Thanks for the opportunity to comment.
I am present at the Berkeley, CA community outreach session.
Based on my work in community transportation planning and research in a variety of low-income neighborhoods and communities of color in California, I offer these recommendations:
1. EJ analysis should cover not only residential populations eligible under EJ, but look at whether the project area includes or proposed projects have an impact on employment, retail, health or human services access low-income populations. Examples include: airports, medical complexes, major retail centers, and social service offices, food pantries, health care clinics, food stores, emergency rooms, food stamp offices, adult education programs, Head Start centers, etc. Essential services and jobs may be located in areas without resident populations, or in moderate or upper income neighborhoods and downtowns. Transportation/construction projects should assess and mitigate or avoid investments and projects that would affect these essential services and economic resources.
2. Highway improvement projects which happen to be surrounded by low-income/EJ neighborhoods should not be weighted as "serving" these neighborhoods unless otherwise documented, and can be shown to outweigh health impacts on air quality or toxic runoff, for example.
3. Projects which create parallel transit systems through low-income neighborhoods in order to move higher-paying passengers to a specific destination at prices or within hours of service that limit use by significant numbers of lower-income transit riders should require higher scrutiny for potential inequity, and potentially excluded from public investment if not mitigated.
4. Thanks for experimenting with outreach! Try holding workshops in large shopping centers serving EJ populations and at adult schools - they are full of target citizens who can't make it to evening meetings.
Good Work!
Betsy Morris, PhD
Planning for Sustainable Communities
Elizabeth Wilson Morris - Comments
This is comment on Notice
Proposed Circulars: Environmental Justice
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