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PART 7b: OTHER ELEMENTS

PUBLIC participation PLAN
and environmental justice POLICY

 

Contents --- 1. Introduction --- 2. Roadway System
3a. I- 84
--- 3b. RT 7 South --- 3c. RT 7 North

4. Projects by Municipality
--- 5. Bus Plan ---
6. Rail Plan
Other Elements 7a, 7b, 7c, 7d, 7e --- 8. Resource Center


PUBLIC PARTICIPATION PLAN
The Housatonic Valley Council of Elected Officials (HVCEO), the regional planning agency for the Greater Danbury - New Milford, Connecticut Area, has been responsible under federal and state law since 1975 for maintaining a regional transportation planning program. The reasoning behind this is that most transportation investments have regional components, and planning for transportation is thus most efficient if conducted on a regional basis.

The board of the HVCEO is composed of the two mayors and eight first selectmen of the ten municipalities in the area. They are the voting members. That they are the elected representatives of their municipalities is in itself a form of citizen participation in transportation planning.

For its transportation planning, the HVCEO maintains an official relationship with the Connecticut Department of Transportation (Conn DOT) in regard to all aspects of its planning activities.

The federal SAFETEA - LU transportation act requires that HVCEO maintain this written public participation plan. As detailed below, this plan lays out the process for collecting public input on HVCEO's transportation documents. Citizen viewpoints can vary widely and can favor what is proposed as well as what is opposed.

In a practical sense that complements the federal law, the chief elected officials on the HVCEO board also want to know the views of their citizens so that they can make proper decisions.

Concerned citizens will be interested in influencing the two main documents produced by the HVCEO regional transportation planning program. These are the Regional Transportation Plan (RTP), a statement of future transportation projects, and the Transportation Improvement Program (TIP), a statement of more immediate and actual projects that Conn DOT intends to fund using federal dollars for construction in the near future.

Citizens can most effectively shape transportation decisions by being aware of these two key documents, the Regional Transportation Plan and the Transportation Improvement Program.

Citizen awareness is facilitated by the fact that HVCEO by federal law must make the RTP and the TIP available to citizens and take into consideration any comments they may make before a decision is reached.

Further, armed with knowledge from the RTP and TIP as to what is being proposed for transportation improvements in their community, citizens are free to work outside of the HVCEO process to lobby state representatives or other parties with influence over transportation decisions. Details as to HVCEO citizen participation policies follow below.

PUBLIC INPUT TO DRAFT TRANSPORTATION POLICY
DOCUMENTS BEFORE VOTES AT BOARD MEETINGS
Access to draft transportation documents and all other transportation program components is the right of every citizen. Below are methods to facilitate this openness:

Legal Notice in News Times. Concerning pending adoption of HVCEO's Regional Transportation Plan and Transportation Improvement Program, to alert citizens and advocacy groups in advance, a legal notice regarding upcoming adoption of these documents will be placed in the area's major newspaper in Danbury, the News Times.

Citizens groups commonly review notices in this newspaper in order to alert themselves to growth, transportation and development issues. The notice will be written in clear and welcoming language.

Direct Mailing List to Citizens. Interested public agencies, private providers of transportation, and other interested parties may elect to receive the Regional Transportation Plan and Transportation Improvement Program directly by mail. A mailing list for this outreach process is maintained at HVCEO. Any interested citizen can be added to this list. The list was extended in 2003 to meet the intent of federal Environmental Justice rules by including minority membership organizations and institutions serving low income populations.

Public Access to Documents. Public access to documents can be at the HVCEO office 8:30 AM to 4:30 PM Monday thru Friday, evenings by appointment, or through direct mail from HVCEO. Email and Internet postings are also available.

Length of Comment Periods. Mailing and notice dates will be scheduled such that the public comment period will be at least 30 days for the Regional Transportation Plan and also 30 days for the TIP and major TIP amendments.

TIP Public Information Meeting. For the draft TIP, in addition to the other participation mechanisms HVCEO will hold a public information meeting. The HVCEO will advertise the public information meeting in the News Times at least 30 days in advance of the information meeting.

Changes to Documents After Draft Reviewed. Also, if the final RTP or TIP either differs significantly from the ones which were first made available for public comment, or if they raise new material issues which interested parties could not reasonably have foreseen, an additional opportunity for public comment on the revised RTP or TIP will be made available.

Summary of Comments. When written or oral comments are received on the draft RTP or TIP as a result of the public involvement process, a summary, analysis, and report on the disposition of each comment shall be made part of the final RTP and TIP.

Direct Inquiries. All comments regarding HVCEO transportation planning should be directed to HVCEO Executive Director Jonathan Chew at HVCEO, 162 Whisconier Road, Old Town Hall, Route 25, Brookfield, CT 06804, or emailed to him at jchew@hvceo.org.

NOTIFICATION OF HVCEO MEETINGS
DEALING WITH TRANSPORTATION ISSUES

General Transportation Planning Other Than the RTP and TIP. There is more to the transportation planning process than just the Regional Transportation Plan (a statement of future improvement projects), and the Transportation Improvement Program (the more immediate list of projects by Conn DOT soon to be implemented). Major transportation studies, transportation policies and status reports on projects are also discussed by the chief elected officials of HVCEO on a regular basis.

For persons wishing to shape transportation investments, it is often wise to make their views known early and often, before the periodic RTP and TIP updated are even formulated. Thus all HVCEO meetings are open to the public for them to express themselves on transportation matters. No advance notice is needed; a sign up sheet is provided for citizens at each meeting and first time visitors are made to feel welcome.

Posting of Meeting Agendas. To facilitate opportunities for public input, advance notice of all HVCEO meetings is provided to city and town clerks where the meeting agendas are publicly posted. Transportation planning related agenda items are clearly described in these notices. This meeting notification process is designed to be in full compliance with Connecticut's Freedom of Information laws, as well as the rules for openness guiding the federal transportation planning process.

Agendas to Media. Meeting notices are provided to the media to stimulate coverage. This mailing will include the New Times as the regional daily newspaper and the two local radio stations WLAD and WINE.

Citizens on Mailing List. All citizens wishing to be on the HVCEO meeting notice distribution list are accommodated at no charge. This will include parties interested in or affected by transportation plans and projects.

HVCEO. ORG Web Site. Transportation projects will also be listed on the HVCEO web site at hvceo.org. Access will be from the main home page of the site, inviting persons to “Comment on Planned Improvements.” This Public Participation Plan is also available on the HVCEO web site. Comment on the policies themselves is invited.

Since 2/2004 the full Regional Transportation Plan has been published at the hvceo.org site, and this outreach process will be continued.

FURTHER IMPROVING THE
PUBLIC PARTICIPATION PLAN

The HVCEO Public Participation Plan will be reviewed periodically to assure full and open access to all. Such revisions can be made at any time.

However, at a minimum, these policies will be reviewed every time the Regional Transportation Plan is updated, that schedule determined by federal rules. As the Public Participation Plan is itself part of the Regional Transportation Plan, a coordinated update process thus cannot be inadvertently omitted.

In addition, for every Regional Transportation Plan update the minority membership organizations and institutions serving low income populations that receive notifications will be contacted determine their satisfaction with the notices received, access to the process, etc.

A Power Point show on the transportation planning process and area transportation issues is maintained and will be kept current. It is colorful, understandable by the layman, entertaining and about 45 minutes in length. This show is available to civic and citizen's groups.

The HVCEO will consider as public input to HVCEO all CT Public Transportation Commission hearing testimony made by the Region's residents.

HVCEO PUBLIC INVOLVEMENT PROCESS AS
PUBLIC HEARING REQUIREMENT FOR FTA GRANTS

In October of 1996 the Federal Transit Administration issued a revised Circular C9030.1B for the Section 5307 Urbanized Area Formula Program (the former Section 9 Program).

This streamlined the public hearing requirements for FTA Section 5307 grants by permitting the grantee, in our area the Housatonic Area Regional Transit District, or HART, in cooperation with the HVCEO, to satisfy the “afford an opportunity for a public hearing” requirement through the HVCEO citizen participation process, rather than HART duplicating it.

Therefore the HVCEO public involvement process will satisfy the opportunity for the public hearing requirement for most routine, traditional Federal Transit Administration Section 5307 grants, including the provision for public notice and the time established for public review and comment.

However, use of the HVCEO process will only satisfy the hearing requirement for routine projects. Projects requiring an environmental assessment or an environmental impact statement will require additional public involvement, in accordance with joint Federal Highway Administration/Federal Transit Administration regulations, 23 Code of Federal Regulations, part 771.

FTA projects that do not normally require an environmental assessment or environmental impact statement include operating assistance, purchase and rehabilitation of replacement bus or rail vehicles resulting in no or only minor expansion of the fleet, equipment for existing facilities, reconstruction and rehabilitation of transit buildings, rehabilitation of rail track, etc.

HVCEO and HART coordinate to ensure that the public is aware that the TIP development process satisfies the above participation requirements, by including this item in these policies, by having draft TIP items to HVCEO forwarded to HART, and having all draft HART TIP items forwarded to HVCEO.

PUBLIC ACCESS VIA WEB BASED
PLAN VERSUS PAPER COPY OF PLAN

Throughout the web based Regional Transportation Plan links to other sites are provided. The web based Plan is then copied to become the paper copy Plan, as it would be wasteful to update and maintain two identical copies in different formats. It is understood that only persons who have access to the Internet will be able to view those links. How to keep this process fair?

Equity is assured by having the web copy of the Plan designed to be stand alone and all inclusive, such that everything is there to give citizens a chance to react to what they liked, don't like, how to access, etc. As the web version of the Plan is not a "cut" version of the "real" Plan, reviewers of the paper copy are not given a "lesser" document.

The printed version, off the web, is "secondary" only in that it cannot incorporate the power of the web to link. So, HVCEO has a hard copy Plan designed to meet all requirements in any case. Given our resources there is no practical way to "pull up" the paper copy to the level of the web copy; that is just the nature of the two mediums.


ENVIRONMENTAL JUSTICE POLICY

No person in the United States shall, on the ground of race, color, or national origin
be excluded from participation in, be denies the benefits of, or be subjected to
discrimination under any program or activity receiving Federal financial assistance."
- Title VI of the Civil Rights Act of 1964

"Each federal agency shall make achieving environmental justice part of its mission
by identifying and addressing as appropriate, disproportionately high and adverse human
health or environmental effects of its programs, policies, and activities on
minority populations and low income populations."
- Executive Order 12898, 1994

POLICY OVERVIEW
The HVCEO’s Regional Transportation Plan, TIP and Public Participation Plan as described above must also comply with Title VI of the Civil Rights Act of 1964, the 1994 Executive Order 12898 on Environmental Justice, and the U.S. DOT Order to Address Environmental Justice in Minority Populations and Low Income Populations.

Those interested in the details of Environmental Justice policy may contact HVCEO and/or access the federal Environmental Justice web site. Spanish language information on this topic is also available; Una Perspectiva sobre la Transportacion y la Justicia Ambiental.

In its planning and project development, HVCEO is committed to FHWA guidance on this matter: “To avoid, minimize, or mitigate disproportionately high and adverse human health and environmental effects, including social and economic effects, on minority populations and low-income populations, to ensure the full and fair participation by all potentially affected communities in the transportation decision-making process, and to prevent the denial of, reduction in, or significant delay in the receipt of benefits by minority and low income populations.”

Specifically concerning the Regional Transportation Plan, Environmental Justice mandates will be met by requiring that HVCEO studies determine impacts and benefits upon the population groups of concern. It must be ascertained that they will benefit from a project in a manner as will the general population, rather than be singled out for receipt of negative impacts of proposed projects.

In its 2/2004 report entitled “Title VI Process Review; Examination of MPO Compliance”, Conn DOT lists three Environmental Justice activities already underway at the HVCEO:

1. "Development of a special mailing list of minority organizations and institutions serving low-income populations.

2. Beginning in 2003 all TIP and Long Range Plan drafts are sent to minority targeted organizations and institutions for comment.

3. Innovative data base developed for Danbury that identifies projects by geographic location. This tool allows the public as well as policy makers to identify projects which may impact Title VI communities."

Since that time, HVCEO has added the items below to the list:

4. This item concerns the summary of transportation projects for Danbury maintained by the staff. This is presented as an agenda item at HVCEO board meetings once per year, where it is discussed. It is also available on the web site.

On the Danbury summary a notation as to "Environmental Justice" has been added. This is a new and permanent feature of this key public information page.

5. The second new item involved the placement on the web site of the MPO’s Public Participation Plan and Environmental Justice policies, in their entirety. These are accessed from the “Trans, Rail & Bus Plans” button on the right side of the home page. The printed version of the Plan has the same full texts.

IDENTIFICATION OF TARGET
POPULATIONS AND DEMOGRAPHIC PROFILE

For a spatial mapping methodology to determine an “Environmental Justice Evaluation Area”, data from the latest census regarding 1) Black population, 2) Hispanic and Latino population, and 3) median household income by census tract is used. These are the primary data sets traditionally used for identifying lower income and minority populations.

The Black and Hispanic and Latino populations are calculated as a percentage of total persons in the area. The median household income for census tracts (subsets of the municipality) are calculated as a percentage of statewide median household income.

A review of census tracts was then conducted in order to identify any areas of concentration. (As noted below, this geographic analysis process is to be upgraded to a review of block groups, the component pieces of census tracts, a finer geographic measuring tool as part of development of the HVCEO’s Environmental Justice policy).

A threshold level of minority percentage is needed in order to determine “concentration.” For the minority populations, the regional averages are used. Similarly, A threshold level for median household income is needed in order to determine “concentration.” The statewide average is used, a broader measure than regional average as incomes are relatively high in this area.

Continuing with use of the income figures, a threshold level of 80% of median is used to determine low and moderate income, as this is the same percentage used for many years by state housing programs in Connecticut.

Income patterns vary throughout
the Danbury metropolitan area.
See the detailed map.

The resulting calculations set the geographic boundaries for an “Environmental Justice Evaluation Area.” Federally funded transportation projects within this area are then subject to review for Environmental Justice considerations.

In this way the HVCEO’s Regional Transportation Plan, TIP and Public Participation Plan will comply with Title VI of the Civil Rights Act of 1964, 1994 Executive Order 12898 on Environmental Justice and related U.S. DOT orders.

As noted above, for the Housatonic Valley Planning Region, the demographic data sets described above show that the review area is a large part of the City of Danbury. Thus as Danbury transportation projects are developed, in cooperation with the Conn DOT, special attention will be paid to determine if there are any adverse impacts to the defined populations.

To document the details of the analyses conducted in the Region and in Danbury, consider that there are fourteen census tracts in Danbury. The data by tract show that three of these census tracts exceeded all three thresholds. These were tracts 2101, 2106 and 2107. Because of this they are definitely included within the Environmental Justice Evaluation Area.

Then five other tracts in Danbury exceed both the minority percentage data thresholds, but not the income threshold. These are 2102, 2103, 2104, 2108 and 2111. Thus they may also reasonably be included in the review area.

Then four tracts, 2109, 2110, 2112 and 2114 exceed only one minority data threshold. Thus their reason to quality for Environmental Justice review is limited. But to be on the safe side, a reasonable strategy is to include the top three out of the four (the fourth and lowest barely exceeds the single threshold).

This leaves only tracts Danbury 2105, 2113 and 2114 outside of the review area; most of the City is included. As omitted tracts 2113 and 2114 are in northeastern Danbury and omitted tract 2105 is all of southern Danbury, the tracts remaining in the review area are contiguous which facilitates review.

POLICY ON BENEFITS AND BURDENS
OF TRANSPORTATION INVESTMENTS

Specifically concerning Environmental Justice and this Regional Transportation Plan (RTP), Environmental Justice mandates will be met by determining that the population groups of concern will benefit from a project in a manner as will the general population, rather than be singled out for inadvertent receipt of negative impacts of a proposed project.

This is a sensitive topic. It is not that such an illegal and discriminatory activity has ever happened here in the Danbury Area. Rather, that the U.S. Congress feels that there is still a risk of such activity happening in this country. Thus, as part of the condition of federal transportation investment in a community, all areas must demonstrate that it is NOT happening in their area, a reasonable requirement.

Methods for these determinations can be project specific. If homes are removed for a transportation project the determination as to this being “good” or “bad” could be complex. And then some planned projects are still in the conceptual stage and until property impacts are estimated, there is not definitive delineation of the project right of way to review against census criteria.

It is prudent to leave room for Environmental Justice evaluation methods to remain flexible such that they can evolve in consultation with the community and officials if and when a transportation idea is flushed out enough such that possible benefits and burdens can be discussed.

Thus the methods shown here are only a base; citizens have a right to request HVCEO to go into deeper analysis as necessary. HVCEO can also make the determination to go into a deeper analysis. However, there will be limitations upon revealing any accident rate data upon which such deeper analyses are based, as explained below.

When evaluating the options for a transportation project to impact a minority or lower income neighborhood, HVCEO staff will use accident rate data available for state roadways, a fundamental measure of traffic problems.

However, if the minority or lower income neighborhood is then selected for the project and their are property or other impacts, we will be sure to follow Conn DOT rules and not let community activists or others outside of selected government staffers examine the accident data

Even though it is upon such data that decisions affecting their neighborhood is based, release of such data to ordinary citizens is not permitted by Conn DOT.

SPECIFIC REVIEW OF BENEFITS AND
BURDENS OF TRANSPORTATION INVESTMENTS

To take a detailed look at projects in the Danbury Environmental Justice Review Area, the following detailed assessments of planned transportation projects are provided:

1. ROUTE 6. Conn DOT Project in Danbury No. 34-288: Widening of Route 6 from Kenosia Avenue easterly to just past I-84 Exit 4. This project is large enough such that it has a separate environmental report prepared by Conn DOT, a “Final Environmental Assessment” approved by FHWA on 9/25/2002.

That report concluded that “Any potential for direct impacts to minority, elderly or low income populations are extremely limited.” Also, the project “will not target an economically disadvantaged area.” Specifically from the perspective of Environmental Justice, the report concludes that “the proposed reconstruction of Route 6 would not result in a disproportionately high and adverse impact on a minority or low income population.”

2. MAIN STREET NORTH. Conn DOT Project in Danbury No. 34-302: Main Street North Streetscape Enhancement Plan. No right of way activities are associated with this project. This is beautification only, involving sidewalk redesign and pedestrian improvement, plantings and landscaping. No impact due to diversion of traffic to another roadway is involved.

3. ROUTE 37 AT STACEY ROAD. Conn DOT Project in Danbury No. 34-305: Realignment and signalization of Route 37 at its intersection with Stacey Road, most work involving the Stacey Road approach. Only very minor right of way land takes involved, no buildings moved, no diversion of traffic to another roadway.

4. ROUTE 806. Conn DOT Project in Danbury No. 34-H050: Widen Route 806 to provide for a west bound left turn lane at old Shelter Rock Road and signalize the intersection. Minor safety improvement, no diversion of traffic to another roadway.

NUMBERS 1-10 IDENTIFY LOCATIONS OF
ENVIRONMENTAL JUSTICE REVIEW PROJECTS

As background,
Green (lighter gray on hard copy) ) designates existing
four lane roadways, while red (darker gray on hard copy) indicates
two lane roadways proposed for expansion to four lanes.

5. I-84 INTERCHANGES. Conn DOT Project in Danbury No. 34-308: Design for minor modifications to I-84 Interchanges 2, 4, 5, and 6. Only Interchange 6 has a commitment for funding of its minor modifications. None of these involve changes to road with or takings of properties. The other interchange improvements are yet to be designed.

By way of background, the initial planning for these projects appears in a Conn DOT report dated June 2000 and entitled “I-84 Corridor Deficiencies and Needs Study Final Report.” This report includes an Environmental Justice evaluation as required of an FHWA report of this nature (Executive Order 12898 is cited). The findings are below:

Interchange 2: Scope is to extend eastbound off ramp deceleration lane, extend westbound on ramp merge area, and widen Old Ridgebury Road approaching Route 6. The EJ finding is that there is “virtually no adverse environmental impact” and “no business or residential displacements would occur.”

Interchange 4: Extend deceleration lanes, new right turn lane on Segar Street. No EJ impacts cited from this minor work.

Interchange 5: Extend westbound and eastbound on ramp acceleration lanes, extend westbound and eastbound off ramp deceleration lanes, and revise signal timing. No EJ impacts cited from this minor work.

Interchange 6: Extend eastbound acceleration lane, extend westbound deceleration lane, restripe under bridge, signalize intersection of Route 37 with eastbound on ramp. No EJ impacts cited from this minor work.

6. ROUTE 37. A proposed Conn DOT Project in Danbury but no project number yet assigned, widening of Route 37 from Main Street north to Stacey Road: Very initial and conceptual improvement plan being developed by Conn DOT Project Concept Unit, no detailed strategy ready for first concept hearing.

7. ROUTE 806. Concept Plan for widening Newtown Road from 2 to 4 lanes from Old Shelter Rock Road easterly to Plumtrees Road: This project has not yet reached the stage where property impacts are known. This is a major commercial corridor, and the concept of the project does not relocate any traffic into any residential areas.

8. ROUTE 53.Concept Plan for creating a full four lane cross section on Route 53 from South Street northerly to Boughton Street: The right of way of Route 53 here is already wide enough for four lanes. The project would be to reorganize traffic such that the pavement width available could be better utilized. Thus no property impacts are anticipated. Also, no rerouting of traffic to residential areas is involved.

9. KENOSIA AVENUE. Widening of Kenosia Avenue from 2 to 4 lanes from Backus Avenue northerly to the vicinity of Lake Kenosia. Preliminary 2003 cost estimate by City is $3.0 million. This is a commercial corridor , and the concept of the project does not relocate any traffic into any residential areas.

10. BACKUS AVENUE. Backus Avenue Corridor improvements, including signal coordination on Backus Avenue near the Danbury Fair Mall, and widening from 2 to 4 lanes from Kenosia Avenue westerly to Miry Brook Road. Preliminary 2003 cost estimate by City for widening is $3.0 million, signal coordination cost estimate pending. This is a major commercial corridor, and the concept of the project does not relocate any traffic into any residential areas.

11. BUS SERVICE. Public Bus Transit in Danbury: It should also be noted in this section that within the City of Danbury and the wider metropolitan area, the Housatonic Area Regional Transit District submits a report regarding compliance with Title VI.

This compliance report is a review of the provision of public bus service level of quality with Title VI equity requirements, the ”Transit Monitoring Report.” This relates detailed demographic criteria to FTA supported bus routes. Thus this HART document can also be considered an Environmental Justice monitoring tool for the area.

In addition to specific route analyses in its Transit Monitoring Report, HART periodically makes assurances to the Federal Transit Agency, which support Environmental Justice concerns with the planning and operation of the regional bus system. These assurances, also hereby endorsed by HVCEO, are as follows:

A. No person on the basis of race, color, or national origin will be subjected to discrimination in the level and quality of transportation services and transit-related benefits.

B. The HART will compile, maintain, and submit in a timely manner Title VI information required by the FTA under Circular 4702.1 and in compliance with the Department of Transportation’s Title VI regulation, 49 CFR Part 21.9.

B. HART will make it known to the public that those person or persons alleging discrimination on the basis of race, color, or national origin as it relates to the provision of transportation services and transit –related benefits may file a complaint with the Federal Transit Administration and/or the U.S. Department of Transportation.

SPANISH LANGUAGE ACCESS TO
REGIONAL TRANSPORTATION PLANNING

As agreed between HVCEO, FHWA and Conn DOT staffs, Spanish is the appropriate alternative language for this MPO to focus its energies on as access by persons with “limited English proficiency” is enhanced. There are several ways HVCEO proposed to address the needs of persons who speak Spanish and not English.

As agreed HVCEO developed a Spanish language page on the hvceo.org web site. This will indicate some basics about the transportation planning program and how Spanish speaking persons can contract HVCEO in their own language.

This is linked from the main transportation related pages, where a short Spanish text will appear as a hyperlink to this main Spanish language page. The web page can be printed and used as a paper copy to insert in other transportation documents.

While it is not practical for an agency this small to begin to produce detailed transportation planning documents in Spanish text, below is a practical alternative for access.

The web page above will give a phone number to a bilingual person who is familiar with the MPO program. A Spanish speaking only person can call that number and make comments about transportation needs that will be summarized in English and provided to the MPO staff Director.

The above may work to successfully respond to some calls but be insufficient for other more complex ones. Some callers may need discussion. What is a caller did not focus on a specific transportation need, but instead inquired as to what the MPO transportation program was all about?

In these instances, the translator and the MPO Director will offer to meet with callers at a location convenient to them. Any resulting input to the program will then be handled in accordance with the regular public participation rules. The time expended, second meetings, additional persons, etc., will be relative to the complexity of the issues raised.

Further, if inquires reach the point of a meeting with the translator and the MPO Director, and the inquiring party wishes to personally address the MPO in Spanish, then the MPO should fund the translator to attend the MPO meeting and make this possible, the most aggressive Environmental Justice strategy practicable given the limited HVCEO transportation planning budget.

The practicality of this translation service arrangement will be enhanced by the fact that the translator will be an employee of the Housatonic Area Regional Transit District, a nearby organization which has a permanent long term relationship with the MPO. HART will invoice HVCEO for these services. HVCEO funded HART for the provision of this service which commenced on 7/1/2004.

There are other ways to provide access in Spanish, the primary non-English medium in this area. While the web site will have a notice in Spanish about the translation service possible, not everyone is on the web and this is not enough.

This an additional Spanish message describing the method of access should appear in the MPO programs items that circulate most widely. These are the TIP, the Plan, and related legal notices. This service will be integrated into the planning program.

FUTURE ENVIRONMENTAL
JUSTICE POLICY DEVELOPMENT

The geographic analysis process for determining the Environmental Justice review area should also be upgraded to a review of Danbury's block groups, the component pieces of census tracts, as part of development of the HVCEO’s Environmental Justice Policy.

This necessitates a complete reexamination of the municipalities around Danbury, as well as the three tracts in Danbury not in the Environmental Justice Review area, as part of a second step.

HVCEO will also develop and document a systematic way to review the effectiveness of public outreach efforts.

Also, HVCEO will continue to include Title VI as part of the Unified Planning Work Program (annual guidance documents for staff activities) and have quarterly reports include updates on Title VI activities when they occur.

Transportation Plan Sections 1 - 2 - 3 - 4 - 5 - 6- 7- 8

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HVCEO, Old Town Hall, Routes 25 & 133, Brookfield, CT 06804 Tel: 203-775-6256  |  Fax: 203-740-9167  |  E-mail: info@hvceo.org