December 1, 2021
Secretary Pete Buttigieg
US Department of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590
Administrator Nuria Fernández
Federal Transportation Administration
US Department of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590
Deputy Administrator Stephanie Pollack
Federal Highway Administration
US Department of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590
Dear Secretary Buttigieg, Administrator Fernández, and Deputy Administrator Pollack,
Denver Streets Partnership is pleased to see the Biden administration’s Justice40 initiative to improve federal efforts on equitable access and the requests for information that you have sought around Title VI implementation.
We believe it is even more important at this time in history to recognize the limitations of Title VI and innovate beyond them. Title VI is by definition a compliance mechanism and although Title VI attempts to prevent federally funded projects from having disparate impacts it is not designed to incentivize the type of proactive or affirmative policies needed to achieve equity.
The Bipartisan Infrastructure Bill signed by President Biden on November 15, 2021 can be a tremendous vehicle for furthering equity or it could take us in the wrong direction. This all depends on the kinds of investments that are funded.
For this reason, we want to call attention to things that the FTA and FHWA can do to build equity into your own respective programs.
The FTA will have a greatly enhanced Capital Investment Grant program which should prioritize transit investments that:
- Improve speed, reliability, accessibility, frequency, and/or span for heavily-used transit corridors.
- Significantly expand access to jobs, schools, stores, medical facilities, and other recurrent destinations, especially for people with low incomes and people of color.
- Achieve network effects through upgrades that improve linked trips or through additional service changes planned in tandem with the primary project.
- Have alignments with stations and stops in places people can easily and safely access via walking, biking, or wheelchair.
Likewise, the FHWA should take proactive steps to further equity through the decisions made through its discretionary grant programs and its Title VI authority and other oversight processes. To further equity the FHWA can prioritize projects that create affordable, safe, multimodal access for all and bring a critical eye to highway projects that threaten to displace residents and businesses, worsen air quality in communities of color, and foster racial and economic segregation.
For example, the Denver region would benefit from capital funding for a Bus Rapid Transit network as outlined in the Regional Transportation District’s Regional Bus Rapid Transit Feasibility Study published in 2020. A connected regional network like this could reduce vehicle miles traveled and the associated impact on air pollution, which disproportionately impacts communities of color; create more reliable access to opportunities for low-income households and households without access to a vehicle; and provide critical connections for people with disabilities and older adults. Funding these projects in the Denver region is an opportunity for your agencies to further equity through our transportation system.
USDOT can also encourage stronger public participation and engagement by local agencies and DOTs and we are pleased that the FTA’s current RFI is asking questions to surface best practices in this area. In November, The Center for Neighborhood Technology and TransitCenter released an important report, Equity-in-Practice, which provides several tangible case studies of strong public participation models. One clear lesson is the importance of investing in meaningful, paid partnerships with community based organizations as facilitators between agencies and communities.
A standout partnership took place in Miami-Dade County where Transit Alliance, a non-profit organization, was integral to planning the Better Bus Network which was unanimously passed by Miami-Dade’s county commissioners on October 5, 2021. Transit Alliance ensured that all data driven propositions for rerouting were checked against local knowledge so that the final redesign, while data informed, was also shaped by riders’ experiences and needs. The key element of these arrangements is that the contracted organizations be viewed as partners, not vendors.
We appreciate the work you do and look forward to continuing the conversation.
Sincerely,
Jill Locantore
Executive Director
Denver Streets Partnership
Cc:
Deputy Secretary Trottenberg
Ann Shikany
Dani Simmons
Veronica Vanterpool
Paul Kincaid
Ileana Astorga
Andres Carrera
Thomas Woodburn
Jeff O’Neil