Leveraging the U.S. Department of Transportation s Environmental Justice Strategy to Build Communities of Opportunity:

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1 Leveraging the U.S. Department of Transportation s Environmental Justice Strategy to Build Communities of Opportunity: Comments on the U.S. Department of Transportation s Draft Environmental Justice Strategy PolicyLink is pleased to offer comments on the U.S. Department of Transportation s (USDOT) Environmental Justice Strategy, issued in October As a leader in the movement to build more communities that are rich with opportunity, PolicyLink 1 is deeply invested in the implementation of strong policy guidance to foster fair and equitable transportation investments that benefit low-income people and communities of color. The USDOT has an important opportunity to leverage its transportation investments to build healthy, sustainable communities of opportunity places with quality schools, access to good jobs with familysupporting wages, affordable housing choices, safe and walkable streets, healthy environments, and strong social networks, among other assets. There are many steps that USDOT could take to that end. By investing in fuel-efficient vehicles and more environmentally-sustainable transportation facilities, air quality can be improved for residents burdened by poor health due to their proximity to intersections with heavy traffic, or by bus depots with outdated vehicles polluting the air. By expanding affordable public transportation services, as well as biking and walking infrastructure, communities that were once isolated from jobs, health services, and education can connect to these important resources that allow them to participate and prosper. Through careful development of transit-oriented communities, lowincome people and communities of color can live in inclusive communities with affordable housing and transportation options. These are just a few of the positive outgrowths of an approach to transportation investments that prioritize environmental justice. USDOT s draft environmental justice strategy re-affirms 2 that achieving environmental justice is part of the USDOT s core mission. Further, the strategy embeds environmental justice into two strategic priorities of the USDOT, namely, building livable communities and fostering environmental sustainability. Adoption and implementation of a comprehensive, department-wide strategy for achieving environmental justice is a critical endeavor for USDOT that requires a thoughtful process in order to achieve an effective final product. USDOT is to be commended for seeking to engage the public in a dialogue about the draft strategy with particular outreach to organizations and networks that focus on the needs of low-income communities and people of color. This dedication is mirrored in USDOT s overall environmental justice strategy, which lifts up the importance of meaningfully engaging low-income people and communities of color starting at the early stages of planning into and through implementation of all transportation projects whether it is a highway, transit, freight, pipeline, or passenger rail project. The environmental justice strategy also recognizes that it is essential to collaborate with local leaders, particularly those who serve low-income people and communities of color, to ensure that vital information is shared with the community that 1

2 would be affected by a proposed transportation project. PolicyLink strongly supports USDOTs commitment to inclusion of community voices in decision-making process. USDOT has an opportunity to build upon the excellent foundation provided in the draft environmental justice strategy and to strengthen it to ensure that the all USDOT investments bring broad benefits to all communities particularly low-income people and communities of color. To this end, we offer the following set of recommendations for how USDOT could strengthen its environmental justice strategy: 1. Focus on Achieving Outcomes that Advance Environmental Justice: USDOT s recognition of their responsibility to achieve environmental justice in its transportation investments is an important first step. USDOT should take this approach one step further and work to ensure that each modal administration develops a focused approach to leveraging federal transportation investments to achieve environmental justice. For example, USDOT could include environmental justice as one of the outcomes in its projects that receive federal funding. 3 Some important outcomes include: o Improved access to jobs for low-income people, seniors, and people with disabilities; o Reduced per capita transportation user costs for low-income individuals. o Safer streets for walking and bicycling particularly for low-income people and communities of color, who suffer disproportionate rates of injury and death. 4 o Improved air quality in communities that are overburdened by harmful air emissions. 2. Develop tools for evaluating progress toward achieving environmental justice: USDOT s strategy suggests that its transportation programs, policies, and investments should focus on several areas including: transportation access to jobs (particularly for those who do not have access to a vehicle or whom do not drive); quality of transportation systems near minority and low-income communities; climate change; and impacts and benefits from freight transportation. USDOT should also consider how wise transportation investment can reduce health disparities. In focusing on these areas, it will be important for USDOT to develop tools that can be used across all modes to measure progress toward achieving these outcomes. USDOT could seek to engage its Research and Innovative Technology Administration in this effort. Moreover, there are several tools under development that USDOT could consider: o The Environmental Justice in Transportation Toolkit 5 provides a host of resources including an accessibility calculator, a community communication assessment tool, and a proximity analysis. o The Environmental Justice Screening Method 6 assesses the cumulative impacts of various activities on low-income populations and communities of color, with a particular focus on hazard proximity and land use; air pollution exposure and estimated health risk; and social and health vulnerability. Given the impact of transportation on air quality and health, this tool is worth exploration. o Equity analyses of transit projects have been used to determine how low-income people and communities of color are impacted by transit projects. 7 However, such analyses 2

3 could be adapted to examine highways, freight corridors, and other modes of transportation. Such analyses could also be utilized to analyze the cumulative impacts of a series of transportation decisions. o There is growing recognition that transportation policy and investments influence community health outcomes. Nationwide, state, regional and local jurisdictions have been adopting a Health in All Policies approach to ensure that community development issues, such as housing, transportation, and economic development, maximize opportunities to achieve healthier, more equitable communities. In California, the state Department of Transportation is working closely with the state health department and other agencies to leverage demographic data and statistics to demonstrate links between public transportation, safe bicycle and pedestrian paths, mobility, and reductions in air pollution, and implementing plans to improve health through transportation policy. 8 o The U.S. Department of Housing and Urban Development plans to employ geospatial mapping and an Equity Assessment Pilot Project to measure their progress toward environmental justice. As these tools are developed, it will be critical to share these tools and the results of the analysis with the public so that they can meaningfully engage in USDOT s efforts to achieve its environmental justice goals. 3. Work to Achieve Synergy within the Department and with other Agencies: Within the USDOT, the Federal Transit Administration has done significant work to develop innovative approaches to achieving environmental justice. While roadways, transit, airports and seaports have unique challenges, we think that there are some significant benefits to having a harmonized approach particularly in the areas of public engagement and analysis of impacts to low-income people and communities of color. To achieve this synergy, we recommend that USDOT do an audit of its activities to assess: o The nature and type of impacts that USDOT activities have on low-income people and communities of color. o The level of alignment that exists between USDOT s overall mission, the mission of each modal administration, and the goals of environmental justice; and o The steps that would be needed to resolve any conflicts and/or competing interests and bring harmony to the mission of USDOT (and/or its modal administrations) and the goals of environmental justice. Additionally, multi-agency initiatives like the Partnership for Sustainable Communities provide an opportunity to break down silos across federal agencies that have been barriers to achieving environmental justice. For example, efforts to expand affordable rental housing stock, located near affordable public transportation has great potential to bring broad benefits to low-income people and communities of color. Moving forward, it will be important for USDOT to continue to work with other agencies to determine how they can collaborate to realize shared objectives 3

4 within each of their agencies environmental strategies. Key agencies for USDOT to target for this effort include: HUD, the Department of Health and Human Services, and the U.S. Environmental Protection Agency. 4. Continue to Engage the Low-Income People and Communities of Color: In issuing this environmental justice strategy, USDOT has utilized face-to-face meetings and online platforms to engage the public in a dialogue about its strategy. Moving forward, as USDOT seeks to finalize and implement the strategy, the department should articulate how it plans to maintain an ongoing dialogue about environmental justice with the public, and particularly low-income people and communities of color. For example, as USDOT takes the important next step of developing additional guidance on how each mode will implement environmental justice, the department should endeavor to share this guidance with the public and seek their input, particularly the stakeholders who have engaged in the dialogue about the overall strategy. In its proposed circulars on environmental justice and civil rights, the Federal Transit Administration outlined an excellent array of specific strategies for targeted outreach to and engagement of low-income people and communities of color, whom are often most impacted by USDOT activities. Furthermore, an important part of USDOT s efforts to achieve environmental justice will be to identify opportunities to achieve more equitable communities by directing federal transportation investments from all modes toward enhancing low-income communities and communities of color, which have been most impacted and have not received the benefits associated with investment. USDOT can start by leveraging its existing programs like TIGER and the Sustainable Communities Initiative to begin prioritizing equitable investments toward communities that need them the most. PolicyLink appreciates the opportunity to comment on USDOT s Draft Environmental Justice Strategy. We urge USDOT to move forward to revise and ultimately implement the strategy. In doing so, we encourage USDOT to incorporate the aforementioned suggestions, which are offered to ensure that all communities share fairly in the benefits and burdens of the plans and projects funded by the USDOT. We stand ready to assist you in that endeavor. 1 PolicyLink is a national research and action institute advancing economic and social equity by Lifting Up What Works. For more information on these comments, please contact Anita Hairston, Senior Associate, Policy Link at or anita@policylink.org. 2 This was previously affirmed in the USDOT Order in This is an approach that the U.S. Department of Housing and Urban Development is pursuing in its Environmental Justice Strategy. Specifically, HUD is using discretionary funds to build capacity among their fund recipients to help them explore and articulate the ways that can address environmental justice in their projects. 4 According to Transportation for America s report, Dangerous by Design, Blacks suffered fatality rates that were 73% higher than those of non-hispanic white pedestrians and Hispanics suffered fatality rates that were 62% higher than those of non-hispanic white pedestrians. Report downloaded from: 5 This toolkit was developed by several organizations in coordination with Morgan State University s School of Engineering and Institute for Urban Research. For more information, see: 4

5 6 This tool was developed Manuel Pastor, James Sadd, Rachel Morello-Frosch, Justin Scoggins and Bill Jesdale. For more information see: 7 There are several approaches to enhancing equity analyses to measure outcomes for low-income people and communities of color. Public Advocates, Urban Habitat, and the Bus Riders Union, provide some approaches in a white paper, titled: Civil Rights and Environmental Justice in Public Transportation: Proposed FTA Actions to Build on its Strong Record of Enforcement. 8 Executive Order S-04-10, establishes a Health in All Policies Task Force under the auspices of the Strategic Growth Council. The purpose of the Task Force is to identify priority programs, policies, and strategi es to improve the health of Californians while advancing the Strategic Growth Council s goals of improving air and water quality, protecting natural resources and agricultural lands, increasing the availability of affordable housing, improving infrastructure systems, promoting public health, planning sustainable communities, and meeting the state s climate change goals. More information is available at: 5