available at: http://www.planbayarea.org/sites/default/files/pdf/Evaluation_Report_PBA_Outreach.pdf. Evaluates the program based on diversity (target audience demographics similar to region’s), reach (number of comments logged, number of individuals responding, number of visits to the website, and number of media mentions), accessibility (meetings in all 9 counties, transit-accessible, linguistically-accessible, and ADA-accessible), impact (all comments logged and conveyed), and participant satisfaction. Plan Bay Area 2035: Final Equity Analysis Report, Metropolitan Transportation Commission, July 2013. Available at: http://www.planbayarea.org/previous-plan/final-supplementary-reports-and-additional-resources. The Bay Area analysis, which uses the same mapped projects analysis and transit investment analysis as reviewed in the TIP. Regional Advisory Working Group, Metropolitan Transportation Commission [online]. Available at: http://mtc.ca.gov/about-mtc/what-mtc/mtc-organization/partnership-committees/regional-advisory-working-group [As of June 13, 2017]. Describes the make-up and participation of the Regional Equity Working Group in the MPO’s equity program. Plan Bay Area 2035, Appendix A-04 Equity Analysis Report, July 2013. Available at: http://mtc.ca.gov/sites/default/files/ A-04_FINAL_PBA_Equity_Analysis_Report.pdf. The Bay Area analysis, which uses the same mapped projects analysis and transit investment analysis as reviewed in the TIP. Title VI of the Civil Rights Act of 1964 Compliance Report, Metropolitan Transportation Commission, August 2014, Available at: http://files.mtc.ca.gov/pdf/title_vi/MTC_Title_VI_2014_Compliance_Report-Final.pdf. Describes MTC’s compliance with Title VI, including identification of and addressing mobility needs for minority groups, analysis of the TIP and public participation in planning processes and research and review of disparate impacts. Public Participation Plan, Metropolitan Transportation Commission, February 2015, Available at: http://mtc.ca.gov/about-mtc/public-participation/public-participation-plan. Describes MTC plan for public participation but doesn’t specifically explain how it will improve participation for COCs. NCTCOG Public Participation Plan: Engaging Diverse Audiences in Planning for Transportation and Improving Air Quality, North Central Texas Council of Governments, February 2015, Available at: http://www.nctcog.org/trans/outreach/involve/index.asp. Describes requirements for public involvement, notice, and comment periods for the development of and updates to the Public Participation Plan, the Unified Planning Work Program, MTPs, TIP, Transportation Conformity, FTA Funding, the annual listing of obligated projects, and the congestion management process. Discusses a process and options for improving engagement with traditionally underrepresented populations. RVMPO Transportation Needs Assessment for Traditionally Underserved Populations, Rogue Valley Metropolitan Planning Organization, March 2016, Available at: https://www.rvmpo.org/index.php/studies/needs-assess. Measures the equitability of transportation projects on servicing low-income, minority, young persons, and senior populations via a survey on impediments to transportation for these populations. Determined that lack of access to public transportation was a major impediment and that it was necessary to expand transit service both geographically and temporally to assist these populations. Also compared per capita and per household spending in the various COCs. Sustainable Communities Grantees Fair Housing Equity Assessments Chicago Metropolitan Agency for Planning (CMAP) and the Chicago Area Fair Housing Alliance. Fair Housing and Equity Assessment: Metropolitan Chicago. November 2013. Available at: http://www.cmap.illinois.gov/documents/10180/198094/Chicago%20Region%20FHEA%20November%202013%20H UD%20Submission.pdf/b0c6946e-4425-49fe-8d0a-f336903bc464/. The Fair Housing Equity Assessment (FHEA) was a requirement under a U.S. HUD Sustainable Communities Regional Planning Grant. The FHEA identifies regional

A-50 Equity Analysis in Regional Transportation Planning Processes housing disparities to identify opportunities for improving access to opportunity. The FHEA includes an overview of the historical and cultural context; analysis of racial segregation, poverty, and access to opportunity; and recommendations for advancing fair housing and equity. Denver Regional Council of Governments (DRCOG). Denver Region Fair Housing Equity Assessment. July 2014. Available at: http://milehighconnects.org/wp-content/uploads/2015/04/Fair-Housing-Equity-Assessment-2014.pdf. The Fair Housing Equity Assessment (FHEA) was a requirement under a U.S. HUD Sustainable Communities Regional Planning Grant. The FHEA identifies regional housing disparities to identify opportunities for improving access to opportunity. The FHEA includes an overview of the historical and cultural context; analysis of racial segregation, poverty, and access to opportunity; and recommendations for advancing fair housing and equity. Greater Des Moines Metropolitan Planning Organization. Greater Des Moines Regional Analysis of Impediments to Fair Housing Choice. 2014. Available at: http://www.thetomorrowplan.com/centraliowa/wp-content/uploads/2014/06/rai- dsm.pdf. The Fair Housing Equity Assessment (FHEA) was a requirement under a U.S. HUD Sustainable Communities Regional Planning Grant. The FHEA identifies regional housing disparities to identify opportunities for improving access to opportunity. The FHEA includes an overview of the historical and cultural context; analysis of racial segregation, poverty, and access to opportunity; and recommendations for advancing fair housing and equity. New York and Connecticut Sustainable Communities Consortium. Implementation Plan for Sustainable Development in the New York – Connecticut Metropolitan Region. May 30, 2014. Available at: http://www.sustainablenyct.org/ SCIImplementationPlan20140602Final.pdf. The consortium covers nine major cities in the New York and coastal Connecticut corridor. Transit oriented development (TOD) is the focus of the consortium around which there are some key planning objectives identified including improving regional scale planning, supporting the Sustainable Communities’ Livability Principles. Puget Sound Regional Council (PSRC). Fair Housing Equity Assessment for the Central Puget Sound Region. January 2014. Available at: https://www.psrc.org/sites/default/files/fairhousingequityassessment.pdf. The Fair Housing Equity Assessment (FHEA) was a requirement under a U.S. HUD Sustainable Communities Regional Planning Grant. The FHEA identifies regional housing disparities to identify opportunities for improving access to opportunity. The FHEA includes an overview of the historical and cultural context; analysis of racial segregation, poverty, and access to opportunity; and recommendations for advancing fair housing and equity. http://www.sacog.org/general-information/hud-regional-sustainability-planning-grant. Advancing SACOG’s planning efforts were supported by a major funding grant received from the U.S. Department of Housing and Urban Development (HUD). Key areas of improvement include fair housing programs analysis, further stakeholder engagement and development of sustainable development plan (MTP/SCS). Sacramento Area Council of Governments. Regional Housing Needs Plan 2013-2021. September 20, 2012. Available at:

Literature Review A-51 Endnotes 1. The U.S. DOT orders operationalizing E.O. 12898 define a “minority” individual as a person who identifies with one or more of the following categories: (1) Black: a person having origins in any of the Black racial groups of Africa; (2) Hispanic or Latino: a person of Mexican, Puerto Rican, Cuban, Central or South American, or other Spanish culture or origin, regardless of race; (3) Asian American: a person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent; (4) American Indian and Alaskan Native: a person having origins in any of the original people of North America, South America (including Central America), and who maintains cultural identification through tribal affiliation or community recognition; or (5) Native Hawaiian and Other Pacific Islander: a person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands. 2. “The FHWA and U.S. DOT EJ Orders define a “low-income” individual as a person whose median household income is at or below the Department of Health and Human Services (HHS) poverty guidelines. This differs from CEQ guidance on EJ, which suggests the use of U.S. Census Bureau poverty thresholds. The HHS website outlines key differences between HHS guidelines and Census guidelines.” (FHWA 2015 EJ Reference Guide) 3. Statutes protect from discrimination on the basis of age (42 U.S.C. § 6102), sex (23 U.S.C. § 324), handicap (29 U.S.C. § 790, repealed, Pub. L. 102-569, Title V, § 502(a), 106 Stat. 44424 (Oct. 29, 1992), or disability (42 U.S.C. §§ 12101- 12213). 4. Unexplained thresholds included those used by Charlotte County (27% low-income, 12.1% minority), CMAP (>50% minority), COMPASS (60% of median HH income, 30% Non-White/Hispanic), DRCOG (less than $15K per capita income), Met Council (40% are below 185% of poverty line), MARC (more than 20% of HH are in poverty); PSRC (11.3% poverty; 33.6% minority; 11.2% elderly; 11.4% persons with a disability); and Wichita (“high concentrations” in MTP; 50% minority or median HH income below poverty in TIP). 5. As measured by concentrations of people in poverty, Hispanic/Latino, Non-Hispanic Non-White minorities, limited English proficiency (LEP), persons with a disability, elderly, zero-vehicle households. 6. As measured by concentrations of people in poverty, carless households, non-Hispanic minority, physical disability, Hispanic, LEP, elderly, female head of household. 7. “minority persons, low-income persons below 200% of the federal poverty level (about $44,000 per year for a family of four), persons with limited English proficiency (LEP), zero-vehicle households, seniors aged 75 and over, persons with a disability, single-parent families, and housing units occupied by renters paying more than 50% of household income on rent.” 8. Wichita’s MTP categories: preservation, modernization, or expansion; TIP categories: road, bike/path, or bus route projects. 9. Example: Roadway capacity expansion. 10. Examples: Bike/ped facilities and streetscape improvements. 11. PSRC listed for each of eight types: bike/ped, highway capacity, multimodal capacity, preservation, safety/efficiency, transit capital and expansion, vehicles/equipment, and other. 12. MARC’s MTP compared average headways and total hours of transit service in COCs to non-COCs. 13. If it was from an MTP, then it was prioritization criteria. If from a TIP, then it was project selection criteria. 14. Although MPOs generally state that a project “benefits” a tract if it is adjacent to it, we anticipate our final guidance will recommend modifying this approach to reflect the concern that major projects may actually have severe net negative impacts on adjacent communities. 15. Ranking criteria recommended improvements for projects to earn points, including guidance on mitigation strategies to use to ensure the project has minimal impacts. Positive impacts are earned with transit improvements, safety enhancements, bicycle/pedestrian improvements; negative impacts would include displacement of residents or creating barriers.

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Transportation agencies that manage federally funded programs and projects are responsible for ensuring that their plans, programs, policies, services, and investments benefit everyone in their jurisdictions equitably.

The TRB Transit Cooperative Research Program's TCRP Research Report 214: Equity Analysis in Regional Transportation Planning Processes, Volume 2: Research Overview describes the results of the research effort and identifies ways in which equity in public transportation can be analyzed and adapted by Metropolitan Planning Organizations (MPOs) in partnership with transit agencies. This report discusses research findings and recommendations organized around a five-step equity analysis framework that is built upon a foundation of public involvement.

A separate report, TCRP Research Report 214: Equity Analysis in Regional Transportation Planning Processes, Volume 1: Guide is designed to help MPOs analyze and address equity effectively in long-range, regional, multimodal transportation planning and programming processes. The reports provide information about methods, tools, and resources that agencies can use to support plans and programs that are compliant with equity-related federal requirements.

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