I applaud what seems to be the intent of the authors, but find the document confusing and possessing mistakes as discussed briefly below. Overall, some discussion of why this is being proposed to APHA would be useful. At the moment, there are far more important issues to address by APHA, such as the health disparities involving the pandemic, and differential delivery of vaccines to protected classes, even beyond those mentioned in the document, for example undocumented people, low literary people, farmworkers, packing shed workers, people with severe disabilities, etc. Specific comments: “minorities” is falling out of favor in use, while “people of color” is seen more. I would delete mention of “Complete Streets policies” because it’s fraught as to what that actually means. Often it means “listen to environmentalists and bicyclists,” and leave out cars. But cars have been an instrument of social and physical mobility for whites, and excluding cars from consideration leaves out groups which could use cars, such as African-Americans. “mixed-use development” doesn’t have much to do with equity and nondiscrimination. As I reach this point in the document, I’m starting to see some confusion between nondiscrimination, equity, and fairness issues with “Big Green” type issues, dominated by middle class whites. This is a trope of progressives: “overburdening residents with engagement requests.” There’s nothing wrong with asking people of all sorts to be engaged in social and infrastructure issues. This is just defensive gobble de goop: “addressing opinions that equity is already embedded in policymaking, so no further work is necessary.” Sometimes equity is embedded, and sometimes it isn’t. There’s nothing wrong with stating what is. The word “impact” is repeatedly used, when the writers appear to be “adversely affect.” This phrase, “tokenizing community engagement,” reflects an ideological set of assumptions. Community engagement is good. Who’s to say what is tokenizing or not? If what you mean is that you suspect that sometimes people of color input is not taken seriously, then say that, and don’t use coded ideological language. There’s something missing in this sentence: “Even more importantly, decision-makers should the racial and social makeup of the communities they serve, from planning and transportation staff to elected and appointed leadership.” In addition, throwing in elected issues moves the discussion away from health and equity into a different, political, realm. This is not necessarily true: “the outcomes described in this problem statement were made by mostly white and mostly male staff and leaders with little guidance from other groups. This fact is at the foundation of the inequities borne through built environment decisions.” Some of these inequities stem from slavery. Blaming them on professional staff should be supported by evidence. This confuses zoning decisions with other causal factors: “planning and zoning decisions that predominantly – and inequitably – distribute resources in wealthier, whiter parts of communities. These resources include parks and recreation facilities, high-quality schools, health care facilities, and grocery stores.” I don’t think that locations of health care facilities and grocery stores are due to zoning. There are indeed health care and food deserts, but that fact is not due to zoning. If anything, zoning has moved big facilities AWAY from wealthy communities. This reflects a very old understanding of transportation planning: “the majority of transportation planning has sought to serve downtowns with the idea that most people are working 9-5 in offices.” Freeways, for example don’t just serve downtowns, but almost by definition connect cities. It is true that a number of subway and heavy rail systems are hub-and-spokes. This sentence is confusing: “Today, after decades of white flight and redlining, the current suburbanization of poverty brings about a new set of health equity challenges.” White flight ended decades ago, and suburbanization of poverty contradicts white flight, and is a more recent phenomenon. The writers appear to have just jumbled together a bunch of old phrases. Re this, “Inadequate infrastructure for active transportation, such as sidewalks, available to these communities can make transportation unsafe or inaccessible,” the sidewalk issue is a fraught one, because many higher income communities don’t have sidewalks. This is not so true anymore: “The urban form resulting from land use and transportation decisions has led to a geographical mismatch of affordable residential areas to employment opportunities, creating barriers to employment, particularly for racial minorities.” The bulk of jobs are no longer located in cities, but have been suburbanized and exurbanized also. The argument, then, would be to put more cars in the hands of African-Americans. This sentence appears to be a mistake: “Compared to taxi service, ride-sharing services better serve minority neighborhoods in terms of both coverage, wait times, and reliability.” Maybe it just needs clarifying. This is a confusing sentence also, “The reliance on mobile technology and internet access for registration and/or payment is a barrier for some populations, such as people with low digital literacy, older adults, individuals without banking, and immigrants.” While being unbanked continues to be a problem among low income people, cellphone penetration is very high among almost all groups in the US. Re this “social networks are shaped by place,” social networks are shaped by many factors, especially today with social media. Place has actually become less important since the advent of the Internet, as we have seen during the pandemic. Re this, “Displacement of communities of color related to transit investments continues today,” I don’t know of any current examples. Perhaps the authors do. If so, I’d like to read them. Thanks. The discussion of traffic safety is an overall societal one, not one that is particularly pertinent to equity. This discussion and that of bicyclists raises the question of the true purpose of the document. This is a pretty outrageous allegation: “suggesting that driver bias may play a role in Black pedestrian deaths.” I’d want to see much more than one academic study on the issue. The allegation implies intentional crashing of white drivers into Black pedestrians. Where is the proof? In four decades of handling discrimination complaints, I've never encountered a single case like this. Once again, this is a society wide problem, and not just an equity one: “Obesogenic environments, such as long distances between destinations or street network designs that make it harder for people to walk or bike, create conditions that promote obesity and allow for low physical activity levels.” This kind of statement once again is not an equity oriented one: “The use of non-renewable, unsustainable energy sources (such as natural gas); a high volume of non-carpooling, private vehicles which run on fossil fuels; and an increase in wildfires resulting from climate change have all impacted air pollution nationally.” By this point in the document, I’m wondering what exactly the authors are driving at. Are they making an environmental statement lightly hidden as an equity statement? Same same with the discussion of GHG. Is this an environmental document, or an equity one? I understand the reference to this toolkit, “the toolkit proposed by the Government Alliance on Race and Equity (GARE),” but the reality is that no GARE related entity can show on the ground quantifiable improvements in equity and a reduction in racism. Re this, “community members serve as decisionmakers to guide interventions,” if that were true, then there would be no need for public health or transportation planners. This is part of a disturbing thrust I have observed among some progressives to disparage the idea of merit and expertise. Re this, “Accessibility is also an important focus for equity in transportation and land use decisions, both through an examination of sociodemographics and mode, and removing barriers to accessing destinations,” one has to be careful with using the word “accessibility,” since it means different things to transportation planners and to people concerned with disability matters. Since the authors have chosen to include disability in the discussion as a protected class, then the meaning chosen should be the one pertaining to people with disabilities. In that case, it should be noted that public transportation is the most accessible form of infrastructure to people with mobility impairments. Re “Safe Routes to School programs,” once again that is not an equity issue. This is a confused discussion: “road user pricing strategies, i.e. direct charges for use of roads or charges designed to reduce use of certain vehicles, can reduce traffic volumes and may reduce VMT and potentially dangerous GHG, particularly for those living near highways. However, these types of policies can also have disproportionately negative impacts on workers who rely on private vehicles as a primary form of transport for reasons such as lack of adequate access to safe, reliable, and timely public transportation and housing costs that prevent them from living closer to their job.” The reality is that increased tolling of lanes, roads, bridges, and tunnels has economically regressive effects on low income people. Re this, “as well as that inequities with regards to transportation and land use are a result of individually-controlled behaviors, responsibilities, and choices rather than stemming from system-level issues and influences,” it’s not either/or, but both/and. Life is complex, and societal problems result from many factors. The document includes phrases that don’t have much intrinsic meaning, such as “healing through leadership.” What the heck does that mean? What does this mean: “incentivize private owners to implement them to ensure such spaces do not promote segregation or exclude certain individuals.” There already are nondiscrimination laws. This is unnecessary: “The President should create an Active Transportation Administration reporting directly to the Department of Transportation (DOT) Secretary to give active transportation a stronger voice within federal government.” There are already numerous such opportunities for input. This is just a canard against bike share operators: “Bike share operators should be required to develop and implement long-term antidisplacement and equitable distribution plans to ensure equitable access to bike share.” Re this, “A greater share of federal, state, and local transportation dollars should be invested in safe infrastructure for active and public transportation (including transit operating funds),” public transportation is already very heavily subsidized. For example, a well-run bus provider only pays about 30% of its operating expenses at the fare box. The rest is subsidized. Once again, a comment like this confuses an enviro emphasis with an equity emphasis: “Transportation policies and subsequent implementation at all levels of government must prioritize reducing the transportation sector’s contributions to global climate change.” The authors should pick a thrust and stick to it. Marc Brenman Mbrenman001(a)comcast.net [Former Senior Policy Advisor for Civil Rights, Office of the Secretary of Transportation; Co-author of The Right to Transportation, American Planning Association, 2007; Co-author of Planning as if People Matter: Governing for Social Equity, Island Press, 2012] > Kelly Rodgers > Executive Director, Streetsmart (http://thinkstreetsmart.org/)kelly@thinkstreetsmart.org > 503.442.7165Portland, OR > > Please note I am working in Pacific Standard Time. > > You received this because you are subscribed to the mailing list maintained by the TRB Health committee (AME70). To unsubscribe, learn more about the list or visit the archives see https://mailman.chrispy.net/postorius/lists/trbhealth.mailman.chrispy.net/ > > To connect with committee visit: https://trbhealth.org