Environmental Justice, Title VI, and public engagement requirements, in coordination with equity and inclusion considerations, are integral to planning and environment linkages (PEL). How is equity and inclusion incorporated into the PEL process, and how is it documented in a PEL study? This post takes a closer look at one example of how a state DOT documented engagement and Environmental Justice in a PEL study.
The Pennsylvania Department of Transportation (PennDOT) completed an Alternative Funding Planning and Environment Linkages Study in September 2021. According to the PennDOT website, the Alternative Funding PEL study evaluates the feasibility of funding options for near-and long term implementation and establishes a methodology for evaluating environmental justice effects associated with each option. The PEL study findings will help guide implementation of future funding strategies and can be modified as needs evolve.
Funding options included in the study are: sales taxes, personal income tax, real estate and property taxes, fuel/gas taxes, other taxes and fees, mileage-based user fees, and tolling. After analysis, bridge tolling and management lanes are the two preliminary recommended near-term (within 2-to-4 years) funding options. Both have potential environmental impacts in the forms of congestion and financial burden.
Equity, Inclusion, and Environmental Justice Aspects of the PEL Study
Stakeholder outreach incorporates inclusive practices. Groups and individuals invited to the table for input and comment include residents and the traveling public, metropolitan planning organizations, rural planning organizations, federal, state, tribal, and local governments, PennDOT, and the state Federal Highway Administration office. The engagement opportunities included targeted outreach to individuals who are of low-income or minority populations, including two meetings in March 2021 to gain feedback from traditionally underrepresented residents (PennDOT PEL Study, Section 1.2.4). Environmental Justice Outreach and Analyses will be conducted in accordance with federal and state guidance as solutions are finalized and project planning occurs.
PennDOT conducted additional outreach to engage low-income and minority populations. An Equity in Transportation Working Group was held, and an online digital survey was conducted using a research panel comprised of minority and low-income Pennsylvania residents.
Section 7 of the study includes a recommended methodology for analyzing potential impacts on low-income and minority travelers and residents. The impact analysis for a facility proposed for tolling will occur within the NEPA environmental analysis process associated with the individual tolling projects.
PEL Study appendices include a detailed stakeholder outreach and engagement plan, record of comments, types of media used, ADA accessibility considerations.
Equity Considerations of Selecting a Toll Alternative
Equity discussions surrounding the recommended near-term funding solution—bridge tolling—involve financial considerations (PennDOT PEL Study Section 5.2.4). User fees are equitable in that all motorists who use a bridge pay a toll. Tolls are less equitable if other bridges in the region remain toll free.
The PEL study notes that tolling bridges in a geographic diverse way across the state would help balance out financial effects, especially for low-income users (p. 56). The link at this point is that due to potential financial impacts of tolling, the PEL study gives special consideration to environmental justice impacts, a primary concern that would be addressed in the NEPA process for a bridge or roadway proposed for tolling (p. 56). Similar impacts, equity considerations, and mitigation concepts are discussed in the Managed Lanes (HOT Lanes) section of the study.
Equity-Focused Engagement as Part of the PEL Study
Section 7.3.1 of the PEL Study describes the role of the study’s Equity in Transportation Working Group dedicated to providing input on potential impacts for underrepresented communities. Invitations were sent to 50 non-profits in Pennsylvania, state and federal agencies, state boards and commissions, MPOs, RPOs, and local government associations. A digital survey was sent in March 2021, with the goal of gathering input from minority and low-income Pennsylvanians. Letters of invitation were sent to 14 tribal entities, explaining the PEL study, funding gap issues, and funding options.
Summary
PennDOT’s Alternative Funding PEL Study is just one example of the many PEL studies conducted for or by state departments of transportation. A closer look at one plan provides an opportunity to see the links between transportation alternative analyses and public engagement, and how equity, inclusion, and environmental justice are addressed within a study framework to meet USDOT and NEPA rules and involve as many voices as possible in the planning process. As federal, state, and local agencies place increased emphasis on equity considerations, methods of inclusion will change over time; however, the practice of considering environmental impacts will remain important to understanding how transportation decision making affects users, residents, and the environment they live in.
