Environmental Justice AnalysisTheories, Methods, and Practice - Chapter 13 pps

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13 Equity Analysis of Transportation Systems, Projects, Plans, and Policies Urban transit systems in most American cities… have become a genuine civil rights issue — and a valid one — because the layout of rapid-transit systems determines the accessibility of jobs to the black community. If transportation systems in American cities could be laid out so as to provide an opportunity for poor people to get meaningful employment, then they could begin to move into the mainstream of American life. Martin Luther King, Jr. The modern civil rights movement has its root in fighting the inequity in transpor- tation systems. A landmark event happened in the early evening of December 1, 1955 (Oedel 1997). After work, Rosa Parks boarded a crowded bus in Montgomery, Alabama. She sat down in the rows marked for whites, and later refused to relinquish her seat when sought by a white rider. Her arrest led to a bus boycott organized by her pastor, Rev. Martin Luther King, Jr. In 1954, the Supreme Court declared unconstitutional the infamous doctrine of “separate but equal,” which the same court upheld when examining the Jim Crow segregated seating law of Louisiana in 1896 (Bullard and Johnson 1997). Later, the Supreme Court declared discrimination in interstate travel unconstitutional. To test this decision, John Lewis and a group of young people began a historic journey by bus from Washington through the Deep South in early 1960s. These Freedom Riders challenged racial segregation and discrimination along their campaign roads and highways. These events preceded the enactment of the Civil Rights Act of 1964. On June 15, 1999, Rosa Parks received the prestigious Congressional Gold Medal of Honor, the highest award bestowed by the U.S. government. Although early struggles have focused on inequity in the operations and services of transit systems, little attention was given to the distributional impacts of trans- portation planning and policies until recently. On April 15, 1997, the U.S. Depart- ment of Transportation (U.S. DOT 1997a) issued the final order to address environ- mental justice in minority populations and low-income populations. The order states two principles to be observed: 1. Planning and programming activities that have the potential to have a dis- proportionately high and adverse effect on human health or the environment © 2001 by CRC Press LLC shall include explicit consideration of the effects on minority populations and low-income populations. 2. Steps shall be taken to provide public access to public information con- cerning the human health or environmental impacts of programs, policies, and activities. Specifically, U.S. DOT will take actions to prevent disproportionately high and adverse effects by 1. Identifying and evaluating environmental, public health, and interrelated social and economic effects, 2. Proposing measures to avoid, minimize, and/or mitigate disproportion- ately high and adverse environmental and public health effects and inter- related social and economic effects, 3. Considering alternatives, where such alternatives would result in avoiding and/or minimizing disproportionately high and adverse human health or environmental impacts, and 4. Eliciting public involvement opportunities and considering the results thereof, including soliciting input from affected minority and low-income populations in considering alternatives. Any programs, policies, or activities that will have a disproportionately high and adverse effect on populations protected by Title VI (“protected populations”) will be carried out only if 1. A substantial need for the program, policy, or activity exists, based on the overall public interest; and 2. Alternatives that would have less adverse effects would either (a) have other adverse social, economic, environmental, or human health impacts that are more severe, or (b) involve increased costs of extraordinary magnitude. On December 2, 1998, the Federal Highway Administration (FHWA) issued order 6640.23 “FHWA Actions to Address Environmental Justice in Minority Pop- ulations and Low-Income Populations,” establishing FHWA’s policies and proce- dures for compliance with EO12898. In a memorandum dated October 7, 1999, FTA and FHWA administrators further clarified their implementation of Title VI require- ments in metropolitan and statewide planning (Linton and Wykle 1999). Specific strategies were identified in a national conference entitled “Environmental Justice and Transportation: Building Model Partnerships,” held in Atlanta on May 11–13, 1995. Some of the recommendations are specifically targeted at transportation and land-use systems. The recommendations also include research and analysis strategies that emphasize the importance of GIS, qualitative and quantitative data, computer models, and multiple and cumulative impacts. In this chapter, we begin with a look at environmental impacts of transportation systems. Next, we discuss the regulatory environment for incorporating equity analysis in the transportation planning process and outline major methods and tools that can © 2001 by CRC Press LLC be used for conducting equity analysis in transportation planning. The first of these methods is based on refinement of transportation system performance measures, which have different strengths and weaknesses for equity analysis. We devote a lot of attention to equity analysis of mobility and accessibility, including basic concepts, measurement methods, their uses and limitations, empirical evidence about mobility and accessibility disparity, and spatial mismatch. In Section 13.5, we discuss use of a hedonic price method for evaluating distributional impacts on property values. In Section 13.6, we outline an integrated GIS and modeling approach to assess differential environmental impacts and examine a few analytical issues. In Section 13.7, we review the equity implications of some transportation policies such as congestion pricing. Finally, we discuss the Los Angeles MTA case and some analytical issues involved. 13.1 ENVIRONMENTAL IMPACTS OF TRANSPORTATION SYSTEMS Highways and transit are a mixed blessing. Accessibility is important in the real estate market, where there is a well-known motto of “Location, Location, Location.” Good accessibility is valued, but this does not mean living right next to an interstate highway. Proximity to highways or transit is “a double-edged sword” (Landis and Cervero 1999). On one hand, people value good accessibility to jobs and services because of highways and transit. In order to obtain good accessibility, households and employers look for their residential or non-residential locations a certain distance from highways or transit. On the other hand, households typically do not like to live right near highways because of negative externalities generated such as noise and pollution. Here is a tradeoff between accessibility and environmental quality. Those homebuyers who are aware of and sensitive to the negative externality of highways and transit and who believe that the benefits associated with locating near highways and transit are less than the associated cost will locate away from highways and transit if they can afford it. Those homebuyers who are unaware of or insensitive to the negative externality of highways and transit will include houses along highways and transit in their house-hunting domain. They will locate right near highways and transit if they perceive benefits such as good accessibility and good home value outweigh costs such as noise and air pollution. The U.S. DOT’s order defines adverse effects from transportation. “Adverse effects mean the totality of significant individual or cumulative human health or environmental effects, including interrelated social and economic effects, which may include, but are not limited to: bodily impairment, infirmity, illness or death; air, noise, and water pollution and soil contamination; destruction or disruption of man- made or natural resources; destruction or diminution of aesthetic values; destruction or disruption of community cohesion or a community’s economic vitality; destruc- tion or disruption of the availability of public and private facilities and services; vibration; adverse employment effects; displacement of persons, businesses, farms, or nonprofit organizations; increased traffic congestion, isolation, exclusion or sep- aration of minority or low-income individuals within a given community or from the broader community; and the denial of, reduction in, or significant delay in the receipt of, benefits of DOT programs, policies, or activities” (U.S. DOT 1997a). © 2001 by CRC Press LLC Transportation emissions continue to be a significant cause of air pollution, although today’s cars are 70 to 90% cleaner than their 1970 counterparts. This happens partly because of the rapid increase in travel activity since 1970. Vehicle miles traveled have almost doubled in the U.S. from 1970 to 1990, tripled from 1960, and increased even faster in many metropolitan areas (U.S. EPA 1998d). In 1970, vehicle miles traveled totaled 1,114 billion, compared with 2,144 billion in 1990 and 2,405 billion in 1995. As shown in Table 10.1, in 1997, the transportation sector accounts for 76.6% (67,014,000 short tons) of all CO; 49.2% (11,595,000 short tons) of NOx; 39.9% (7,660,000 short tons) of VOCs; and 13% (522 tons) of lead (U.S. EPA 1998c). In 1993, mobile sources contributed 21% (1.7 million tons) of 166 air toxics, and on-road gasoline vehicles emitted 76% of all mobile source Hazardous Air Pollutants (HAPs) nationwide (U.S. EPA 1998d). Transportation impacts decay with distance from roadways. Transportation- related air pollution is the most serious near roadways, and tends to reduce to the background level between 500 and 1000 meters (1640 to 3280 feet) from the roadway (FHWA 1978). Traffic noise depends on the volume, speed, and composition of traffic, and often lessens to the background level at about 1000 feet (300 m) from a highway (Hokanson et al. 1981). Acting as barriers, the first row of houses along a transportation corridor absorbs most noise impacts (Stutz 1986). In old city centers, a street network is often in grids. Houses are usually attached and face a street. More or less, most houses in city centers are impacted by noise associated with vehicles. However, a street network consists of links to various functions with various traffic volumes and speed. Some streets serve a local purpose, others serve as minor arteries, and still others serve as major arteries. This means that environmental impacts from the transportation network are different for different neighborhoods. This has been commonly recognized in the real estate market. Besides environmental impacts, transportation projects and plans also have a wide range of social and economic impacts on the communities. The U.S. Department of Transportation’s Community Impact Assessment reference guide (FHWA 1996) iden- tifies a variety of potential community impacts that need to be addressed (Table 13.1). Clearly, transportation projects, programs, and plans have much broader impacts. 13.2 INCORPORATING EQUITY ANALYSIS IN THE TRANSPORTATION PLANNING PROCESS The Clean Air Act Amendments (CAAA) of 1990 mandate integration between transportation and air quality processes at all levels of governments. The planning process is the focal point for consideration of existing transportation system perfor- mance, transportation management strategies, CAAA requirements, transportation improvement program and implementation, funding, and other factors such as social, economic, and environmental factors. TEA-21 consolidates the previous sixteen planning factors into seven broad areas to be considered in the planning process (same as for statewide planning). As mentioned earlier, FTA and FHWA administrators jointly issued a memoran- dum to further clarify their implementation of Title VI requirements in metropolitan © 2001 by CRC Press LLC and statewide planning (Linton and Wykle 1999). The memo emphasizes that the law applies equally to the processes and products of planning as well as to project development. They request actions to ensure compliance with Title VI during the planning certification reviews conducted for Transportation Management Areas (TMAs) and through the statewide planning finding rendered at approval of the Statewide Transportation Improvement Program (STIP). The reviews assess Title VI capability in terms of overall strategies and goals, service equity, and public involve- ment. Review questions address specific procedural and analytical capabilities for complying with Title VI. “Does the planning process have an analytical process in place for assessing the regional benefits and burdens of transportation system invest- ments for different socio-economic groups? Does this analytical process seek to assess the benefit and impact distributions of the investments included in the plan and TIP (or STIP)?” In 2000, FHWA and FTA revised planning regulations (23 CFR 450 and 49 CFR 619) and environmental regulations (23 CFR 771 and 49 CFR 62) to propose appropriate procedural and analytical approaches for Title VI compliance. These laws and regulations prompt a paradigm shift in transportation planning. It moves away from the old paradigm, which emphasizes how fast vehicles move. The new paradigm emphasizes how well people’s travel needs are met economically efficiently, environmentally friendly, justly, and socially. TABLE 13.1 Community Impacts of Transportation Impact Category Examples of Impacts Social and psychological impacts Redistribution of population, community cohesion and interaction, social relationships and patterns, isolation, social values, and quality of life Physical and visual impacts Barrier effect, sounds (noise and vibration), other physical intrusions (dust and odor), aesthetic character, compatibility with community characteristics Land-use impacts Farmland, induced development, consistency and compatibility with land-use plans and zoning Economic impacts Location decision of firms (move-in, move-out, close, stay-put), direct impacts of construction on local economy, tax base, property value, business visibility Mobility and access impacts Pedestrian and bicycle access, traffic-shifting, public transportation, vehicular access, parking availability Public services impacts Relocation or displacement of public facilities or community centers, inducing or reducing use of public facilities Safety impacts Pedestrian and bicycle safety, accidents, crime, emergency response Displacement Effect on neighborhood, residential displacements (characteristic of displaced population, types and number of dwellings displaced, residents with special needs), business and farm displacements (types and number of businesses and farms displaced), and relocation sites Source: Federal Highway Administration. 1996. Community Impact Assessment: A Quick Refer- ence for Transportation. Publication No. FHWA-PD-96-036. Washington, D.C. © 2001 by CRC Press LLC Equity analysis of transportation systems is more complicated than most other environmental justice issues. While most environmental justice controversies origi- nate from specific site-based projects in a particular time, transportation systems involve much broader spatial and temporal dimensions. In the spatial dimension, transportation systems (either highway or transit) are linear and penetrate every community, compared with scattered points with limited impact areas of some LULUs in a few communities. In the temporal dimension, transportation systems have definite planning horizons well into 20 years in the future, as well as their legacy from the past. While transportation projects are carried out one by one in different communities, they generally have to go through transportation planning processes at the city, county, regional, or state levels. Those federally funded projects with regional significance require evaluation in the metropolitan planning process, which involves both project and policy levels. Clearly, equity analysis has to deal with these two levels. Table 13.2 lists major methods and tools for conducting environmental justice analysis in transportation planning. They are built upon existing analytical capabil- ities of metropolitan planning organizations. Technical staff for MPOs need to adapt these methods and tools to deal with environmental justice issues in their regions. For example, many MPOs use a traditional four-step transportation modeling chain (see Figure 13.1) to forecast travel demand and evaluate air quality conformity. These models can be refined and adapted to provide measures for equity analysis, TABLE 13.2 Methods for Conducting Environmental Justice Analysis in Transportation Planning Categories Methods/Tools Transportation systems Performance measures by population groups Accessibility and mobility Vehicle availability and vehicle availability modeling Accessibility measures • Distance/time-based measures • Cumulative-opportunity measures • Gravity-type accessibility index GIS Property value impacts Hedonic price methods/GIS Environmental impacts Land-use/transportation modeling Environmental modeling GIS User benefits Consumer welfare measures by population groups • Travel demand models/urban models Direct valuation of travel time saving, operating costs, and safety improvement • Travel demand models • Benefit-cost analysis Fiscal impacts of transportation funding and pricing Welfare economics and incidence of tax analysis © 2001 by CRC Press LLC such as accessibility. In particular, mode choice and trip generation submodels are very useful for equity analysis. A mode choice submodel can provide accessibility measures and consumer welfare measures (see Chapter 9 and Section 13.4 below). These measures can be stratified by income and race for equity assessment. Trip generation and vehicle availability submodels can provide measures for evaluating the impacts of transportation projects and plans on mobility by various population groups. Most data needed to carry out these analyses are available. In the following, we will discuss some of these methods in detail. 13.3 TRANSPORTATION SYSTEM PERFORMANCE MEASURES With a shift in the planning paradigm, new performance measures are adopted to evaluate transportation systems. Vehicle Miles of Travel (VMT), vehicle trips, and average travel speed are three performance measures that are very important in linking transportation planning and air quality planning. Planners and engineers have used a lot of variables to measure transportation system performance. For example, people often feel and complain about congestion during commuting, but it is not easy to define and measure congestion. Congestion is vaguely defined as “the level at which transportation performance is no longer acceptable due to traffic interference. The level of acceptable system performance may vary by type of transportation facility, geographic location and/or time of day” (Interim Final Rule on Management and Monitoring Systems). With this definition, the federal government gives state and local governments substantial flexibility to measure congestion. FIGURE 13.1 Traditional four-step transportation modeling. © 2001 by CRC Press LLC Each performance measure shows different strengths and weaknesses which have various equity implications (Table 13.3). These measures can be segmented by population group for evaluating distributional impacts of transportation projects. For example, a VMT measure was used to assess the disproportionate impacts of the Barney Circle Freeway Modification Project in Washington, D.C. (Novak and Joseph 1996). The goals of the project were to complete a vital freeway link as a major commuter route in the District and to divert through traffic from residential streets to freeways. The project was controversial and opposed by a coalition of civic, neighborhood, and environmental groups (Sphepard and Sonn 1997). To measure the distributional impacts of the changes in freeways and residential streets, VMT- persons were estimated as the changes in VMT on each residential street link and each freeway segment multiplied by the population that is affected (Novak and Joseph 1996). Reduction in VMT in residential streets is a benefit that accrues to local residents, while an increase in VMT on freeways is a burden to local residents. VMT-persons measure the magnitude of benefits and burdens for local residents. Holding population constant, a census tract with a large VMT reduction in residential streets benefits more than a census tract with a small VMT reduction. VMT changes in each census tract were derived from traffic modeling. To assess distributional impacts, VMT-persons were estimated separately for minority and low-income pop- ulations and compared to the proportion of the total population that each group comprises in the area. Any disproportionate impacts were then spatially identified. 13.4 EQUITY ANALYSIS OF MOBILITY AND ACCESSIBILITY 13.4.1 C ONCEPTS AND M ETHODS Mobility, literally the ability to move around, “relates to the day-to-day movement of people and materials” (U.S. DOT 1997b). Is mobility a merit good or a right? The majority of 1,600 people randomly surveyed in New Mexico considered mobility as a right (Hamburg, Blair, and Albright 1995). They were asked the question: Do you believe that the ability to get where you want to go in a reasonable time and for a reasonable cost is or should be a basic right in the same sense as freedom of speech or the pursuit of happiness? Of the approximately 1,600 people surveyed, 58.9% responded yes, and 20.8% responded no. The survey also shows that females and low-income people are more likely to consider mobility as a right. Mobility is an easy to define concept but is not easy to measure. The measures often used include vehicle availability and number of miles traveled or trips taken during a given time, the latter referred to as revealed mobility. Factors affecting mobility trends include income growth, household size, labor force participation (particularly women), aging, changing levels of immigration, residential and job location, changes in the nature of work and workplaces, and advances in information technologies (U.S. DOT 1997b). Accessibility is a concept that is not easy to define and measure. When people talk about how accessible a place is, they relate that place to other places. Accessi- bility involves relative locations of activities or opportunities such as working places, © 2001 by CRC Press LLC TABLE 13.3 Transportation Performance Measures and Their Equity Implications Measure Definition Strengths Weaknesses Equity Implications Person-miles of travel (PMT) or passenger-miles traveled Vehicle volume × link length × vehicle occupancy Can be aggregated to any spatial level (link, facility, subarea, region) and to any temporal level (peak-hour, peak-period, daily, weekly, monthly, annually) Can be used by mode, including trucks Reflects persons’ real demand for travel Does not directly address air quality impacts from vehicle trips Favors long-distance travelers Vehicle miles of travel (VMT) Vehicle volume × link length Can be aggregated to any spatial level and to any temporal level Can be used and aggregated by mode, including trucks Related to air quality, accessibility, and sustainability Does not address non-motorized trips Generally used for car or truck, and would give misleading and difficult-to- interpret information if including transit vehicles Favors users of motorized modes such as car, truck, or transit Favors particularly drivers with more mileage than average Vehicle hours of travel (VHT) Vehicle volume × travel time Accounts for congestion More directly related to air quality Better proxy for mobility, accessibility and sustainability Does not address non-motorized trips Favors users of motorized modes Average speed Speed of person trips between origin and destination averaged for a period of time Intuitively appealing Can be aggregated by trip purpose, mode, spatially, and temporally Related to air quality Overemphasis on vehicle trips Favors users of motorized modes Average trip length, time Distance and time of person trips between origin and destination averaged for a period of time Intuitively appealing Can be aggregated by trip purpose, mode, spatially, and temporally Related to accessibility. Requires Origin-Destination Survey which is expensive Can show accessibility disparity continued © 2001 by CRC Press LLC Congestion (hours of delay) Free flow speed operating speed Delay per vehicle at intersections is standard for measuring intersection level of service Directly reflects traveler’s perspective Difficult to define free flow speed Free flow speed may change and affect the public’s understanding Favors travelers using congested roads Congestion (volume/capacity ratio; level of service) Volume/capacity Level of Service is a set of descriptors (such as A to F) to measure transportation system performance and is defined based on travel time, cost, number of transfer, volume/capacity ratio, etc. Data are readily available Easy and inexpensive to estimate Difficult for the public to understand Requires a good estimate of capacity, which is difficult Cannot measure a volume that is greater than capacity in reality Deficient in over-saturated conditions Difficult to aggregate to a higher level of geography such as a region Favors travelers using congested roads Congestion (speed or travel time) Defined by speed/travel time threshold range by facility. For freeways, severe congestion occurs if speeds less than 30 MPH Directly addresses traveler perspective of congestion Expensive to collect data Favors travelers using congested roads Vehicle Trips Number of trips taken using vehicles. Related directly to air quality Does not address non-motorized trips Favors users of motorized modes Person Trips Averaged number of trips per person Can be aggregated by trip purpose, mode, spatially, and temporally Does not address accessibility Can show mobility disparity TABLE 13.3 (CONTINUED) Transportation Performance Measures and Their Equity Implications © 2001 by CRC Press LLC [...]... accessibility measures 13. 6 MEASURING ENVIRONMENTAL IMPACTS In Chapters 8 and 9, we discussed the integration of urban and environmental models in a GIS environment This integration serves as a framework for evaluating the environmental impacts of transportation systems, projects, plans, and programs on different population groups This methodology follows a sequential process (Table 13. 4) Land and transportation... that these taxes are regressive overall The clash between some mainstream environmental and environmental justice groups and between environmental and equity goals is demonstrated in various road pricing or value pricing proposals Economists and some environmental groups argue that auto driving has been underpriced and subsidized and does not account for external costs caused by driving To combat air... level The analyst needs to develop an interface among different modeling domains and units of analysis for integrating urban and environmental models © 2001 by CRC Press LLC TABLE 13. 4 Integrating Urban Models, Environmental Models, and GIS for Transportation Equity Analysis Modeling Land-use/Transportation Modeling • Land-use model • Vehicle availability • Trip generation • Trip distribution • Modal... reduce traffic congestion, air pollution, and automobile dependency and, thereby, benefit the low-income population In particular, as discussed in Chapter 10, studies have shown that a low-income population tends to be exposed to a higher degree of air pollution nationwide Cameron (1994) evaluates efficiency and equity of existing transportation systems and a 5-cent-per-mile VMT in Southern California The... interchanges are also sold at a discount In Alameda and Contra Costa counties of the San Francisco Bay Area, the 1990 sales price of a home declined $2.80 and $3.41, respectively, for every meter closer to a freeway interchange (Landis and Cervero 1999) On the other hand, new 4-lane roads generally raise land values by 3% to 5% for houses within a 0.5-mi radius, and the impact can extend further, as much as... total), the lower-middle income group receives $1,430, the middle-income group receives $1,980 (19% of regional total), the upper-middle-income group receives $2,880, and the upper-income group receives $3,750 (35% of the regional total) Comparing it with personal income distribution, the current transportation system redistributes transportation benefits toward those in the middle A 5-cent-per-mile VMT fee... transportation or land-use models may also generate consumer welfare measures by different populations Hedonic price methods can be used to assess capitalized benefits of accessibility improvements in the land market Integration of land use/transportation models, environmental models, and GIS has great potential for conducting a multi-objective analysis of efficiency, equity, and environmental sustainability... races and Hispanics (of all races) (see Figure 13. 3) © 2001 by CRC Press LLC After controlling geographic locations (central city, suburban, and nonmetropolitan areas), the disparity remains (U.S DOT 1997b) In 1990, white men in urban areas traveled 39 mi and made 3.4 trips a day on average, compared with 29.5 mi and 2.8 trips for Hispanic men and 24.1 mi and 3.0 trips for black men (Figure 13. 4) In... areas In 13 metropolitan areas, workers residing in the largest poverty enclave in the central city had the longest average commute times, usually 10% more than the other areas An improvement in the recent literature is use of gravity-type accessibility measures and fine-grained units of analysis Sanchez (1999) used gravity-type accessibility measures for access to job and a two-stage least-square regression... market (e.g., direct costs), user non-market (e.g., travel time and comfort), external market (e.g., subsidies), external environmental (e.g., air and water pollution), automobile dependency, and economic (e.g., changes in consumer prices and employment) Using this classification scheme, he summarizes equity impacts of an automobile-user price increase, transit subsidy, and traffic management strategies . gravity-type accessibility measures and fine-grained units of analysis. Sanchez (1999) used gravity-type acces- sibility measures for access to job and a two-stage least-square regression for esti- mating. Actions to Address Environmental Justice in Minority Pop- ulations and Low-Income Populations,” establishing FHWA’s policies and proce- dures for compliance with EO12898. In a memorandum dated October. (dust and odor), aesthetic character, compatibility with community characteristics Land-use impacts Farmland, induced development, consistency and compatibility with land-use plans and zoning Economic

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  • Environmental Justice Analysis

    • Table of Contents

    • Equity Analysis of Transportation Systems, Projects, Plans, and Policies

      • 13.1 Environmental Impacts of Transportation Systems

      • 13.2 Incorporating Equity Analysis in the Transportation Planning Process

      • 13.3 Transportation System Performance Measures

      • 13.4 Equity Analysis of Mobility and Accessibility

        • 13.4.1 Concepts and Methods

        • 13.4.2 Using Accessibility for Equity Analysis

        • 13.4.3 Empirical Evidence about Mobility Disparity

        • 13.4.4 Accessibility Disparity and Spatial Mismatch

        • 13.5 Measuring Distributional Impacts on Property Values

        • 13.6 Measuring Environmental Impacts

        • 13.7 Equity Analysis of Transportation Policies

        • 13.8 Environmental Justice of Transportation in Court

        • 13.9 Summary

        • References

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