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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.

Table 4-1:  Equity Evaluation Guidelines
Step 1. Consider any potential equity impacts of pricing early in the project—during the planning and design phases.
Step 2. Determine who may potentially be impacted by the project.  What kind of equity is important?
Step 3. Evaluate potential equity impacts of the base case or “no build” alternative to compare against the equity impact of the road pricing project.
Step 4. Consider variety of perspectives and impacts.
Step 5. Measure effects (measuring equity impacts is addressed in Section 5).

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.

Table 4-2: Procedure for Conducting an Environmental Justice Analysis6


  • Clearly identify the composition of the region of influence and include appropriate criteria and data on the community.
  • Analyze the identification of the region of influence using appropriate data on the affected community.
  • Ensure that the affected community input during the scoping process includes access to information and meetings.


  • Define the criteria for recognizing the affected community and do criteria include minority and low-income groups and Indian tribes.
  • Analyze the affected community and include information on patterns of subsistence consumption of fish, vegetation, or wildlife.
  • Ensure that the community provides input to the identification of the community of concern and has associated access to information and meetings.


  • Identify the sources of exposure and likelihood of exposure to the affected community including potential environmental, human health, social, economic, and cultural impacts.
  • Analyze potential direct, indirect, multiple, and cumulative impacts to the affected community.
  • Ensure that the affected community’s input is considered in the identification of the sources of exposure and likelihood of exposure.  Also that they receive access to information and meetings.


  • Identify the potential or adverse impacts on the community and whether they include potential environmental, human health, social, economic, and cultural impacts.
  • Analyze the potential for adverse impacts and evaluate both whether it is disproportionate on the community and whether it includes potential environmental, human health, social, economic, and cultural impacts.
  • Ensure that community provides input in the assessment of impacts and potential for disproportionate impacts on the community and has access to information and meetings.


  • Identify potential alternatives, mitigation measures, and monitoring to minimize the potential impact on the community.
  • Analyze the potential alternatives, mitigation measures, and monitoring to minimize the potential impact to the community.
  • Ensure community input to the identification of actions and ensure access to information and 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.

Table 4-3: Project-Level Evaluation of Toll Roads7

All projects should document and discuss:
  • Available non-tolled facilities (that can be used as substitutes for the tolled facility).
  • Travel time differences between tolled and non-tolled routes.
  • Transit vehicle toll policies.
  • Toll rates or toll ranges.
  • Methods of toll collection and how they may affect access and cost.
  • Cost differences between acquiring toll tag with credit card or with cash.
  • Location of toll booths, particularly in relation to identified EJ areas.
  • EJ-related demographic data by traffic analysis zone (TAZ).
  • Potential economic impact to individuals (for example, assuming 250 tolled round trips to work per year) and calculating toll proportion of income.
  • Expected use of toll revenues.
  • Potential remediation measures.
  • Accommodations for Limited English Proficiency and disabled travelers to use the toll facility.
  • Potential users of the facility using origin and destination studies identified by decreased travel time with use of the tolled facility.
  • Assumptions and limitations of any travel demand models used in the study.

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.

Scenario 1: Agencies considering implementing roadway congestion pricing strategies for the first time
County X should consider equity impacts early and often in contemplating their potential pricing project. Transportation planners and decisionmakers should consider users impacted by the proposed tolling strategy. Since they are considering tolling an HOV lane adjacent to non-tolled lanes, then they already have identified a substitutable non-tolled lane. As such, county X's equity analysis should focus primarily on the tolled lane potential users, specifically how the tolled travel time compares to the travel time on the non-tolled lanes and how toll fares are collected.

Scenario 2: Agencies considering road pricing expansion along their network
City Y should consider the network effects of their expanding system. And equity issues did not arise before when only one road was tolled, but now that several roads are likely to be tolled and the additional roads do not have existing HOV or HOT lanes, road pricing equity impacts could be substantial. The public often balks at charges for roadways that had previously been un-tolled. If the pricing expansion ensures that all priced lanes also accommodate HOV for free, then the equity impacts may be reduced. Transportation planners and decisionmakers in city Y should identify potential equity impacts early on rather than continue to ignore equity considerations. Without considering equity and user impacts early, there may be concerns about the city's ability to successfully implement its toll expansion initiative.

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. ]