Stronger commitments from the Administration are needed to ensure that federal transport investments do not continue to exacerbate environmental inequity, climate change, and public health concerns nationwide. In July, ITDP submitted comments in response to USDOT’s request for information and input on the USDOT Equity Action Plan on behalf of 20 national and community-based stakeholder groups representing millions of Americans. Signatories include: ITDP; Transportation for America; National Campaign for Transit Justice; Just Strategy; Sierra Club; Elders Climate Action; New Urban Mobility Alliance; League of American Bicyclists; America Walks; Equiticity; Southern Environmental Law Center; Coalition for Smarter Growth; Air Alliance Houston; Colorado Call to Action; Colorado Coalition for a Livable Climate; Vibrant Littleton (Colorado); Sustain Charlotte; Wall of Women; and United North Metro Denver. 

“The equity and environmental justice commitments of the USDOT Equity Action Plan need to be bolstered by fixes to the broken project planning and approval process, which now produces absurd findings about project impacts,” said Michael Replogle, Founder and Senior Advisor to ITDP. 

“Unless federal rules and standards are reformed using existing legal authority, it is likely that much of the half a trillion dollars in federal formula transportation funds under the Infrastructure Investment and Jobs Act (IIJA) will be spent by states undermining environmental justice, worsening climate change, and eroding public health,” he continued.

This working group is asking the USDOT to add strategies to ensure that transportation plans and project reviews carried out by states and other jurisdictions under federal transportation planning rules, the National Environmental Policy Act, and the Clean Air Act: 

1. Identify and quantify the magnitude of both Greenhouse Gas (GHG) emissions and traffic-generated health hazards, and the benefits that would be achieved by adopting mitigation strategies designed to reduce emissions, improve community health, and remediate adverse impacts of past and current facility siting decisions, and enhance mobility for non-drivers and underserved communities;
2. Require that modeling account for induced travel demand, changes in multi-modal accessibility when comparing alternatives, and recognize capacity limitations when forecasting future traffic, emissions, community exposures, and estimating the benefits of mitigation measures; and
3. Include publication at the metro, state, and federal levels of summaries and analysis of how forecasts and alternative evaluations support, or fall short, of economy-wide emissions GHG goals submitted by the United States to the UN Framework Convention on Climate Change, as well as goals for remediation of disparate impacts on disadvantaged and overburdened communities. 

“Without such actions, the Equity Action Plan will fail to protect at-risk communities from continued and growing exposure to environmental hazards and safety threats, especially when highways or freight systems are proposed for capacity expansion,” Replogle added. “It will also fail to meet the Biden Administration’s proposed GHG goals, leading to further disparate impacts on already overburdened communities.”

Replogle and other members of the working group have held constructive discussions with senior USDOT officials and staff to discuss these comments and proposals.