Comment from National Association of City Transportation Officials
Dear Secretary Buttigieg, Deputy Secretary Trottenberg, and Assistant Secretary Coes:
On behalf of our 87 member transportation and transit agencies in the United States, NACTO is pleased to submit the attached comments in response to USDOT’s Request for Information on the Equitable Transportation Community Explorer (ETCE) Tool and Index Methodology.
Executive Director, NACTO
Comment On Document ID:DOT-OST-2023-0020-0028
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Comment from Robert Case
The purpose of this index is to guide transportation funding to disadvantaged communities. The more directly a disadvantage is related to transportation, the more effective transportation funding will be in alleviating that disadvantage. The draft index includes five disadvantage areas- two more directly related to transportation—Transportation Insecurity and Social Vulnerability—and three less directly related to transportation—Environmental Burden, Climate Risk Burden, and Health Burden. Although federal spending on public transportation may improve all five areas of disadvantage for the US as a whole, directing those public transportation dollars to communities with a high need for public transportation (e.g. those currently with a poor system) will be more effective than directing those public transportation dollars to communities that have good public transportation but need (say) environmental cleanup.
Transportation can directly help communities suffering from Transportation Insecurity and Social Vulnerability:
- Communities with low vehicle availability (one of the Transportation Insecurity indicators) would benefit directly from investment in public transportation, an alternative to automobile travel
- Communities with high unemployment (one of the Social Vulnerability indicators) would benefit directly from investment in transportation that improves access to jobs
Conversely, transportation’s relationship to health, climate, and the environment is less direct:
- If a community suffering from cancer (one of the Health Burden indicators) due to proximity to a hazardous site (one of the Environmental Burden indicators) received $1 billion transportation dollars, it would still suffer from cancer.
- If a community suffering from drought (one of the Climate Risk Burden indicators) received the entire budget of the USDOT, it would still suffer from drought.
To include in the index those areas less directly related to transportation weakens the strength of the areas more directly related to transportation, and thereby directs transportation dollars to communities in which those dollars will have less impact, at the expense of those communities where transportation dollars would have more impact alleviating disadvantages.
Comment On Document ID:DOT-OST-2023-0020-0027
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Comment from Association of Monterey Bay Area Governments
Dear Secretary Buttigieg:
The Association of Monterey Bay Area Governments, Santa Cruz County Regional Transportation Commission, and Transportation Agency for Monterey County, and Council of San Benito County Governments urge the US DOT to refine the methodology behind its Equitable Transportation Community criteria to ensure that historically disadvantaged, low income, and vulnerable communities in the Monterey Bay Area are not further disadvantaged and instead support compact, responsible, and sustainable development aimed at improving access and mobility.
Our agencies share the Biden Administration’s Justice40 initiative goals and support efforts to keep standards up to date for determining disadvantaged Census tracts. However, we find that the draft changes, as presented in the Equitable Transportation Community Explorer and methodology, fail to sufficiently consider many of the disadvantages and vulnerabilities that many residents of the Monterey Bay and San Benito area face, and appear to be designed to direct federal funding almost exclusively to sparsely-populated, remote areas. We are alarmed that the proposed changes would serve to discourage climate-responsible sustainable solutions and instead encourage rural and exurban sprawl, loss of agricultural and natural lands, and increased vehicle miles traveled and emissions – major impacts that will ultimately fall hardest on the least advantaged Americans.
Specifically, the following Disadvantage Components appear to most significantly miss the challenges our residents face:
•Climate & Disaster Risk Burden
Under the Transportation Insecurity component, the overemphasis on the following subcomponents without any consideration of the many societal benefits of compact, denser development will produce results that are inconsistent with both equity and sustainability goals:
•Average commute time to work
•Peak transit frequency
•Jobs within 45-minute drive
•Transportation cost burden
Clearly, remote areas will score highly for all these things, however those households benefit enormously from a dramatically lower cost of housing, which cannot be ignored. Population density and existing infrastructure network must be considered in order to account for the far greater number of people that will benefit from investments in more compact areas.
With an extremely high cost of living, high rates of highway congestion, and relatively low wages, our residents struggle to pay rent and to have time to spend with their families. Cities including Watsonville, Salinas, and Santa Cruz suffer high rates of pedestrian and bicycle crashes. Several cities are majority non-white and have experienced historic underinvestment. Many tracts have high rates of disabilities and poverty and low rates of vehicle ownership. As our region works to improve multimodal travel options and do our part to reduce emissions, we suffer from climate-induced disasters including recent massive wildfires (Dolan, CZU, River, Soberanes) and the 2022-2023 winter storms which have caused widespread landslides, roadway washouts, floods, and power outages. Considering these facts, it is difficult to understand why the Climate & Disaster Risk scores are so low across our region.
We urge the US DOT to replicate the standards of established California tools such as the Priority Populations criteria established by state agencies and used by major grant programs, including those developed by the California Air Resources Board (https://webmaps.arb.ca.gov/PriorityPopulations/) and the equity index currently under development by the California Department of Transportation (Caltrans). We encourage the US DOT to more significantly consider cost of living, real poverty, and the other environmental components (link provided in attached letter). Additional considerations, as used in our regional definition of “disadvantaged community” (link provided in attached letter), include Census measures of race/ethnicity, income, elderly age, automobile ownership, disability, limited English proficiency, and educational attainment.
Thank you for the opportunity to comment on the proposed changes.
Maura Twomey, Executive Director, Association of Monterey Bay Area Governments
Todd Muck, Executive Director, Transportation Agency for Monterey County
Guy Preston, Executive Director, Santa Cruz County Regional Transportation Commission
Binu Abraham, Executive Director, Council of San Benito County Governments
Comment On Document ID:DOT-OST-2023-0020-0023
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