title vi– environmental justice analysis · title vi– environmental justice analysis....

TITLE VI–ENVIRONMENTAL JUSTICE ANALYSIS

Introduction The Pikes Peak Area Council of Governments (PPACG) is the designated Metropolitan Planning Organization (MPO) for El Paso and Teller Counties. As the designated MPO, PPACG serves as a forum for carrying out the federally mandated comprehensive, cooperative, and continuing (3‐C) regional transportation planning process. PPACG is responsible, together with the Colorado Department of Transportation (CDOT), for producing a long-range regional transportation plan that meets the social, environmental, economic, and travel needs of the region. PPACG is also responsible for developing a transportation improvement program (TIP) which assigns federal transportation funds to specific projects. PPACG involves and informs the public on transportation planning decisions throughout the planning process. The implementation of PPACG’s transportation plan is carried out by PPACG’s member agencies.

The Title VI Program includes an effort by the Pikes Peak Area Council of Government to perform a review of environmental justice issues, as well as to implement a standard procedure for including environmental justice in the planning process.

Environmental Justice Requirements On February 11, 1994, President Clinton issued Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low‐Income Populations." This Executive Order is closely related to Title VI of the Civil Rights Act of 1964. As a federally funded agency, the Pikes Peak Area Council of Governments is required to be in compliance with both of these federal orders. The U.S. Department of Transportation (USDOT) has encouraged a proactive approach to the implementation of Title VI and environmental justice. In April of 1997, USDOT issued an Order on Environmental Justice (EJ Order 5610.2) requiring the USDOT to implement the principles of Executive Order 12898 through the incorporation of EJ principles in all programs, policies and activities carried out by USDOT. In December of 1998, the Federal Highway Administration issued a similar order requiring the incorporation of EJ principles in all FHWA programs, policies, and activities.

Executive Order 12898 was created to bring federal attention to the environmental and human health conditions in low‐income and minority communities with the goal of achieving environmental justice. The goal of environmental justice is to ensure that any adverse human health or environmental effects of any government activities do not disproportionately affect minority or low‐income populations. EJ does not intend to provide preferential treatment to these populations, but rather fair treatment to all populations. Specific to transportation, Executive Order 12898 has been issued in order to ensure that all federally‐funded transportation related programs, policies, and activities that have the potential to cause adverse impacts specifically consider the effects on minority and low‐income populations. EJ is a public policy objective that has the potential to improve the quality of life for those whose interests have traditionally been overlooked. According to the USDOT, there are three core principles of environmental justice:

To avoid, minimize, or mitigate disproportionately high and adverse human health or environmental effects, including social and economic effects, on minority and low‐income populations.

To ensure the full and fair participation by all potentially affected communities in the transportation decision‐making process.

To prevent the denial of, reduction in or significant delay in the receipt of benefits by minority and low-income populations.

As the primary forum for the cooperative development of regional transportation plans, MPO’s need to be in compliance with Title VI and incorporate EJ concerns. MPO responsibilities include:

Identify low‐income and minority populations so that their needs can be identified and addressed and that the benefits as well as the burdens of transportation investments can be fairly distributed throughout the planning area.

Enhance existing analyses processes to ensure that the Regional Transportation Plan and Transportation Improvement Program comply with Title VI requirements.

Evaluate the existing public involvement processes and improve if necessary to include minority and low‐income populations in the decision making process.

PPACG’s Environmental Justice Program Objective PPACG's Title VI Environmental Justice initiative is intended to ensure that EJ principles are included in PPACG's planning process. PPACG's objective is to fulfill this requirement proactively. The following steps describe PPACG's approach to implementing EJ:

Educate staff on EJ regulations, issues, and components. In the past several years, PPACG has participated in a number of state and federal EJ workshops and conferences to gain greater understanding.

Provide staff with case studies of successful EJ implementation. PPACG has reviewed and gleaned insights from a number of successful case studies, most notably that of Capital District Region Transportation Committee, Albany, New York.

Collaborate with CDOT and other MPO's regarding their status/approach concerning EJ implementation.

Formulate a standard procedure that allows for the realistic implementation and documentation of EJ analysis and principles. PPACG staff continues to develop more effective approaches. EJ consideration has been explicitly added to long-range plan, TIP, and UPWP planning considerations.

The following components are present in planning process as directed in the existing federal guidelines:

Public Involvement – Meaningful public participation is critical to the successful implementation of EJ. Public involvement occurs throughout the PPACG process. Public participation will be inclusive of all affected parties and will take their needs into consideration.

Systems Level Approach – EJ is considered at the program level as well as the project level. The overall 20‐year plan is responsive to citizens' concerns. EJ is integral to the planning process, not something extra that is sometimes included.

Nontraditional Approach – For successful implementation of EJ practices, PPACG goes beyond traditional means of reaching out to the public. These nontraditional approaches will aid in improving the overall quality of life of the various affected populations.

Documentation – EJ assessment is documented and included in the planning documentation.

Teamwork – PPACG's EJ policy adheres to the EJ policies of cooperating agencies, particularly CDOT.

Tools, Data Collection, and Technical Analysis PPACG uses attribute data primarily from the U.S. Census Bureau as well as any additional available data that will be useful in identifying EJ populations. The data used for the 2040 Regional Transportation Plan EJ analysis came from the 2006-2010 American Community Survey (ACS) Census Transportation Planning Products (CTPP). This data is available at the TAZ level, which gives PPACG the ability to compare data

with the travel demand model. For this analysis we collected:

1. Population Over 65 by TAZ 2. Household Poverty by TAZ 3. Non‐white (or Minority) Population by TAZ 4. Hispanic Population by TAZ

Technical Approach The following sections describe the technical approach to evaluating the extent to which PPACG's 2040 Regional Transportation Plan’s fiscally constrained project list (not including local and/or privately funded projects) achieves the objectives of Executive Order 12898 and the overall requirement of Title VI.

Objective: Assure equitable access to, consideration within, and effects of the planning agenda, planning products and program of federally‐assisted transportation projects in the Pikes Peak Region.

Equitable access to, consideration within, and effects of the design and implementation of federally‐assisted projects are also keys aspect of environmental justice. However, design and implementation are the responsibility of project implementers in the case of the Pikes Peak Region. Implementers include the Colorado Department of Transportation, Pikes Peak Rural Transportation Authority, and the region's counties, cities and towns. PPACG's environmental justice program cannot fully address the adequacy of processes used by these entities. The approach seeks to answer three core questions:

1. Is there adequate access to the process? 2. Is the outcome equitable? 3. Are the impacts fairly distributed?

Method: Use geographic information system (GIS) tools to facilitate the identification of geographic areas of low-income, minority, Hispanic, and elderly populations.

Considerations Given the topology of PPACG’s extensive data base and travel demand model, traffic analysis zones were selected serve as the primary geographic unit of aggregation for the EJ analysis. Traffic analysis zones (TAZs) represent a finer geographic level than census block groups.

The analysis was performed at the MPO level. Of the 786 traffic analysis zones in El Paso and Teller counties, 734 TAZs are in the MPO area. A TAZ is counted as part of the MPO area if any/all of the TAZ is inside the MPO boundary. For the project‐level analysis, a buffer of one quarter mile was overlaid on all project locations.

The U.S. Census Bureau's data, which includes ACS data, offers respondents the option to report more than one race. Remember that because Hispanic identifies an ethnicity, rather than a race, persons identified as Hispanic may be of any race. For those projects without any one specific geographic location, one can note most transit projects in our region impact low-income, minority, and elderly citizens in a positive way. The state and federally funded projects that staff was not able to map were:

Environmental Mitigation for Transportation Projects

Right-of-way for Powers Blvd. and other State Highways

Transit: Maintenance of Existing Operations/Admin

Park-and-Ride Access for Bicycles and Pedestrians

Advanced Traffic Detection: Major Corridors in Colorado Springs

Capital Improvements and Planning Efforts USC Section 5307

Metro Rides Regional Travel Demand Management Program

23 USC Section 104 and Section 5305 Metropolitan Transportation Planning

Traffic System Upgrades

Transit Planning Studies

MPO Planning

CDOT Maintenance and Operations

Maintenance and Operations

Major Transportation Corridor Plan Update Where appropriate, PPACG uses quantitative measures to complement qualitative assessment of EJ performance. Quantitative measures are derived primarily from PPACG's core and supplemental system performance measures. These measures match the planning issues of MAP-21 well and are quite comprehensive. While many measures (such as energy consumption, emissions contributing to ground level ozone or impact on climate change) are best assessed at a regional level, a number of others can be used at a local level to measure need (in examining the emphasis of the planning program) and effect (in examining the equity of positive and negative impacts of recommended actions and projects). This is a work in progress and quantitative measurement is still evolving.

PPACG staff will continue to explore the feasibility of assessing need and effects using a combination of these measures in EJ documentation. Additional experience will be required to identify what set of these measures constitutes a practical reflection of a range of needs and impacts for which equitable consideration is required. At all times, PPACG will seek to keep the EJ/Title VI measures integrated with the overall system planning and project‐level measures used for decision‐making.

Identification of Geographic Areas of Special EJ Concern Methodology Used to Identify Environmental Justice Areas PPACG has identified target populations for minority, Hispanic, elderly, and low‐income residents within the MPO area. PPACG's planning area includes portions of El Paso and Teller Counties.

To identify the size and location of target population groups, PPACG used the ACS 2006‐2010 Survey CTPP data at the TAZ level. The average percentages of each target population in the MPO area were calculated and these became thresholds for the analysis as described in Table L-1. The analysis identifies the TAZs that exceeded the threshold in each category and identifies projects in proximity to these target TAZs. Color‐coded maps illustrate the areas exceeding the thresholds.

Table L-1: Regional Profile of MPO Target Populations based on 2006-2010 ACS Data

Data Set Total in MPO Area TAZs Threshold

Minority (Non-White) Population 163,710 27.05% Hispanic Population 86,871 14.35% Low-income Households 23,812 10.39% Over 65 Population 58,494 9.66%

From this effort, it was determined that the MPO area population is composed of 27.05% non‐white residents and 14.35% Hispanic residents. Low-income households (below the poverty level) comprise 10.36% percent of regional households. The elderly population was defined as over 65 years of age, and comprises of 9.66% of the population. Any TAZ's that were greater than these percentages were identified as environmental justice target areas

Identification of EJ Populations: Minority Population According to the CTPP data, there are 199 TAZ's out of a total of 734 in the MPO area with a minority (non-white) population greater than the regional average (27.05%). Figure L‐1 identifies those TAZ's that exceed the EJ minority threshold (Minority Target TAZ) and those TAZ’s that exceed the threshold and are in proximity to RTP projects.

Projects that are in proximity to Minority Target TAZs are listed below:

Academy Blvd. at Fountain Blvd. Transportation Systems Management and Operations Study

Academy Blvd. widening: Drennan Rd to Hwy 115

Academy Boulevard at Portal Drive Intersection Improvement

Academy over Platte Ave. Deck Replacement

Academy over Sand Creek Bridge Rehabilitation

Airport over Sand Creek Bridge Rehabilitation

Airport Rd. Bicycle Lanes: Chelton to Murray

Astrozon Blvd. over Peterson Channel Bridge Replacement

Black Forest Road Improvements: Woodmen Rd. to Hodgen Rd.

Briargate Pkwy./Stapleton Rd. Connection

Constitution Ave. Extension: Academy Blvd. to I-25/Fontanero St. Interchange

Downtown Monument Sidewalks

Fillmore St. Corridor East of I-25

Fillmore St. over Monument Creek Bridge Rehabilitation

Fillmore St. over UPRR Bridge Rehabilitation

Fountain Blvd. over Shooks Run Bridge Replacement

Fountain Creek Regional Trail (#16) Construction

Fountain Creek Regional Trail Extension Through Downtown Fountain

Fountain Creek Trail Bridge Repair

Fountain over Spring Creek Rehabilitation

Garden of the Gods Rd. over S. Douglas Creek Bridge Rehabilitation

Hancock Expwy. Corridor

Hancock Expwy. East Bound Over Spring Creek Bridge Rehabilitation

Hancock Expwy. West Bound Over Spring Creek Bridge Rehabilitation

I-25 North Bound Acceleration Lane at S. Academy Blvd.

I-25 Widening: S. Academy Blvd. to Circle Dr./Lake Ave. Interchange

I-25/Cimarron St. Interchange Reconstruction

I-25/Tejon St. Park-and-Ride

Jimmy Camp Creek Trail Construction

Las Vegas St. over Shooks Run Bridge Rehabilitation

Maizeland Rd. over Sand Creek Bridge Replacement

MLK Bypass/Union Blvd. Intersection Improvements

MMT Route 1 and 7 Phase 2 Enhancements

MMT Route 12 Phase 4 Enhancements

MMT Route 16 and 4 Enhancements






MMT Route 8 Pedestrian/Transit Accessibility Improvements




MMT Routes 1 & 7 Pedestrian/Transit Accessibility and Bicycle Lanes

Nevada Ave./Mt. View Lane Intersection

Nevada Ave./Platte Ave. Intersection Improvements

Palmer Park Blvd. over Sand Creek Bridge Rehabilitation

Pedestrian Bridge over Platte Ave. Bridge Rehabilitation

Platte Avenue Bridge Replacement

Powers Blvd. (SH 21) Intersection Improvements from North Carefree Cir. to Constitution Ave.

Powers Blvd. (SH 21) Safety Improvements: from Stetson Hills Blvd. to Woodmen Rd.

Powers Blvd. (SH 21) Widening: Platte Avenue to Fountain Blvd.

Powers Blvd. (SH 21) Widening: Woodmen Rd. to SH 83

Powers Blvd. (SH 21)/Research Pkwy. Interchange

Powers Blvd. (SH 21)/Stewart Ave. Interchange

Right-of-Way for Powers Blvd. (SH 21) and Other State Highways

Sand Creek Trail: N. Carefree Cir. to Barnes Rd.

SH 83 Traffic/Safety Improvements

SH 83 Traffic/Safety Study

SH 85 Widening: from Comanche Village Dr. to Mesa Rd.

SH 94 Corridor Safety Study

Squirrel Creek Rd. Extension (Phases 2 and 3)

Union Blvd. at Pikes Peak Intersection Improvements

Union Blvd. over Cottonwood Creek Bridge Replacement

Union Blvd./ Academy Blvd. Interchange

Union Blvd./Constitution Ave. Intersection Improvements

UPRR over Uintah St. Bridge Replacement

US 24 East Safety Improvements Study

US 24 East Widening: Garrett Rd. to Stapleton Rd.

US 24 East Widening: SH 21 to Marksheffel Rd.

US 24 Realignment/Woodland Park Bypass Study

US 24 West Corridor in the Pikes Peak Transportation Planning Region

US 24 West/21 St. Intersection Improvements

US 24 West/8th St. Interchange

West Uintah St. Corridor Improvements

Figure L‐1: TAZ’s with Higher than Average Percent of Minority Population in Proximity to RTP Projects

Hispanic Population According to the CTPP data, there are 195 TAZ's out of a total of 734 in the MPO area with Hispanic populations greater than the regional average (14.35%). Figure L‐2 identifies those TAZ's that exceed the EJ Hispanic threshold (Hispanic Target TAZ) and those TAZ’s that exceed the threshold and are in proximity to RTP projects.

Projects that are in proximity to Hispanic Target TAZs are listed below:








Arnold Ave. Bridge Replacement














Gleneagle Dr. and Struthers Rd. Roundabout





















































Vincent Dr. Bridge over Cottonwood Creek Rehabilitation West Uintah St. Corridor Improvements

Figure L‐2: TAZ’s with Higher than Average Percent Hispanic Population in Proximity to RTP Projects

Low-Income According to the CTPP data, there are 210 TAZ's out of a total of 734 in the MPO area with a greater than average number (10.39%) of low-income households. Low-income is defined by the ACS as below the poverty level by household. Figure L‐3 identifies those TAZ's that exceed the EJ low-income threshold (Low-income Target TAZ) and those TAZ’s that exceed the threshold and are in proximity to RTP projects.

Projects that are in proximity to low-income Target TAZs are listed below:

21st St. Over Bear Creek Bridge Rehabilitation

26th St. over Fountain Creek Bridge Rehabilitation








American Discovery Trail Connection





Creek Walk Trail Schryver Park to Manitou Ave./Park Ave. Intersection - Phases III through VII




Fontanero over Camp Creek Bridge Replacement










Historic Bridges Repair and Restoration








Manitou Avenue West End Pedestrian and Drainage Improvements


























Ruxton Ave. Pedestrian and Drainage Improvements

SH 67 Corridor Improvements Phase I


















US 24 West/Ridge Rd. Overpass

US 24 Wildlife Fencing

West Uintah St. Corridor Improvements

Figure L‐3: TAZ’s with Higher than Average Percent of Low-Income Households in Proximity to RTP Projects

Senior Populations According to the CTPP data, there are 272 TAZ's out of a total of 734 in the MPO area with senior (65+) populations greater than the regional percentage (9.66%). Figure L‐4 identifies those TAZ's that exceed the EJ senior population threshold (Senior Target TAZ) and those TAZ’s that exceed the threshold and are in proximity to RTP projects.

Projects that are in proximity to Senior Target TAZs are listed below:

21st St. Over Bear Creek Bridge Rehabilitation

26th St. over Fountain Creek Bridge Rehabilitation







American Discovery Trail Connection

Arnold Ave. Bridge Replacement




Cheyenne Canyon Rd. Bridge Replacements


Creek Walk Trail Schryver Park to Manitou Ave./Park Ave. Intersection - Phases III through VII





Fontanero over Camp Creek Bridge Replacement










Historic Bridges Repair and Restoration








Manitou Avenue West End Pedestrian and Drainage Improvements























Ruxton Ave. Pedestrian and Drainage Improvements



















US 24 West/Ridge Rd. Overpass

US 24 Wildlife Fencing

Vincent Dr. Bridge over Cottonwood Creek Rehabilitation West Uintah St. Corridor Improvement

Figure L‐4: TAZ’s with Higher than Average Percent of Seniors in Proximity to RTP Projects

title vi– environmental justice analysis · title vi– environmental justice analysis....

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