Guidebook for State, Regional, and Local Governments on Addressing Potential Equity Impacts of Road Pricing
4.0 Incorporating Equity in the Transportation Planning Process
Equity analysis will be most effective if it is incorporated into the development of road pricing projects from the beginning. This is especially true of the design of the pricing structure, where failure to address equity concerns may necessitate a complete reanalysis.
4.1 General Guidelines to Consider when Incorporating Equity in the Transportation Planning Process
There are some general guidelines that all public agencies contemplating road pricing projects should follow in order to measure and evaluate equity impacts. It is likely that the same agency or group of agencies that is proposing a project will be responsible for all aspects of the project, including evaluation, implementing potential remediation schemes, and communicating about the project. In theory, the evaluation and its results should be independent from the entity performing the evaluation, be it a State or a local department of transportation, a Metropolitan Planning Organization, or any other planning authority. In practice, these agencies may need to participate in the evaluation as they may control the revenue generated. When this is the case, all of the participating agencies should be involved and the process should be open and transparent. All agencies should try to follow guidelines and procedures consistent with those listed in Table 4-1.
1. Consider equity impacts early and throughout the project planning process: Agencies will benefit from identifying and measuring potential equity impacts early and throughout the process, which should lead to greater awareness and public acceptance and ultimately success of the road pricing project.
2. Determine users potentially impacted by the proposed project as well as regional equity priorities: Section 3.0 demonstrated that various categories of users may become impacted by a particular road pricing project. How the impacts are measured may vary with whether the proposed road pricing project impacts low income travelers, particular ethnic groups, particular residents, and/or travelers with less access to alternative travel modes. A socio-economic analysis of an agency’s and a project’s regional boundaries can help identify the various demographic, socioeconomic, industry, and other system user groups potentially affected by the proposed road pricing initiative. Evaluating and measuring the impacts of congestion pricing strategies on system users is discussed in more detail in Section 5.0. The magnitude of road pricing equity impacts will likely influence the choice of an appropriate remediation method (addressed in Section 6).
3. Evaluate equity impacts of the base case or “no build” alternative as well as the impact of the road pricing project: A roadway may have a negative impact on low-income travelers or particular residents with less access to alternative modes whether or not the roadway is priced. A limited access roadway (such as a highway) may limit local connectivity and access to shopping and services. There may be externalities like noise and air pollution. For these reasons and others it is important to consider impacts of the no-build scenario as well as the impact of the road pricing project. Part of the baseline evaluation is that, at a minimum, an agency should “do no additional harm” with a road pricing project.
4. Consider a variety of perspectives and impacts:– It is likely that all projects will have groups of people that benefit from the project and may have other groups that are negatively affected. Project evaluation should consider impacts on all impacted groups, not just those on lower income people or the residents of one particular neighborhood. It is better to consider multiple origins and destinations and multiple types of potential users.
5. Measure effects: Section 5.0 describes several qualitative and quantitative methodologies for measuring equity impacts. Until impacts are quantified and compared against the base, no-build case, it is difficult to fully understand how the project affects different groups.
4.2 An Example of Equity Analysis: Environmental Justice
Environmental Justice (EJ) is a type of equity in which only environmental impacts are considered. Because equity analysis encompasses more than just an environmental justice analysis, this guidebook recommends that agencies perform a larger equity analysis as they contemplate road pricing projects and implement road pricing. The equity analysis should be performed in addition to any environmental evaluation required by law.
As described in Table 4-2, procedures for an EJ analysis illustrate how equity analysis can be completed. EJ Analysis is a type of equity analysis that focuses on environmental impacts. The guideline provided in Table 4-2 is based on actual analysis performed on Environmental Protection Agency (EPA) projects where 200 draft Environmental Impact statements were reviewed to determine how many EJ analyses were performed as part of the Environmental Impact Statement process. The project analyzed EJ impacts related to project scope, affected project area, sources of exposure, potential for disproportionate effects, and project actions. The emphasis is not just on potential impacts of project alternatives on the affected community, but whether the community participated in project inputs and project meetings.
FHWA and the Texas Department of Transportation (TxDOT) compiled detailed how-to guidance in April 2009 for how to perform project-level and network-level environmental justice evaluations of toll roads. In this case, this is the equivalent to what can be done for a road pricing equity analysis. The document explains that an EJ area may be one where minorities or low-income populations in the traffic analysis zone (TAZ) exceed 50 percent. The general guidance is presented in Table 4-3.
The FHWA/TxDOT source also describes evaluation of a network of toll roads which includes priced managed lanes.8 In addition to the information highlighted in Table 4-3, the source includes how the network will be tolled over time, an estimation of the cumulative economic impact of the tolls and expanding toll network, and a comparison of the tolled and non-tolled network benefits over time.
4.3 Incorporating Equity in the Transportation Planning Process – Illustrative Examples
To further illustrate how agencies should consider equity in evaluating their projects, each of the scenarios described in Section 2.0 is presented below along with a discussion around how equity should be incorporated in each scenario.
6 Based on Booz Allen project, Analysis of Federal Agency Practices in Implementing E.O. 12898 and Accompanying Presidential Memo, March 2011. [ Return to note 6. ]
7FHWA and TxDOT, “Joint Guidance for Project and Network Level Environmental Justice, Regional Network Land Use, and Air Quality Analyses for Toll Roads,” April 23, 2009. [Obtained by email between Anita Wilson and Patrick DeCorla-Souza, FHWA.] [ Return to note 7. ]
8Ibid. [ Return to note 8. ]
United States Department of Transportation - Federal Highway Administration