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.
“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
“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
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,
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
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
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
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
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.
[Former Senior Policy Advisor for Civil Rights, Office of the Secretary of
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,
On 02/27/2021 4:35 PM Kelly Rodgers
Hello all -
I was part of a team that just submitted an updated policy statement,'Ensuring Equity
in Transportation and Land Use Decisions,' to theAmerican Public Health Association
(APHA) for consideration during the 2021 policy cycle, attached. This will be
reviewed/commented on by APHA leadership and members over the next few months, but we
encourage feedback from as many other diverse stakeholder organizations and community
members as possible.
BACKGROUND: APHA identified this topic as a policy statement gap in 2019 to update and
replace an older policy statement (https://lnkd.in/duVi5y6
). Policy statements help shape
APHA's position on legislation/regulations and inform materials including briefs,
statements, reports, and more. In summer 2019 we assembled our volunteer working group,
and the effort has been in the making since then.
If you have comments, please send them my way. Thanks!
> Kelly Rodgers
> Executive Director, Streetsmart
> 503.442.7165Portland, OR
> Please note I am working in Pacific Standard Time.
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> To connect with committee visit: https://trbhealth.org