Beyond NEPA and Title VI: Why “Meeting Requirements” Will Always Fail to Achieve Social Equity

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Beyond NEPA and Title VI: Why “Meeting Requirements” Will Always Fail to Achieve Social Equity

  • December 15, 2022
  • Mary-Katherine Duncan

Much of today’s transportation infrastructure was planned and developed prior to the protections offered by the 1970 National Energy Policies Act (NEPA) and the 1994 Executive Order on Environmental Justice. Yet plans only consider present and future actions without consistent regard for the ongoing implications of prior decisions for minoritized populations.

While a national community of experts in environmental justice and compliance has surrounded NEPA and Title VI compliance, the focus has largely been on how to follow an equitable forward-looking process without applying the necessary disciplines to understand the historical, economic, and social role such a process plays in the overall development of a minoritized community. For example, Title VI experts are quick to demonstrate that they have reached out to minoritized populations with ever more innovative techniques – yet seldom ask how a given choice follows from the decades of lived experience before and what relevance (if any) the alternatives and issues presented may have to that experience.

For this reason, Metro Analytics deliberately approaches transportation equity from outside of the traditional “minimum requirements” and “best practices” and incorporates the full body of knowledge from both the humanities and social sciences to critically evaluate and re-design transportation decision-making.


Metro Analytics has developed the H.E.A.L. (Historical Equity Action Lens) approach to achieving more equitable outcomes by ameliorating the legacy costs that have resulted from past planning decisions and preventing similar costs in the future.

This approach centers on applying evidence-based historical methods for placing each decision in its chain of trends, events, and choices as experienced by minoritized communities. The results of this approach are not tools for compliance but rather a lens for restructuring the way transportation planning understands needs, develops options, and tracks progress over time.

Metro Analytics seeks outcomes that will equip agencies to meet contemporary demands for practical and actionable remedies to historical inequities. The results are pragmatic step-by-step, proven guidance for diagnosis, treatment, and measured recovery from historical trauma associated with the long-term development of transportation infrastructure and systems. This approach entails achieving three critical success factors:

  • A guide to incremental change
  • Defensibly Incorporating the Humanities
  • Quanitifying Legacy Costs and Progress Toward Goals

If you are interested in learning more about how Metro Analytics can assist you in achieving more equitable outcomes and alleviating the legacy costs of past investment and policy decisions, please contact Chandler Duncan, Mary-Katherine Duncan, or Wade Carroll.

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