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What’s In the US DOT ‘Equity Action Plan’

Caltrans always wants more

A new federal action plan to advance "equity" in the transportation realm includes concrete commitments to reform a transportation network that too often disenfranchises racially and socially marginalized people — but some advocates say those communities deserve a far more radical transformation.

On April 14, US DOT was one of 90 federal agencies to release a bespoke "Equity Action Plan," which outlines the moves the department will undertake to make its core programs more equitable over the next five years.

The report focuses on four key areas, all of which require decoding a little government vague-speak to understand:

    • "Wealth creation," and more specifically, making sure that 25 percent of federal transportation investments flow to "small disadvantaged businesses" by 2025
    • Enhancing the "Power of Community," or obligating grant recipients to do more meaningful public participation around federally funded projects
    • "Interventions," or providing disadvantaged agencies and community based organizations the resources they need to access federal dollars, particularly when it comes to competitive grants
    • "Expanding access," or assessing projects on their ability to provide underserved communities affordable, convenient, and multimodal transportation options that give them access to social and economic opportunities

In addition to those goals — all of which were tied to discrete, deadlined actions the agency says it will take — the document provides the most specific accounting yet of what mobility justice really means to the current DOT. Secretary Pete Buttigieg and his colleagues have consistently emphasized "equity" in many of their grant-making decisions since they took office — sometimes to fiery pushback from the GOP.

"From the construction of the transcontinental railroad to the Montgomery Bus Boycott, transportation has always been inseparable from America’s struggle for racial and economic justice," Buttigieg said in the release. "At its best, transportation can be a powerful engine of opportunity, connecting people to jobs, education, and resources — whether they live in a big city, a rural community, or anywhere in between."

Advocates appreciated the plan's commitment to broadly operationalizing equity measures within the agency's processes, but questioned whether it had thought broadly enough about how to uplift the needs of racially and socially marginalized groups.

"It’s a good first step, but there are some gaps in this document that I wish would have been explored," said Olatunji Oboi Reed, president and CEO of Equiticity.

Reed took particular issue with the action plan's emphasis on expanding "access" to mobility choices and the federal dollars that help create them, rather than on how many people from socially and racially marginalized communities, specifically, are actually using the transportation assets DOT is helping put in their neighborhoods.

"Access implies that the program is available; the door is open," he adds. "What we’re advocating for is getting people through the door and actually using the program."

Reed cites the micromobility industry, which has consistently attracted an overwhelmingly white male ridership in most markets, despite city leaders' efforts to require vehicles to be distributed in neighborhoods of color and build out the kind of protected bike lane networks that attract women riders. Since the passage of the Bipartisan Infrastructure Law, shared bikes, scooters and other micromobility projects are newly eligible for several DOT grants, but just because those services exist doesn't mean that some groups won't face other barriers to using them.

"We have to acknowledge the failure of traditional profit-focused micromobility in the US and its inability to serve marginalized communities," Reed adds.

Graphic: US DOT
Graphic: US DOT

Serving those communities isn't just about installing bike or bus lanes, Reed says. He commends DOT for its commitment to developing a "national transportation cost burden measure" — the agency says it will begin piloting the metric in December 2023, and will expand its data collection more broadly by 2026 — but wonders why the report didn't discuss other burdens placed upon marginalized groups in transportation, including things like assault, theft, and harassment, which Black cyclists frequently cite as barriers.

The DOT also neglected to mention police violence as a barrier to equitable transportation outcomes, despite the universe of data on how often Black road users, in particular, fall victim to it. Under the latest transportation reauthorization bill, DOT allows states to spend up to 10 percent of their Highway Safety Improvement Program funding on officer-based enforcement — and about half of U.S. states evaluate which departments will receive the most money based on troubling performance measures, like how many motorists they can stop per hour.

DOT also co-sponsors a controversial program with the department of justice that "teaches police that they can use traffic stops to drive down crime and it encourages police to focus their enforcement efforts in 'high crime' locations," as a coalition of 71 advocacy groups recently wrote in an open letter to Buttigieg and Attorney General Merrick Garland. 

The Equity Action Plan does not mention police enforcement at all.

"These things are antithetical to an equity action plan," Reed sad. "US DOT should publicly state that they do not support pretextual vehicular stops, period." 

Perhaps the biggest missed opportunity of the Equity Action Plan, though, is its lack of imagination about what the agency can do to make cities more equitable places to live and move, Reed says. He thinks the document focuses too heavily on adjusting the programs the department already has to achieve better equity metrics, rather than creating innovative new ones that might make a bigger difference.

Reed says those might include things as simple and inexpensive as "soft" infrastructure targeted specifically to underserved Black and brown communities; community Open Streets events, mobility hubs, and "community mobility rituals" like group bicycle rides would all fit the bill.

"Those are powerful in helping people reimagine their relationships to the modes of travel in their communities," he adds. "That money should be coming down to community-based organizations who are empowered to do that work best."

As DOT's Equity Action Plan continues to evolve, Reed hopes that the agency will go further.

"I completely understand the need for data to back up our [equity plans]," he said. "What I struggle with is this idea that a data-driven equity assessment is sufficient. Inherently, what that means is that you’re measuring that’s already been done. And we know what’s been done is not working for racially and socially marginalized people."

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