Environmental Justice & CRCOG's Transportation Planning Program

FINAL REPORT

This report contains an evaluation of how CRCOG addresses environmental justice & social equity issues in its transportation-planning program. It also includes an Action Plan with specific recommendations on how CRCOG can improve the way it addresses these issues through increased involvement of minority and low-income communities, and through better quantitative methods for evaluating the benefits and impacts associated with transportation projects it recommends.

ENVIRONMENTAL JUSTICE & TITLE VI CHALLENGE GRANT

December 2002

Capitol Region Council of Governments
241 Main Street, Hartford, CT 06106 (860) 522-2217 www.crcog.org

CONTENTS

• Goals of CRCOG's Challenge Grant Project
• Summary of the Action Plan
• Organization of the Report
• Principles of Environmental Justice

• Minority Population
• Low-Income Population
• Transportation Disadvantaged - No Access to a Car

• Evaluating CRCOG's Program through Community Workshops
• Workshop 1: Getting Started
• Workshop 2: Community Critique of Prior Planning Project
• Workshop 3: Conversations on Planning Process & Community Needs
• Workshop 4: Preparing an Action Plan for Improving the Planning Process
• Conclusions - How to Better Involve Minority Communities
• More Effective Outreach to Target Communities
• More Effective Input into Core Decision-Making

• Goals: easy to apply, easy to understand, helpful to decision makers
• Task 1 - Define Target Areas
• Task 2 - Equity Assessment of the TIP
• Task 3 - Equity Assessment of the Transportation Plan

• Action Plan for Improving the CRCOG Transportation Planning Program
• Status of Action Plan Implementation & Commitment to Future Actions

List of Figures

2.1 Capitol Region
2.2 Distribution of African-American Population
2.3 Distribution of Hispanic Population
2.4 Distribution of Minority Population
2.5 Distribution of Persons below Poverty Level
2.6 Distribution of Persons below 150% of Poverty Level
2.7 Distribution of Households without Access to a Car
4.1 Potential Minority Target Areas: 50% Threshold vs. 27% Threshold
4.2 Low-Income Target Area Based on 30% Threshold
4.3 Low-Income Target Area Based on 20% Threshold
4.4 Map of TIP Projects & Target Area

1. INTRODUCTION

In early 2001, the Capitol Region Council of Governments (CRCOG) was one of four agencies from across the nation selected to participate in a federal Environmental Justice Challenge Grant program. The purpose of the challenge grant was to allow each of the four planning agencies to thoroughly assess how well their transportation planning programs met the goals and requirements of Title VI and environmental justice, and to identify ways to improve how their planning programs involve minority communities and address the needs of those communities. CRCOG has spent the past year conducting that evaluation and developing an Action Plan for improving our planning process.

This report documents the results of the yearlong evaluation process. Specifically, the report includes the following:

1. documentation of how CRCOG evaluated the effectiveness of our transportation planning process in meeting environmental justice and Title VI requirements;
2. a summary of the results of that evaluation; and
3. an Action Plan for improving our effectiveness in meeting environmental justice goals.

GOALS OF THE CRCOG'S CHALLENGE GRANT PROJECT

The ultimate goal of our Challenge Grant project is to improve our transportation planning process to assure that we give full and fair consideration to the needs of minority and low-income residents. To accomplish this goal we established three specific objectives for the Challenge Grant project:

1. Community Profile. Develop a profile of the target communities - most importantly low-income and minority communities. The first objective was to develop a good up-to-date profile of the target communities using 2000 Census data and our Geographical Information system (GIS) to map the distribution of target groups.
2. Community Involvement. Develop recommendations for increasing low-income and minority community involvement in all phases of CRCOG's transportation planning process - including core decision-making functions. This was the primary objective of the project. We wanted to move beyond the community outreach efforts used in our transportation studies, and develop ways of involving minority community representatives directly in our decision-making process.
3. Equity Assessment Methods. Develop quantitative methods that CRCOG can use to assess the distribution of benefits associated with its transportation programs relative to target communities. These methods will help assess whether minority and low-income communities are receiving a fair share of benefits, or a disproportionate share of burdens.

The Action Plan is the culmination of the Challenge Grant project and assures that CRCOG will give full and fair consideration to the needs of minority residents as we conduct our transportation planning process. The recommendations in the Action Plan are a direct response to the lessons we learned during our yearlong evaluation process. They address nearly the full spectrum of the planning process from the basic structure of our Transportation Committee that oversees our core functions, to special studies, to project selection, and to the development of the regional transportation plan and the TIP. Key recommendations include:

• form an Environmental Justice Advisory Board to regularly review CRCOG programs,
• appoint a member of the Board to CRCOG's Transportation Committee to assure direct access to the core transportation decision-making group,
• improve our outreach efforts to minority communities during special studies,
• improve our outreach efforts to minority communities during development our primary products such as the Transportation Improvement Program (TIP) and the Regional Transportation Plan,
• develop equity assessments methods to evaluate the TIP and Regional Transportation Plan, and
• form a transit users advisory group.

The most important aspect of the Action Plan is the focus on a process-oriented strategy rather than project-oriented one. We also chose to place more emphasis on improving how we involve the minority and low-income communities in our planning program, and less on developing quantitative methods for assessing transportation needs, benefits, and burdens. This focus on process and community involvement fosters regular re-evaluation, refinement, and improvement of our planning program as it affects low-income and minority communities. Quantitative assessment methods are addressed, but we are more concerned that a process be in place that assures the equity assessment data can be used productively.

CRCOG's primary objective in Challenge Grant project was to improve our transportation planning program to assure that we adequately address the needs of low-income and minority populations. We took a major step toward accomplishing that goal with the adoption of our Action Plan. Many of the recommendations in the Action Plan have already been implemented, and we expect to implement the remainder of the recommendations within the next year.

This report documents the results of our initial evaluation and initial set of recommendations. It should not be viewed as the end of the CRCOG's efforts in this area. We consider this to be the first phase in a continuing effort to evaluate and improve the way we address the issues of low-income and minority communities. We fully expect that as we gain experience implementing the initial set of recommendations, we will find ways to further improve our planning process and assessment techniques.

ORGANIZATION OF THE REPORT

• Chapter 2: Presents a profile of minority and low-income communities in the Capitol Region.
• Chapter 3: Presents an evaluation of how well CRCOG involves these communities in its planning process, and how we can achieve more effective and meaningful community involvement.
• Chapter 4: Identifies quantitative methods that CRCOG can use to assess the equity of the distribution of benefits associated with its transportation projects and programs.
• Chapter 5: Outlines an action plan for improving CRCOG's transportation planning program.

PRINCIPLES OF ENVIRONMENTAL JUSTICE

The term environmental justice was created by people concerned that everyone within the United States deserves equal protection under the country's laws. By equal protection it's meant that no group bears more than its share of negative environmental, social or economic effects, and no group receives less than its share of benefits. Environmental justice is not a new concept. It has its roots in Title VI of the Civil Rights Act of 1964. Title VI bars intentional discrimination as well as disparate impact discrimination. In 1994, President Clinton took this one step further by issuing Executive Order 12898, commanding all Federal agencies to implement environmental justice.

Civil Rights Act of 1964, Title VI "No person in the United States shall, on the ground of race, color, or national origin be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance."

Executive Order 12898, Environmental Justice "Each federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations."

The U.S. Department of Transportation (USDOT) also issued its DOT Order to Address Environmental Justice in Minority Populations and Low-Income Populations in 1997. It identified environmental justice as an "undeniable mission of the agency" along with safety and mobility. USDOT stresses three principles of environmental justice:

The Federal Highway Administration (FWHA) and the Federal Transit Administration (FTA) have been working with their State and local transportation partners to make sure that the principles of environmental justice are integrated into every aspect of their transportation programs.

Title VI and environmental justice are more than a set of legal and regulatory obligations. Properly implemented, environmental justice principles and procedures improve all levels of transportation decision-making. This approach will:

• Make better transportation decisions that meet the needs of all people.
• Design transportation facilities that fit more harmoniously into communities.
• Enhance the public-involvement process, strengthen community-based partnerships, and provide minority and low-income populations with opportunities to learn about and improve the quality and usefulness of transportation in their lives.
• Improve data collection, monitoring, and analysis tools that assess the needs of, and analyze the potential impacts on minority and low-income populations.
• Partner with other public and private programs to leverage transportation-agency resources to achieve a common vision for communities.
• Avoid disproportionately high and adverse impacts on minority and low-income populations.
• Minimize and/or mitigate unavoidable impacts by identifying concerns early in the planning phase and providing offsetting initiatives and enhancement measures to benefit affected communities.

2. PROFILE OF MINORITY & LOW-INCOME POPULATIONS

This section provides an overview of the geography and demographics of the Capitol Region. More importantly, it provides a profile of minority and low-income communities within the region. The equity performance measures developed in Chapter 4 are based on the socioeconomic and demographic data presented in this chapter.

REGIONAL OVERVIEW

The Capitol Region is composed of 29 municipalities in the Hartford metropolitan area. Hartford is the core city of the Capitol Region and also is the capital city of Connecticut. Hartford contains 28% of the region's jobs and 17% of its population, but its land area is very small (18 square miles).

The region includes approximately 760 square miles, has a population of just over 720,000, and an employment base of about 440,000 jobs. Figure 2.1 shows the 29 towns and cities that form the Capitol Region.

MINORITY POPULATIONS

Minority groups in the Capitol Region comprise about 27.5% of the entire population. The racial and ethnic composition of the minority population in the Capitol Region is shown in Table 2.1.

The predominant minority groups in the Capitol Region are African-Americans and Hispanics. These groups comprise 12.2 percent and 10.7 percent of the region's population, respectively. Combined they account for almost 84% of the minority population within the Capitol Region.

In an effort to better understand the geographic distribution of the minority communities in the Capitol Region, we color-coded and plotted the percentage of minority population in each Census block group within the region. These maps show a concentration of minority populations in the central city and within the "inner ring" communities.

African-Americans. African-Americans make up 12.2% of the total Capitol Region population and are about 45% of the Capitol Region minority population. Geographically, the African-American population

Hispanics. Hispanics make up 10.7% of the total Capitol Region population, and comprise 39% of the Capitol Region minority population. As shown in Figure 2.3, the Hispanic population is concentrated in the southern and northeastern sections of Hartford. There are also significant numbers of Hispanic residents in the southeastern corner of West Hartford, and the central section of East Hartford.

All Minorities. When all minority populations are combined, they comprise 27.5% of the Capitol Region population. The geographic distribution of all minorities is shown in Figure 2.4. There is a high concentration (where minorities comprise 50% or more of a block group's population) in Hartford and the inner suburbs - especially those north and east of Hartford. Minority residential areas in the suburbs include southeastern West Hartford, southern Bloomfield, southern Windsor, eastern East Hartford and a portion of Manchester.

LOW-INCOME POPULATION

While the federal government provides an official definition of poverty, there is no officially accepted definition of low-income. For purposes of this report, we have provided statistics for two possible definitions of low-income: the federally defined ‘poverty’ level, and another less strict definition based on households earning up to 50 percent more income than allowed under the poverty definition. Both definitions have the advantage of readily available data published by the Census. The income cutoff levels for both definitions are provided in Table 2.2.

Based on these definitions, the region’s low-income population is significantly smaller than its minority population. Nine percent of our residents live at or below the poverty level, and 14.2 percent of our residents have incomes at or below the 150-percent poverty level. By comparison, the percentage of minority residents is 27.5 percent, or nearly twice that of low-income residents.

While the numbers of low-income residents are much smaller than those of minority residents, there is some similarity, but not a close correlation in the distributions of the two populations. The greatest commonality is a concentration of both low-income and minority residents in the central city of Hartford. However, the low-income population is more dispersed with a scattering of low-income residents in many of the region’s towns. The distributions are discussed in more detail below.

Below the Poverty Level. The percentage of persons living in households with an income below the poverty level threshold for each Census block group is shown in Figure 2.5. The greatest concentration of residents living below the poverty level is within the City of Hartford, with some smaller clusters in the older more urban sections of suburban towns like East Hartford, Manchester, and Vernon.

Below 150% of the Poverty Level. The second definition of low-income is based on a household earning up to 50 percent more than the federally defined poverty level. The distribution of low-income persons based on this higher threshold is shown in Figure 2.6. While there is still a concentration of low-income persons in Hartford, the distribution of is more dispersed given this higher income threshold. In addition to the older suburban areas, there are also small numbers (10-20%) of low-income persons in some outer suburban and even rural areas.

TRANSPORTATION DISADVANTAGED - NO ACCESS TO A CAR

3. INVOLVING MINORITY & LOW-INCOME COMMUNITIES
IN CRCOG'S TRANSPORTATION PLANNING PROCESS

CRCOG has a positive history of involving low-income and minority communities in our planning projects and programs. We have undertaken initiatives like the Jobs Access Transportation Program that improved and expanded the transit system's ability to serve the needs of low-income workers. We have also been successful in getting the active participation of minority communities in some of our special transportation studies. However, this is still a limited cross section of CRCOG's full program of transportation planning activities. We recognize that despite our success in some activities, there are other areas in which we need to improve the level of minority community involvement.

When we applied to participate in the Challenge Grant program, it was with the intention of examining all of our basic planning activities to see if there were ways to increase the participation of minority and low-income communities in the full range of CRCOG activities. Our goal was to examine all aspects of our planning program to identify ways to allow more minority community involvement. While we had made progress in special projects like the Jobs Access Program and special corridor studies, we felt that there was opportunity to increase involvement in some of our core decision-making activities like adoption of the TIP, project selection, and development of the Regional Transportation Plan. Since these are controlled primarily through our Transportation Committee, this meant we also had to examine the structure of that Committee.

EVALUATING CRCOG'S PROGRAM THROUGH COMMUNITY WORKSHOPS

CRCOG's original intention was to conduct our transportation program evaluation with a special committee composed of representatives of the minority and low-income communities as well as representatives of other agencies involved in transportation decision-making. Our strategy was to work with a select group over the course of a year to review our full range of transportation planning and programming activities. However, we radically changed our approach after just one meeting when it was apparent that the approach would not work. Based on the response to the first meeting (workshop), we determined that it would be impractical to expect a single group of individuals to sustain their interest in this review process over the course of a year. We decided that a more practical approach was to reach out to a greater number of people through a series of workshops designed to accomplish the same comprehensive review process.

Our revised approach was to conduct a series of workshops in minority neighborhoods at which both the topics and the attendees varied. At each workshop, we reviewed one or more aspects of our transportation planning program. After an initial presentation on how we conduct certain planning activities, we engaged the participants in a discussion of how we might improve the way we conduct those activities to: (1) encourage more participation from the minority community, (2) do a better job of identifying and addressing issues of concern to the community, and (3) do a better job of informing the community.

A summary of each workshop is presented below along with conclusions regarding how we might improve our planning program.

WORKSHOP 1: GETTING STARTED (April 3, 2001)

This workshop was the first and only meeting of the Environmental Justice Challenge Grant Steering Committee. While the committee approach was discontinued after this meeting in favor of the workshop approach, there were some lessons learned that have been incorporated into the final action plan.

The Committee meeting was held on April 3, 2001 from 10:00 AM to 12:00 noon. The Committee met in the Safety Training Center Conference Room at the Greater Hartford Transit District's offices at Union Station in downtown Hartford. The site was selected because it is in a central location (in the central business district), and it has good transit access.

The Steering Committee itself was selected to include a cross section of minority and low-income communities in the region as well as to assure that we had good geographic coverage of the City of Hartford. We asked CRCOG staff members and associates of CRCOG for suggestions on whom to invite to the Committee. Some of the names suggested had no prior involvement with CRCOG. Initially this was considered an advantage since persons not affiliated with CRCOG might be able to provide a more objective evaluation as we reviewed each element of our transportation program. In hindsight, this lack of affiliation with CRCOG was probably one of the reasons we had poor attendance at our first workshop. Since most of the people we invited were community leaders with busy schedules, there was little incentive for them to attend a meeting when they did not have any prior relationship with CRCOG.

The meeting itself was intended to be an introductory meeting that reviewed the purpose and scope of the Challenge Grant project and established time and place for future meetings. However, the poor attendance at the meeting caused us to reassess our approach to community involvement on this project. CRCOG staff conducted a post-meeting critique and reached some conclusions regarding the reasons for poor attendance. They are presented below as lessons learned.

Lessons Learned

• Early Evening Meetings More Convenient. Of the 10 persons who attended the meeting, most were representatives of transportation agencies or social service agencies who could attend the meeting as part of their job. While the midday meeting time was convenient for them, it was not convenient for most of the community leaders we invited. It was decided that future meetings would be held in the early evening.
• Neighborhood Meeting Places Preferred. The downtown location was central and easily accessible by transit, so this was probably not the primary reason for poor attendance. However, we still concluded that we stood a better chance of having community and neighborhood leaders attend if we held the meeting in one of the neighborhoods. The risk in this approach is that we might discourage attendance from neighborhoods located across town from whatever neighborhood we chose for a meeting site.
• Work with Persons Who Have a Stake in the Process. Perhaps the most important lesson learned is that it is extremely hard to get persons with no affiliation with CRCOG to commit to a series of meetings that are focused on evaluating CRCOG programs. They have no stake in CRCOG, and find it difficult to see how their attendance can benefit them or their community. We decided that we needed to focus more on individuals, neighborhoods, and organizations that had some prior or current involvement with CRCOG. They were more likely to see some potential benefit to themselves, or at least feel a sense of responsibility to attend.
• Workshops Might Draw Broader Audience. The poor attendance at the first meeting gave us reason to reconsider whether conducting the evaluation with a single committee with fixed membership was best. We decided to discontinue the committee approach in favor of a workshop approach that allowed us to reach a larger audience. The disadvantage of the workshop approach is the potential lack of continuity of participants throughout the process.

WORKSHOP 2: COMMUNITY CRITIQUE OF PRIOR PLANNING PROJECT (June 25, 2001)

The second workshop was held on June 25, 2001 from 5:30 PM to 7:30 PM. The committee met at the Artist Collective on Albany Avenue in Hartford. A light supper was served. The purpose of the workshop was to evaluate how CRCOG conducted its special studies. In this case, we proposed to evaluate the Albany Avenue corridor study we had completed several years prior.

The time and location of the meeting were selected in response to the lessons learned in the first workshop. The start time of 5:30 pm was used since many neighborhoods residents could stop on their way home from work. The adjournment time was set at 7:30 pm to allow participants to still be able to enjoy most of the evening at home.

Since we were focusing on the Albany Avenue study, it made sense to hold the meeting in the Upper Albany neighborhood. The Artist Collective was selected as the meeting place because it was a well known institution in Hartford and the neighborhood, and it offered new and comfortable meeting facilities, convenient parking, and good transit access.

• Light supper & welcome
• Review of community involvement efforts on Route 44 (Albany Avenue) corridor study
• Group discussion & critique of the Route 44 corridor study community involvement process
• Presentation on CRCOG's upcoming Griffin Busway Study
• Suggestions for developing a community involvement process for the Griffin study

Purpose of the Meeting

The workshop was held to review and evaluate CRCOG's public involvement efforts in Hartford on the Route 44 (Albany Avenue) corridor study. Albany Avenue crosses several predominantly African American neighborhoods in Hartford, so outreach to the African American community was an important part of the study.

A second purpose was to seek suggestions on how to organize the community involvement efforts for the Griffin Busway Feasibility Study. The proposed busway crosses many of the same neighborhoods as Albany Avenue; therefore the critique of the Albany Avenue study could yield valuable insights on how to improve our community outreach for this second study.

Invited Participants & Efforts to Increase Attendance

Our goal was still to get good representation of minority and low-income groups, but we also recognized that this workshop was focused on a study that involved several African-American neighborhoods in the northwest section of Hartford. Therefore, in addition to the mailing list that we used for the first workshop, we added names of individuals or organizations from the affected neighborhoods.

In advertising this workshop we stressed the need to evaluate the work previously done in the Albany Avenue neighborhoods and the opportunity for early input to the upcoming Griffin study. We were attempting to show the relevance of the workshop in order to encourage better attendance. We also made personal phones calls to everyone on the mailing list and made personal appeals to persons we had worked with previously.

As further enticement to attend, we tried to select a convenient time (5:30 - 7:30 pm), set a time limit, offered a light supper, and held the meeting at a well known and convenient neighborhood location.

Presentation of Community Involvement Effort on Albany Avenue Study

There was a 20-minute presentation on the Route 44 corridor study and CRCOG's efforts to involve the neighborhoods along Albany Avenue. A CRCOG staff member explained the project's early efforts relied on a 'regional' approach to public involvement. He then explained how CRCOG modified its approach and adopted a neighborhood-level approach to achieve more effective community involvement.

Group Discussion on Albany Avenue Study

Joyce Hamilton of Democracy Works acted as facilitator for a group discussion. The purpose of the discussion was to critique CRCOG's efforts and suggest ways to improve the community outreach effort. The following are key points from that discussion.

Lessons Learned

• Adopt a Neighborhood Approach to Public Involvement
  . Unlike most suburban towns, the City of Hartford has very strong neighborhood organizations. A community involvement program in Hartford should be neighborhood based. CRCOG's initial approach in the Albany Avenue (Route 44) study was to use a regional approach since it was a multi-town study. Early public meetings were set up to serve two or more towns and proved to be ineffective. CRCOG switched its approach to focus on individual towns. In Hartford, we eventually moved to an even smaller scale approach with a focus on individual neighborhoods.

The workshop participants commended CRCOG for recognizing its initial mistake and changing to a neighborhood approach. They suggested that any future studies in Hartford need to be neighborhood based.

• Involve All Neighborhoods. In the Albany Avenue study, CRCOG worked primarily with two neighborhoods most affected by the study. Workshop participants pointed out that we should have involved any neighborhood study area, even if it is just a small portion of the neighborhood falls within the study area.
• Add Neighborhoods to Advisory Committee. CRCOG typically sets up local advisory committees for its studies. When setting up a local advisory committee in Hartford, we should make sure the committee is composed of representatives from the neighborhoods, not just City leaders and City staff. We should not assume that City officials can adequately represent neighborhood interests.
• Suggestions for More Effective Outreach.
• Advertise Through Neighborhood Organizations. Neighborhood and church groups can be effective at publicizing meetings and helping build community interest. We need to work more closely with these groups to advertise meetings through their newsletters and announcements at their meetings. Another option is to offer to pay postage if these groups will send out flyers/meeting announcements under their letterhead. With a neighborhood group's letterhead, residents are more apt to read the announcement than if it comes from an unfamiliar regional agency.
• Neighborhood Organizations & Small Group Meetings. The participants felt strongly that in the early phase of a study CRCOG needs to reach out to the community as widely as possible, but to do so through informal small group meetings, rather than formal public meetings. Attending regularly scheduled meetings of neighborhood and church organizations is one way to accomplish this. Small group meetings like these can be good opportunities since you are guaranteed an audience, and the audience is typically one with strong civic interests. A small group meeting is also more conducive to good discussion.
• Build Trust. There is no formula for this, but workshop participants emphasized the issue of building community trust. In the Albany Avenue study, that trust was eventually won because CRCOG was able to show that they had incorporated the community's input from earlier meetings. This was one way to show good faith. It demonstrated that CRCOG was truly listening to community input. It was also suggested that small group meetings such as the ones recommended above are another way to talk more directly to people and gain their trust.

WORKSHOP 3: CONVERSATIONS ON PLANNING PROCESS & COMMUNITY NEEDS (Feb. 20, 2002)

The third workshop was held on February 20, 2002 from 5:30 PM to 8:00 PM. The meeting was held at the Connecticut Puerto Rican Forum on the south side of Hartford.

The time of the meeting was similar to the second workshop since that was successful. The location was shifted from the north side of Hartford to the south side of Hartford in an attempt to encourage greater participation from Hartford's Hispanic community, which is concentrated on the south side. We also chose the Puerto Rican Forum as the meeting place since it is a well-known institution in the Hispanic community. We used the same mailing list as the previous workshop, but worked with the Puerto Rican Forum to add additional names of persons from the Hispanic community. Parking was less convenient at this location, but it was available and the location was also accessible by bus.

Purpose of the Meeting

The purpose was twofold: (1) to evaluate aspects of CRCOG's planning program other than special studies which were reviewed in Workshop 2, and (2) to gather input into the development of the next regional transportation plan. On the second point, we hoped that a discussion of the planning process might help identify transportation issues that were important to Hartford's low-income and minority residents and the agencies representing them. If issues of particular importance to the community could be identified, we could incorporate the issues into the next update of the regional transportation plan.

• Light supper & welcome
• Environmental Justice/Title VI discussion
• Overview of CRCOG's transportation planning program and the Regional Transportation Plan
• Group discussion:
• Comments on the planning process
• Transportation issues of importance to workshop participants

A CRCOG staff member gave an overview of CRCOG's transportation planning program. To make the presentation relevant to participants, we used a lot of familiar Hartford projects as examples. We explained how the projects originated, how they were selected for funding, and the various steps involved such as corridor studies, the TIP, and the transportation plan. The role of the transportation plan was emphasized as the key starting point where transportation needs and issues are often first identified.

Kerry Colvin, a CRCOG staff member and manager of the Challenge Grant project, acted as facilitator for a group discussion. One purpose of the discussion was to critique CRCOG's planning program. But the more important objective was to identify transportation issues of importance to the African American and Hispanic communities. The following are key points from that discussion.

Lessons Learned - Ways to Improve CRCOG Planning Process

• Better Ways to Communicate. Workshop participants offered several suggestions for improving the way CRCOG communicates with the public. Besides neighborhood associations CRCOG can reach out to communities as follows:
• Place meeting announcements on buses and at bus shelters. Residents felt that using bus shelters to post public meetings would increase attendance.
• Create problem-solving groups.
• Televise meetings on local access cable TV stations.
• Post meeting notices on local access cable TV stations.
• Re-examine Committee Structure & Funding Allocation. Workshop participants questioned whether CRCOG's structure allowed for adequate representation of Hartford and whether or not Hartford got its fair share of projects. We agreed that we needed to review this issue further.

  Subsequent to this workshop we recognized that the issue is probably better framed as whether or not minority groups have adequate representation on CRCOG committees and whether or not they get a fair share of transportation 'benefits.' This is discussed further in the assessment methodology section, the Action Plan section, and the summary of the fourth workshop.

• Invite Environmental Justice Organizations. This workshop benefited from the participation of the Hartford Environmental Justice Network (HEJN). We were fortunate enough to have an existing group in the area that was formed to address environmental justice issues. The group's focus had been primarily environmental health issues, but we felt the organization might still be interested in expanding its activities into the field of transportation. We met with the group's director and he decided that the HEJN would participate in the evaluation process. Since they were already familiar with the general principles of environmental justice, they were important contributors to the discussion at this third workshop.

Lessons Learned - Transportation Issues Important to the Community

The following is a list of issues that participants identified as being significant to Hartford residents. Additional details are available in the meeting minutes provided in the appendix.

• Clean fuel buses. Residents would like to see alternative fuel vehicles used on the busway project as well as in the CT Transit fleet. There is a strong interest in reducing diesel vehicle emissions, which participants feel pose a health hazard to city residents.
• Conclusion: The issue of clean fuel buses should be identified and addressed in the regional transportation plan.
• Transit service. Transit service is an important issue for city residents and this was discussed at length. Suggestions included better bus stops, better advertising of new services, continuation of the L-Route service, better access to daycare, and easier access to bus schedules.
• Conclusion: Identify Issue in Plan. The need for better transit service needs to be identified in the regional transportation plan as a critical issue for the region's minority communities.
• Conclusion: Form Transit Users Group. Based on the strong interest in basic service and operational issues, there is a need to form a transit users advisory group to provide a forum for the discussion of problems with the existing service and unmet transit needs of transit dependent residents.
• Bicycle Travel in the City. Some participants in the workshop noted how difficult it was to ride a bike in the City and that some City residents use a bike for basic travel purposes. They offered some suggestions on how to make it easier and to promote more bicycle travel.
• Conclusion: Identify Issue in Plan. The need for safer bicycle travel in the City to be identified in the regional transportation plan as a significant issue for the region's minority communities.

WORKSHOP 4: PREPARING AN ACTION PLAN FOR IMPROVING THE PLANNING PROCESS

The fourth workshop was held on May 14, 2002 at the South Congregational Church in downtown Hartford. It was held from 12:00 noon to 1:30 pm.

The midday meeting and central location reflects the change in emphasis at this late stage in the evaluation of our planning program. We felt we had learned enough from the previous workshops that we were able to draw conclusions on what parts of our planning process were most in need of improvement, and to draft some preliminary recommendations on how to address them. We wanted to start working with a core group of participants to finalize the recommendation. It was also our intention to make this group the core members of the permanent advisory board that we proposed to form.

• Lunch & welcome
• Presentation of conclusions and recommended action plan
• Group discussion
• Endorsement of preliminary action plan

For this final workshop, we wanted to assemble a group of people that would form the nucleus of the future Environmental Justice Advisory Board. With this in mind, we invited persons who had indicated both an interest in the process as well as a commitment to devote the time for 2-3 Board meetings per year. Most participants were selected from the list of attendees at the prior three workshops. We also invited a few members of CRCOG's Transportation Committee and Policy Board.

One of the goals of the Action Plan is to allow the minority communities to have more direct input into CRCOG's planning process. We felt this could be facilitated by having CRCOG committee members sit on the same Board with community representatives and engage in the same discussions of how to improve our planning process. This objective was also advanced by the related recommendation in the Action Plan to have a member of the Advisory Board sit on the Transportation Committee.

A CRCOG staff member gave an overview of the Challenge Grant project to date with special emphasis on previous workshops and lessons learned. A preliminary Action Plan for improving CRCOG's transportation planning process was presented. Key elements are listed below. The complete Action Plan is provided in chapter 5.

Key elements of Action Plan
1. Formally establish an Environmental Justice Advisory Board.
2. Appoint a member of Advisory Board to the Transportation Committee.
3. Expand special outreach efforts.
4. TIP - assess benefits, plus improve outreach efforts.
5. Transportation Plan - assess benefits, plus improve outreach efforts.
6. STP-Urban Funding Program - continue use of environmental justice criteria.
7. Establish transit users advisory group.

A special presentation was made on the TIP and the proposed method for assessing benefits of the programmed projects. The presentation on the TIP also included a proposal on how to define the target areas to be used for assessment of benefits.

Group Discussion & Actions

Since most of the participants had taken part in prior workshops, they understood the rationale behind the key elements of the Action Plan. The group readily endorsed all of the recommendations, with the exception of the procedures for assessing the TIP. The TIP assessment procedures were endorsed by the group, but with the comments or suggestions listed below. For a more complete explanation of the assessment procedure, see Chapter 5.

• Target area definition - The group agreed that the target area for assessment purposes should be defined as encompassing those zones in which the minority population exceeded 50 percent.
• Define 'Positive' Impact - The group asked that we provide a clear explanation of how we determine if a project is apt to have a positive impact on low-income or minority communities.
• Better TIP Format - A suggestion was made to produce the TIP in a format that is easier for the layman to understand.

Lessons Learned

Since the purpose of this meeting was to gain endorsement of the proposed Action Plan, we were not actively soliciting ideas on ways to improve our program. Nonetheless we can draw two conclusions from the meeting.

• Better TIP Format. If we really want to have more community response to the TIP, we need to develop a document format that is more understandable to lay persons. It was pointed out that even the document title of Transportation Improvement Program does not give a clear idea of what the purpose of the document is. A better title might be something like 'Transportation Projects in the Hartford Area.'
• Midday Meetings Can Work for Some Groups. Whereas midday meetings proved unsuccessful when we were trying to attract the general public, this midday meeting was successful. In this case, we were targeting a different audience. The persons invited were all people who had some affiliation with CRCOG or who had already demonstrated a commitment to the environmental justice project through their attendance at previous meetings. Furthermore, prior to setting the meeting time, we surveyed the participants to determine the time most convenient for participants. Most participants preferred a lunchtime meeting.

  A note of caution is needed here. While the midday meeting was successful in this case, it succeeded in part because many of the participants were already involved in the project and understood its value to the community as well as to CRCOG. There was not the same degree of understanding and commitment earlier in the project.

CONCLUSIONS - HOW TO BETTER INVOLVE MINORITY & LOW-INCOME COMMUNITIES

Over the past year, we have evaluated through workshops and internal staff reviews ways of providing more opportunities for minority communities to become involved in CRCOG's transportation planning process. This evaluation was done on two levels: (1) methods to improve our outreach efforts, and (2) methods to increase minority community participation in CRCOG's core decision-making activities. On the first level, we examined numerous ways to improve our outreach efforts to encourage more African Americans and Hispanics to participate in special studies, public meetings, and other activities that we conduct. On the second level, we examined our core planning activities to determine how we might provide more opportunities for meaningful and direct input into our basic decision-making.

Level 1: More Effective Outreach to Title VI/Environmental Justice Target Populations

Even prior to the Challenge Grant project, CRCOG was experimenting with ways to improve its public outreach efforts to minority and low-income populations. The Challenge Grant project gave us an opportunity to formally assess those methods, learn about other potential methods, and develop new strategies for outreach to minority communities. Listed below are the strategies we are committed to pursuing. However, experience has shown that general strategies such as these typically need to be adapted to individual situations. Thus, application of these strategies needs to be flexible and should be directed and focused as required for the specific communities targeted.

Outreach Efforts for Special Studies

• Local Advisory Committees. Local advisory committees formed for special studies should include neighborhood representation.
• Neighborhood Groups. Work with established neighborhood groups in areas affected by particular studies or plans.
• Go to Community Meetings. Make presentations at regularly scheduled meetings of community groups, church groups, etc.
• Small Group Meetings. Do not limit outreach to large formal meetings. Make use of small, informal meetings or focus groups - especially early in a study.

Outreach Efforts for Basic Activities

• Improve outreach efforts. For standard CRCOG tasks such as update of the TIP and the Regional Transportation Plan, improve and enhance outreach efforts.
• Environmental Justice Mailing List. Maintain special environmental justice mailing list for standard mailings - TIP, Transportation Plan, etc.
• Newspapers. Use appropriate community newspapers for posting of public notices.
• Spanish Language. Provide notices in Spanish language format.
• Community Access TV. Pursue use of community access TV.

Level 2: More Effective Input to Core Decision-Making

When CRCOG applied to participate in the Challenge Grant program, it was with the intention of examining all of our basic planning activities to see if the were ways to increase participation of minority and low-income communities in the full range of CRCOG activities. While we had made progress in special projects like the Jobs Access Program and corridor studies, we felt that there was the potential to improve in regard to our core decision-making activities like project selection, development of the TIP, and development of the Regional Transportation Plan. These tasks are controlled primarily through our Transportation Committee, so we felt we also needed to explore methods for more direct minority community input to the Transportation Committee.

At the end of the Challenge Grant project, we identified two organizational changes that would provide more opportunities for representatives of the African-American and Hispanic communities to influence the basic transportation decision-making process at CRCOG. These changes include:

• form an Environmental Justice Advisory Board to advise the Transportation Committee, and
• appoint an Advisory Board member as a voting member of the Transportation Committee.

Create Environmental Justice Advisory Board.

One way to provide a continuing role for minority communities in the transportation planning process is to create a special Environmental Justice Advisory Board and assign it a direct role in basic transportation decision-making at CRCOG.

Advisory Board Membership. The Advisory Board will be composed of representatives of the low-income and minority communities, but will also contain some members of the CRCOG Transportation Committee. The inclusion of Transportation Committee members assures that at least some Committee members participate in the Advisory Board discussions and are fully versed in the issues, concerns, and needs of the minority communities as expressed at the Advisory Board meetings.

Achieving good representation of the target communities was an important task in structuring the Advisory Committee. Based on our early efforts at organizing a Challenge Grant steering committee, we also knew it could be a difficult task. Fortunately, we were able to learn from our early experience, and to build on the interest in our process that some individuals and groups developed by participating in the Environmental Justice Challenge Grant project.

Beyond the obvious goal of making sure we had adequate representation of the key target communities (African American, Hispanic, and low-income), we also wanted representatives that would be active and committed to the process. To make certain we got committed and effective Board members, we selected people from sources we felt assured the sense of commitment we needed. The sources are listed below.

• Challenge Grant Participants - The most obvious source of new Board members is the list of persons who had actively participated in the Challenge Grant project. There was a ready pool of individuals who already demonstrated their interest and commitment, and who had begun to understand the transportation planning process and how it might affect minority communities.

• Jobs Access Transportation Program - A second source of potential members was CRCOG's Jobs Access Taskforce. The Taskforce had already proven to be a good source of participants for the Challenge Grant, and will likely continue to be a source of good Board members. There are two reasons why the Jobs Access Taskforce is a good source of Board members. First, the Taskforce members represent agencies that serve low-income residents, which is one of the target groups for Environmental Justice. Second, Taskforce members are already familiar with CRCOG and are more likely to feel a sense of obligation to assist CRCOG in fulfilling its environmental justice requirements. The latter point is important since we want Board members who will be committed to the process.

• Prior CRCOG Studies - Another source of potential Advisory Board members was the list of participants in prior CRCOG corridor studies that involved minority neighborhoods. The same rationale applies for this as for the Jobs Access program: study participants are already familiar with CRCOG and are more likely to feel a sense of obligation to assist CRCOG in fulfilling its environmental justice requirements.
• Environmental Justice Organizations - If you are fortunate to have an existing environmental justice organization in your area, it can be another good source of interested and committed Advisory Board members. In CRCOG's case, we were fortunate to have the Hartford Environmental Justice Network. This group focuses its efforts mostly on 'environmental' issues such as the prevalence of asthma in inner city neighborhoods, diesel emissions, the siting of potentially harmful facilities such as trash to energy plants in the inner city. However, in our case they were very interested in participating in a process focused on transportation issues as they affect low-income and minority populations. While the organization was not very familiar with CRCOG, they proved to be very committed to the Challenge Grant project due to their strong interest in environmental justice issues in general.

We also gave consideration to neighborhood groups and associations representing various minority communities. However, we learned from the early part of our Challenge Grant project that the response rate from these groups can be low unless they are already familiar with CRCOG. Many of these groups are busy with other activities and issues, and have little incentive to commit time and effort to yet another activity when they have no prior relationship with CRCOG and little familiarity with its programs.

Advisory Board Functions. To assure that the Advisory Board will be an effective group, we propose to assign it several functions that relate directly to critical decision-making functions in the transportation planning process. These range from assistance in updating mailing lists to participating in the update of the regional transportation plan. Proposed functions are described below.

• Review Annual Work Program - The Advisory Board will review and comment on the annual Unified Planning Work Program. This will provide the Board an opportunity to directly influence the type of planning projects undertaken in the region.
• Review Annual TIP Update - We will ask the Board to review and comment on the annual update of the TIP. As part of this process, they will receive a report on the equity assessment that will be done as part of the update.
• Participate in Update of Regional Transportation Plan. Whenever CRCOG undertakes an update of its regional transportation plan, we will consult with the Environmental Justice Advisory Board throughout the process as appropriate. We will consult with them early in the process to allow an opportunity to help define the issues to be addressed in the update. We will also consult with them later in the process as recommendations are being developed. The Board will also have an opportunity to review and evaluate the equity assessment that will be done for the draft plan. We expect this will be a very effective way to provide representatives of the target communities with a way to directly influence the development of the region's most important planning and policy document.
• Advise CRCOG on Outreach Efforts - The Board will possess a special knowledge of Hartford area minority communities and issues. This will be useful in helping CRCOG tailor its outreach efforts to be more effective in reaching the intended audience and more successful in engaging the community.
• Update Environmental Justice Mailing List - An important component of CRCOG's new outreach effort will be to distribute key CRCOG reports to wider audiences in the African American and Hispanic communities to both raise awareness of CRCOG programs and to invite comment and input. Keeping the mailing list current and targeted to the appropriate groups will require regular review and update. We expect the Advisory Board to provide important assistance, particularly in regard to the targeting of appropriate groups.

Appoint Representative to Transportation Committee

A second way to provide a continuing role for minority communities in the transportation planning process is to appoint a minority community representative to CRCOG's Transportation Committee. The Committee is composed primarily of appointees from CRCOG's member municipalities. In most cases, these are municipal officials such as town engineers, town managers, or town council members. While these officials represent the interests of all their respective municipality's residents, there is no individual representing the interests of minority communities in particular.

To assure those interests are represented at the Transportation Committee, we propose that a seat on the Committee be provided to someone representing the minority communities. The most straightforward way to select the representative is to give the Environmental Justice Advisory Board the responsibility of appointing one of its members to the Transportation Committee. This has the added advantage of strengthening the linkage between the Advisory Board and the Transportation Committee.

The question of an appointee was put to the unofficial Advisory Board members who met for the Challenge Grant project's fourth and final workshop. The Board suggested two representatives - one African American and one Hispanic. CRCOG's Policy Board, which approves Committee appointments, accepted the two nominations and the two representatives now serve on the Transportation Committee.

The two appointees provide a direct voice for the minority communities on the core transportation decision-making entity at CRCOG - the Transportation Committee. Since all transportation issues pass through the Transportation Committee, the minority community representatives will have the opportunity to influence all transportation decisions at CRCOG, including the core activities such as project selection, the transportation plan, and the TIP.

4. EQUITY ASSESSMENT METHODS FOR TRANSPORTATION PLANNING

The third objective of the CRCOG's Challenge Grant project was to develop quantitative methods for assessing the relative distribution of transportation burdens and benefits among target and non-target communities. We need quantitative assessment methods to help us determine if target communities are getting an equitable share of the benefits associated with our transportation programs. We also need methods to assess if target communities are getting a disproportionate share of the adverse impacts or burdens associated with transportation projects and programs.

These assessment methods will be used for two primary purposes. First, they will be used to assess the final results of the transportation process, whether the sum of all the recommended programs and projects results in a fair and equitable distribution of benefits and burdens. If the assessment shows us to be deficient in some areas, we can use the information to revise and improve future programs. Second, the same methods will also be used in a more proactive way to guide the decision-making process to assure more equitable results. The ultimate goal is to provide decision-makers with an equity assessment tool to evaluate the distribution of benefits of various alternatives before they select a preferred option. If decision makers have better information about the potential equity impacts of alternatives, they can make better choices that do not unfairly benefit some populations at the expense of others.

GOALS

In approaching this task, we had several goals we wanted to satisfy in regard to the methodologies or assessment techniques we might develop. The goals relate to how easy they are to apply given existing staff skills, how easy they are for decision makers to understand, and how helpful they are as decision-making tools.

Easy to Apply. The techniques should be easy to apply for existing CRCOG staff given available data and computer software. Techniques that are cumbersome or difficult to apply will not be used as often as tools that are simple and straightforward to apply. To assure that assessments are done for as many decisions as possible, we want to develop tools that can be readily applied by existing staff with available data and software.

Easy to Understand. An assessment technique is of no value if decision makers cannot understand it. Unfortunately, many of the assessment tools cited in the literature are based on 'accessibility' measures derived from travel forecast models and are difficult for most people to understand. While travel model practitioners might understand the more abstract accessibility measures used in some other studies, we want to develop measures that are less abstract, and that can be easily understood by the lay members of our Transportation Committee and our Environmental Justice Advisory Board.

Helpful to Decision Makers. The most important goal is to develop methods that are actually useful in guiding decision makers in the process of choosing alternatives, developing policies, and evaluating program performance. The tools must be appropriate to the decisions they are making. Therefore, we sought to develop tools suited to the important decision-making functions carried out by CRCOG committees.

There were three primary types of assessment tools we set out to develop as part of this project. These include the following:

1. Target Areas - As a first step for some types of assessments, we need to geographically define 'target areas' where there are large concentrations of the low income or minority populations. The target areas are needed for some of the geographic-based assessment tools listed below.
2. TIP Assessment Tools - We want to develop tools to help us evaluate the distribution of benefits of projects in the TIP (Transportation Improvement Program) our short-term programming document.
3. Plan Assessment Tools - We also want to develop tools to help us evaluate the distribution of benefits of projects in our long range planning documents such as the Regional Transportation Plan and major investment studies.

Each type of tool is discussed below.

TASK 1 - DEFINE TARGET AREAS

For certain types of benefit assessments, it is necessary to define a geographic area that constitutes a 'target area' for environmental justice assessment purposes. Target areas are districts where there is a concentration of one or more of the population groups under study. For purposes of CRCOG's environmental justice project, we need to define these target areas for both minority and low-income populations.

Minority Target Area

The minority target area is intended to include all the neighborhoods in the Capitol Region in which the minority populations compose a large or disproportionate segment of the residents in the neighborhood. By defining a specific minority target area we can compare the level of transportation service and impacts within the target area to the level of service and impacts outside the area.

A key step in defining the minority target area was deciding what threshold level to use to classify a locale as a minority area. While a variety of different thresholds have been used in other places in the country, the most common are:

• Simple Majority Threshold (50%): The first threshold option is based on the premise that if a majority of the residents (50 percent) in a district are members of a minority group, the district should be classified as a minority district and included in the 'target area.'

• Regional Proportion Threshold (27%): In the Capitol Region as a whole, 27 percent of the residents are members of a minority group. The second option is to use this lower threshold level, and classify a district as a minority district if at least 27 percent of its residents are minorities. Thus, the 'target area' would include all districts with minority populations of at least 27 percent.

Of the two options, the simple majority threshold was selected for use in defining the target area for minority populations in the Capitol Region. The selection was done after comparing the maps of the two potential target areas, and after consulting with participants in the fourth environmental justice workshop (see Chapter 3).

The primary rationale for selecting the 50-percent threshold is that it is a smaller, more focused area. As such, it creates a more rigorous test when comparing the distribution of transportation investments between minority and non-minority areas. As illustrated in Figure 4-1, the target area for the 50-percent threshold is significantly smaller than the target area for the 27-percent threshold. The larger area encompassed by the 27-percent threshold includes more suburban neighborhoods with a high proportion of white, middle income families. We decided to focus our assessment efforts on the area defined by the 50-percent threshold where the greatest concentration of minority families exists. There is a strong desire to assure that this core area receives its fair share of transportation investments, and that it is not unfairly burdened by the negative impacts often associated transportation facilities can sometimes bring.

Low-Income Target Area

At the end of the Environmental Challenge Grant project, the low-income target area was not yet defined. Inability to complete this task was due to the fact that the income data from the 2000 Census was not realized until late in the project schedule. When the data did become available in the summer of 2002, we conducted a number of mapping analyses to evaluate possible variables and thresholds that we might use, but there was no opportunity to discuss the findings with participants at the environmental justice workshops. This discussion will be held when we convene the new Environmental Justice Advisory Board early in 2003. At that time, we will present the results of the mapping exercises we conducted with the low-income data, which are summarized below.

Defining the low-income target area involves one additional step beyond what was done for the minority target area. In addition to determining a threshold level, we also have to determine the most appropriate income level to use. That is, what income level do we consider to be low-income?

The 2000 Census provides a lot of income data that makes it possible to select a wide range of measures to define low income. Perhaps the most useful data provided is the data on the number of persons who have household incomes at or below the federally defined 'poverty' level. Under federal guidelines, the income level considered to be poverty level varies by size of the household. Table 4.1 lists the income levels that the Census used to define poverty in 2000.

While a variety of different thresholds have been used in other places in the country, most have used either poverty level or 150-percent of poverty level. Each is explained below.

1. Poverty Level. A very simple option for defining low-income is to use the federally defined poverty levels. The data is readily available in the Census and it has the added value that it is an officially recognized measure of poverty. The disadvantage is that it excludes numerous households have incomes that are above the poverty level, but who still struggle to achieve comfortable lifestyles. More importantly, it excludes many whose income is still too low to afford car ownership.
2. 150% of Poverty Level: Rather than defining low-income as poverty level or below, we also considered establishing the low-income cutoff point as an income level 50 percent higher than the poverty income level. As can be seen in Table 4.1, the 150-percent income cutoffs are still extremely modest income level

Recommendation: 150-percent. While no official decision has been made on which income level to use for purposes of CRCOG's environmental justice assessments, CRCOG will be recommending the adoption of the 150-percent level to the Environmental Justice Advisory Board.

Threshold Level.

In addition to determining which income level to use, we also have to select the threshold level, or the minimum percentage of a block group's population that must be low-income for it to be classified as a low-income area. This selection is more difficult than it was when defining the minority target area. The difficulty is due to the smaller number of low-income persons, and the more dispersed distribution of the low-income population. (Figure 2.6 illustrates the dispersed nature of the low-income population.)

When compared to the minority population, the low-income population is much smaller in number. Whereas 27 percent of the region's population is classified as belonging to a minority group, only 9.0 percent of the region's population is at or below the poverty level. Even if we use the 150-percent of poverty income cutoff, the low-income population is still substantially less than the minority population. Fourteen (14.2) percent is at or below the 150-percent poverty level.

Numerous threshold options were evaluated, and several of these are discussed below. The only ones presented below are ones based on the 150-percent poverty level.

1. Simple Majority Threshold (50%): This is based on the premise that if a majority of the residents (50 percent) in a block group are low-income, the district should be classified as a low-income district and included in the 'target area.'

   A simple majority rule results in such a small target area that is not a practical threshold to use. The 50-percent threshold encompasses only 26 percent of the region's low-income population. This leaves too many low-income individuals outside the target area and unaccounted for in an assessment that is based on target areas.

2. Regional Proportion Threshold (14.2%): In the Capitol Region as a whole, 14.2 percent of the residents have household incomes at or below the 150-percent of poverty level. Under this option, we classify a district as a low-income district if at least 14.2 percent of its residents are low-income. Thus, the 'target area' would include all districts with low-income populations of at least 14.2 percent.

   A 14-percent threshold is simply low too for any practical applications in environmental justice assessments. It is hard to think of a neighborhood as a 'low-income' neighborhood if only 14 percent of its residents are low-income. Additionally, the resultant target area is so dispersed that assessment of transportation impacts is likely to be meaningless.

3. Intervening Thresholds (20% or 30%): Given the problems with the simple majority and regional proportion thresholds, it was necessary to also consider threshold levels in between these two extremes. Therefore, thresholds of 20 and 30 percent were evaluated.¹

   The target area based on the 30-percent threshold level is illustrated in Figure 4.2. It is overlaid on the minority target area for comparison. The minority target area is larger, but there are a few low-income neighborhoods that lie outside the bounds of the minority target area. These outlying areas include:

   • Vernon: 3 block groups in the Rockville section
   • Enfield: 1 block group in the Thompsonville section
   • Manchester: 1 block group
   • East Hartford: 2 block groups
   • Hartford: 2 block groups

¹ The 40-percent threshold was considered, but quickly dismissed as being too restrictive. The size of the 40-percent target area was still small and entirely encompassed within the previously defined minority target area.



The target area based on the 20-percent threshold level is illustrated in Figure 4.3. It is overlaid on the minority target area for comparison. The 20-percent threshold expands the low-income area slightly beyond the limits of the 30-percent threshold area. While the low-income area still remains largely within the minority target area, there are more low-income neighborhoods that lie outside the bounds of the minority target area. These outlying areas include:

• Vernon: 3 block groups in the Rockville section (no change)
• Enfield: 1 block group in the Thompsonville section (1 added)
• Manchester: 9 block groups (8 added)
• East Hartford: 6 block groups (4 added)
• Hartford: 2 block groups (no change)
Additional towns included with 20-percent threshold:
• West Hartford: 6 block groups in West Hartford (6 added)
• Windsor: 1 block group near downtown (1 added)
• Windsor Locks: 1 block group near downtown (1 added)
• East Windsor: 1 block group in the Warehouse Point section (1 added)

The 20 and 30-percent thresholds are more practical options than the simple majority or the regional proportion thresholds. They are much less dispersed than the target area based on regional proportion threshold (14.2%), but they also large enough to include a reasonable proportion of all low-income persons. The 30-percent threshold incorporates 53 percent of all low-income persons in the region. The 20-percent threshold incorporates 65 percent of all low-income persons in the region.

Recommendation: Use 20 or 30% Threshold based on 150% Poverty Level. While no official decision has been made on which income level and threshold to use for purposes of CRCOG's environmental justice assessments, CRCOG staff will be recommending use of the 20 or 30-percent threshold in combination with an income cutoff level based on 150-percent of the poverty level.

Combined Target Area

The issue of combining the two target areas (minority and low-income) was not addressed during the Challenge Grant Project since the income data became available very late in the project. However, CRCOG's Environmental Justice Advisory Board will eventually discuss the issue and make a decision. Administratively there are many advantages to working with a single combined target area, so CRCOG staff will likely recommend combining the two. If the Advisory Board agrees, the combined area would include all of the shaded areas shown in either Figure 4.2 or Figure 4.3.

TASK 2 - EQUITY ASSESSMENT OF TIP

The definition of the target area is the first step in the development of an assessment tool for evaluating the distribution of transportation investments as represented in the TIP. The TIP, or Transportation Improvement Program, is our short-term programming document and includes a list of projects we expect to fund over a 3-year period. We propose to assess the distribution of benefits with a rather simple comparison of investment levels between the target area and the non-target area. Specifically, we propose to use GIS tools to determine how much of the transportation funds programmed in the TIP are allocated to projects that fall in the target area versus how much funding is allocated to projects outside the target area.

Developing an Assessment Methodology for the TIP

The assessment technique proposed for the TIP is less sophisticated than ones to be used for assessment of the regional transportation plan (long range plan), but this reflects the short-term nature of the TIP. Because it is a 3-year programming document, the projects included can vary significantly from year to year as project phases are completed or as project schedules are modified. This variability means that any single TIP assessment might not yield a good picture of how benefits will be distributed over the longer term. It ignores many major projects that are planned, but not yet programmed. It also ignores projects that are already completed - even if they were completed just one or two years earlier.

Single Year Assessment Versus Long Term Tracking. Given the TIP's variability we cannot expect to meet a goal of fully proportional funding for any given TIP. Thus, the TIP assessment is only intended to provide a rough indicator of how investments are distributed between target and non-target areas. What is of greater importance is that the distribution of investments be equitable over the longer term. While the Regional Transportation Plan is the better document to assess for this purpose, we can also gain insight into our progress by tracking the TIP performance over a period of several years. An important part of the TIP assessment will be to monitor progress over a multi-year period and report how the target/non-target area balance of funding shifts over time.

Entitlement versus Avoidance of Discriminatory Effects. There are two potential problems associated with an assessment technique that relies on an accounting of 'investments.' The first potential problem is the risk that some might see the assessment as guaranteeing some type of funding entitlement. Our goal in measuring investments is not to guarantee proportional funding for target areas or to create a sense of entitlement to that funding. Rather, our goal is to assure an equitable process that does not result in a distribution of benefits that is discriminatory. The second potential problem is the fact that transportation investments are not the same as transportation 'benefits,' and our ultimate goal is to assess the distribution of benefits. While investment level is the most convenient measure to use for assessing the TIP, we will develop better tools for assessing the distribution of benefits; but these tools will be used for evaluating longer-range documents like the regional transportation plan. For the regional transportation plan we will directly measure transportation benefits like changes in travel time and access to jobs. However, for a short-term document such as the TIP, investment level is still the most convenient measure available. Sophisticated techniques such as calculation of accessibility measures are not easily adapted to the TIP.

Initial Assessment Tool as Adopted

An initial environmental justice assessment tool was adopted in order to conduct an evaluation of the 2003-2005 TIP. It is not identified as a final technique since we recognize that the methodology will be refined and improved as our Environmental Justice Advisory Board gains experience working with it.

The technique involves using the GIS system to analyze the distribution of projects listed in the TIP.

1. Locate Target Area: The target area is defined (For the 2003-2005 TIP assessment we used the 'minority' target area based on the 50% threshold.)
2. Locate Projects: Each project in the TIP is located on the map using the GIS system.
3. Develop Graphic Symbols for Each Project Type: To aid visual analysis, we use icons or symbols to represent each major type of project. Samples are provided Figure 4.4.
4. Identify Projects in Target Area: The GIS system is used to identify projects within the target area. A portion of that map is shown in Figure 4.4.



5. Calculate Investment in Target Area. The GIS system is used to calculate the total investment in projects located in the Target Area.
6. Identify Non-Geographic Projects that Benefit Target Groups. For projects that are not location specific, we determine whether they benefit the target populations. Examples of beneficial projects include operating subsidies for the public transit system, and capital purchases for the public transit system.
7. Calculate Combined Investment for Target Groups. Add the total investment identified in step 6 to the investment total identified in step 5.
8. Compare Target Group Investment to Benchmark. Minority residents make up 27 percent of the population in the region. We use this as a preliminary benchmark against which to compare the level of investment benefiting minority populations. When we assessed the 2003-2005 TIP, we found that 26 percent of the total funds in the TIP were allocated to projects that were either in the target area or directly benefited the target groups.

Conclusions

The adopted TIP assessment methodology is a simple GIS-based comparison of investment levels in the target area. It is easy to apply and easy to understand. Its disadvantages include: (1) that it is based on investment or spending level rather than benefit level, (2) that the assessment process might be seen as guaranteeing an entitlement for target areas, and (3) that any assessment based on the TIP can consider only three years of a much longer term transportation program. However, the assessment process serves the basic purpose of providing a rough indication of how investments are distributed between target and non-target areas in the short term. The short-term nature of the process will be partially offset after several years of TIP assessments when we have built a historical record of investments.

The initial application of this assessment technique showed that there is no strong bias in the current investment pattern. Nearly as much transportation funding is being spent in target areas as you would expect based simply on population size.

TASK 3 - EQUITY ASSESSMENT OF TRANSPORTATION PLAN

The Regional Transportation Plan, or long-range plan, is the region's most important planning document. It is also referred to as the RTP or Plan, and it outlines the region's vision for its entire transportation system, and details the major system improvements and investments needed to achieve that vision over the next 20 years. It is the most important document in defining how the region will be investing its transportation funds both in the short and long term.²

Fortunately, there is already an assessment tool for the RTP that can be adapted for the type of equity analysis that is required for environmental justice purposes. It is CRCOG's regional travel forecast model, which is the primary analytic tool used to prepare and evaluate the Plan. The model can be modified to produce a variety of accessibility and travel time measures that are very useful for quantitatively assessing the distributions of benefits.

Our proposed approach for developing an environmental justice assessment tool for the RTP is to modify our regional travel model to produce new performance measures to assess how equitable the distribution of transportation benefits is. We will introduce new performance measures based on equity that will supplement the standard transportation system performance measures such as vehicle miles of travel (VMT) and transit ridership that the model currently produces. The nature of these desired equity measures is discussed below.

²In contrast, the TIP is the short term programming mechanism that contains only those projects that are scheduled for funding over the next three years.

Potential Equity Performance Measures

Numerous equity performance measures have been developed and used by other regions in assessing their transportation plans. For purposes of our equity assessment, we propose to develop performance measures based on two basic concepts: accessibility and travel time. Both concepts are well suited to measuring the 'benefits' residents gain from improved transportation, and both can be calculated using data derived from the travel model.

Accessibility as an Equity Performance Measure (Type 1)

Accessibility is a measure of how easy it is for a person to reach a given type of destination such as employment, shopping centers, medical treatment facilities, or recreational facilities. Accessibility for a residential neighborhood is determined by two factors: (1) the number and distribution of the opportunities within a reasonable distance from the neighborhood, and (2) the availability and quality of transportation connections from the neighborhood to the destinations. If for a given residential neighborhood there are a lot of opportunities located nearby, and there are good quick transportation connections to the locations, then the neighborhood is considered to have good access to that type of opportunity, activity, or service. Accessibility is a good planning tool because it measures both the pattern of land use (or distribution of activities) and the quality of the transportation system.

There are two types of accessibility measures CRCOG is considering adopting as equity performance indicators. The first is access to job opportunities, and the second is access to nonwork opportunities (an aggregate of shopping, medical, recreation, and all other nonwork activities).

Job Opportunities Access Indicator

We are committed to using a job access measure for two reasons. First, CRCOG has used this type of measure previously and found it to be both useful and relatively easy to calculate. Second, and more importantly, improving access to jobs for low-income households is an important regional goal. Job access was the primary goal in establishing CRCOG's Jobs Access Taskforce, which has succeeded in creating several new transit services and helping over 2800 low-income residents reach job opportunities not previously available. Job access was also a key goal in the preparation of our Regional Transit Strategy, which proposed a new rapid transit that will greatly expand access to job opportunities for low-income residents.

There are several different methods to calculate a job access performance indicator. Accessibility can be measured based on transit access or auto access. It can be calculated for various groups such as low-income populations, minority populations, or for no-target group populations. In most cases, accessibility is based on some maximum travel time that is predefined as the limit for a reasonable trip. For example, some regions have established the limit as 20, 30, or 40 minutes, and they measure the number of job opportunities available within the selected travel time limit. The exact limit is not critical since all we are trying to do is get a general indication of how accessible a location is relative to other locations. In all cases, access is based on access to job 'opportunities,' and we measure how many jobs or what share of the region's jobs, are available within the prescribed time limit. The most accessible locations are those with a large number of job opportunities, or a large percentage of the region's jobs within a reasonable commute time.

CRCOG has previously used an accessibility performance measure to evaluate the social equity implications of major plan recommendations. In March 2001 CRCOG adopted a Regional Transit Strategy as part of its Regional Transportation Plan. As part of the development of the Regional Transit Strategy we developed a jobs access performance measure that was helpful in answering some the environmental justice & social equity questions that were raised. We intend to retain, but improve this equity performance measure for future plan evaluations. It is explained below.

Accessibility Measure Used For Regional Transit Strategy. The measure used by CRCOG was prepared for the Regional Transit Strategy and was based on transit travel times since we were evaluating transit options. We were also assessing the environmental justice implications of the proposed Transit Strategy, so we focused the performance measure on the transit disadvantaged. Our target group in this case was households that did not have an automobile available. Our accessibility measure was defined as the number of job opportunities available to zero-car households within a 30-minute transit trip. The results, which are presented below, showed that if the recommended Plan or Regional Transit Strategy is implemented, we would greatly increase access to jobs for zero-car households.

REGIONAL TRANSIT STRATEGY Access to Job Opportunities for Zero-Car Households
Transit Options	Jobs within 30 Minutes	Increase over No Build
Option 1: No Build or No New Transit Service	132,640	----
Option 2: Low Capital- More Bus Service	145,857	13,217 (10%)
Option 3: High Capital - New Rapid Transit	188,602	55,962 (42%)

Need to Add Comparative Data for Non-Target Group. What was missing from this analysis that would have made it a more useful equity evaluation was a comparison between the accessibility gains for zero-car households and accessibility gains for households with cars. If zero-car household job accessibility increased by 42 percent, how much did accessibility increase for other households? For future analyses we will provide this comparative data.

Need to Add Low-Income & Minority Assessment. To fulfill the goals of our new Environmental Justice Action Plan, we will also have to expand the accessibility analysis to include more target groups than just zero-car households. We propose to calculate the same performance measures for both low-income population and minority populations. This will require a refinement of the modeling procedures since the income data and minority population data are not directly integrated into the modeling process.

Need to Add Auto Access Measure. The accessibility measure used for the RTS was based exclusively on transit travel times. We need to add a second measure that is based on auto travel times to track changes is accessibility for both modes of travel. Tracking only the changes in transit access would mean we were ignoring any access changes resulting from proposed highway improvements.

Recommendation: Use Improved Jobs Access Measure from RTS. While no official decision has been made on which jobs access performance measure to use, CRCOG staff will recommend use of the same type of accessibility measure used for the Regional Transit Strategy with improvements as noted above.

Nonwork Opportunities Access Indicator

CRCOG will also explore options for developing a measure of accessibility to other activities, services, and opportunities other than jobs. The regional travel model produces estimates of nonwork trips as well as work trips so it is possible to develop a similar performance measure for nonwork opportunities. However, a nonwork trip measure would suffer some disadvantages compared to the work or job opportunities measure. First, the nonwork trip category is a broad one that includes a variety of trip purposes such as medical, recreational, shopping, school, social/visiting, church, etc. It will not be possible to isolate any one trip purpose or even to sort out essential from nonessential trip purposes. As a result, the performance measure will be more difficult to interpret. We would be measuring access to all opportunities other than jobs.

An option in lieu of using a full-fledged accessibility measure is to use a simplified measure focused on access to key services or facilities such as hospitals, grocery stores, and major shopping centers. A measure that has been used elsewhere is the percentage of the target population that lives close to one of these facilities. An example is to calculate the percentage of the region's low-income population that lives within 20 minutes travel time of a grocery store.

The disadvantage of the simplified performance measure is that it measures access only to the single nearest facility of interest, rather than to all potential opportunities within a reasonable distance. Nonetheless, it is an option for measuring access to important services, activities, or facilities.

Recommendation: Continue to Evaluate Options. No decision was made on whether to develop a nonwork accessibility measure. However, CRCOG is committed to exploring options further. The evaluation will be resumed after the conversion process for CRCOG's travel model is completed.

Travel Time Savings as an Equity Performance Measure (Type 2)

A second type of performance measure that is useful for evaluating the distribution of benefits from transportation improvements is travel time savings. For this type of indicator, the regional travel model calculates the cumulative travel times for all trips made by persons under different transportation improvement options, and compares the options to see which yields the most travel time savings. Typically, the Plan's recommended transportation improvements are one option, and the other option is the 'no build' or no improvement' option. The goal is to see how large a reduction in travel time can be achieved if the proposed transportation improvements are built. By comparing the total travel time for the 'build' option (the Plan) to the 'no build' option, we can derive the travel time reduction or savings.

Comparative Assessment for Equity. For use as an equity performance measure, we need to calculate travel time savings separately for the individual groups we want to compare. For CRCOG's purposes this means we will calculate the savings for at least two target groups: the low-income population and the minority population. Each will then be compared to their respective comparative group: the moderate-high population and the non-minority population. It is possible that we might also do a comparison between households without cars to those that have cars.

Adapting FTA's Summit User Benefits Software. CRCOG is investigating the possibility of adapting a new software package developed by the Federal Transit Administration (FTA) for use in the travel time analysis discussed above. This new software package, called Summit, is used to measure benefits associated with major transit project proposals. While Summit was developed to help FTA evaluate requests for federal funding assistance on proposed transit projects, it is suitable for measuring highway user benefits as well as transit user benefits, and it can be applied to a regional plan that includes multiple projects as well as to just a single project. CRCOG will work to adapt the Summit software to conduct the specific user benefits assessments that are needed for the equity evaluation as discussed above.

Recommendation: Develop Travel Time Savings & Other User Benefit Measures. CRCOG will develop appropriate user benefit measures that will include travel time savings. These will be developed by adapting the Summit user benefits software to the regional travel model.

Conclusion: Integrate Equity Assessment into the Development of the RTP

Since the RTP is CRCOG's most critical planning document, it is important to develop a good assessment methodology for evaluating the Plan recommendations as they affect minority and low-income communities. Our primary goal in developing this will be to create an effective tool for CRCOG's key decision-making groups, which include the Environmental Justice Advisory Board as well as the Transportation Committee and Policy Board. These groups need to be able to use data produced from the assessment to help decide which projects to include in the Plan and what priorities to set. The data needs to be both easy for decision-makers to understand, and provide meaningful information on the distribution of benefits to target and non-target groups.

The approach we propose to follow in developing an assessment methodology is to integrate the measurement of benefits directly into our standard Plan development and evaluation process. We already have a number of criteria we use for Plan evaluation such as vehicle miles of travel and transit ridership. Now we will add a set of equity criteria to our standard transportation system performance criteria. These performance measures will be derived from the same regional travel model we use to develop the standard transportation system performance measures such as VMT. Specifically they will include:

• Accessibility Measures: Job accessibility will be the primary measure. Other measures might be developed for nonwork trip purposes, but this requires further evaluation.
• Travel Time Savings: A travel time savings measure will be developed. We will adapt FTA's Summit software for this task and also explore the potential for creating other user benefit measures using the same software.

The development of these measures was not completed during the Challenge Grant project due to an ongoing effort to convert our travel model to a new software package. However, we have outlined a series of recommendations on the types of performance measures we should develop and how they can be developed. CRCOG staff will undertake this development process in the near future, and we will do so in consultation with the Environmental Justice Advisory Board.

5. ACTION PLAN & STATUS REPORT

The Capitol Region Council of Governments intends to take the actions necessary to assure that the voices of all the Capitol Region's communities are heard, and that future decisions include fair consideration of all social and economic issues in all the affected communities. CRCOG is committed to fully integrating the basic principles of environmental justice into all of our transportation planning programs and activities. These principles are:

• To ensure public involvement of low-income and minority groups in decision making;
• To prevent "disproportionately high and adverse" impacts of decisions on low-income groups and minority groups; and
• To assure low-income and minority groups receive a proportionate share of benefits.

To this end the Policy Board of the Capitol Region Council of Governments adopted the following Action Plan on June 26, 2002.

ACTION PLAN FOR IMPROVING THE
CRCOG TRANSPORTATION PLANNING PROGRAM

1. TITLE VI/ENVIRONMENTAL JUSTICE ADVISORY BOARD
   • Establish a special advisory board to review CRCOG's program and products.
     • Review & update Environmental Justice mailing list.
     • Review annual TIP update.
     • Review annual transportation planning work program.
     • Review Regional Transportation Plan updates.
     • Advise and assist CRCOG in special outreach efforts.
2. TRANSPORTATION COMMITTEE
   • Appoint an Environmental Justice Advisory Board member to the Transportation Committee.
3. SPECIAL OUTREACH EFFORTS
   • Continue and improve special outreach efforts used for special studies. (examples below)
     • Local Advisory Committees. Local advisory committees formed for special studies should include neighborhood representation.
     • Neighborhood Groups. Work with established neighborhood groups in areas affected by particular studies or plans.
     • Go to Community Meetings. Make presentations at regularly scheduled meetings of community groups, church groups, etc.
     • Small Group Meetings. Do not limit outreach to large formal meetings. Make use of small, informal meetings or focus groups - especially early in a study.
   • Improve outreach efforts for more standard CRCOG tasks such as update of the TIP and the Regional Transportation Plan.
     • Maintain special EJ mailing list for standard mailings - TIP, Transportation Plan, etc.
     • Use other outreach efforts as appropriate (examples below)
       • Newspapers. Use appropriate community newspapers for posting public notices.
       • Spanish Language. Provide notices in Spanish language format.
       • Community Access TV. Make more use of community access TV
4. TIP (TRANSPORTATION IMPROVEMENT PROGRAM)
   • Conduct an assessment of transportation benefits for the annual update of the TIP.
   • The TIP and assessment of benefits will be reviewed by the EJ Advisory Board.
   • Provide notification of the TIP update process to the full EJ mailing list.
   • Schedule the public meeting at an appropriate time and place.
5. REGIONAL TRANSPORTATION PLAN
   • Conduct an equity assessment for each update of the Plan.
   • The Plan and equity assessment will be reviewed by the EJ Advisory Board.
   • Provide notification of the Plan update process to the full EJ mailing list.
   • Conduct a special outreach effort to involve members of minority & low-income groups.
   • In the next update of the Plan, include a discussion of the substantive transportation issues raised in the last EJ Workshop.
6. STP-URBAN PROGRAM
   • Continue to use environmental justice as a criterion in the selection of STP-Urban projects.
7. TRANSIT USERS ADVISORY GROUP
   • Form a transit users advisory group or forum to provide more opportunity for transit users to comment on the bus service.