PUGET SOUND GATEWAY PROGRAM PHASE 1 OF THE SR 509 COMPLETION PROJECT. Environmental Justice Technical Report

PUGET SOUND GATEWAY PROGRAM PHASE 1 OF THE SR 509 COMPLETION PROJECT Environmental Justice Technical Report Prepared for Washington State Department of Transportation Prepared by PRR October 2017

Table of Contents Summary... 6 1. Introduction... 8 2. What are the Phase 1 Improvements and how do they compare with the 2003 FEIS Alternative C2?... 11 3. What methods were used to analyze Phase 1 Improvements? How do they differ from those used for the 2003 FEIS Alternative C2?... 14 4. What has changed in the affected environment since 2003?... 22 Distribution of Environmental Justice Populations... 22 Consideration of Limited English Proficient Populations... 29 Potential Users of Tolled Portion of SR 509... 33 5. How would permanent project effects (beneficial and/or adverse) compare to the 2003 FEIS Alternative C2?... 38 Potential Benefits to All Users, Including Environmental Justice Populations... 38 Potential Effects of Tolling on Environmental Justice Populations... 39 Other Effects to Environmental Justice Populations... 43 6. How would mitigation measures during operation compare to the 2003 FEIS Alternative C2?... 46 Mitigation for Effects of Tolling... 46 Mitigation for Other Permanent Impacts... 46 7. How would temporary construction effects compare to the 2003 FEIS Alternative C2?. 49 8. How would mitigation measures during construction compare to the 2003 FEIS Alternative C2?... 49 9. How would cumulative and indirect effects compare to the 2003 FEIS Alternative C2?. 50 10. How will WSDOT engage with environmental justice communities moving forward?... 51 11. Would Phase 1 Improvements have any new significant adverse effects that would have a disproportionately high and adverse effect on environmental justice populations?... 52 References... 53 GIS Data... 56 Tables Table 1. Comparison of SR 509 Completion Project Design Components Table 2. Comparison of Demographic Analysis Methods Table 3. Comparison of Minority and Low-Income Populations in the Study Area Table 4. Race and Ethnicity of Populations in the Study Area Table 5. Comparison of Data for Students Enrolled in Public Elementary Schools in the Study Area Table 6. Percentage of Limited English Speaking Households in the Study Area Table 7. Percentage of Transitional or Bilingual Students in the Study Area Schools Table 8. Comparison of Peak Period, Weekday Toll Rates for Passenger Vehicles on Tolled Facilities in the Region Table 9. Comparison of Percentage of Household Income for Different User Types Table 10. Comparison of Average Travel Times for Tolled and Non-Tolled Routes Table 11. Comparison Summary of Impacts: 2003 FEIS Alternative C2 and Phase 1 Improvements Table 12. Comparison Summary of Mitigation: 2003 FEIS Alternative C2 and Phase 1 Improvements SR 509 NEPA RE-EVALUATION 3

4 SR 509 NEPA RE-EVALUATION

Figures Figure 1: Project Vicinity Figure 2: Phase 1 Corridor-wide Improvement Map (SR 509 Extension from S 188 th Street to I-5) Figure 3: Phase 1 Corridor-wide Improvement Map (I-5 from SR 509 to S 272 nd Street) Figure 4: SR 509 Study Area Figure 5: SR 509 Travelshed Figure 6: Census Block Groups in the SR 509 Study Area Figure 7: Percent Minority in the SR 509 Study Area Figure 8: Percent Low-Income in the SR 509 Study Area Figure 9: Percent Linguistically Isolated in the SR 509 Study Area Figure 10: 5%+ Spanish Speakers in the SR 509 Study Area Figure 11: Percent Minority in the SR 509 Travelshed Figure 12: Percent Low-Income in the SR 509 Travelshed Figure 13: Percent Linguistically Isolated in the SR 509 Travelshed Figure 14: 5%+ Spanish Speakers in the SR 509 Travelshed SR 509 NEPA RE-EVALUATION 5

Summary What is our study approach? To evaluate the effects of Phase 1 of the SR 509 Completion Project on environmental justice populations, we began by determining if minority, low-income, or limited English proficient individuals live in the project study area or will use the future extension of SR 509. Next, we identified any substantially new benefits or adverse effects of Phase 1 to environmental justice populations since the SR 509: Corridor Completion/I-5/South Access Road Final Environmental Impact Statement (2003 FEIS). We used demographic analyses to determine if any of these benefits or adverse effects will disproportionately affect environmental justice populations and, if so, whether the adverse effects will be high or severe. We identified mitigation to avoid or minimize disproportionately high and adverse effects. What are the existing conditions? Current demographic analyses indicate that minority, low-income, and persons who are limited English proficient reside in the project study area. There are also minority, low-income, and limited English proficient individuals living in the SR 509 travelshed (the geographic area from which traffic on SR 509 originates). How will Phase 1 benefit environmental justice populations? As trips shift from I-5 and arterials to the new SR 509 facility, travel times will improve for all routes through the project study area compared to No Build conditions. Motorists who choose to pay a toll and use the new SR 509 facility will benefit from a more direct route between South King County and SeaTac airport. Even for those motorists who do not pay a toll including environmental justice populations Phase 1 improvements will relieve traffic congestion on existing arterials and intersections in the project study area, as some trips shift to the new SR 509 facility. Phase 1 improvements will accommodate proposed improvements to transit services and facilities in the study area, including future light rail between the Angle Lake Station in SeaTac and the Federal Way Transit Center in Federal Way. The SR 509 NEPA Re-Evaluation Transportation Discipline Report also finds travel times and reliability for transit vehicles will improve on arterials and major roadways in the study area. Are there new and significant effects of the project on environmental justice populations since the 2003 FEIS? Most construction and operational effects to environmental justice populations will be the same or less than those documented in the 2003 FEIS. The main change is that Phase 1 would include tolling of the entire new portion of SR 509. No tolls will be charged on existing SR 509 facilities. Any toll even relatively low-cost tolls like the ones planned for this project disproportionately affects low-income households. Compared to households with moderate and high incomes, the toll would represent a higher proportion of annual income. Furthermore, all-electronic tolling will disproportionately affect individuals who do not have debit, credit card, or EBT accounts; do not have enough funds to start an electronic toll account; or do not have Internet access. Many of these individuals are low-income and/or limited English proficient. As such, low-income and limited English proficient individuals may not be able to derive the same benefits from the new SR 509 facility as middle- and higher-income individuals. 6 SR 509 NEPA RE-EVALUATION

I-5 and arterials will remain accessible alternatives to the new tolled facility and are expected to offer improved travel times for both motorists and transit over the No Build conditions. As such, the disproportionate impact of tolls on environmental justice populations who travel in the study area will not be significant. What measures will WSDOT take to avoid or minimize new adverse effects to environmental justice populations? For most construction and operational effects to environmental justice populations, mitigation measures will be the same as those documented in the 2003 FEIS. The tolls will disproportionately affect low-income and limited English proficient populations, but improved travel times on untolled alternatives like I-5 and local arterials should offset these effects. To further minimize the disproportionate effects of the tolls on limited English proficient populations, WSDOT will translate information about electronic tolling into multiple languages. Our demographic analysis indicates that all information should be translated into Spanish, but stakeholder interview participants also recommended translation into Russian, Samoan, Vietnamese, Chinese, and Cambodian. In addition, WSDOT is considering taking the following measures to further minimize adverse effects of tolls on environmental justice populations: Exempt transit and paratransit from the tolls. Make it easy for people without a bank account to purchase and pre-load a Good To Go! pass for example, selling them in local grocery stores and pharmacies and allowing people to use cash to load them. WSDOT is in the process of re-procuring the vendors that support the Good To Go! system and is looking to expand the network for retail pass sales and options for unbanked customers. Would Phase 1 Improvements have any new significant adverse effects that would have a disproportionately high and adverse effect on environmental justice populations? The adverse effects to environmental justice populations described in this report are similar to those described in the 2003 FEIS, with one important exception: The 2003 FEIS did not assume the project would be tolled. Our analysis considers the effects of tolling on environmental justice populations. We conclude that, with accessible and convenient untolled alternatives available, tolling will not have a disproportionately high and adverse effect on environmental justice populations. SR 509 NEPA RE-EVALUATION 7

1. Introduction This memorandum was prepared in support of the Phase 1, SR 509 Completion Project National Environmental Policy Act (NEPA) re-evaluation. It compares the changes to the project and resultant impacts (beneficial and/or adverse) against the Record of Decision (ROD) issued by the Federal Highway Administration (FHWA) in 2003 to determine if Phase 1 of the SR 509 Completion Project would result in any new significant impacts not evaluated in the SR 509: Corridor Completion/I-5/South Access Road Final Environmental Impact Statement (2003 FEIS). This Re-evaluation Memo makes many references to the 2003 FEIS, including the maps and mitigation measures that are still relevant to the updated analyses. The SR 509: Corridor Completion/I-5/South Access Road FEIS can be found on WSDOT s website at http://www.wsdot.wa.gov/projects/sr509/completion/library.htm. 1.1. Project History ENVIRONMENTAL JUSTICE Environmental justice acknowledges that the quality of our environment affects our lives and that negative environmental effects should not disproportionately burden low-income or minority populations. The State Route (SR) 509 Completion Project is based on more than two decades of project planning and development. In 1995, Washington State Department of Transportation (WSDOT) released the Tier I Corridor Draft Environmental Impact Statement (DEIS), which recommended extending SR 509 from S 188th Street southward to connect with Interstate 5 (I-5) and adding a spur roadway, the South Access Road, to connect with Seattle-Tacoma International Airport (Sea-Tac Airport). Within the SR 509 corridor, three routes and a No Build Alternative were evaluated in a project level (Tier II) Draft EIS published in 2002. The Final EIS (FEIS) and Record of Decision (ROD) issued in 2003 identified a six-lane Preferred Alternative (Alternative C2) that included two general purpose (GP) lanes and one highoccupancy vehicle (HOV) lane northbound and southbound on SR 509. It also included interchange connections at S 188th Street, S 200th Street, 24th/28th Avenue, and I-5 and a new South Access Road. Since the ROD was issued, project progress has included actions such as the purchase of needed rightof-way (ROW), construction of an advanced wetland mitigation site, construction of work elements in coordination with local agencies, and refinements in preliminary design. The project area is shown in Figure 1. With the passing of the Connecting Washington Transportation Package in 2015 by the state legislature, funding has become available for the first phase of the SR 509 Completion Project (Phase 1 Improvements) to proceed through environmental review, design, and into construction. WSDOT undertook a Practical Solutions design approach for the project which allowed a fresh look at the previous project plans to ensure that the revised project is designed according to actual demand and needs. Part of the Practical Solutions approach included reengaging stakeholders to review design and potential changes. The purpose of this document is to reevaluate the Phase 1 Improvements to determine whether they have the potential to result in any new significant environmental impacts that were not previously evaluated in the 2003 FEIS and 2003 ROD. Table 1 provides a comparison of Alternative C2 with the Phase 1 Improvements. 8 SR 509 NEPA RE-EVALUATION

Figure 1 Project Vicinity SR 509 NEPA RE-EVALUATION 9

Table 1. Comparison of Design Components SR 509 SR 509: I-5 to S 188th Street S 188th Street Alternative C2 (2003 FEIS and ROD) Six lanes (120 feet), 60 mph 2 GP lanes in each direction and 1 HOV lane each direction Full single-point urban interchange (SPUI) Phase 1 Improvements (Re-evaluation) Four lanes (78 feet), 60 mph 2 GP lanes in each direction 1/2 diamond (ramps to/from north) but doesn t preclude future construction of full diamond with additional funding. S 200th Street 1/2 diamond (to/from north) a None but doesn t preclude future construction with additional funding South Access Roadway Four-lane limited access facility to S 200th Street None but doesn t preclude future construction with additional funding 24th Avenue S/28th Avenue S 1/2 diamond (to/from south) 1/2 diamond (ramps to/from south) Tolling None 2 GP lanes in each direction Toll Points None One south of 24th Avenue S/28th Avenue S Interstate 5 Alternative C2 (2003 FEIS and ROD) Phase 1 Improvements (Re-evaluation) I-5/SR 509 GP connection 60 mph 50 mph I-5 SB: SR 516 to SR 509 Southern braid three-lane C/D Northern braid and two-lane C/D I-5 NB: SR 516 to SR 509 two-lane C/D Auxiliary lane but doesn t preclude future construction with additional funding I-5/SR 509 HOV Direct Connection I-5/SR 516 Interchange b I-5 SB: SR 516 to S 272nd Street I-5 SB: 272nd to S 320th Street I-5 NB: S 272nd Street to SR 516 I-5/SR 509 center-to-center HOV direct access roadway Full diamond and at grade intersection with Veterans Drive connector Two auxiliary lanes One auxiliary lane One auxiliary lane S 272nd Street to SR 516 None but doesn t preclude future construction with additional funding Full diamond and at-grade intersection with Veterans Drive connector One auxiliary lane but doesn t preclude future construction with additional funding None but doesn t preclude future construction with additional funding None but doesn t preclude future construction with additional funding a 1/2 diamond interchange has an on and off ramp that serves traffic to and from one direction. b The Phase 1 Improvements would also maintain pedestrian connections on both sides of the I-5/SR 516 interchange and construct a new pedestrian path from Veterans Drive to SR 516/Kent Des Moines Road, which would help facilitate pedestrian trips to and from the transit centers around this interchange. C/D = collector/distributor lanes; GP = general purpose; HOV = high-occupancy vehicle; mph = miles per hour; NB = northbound; SB = southbound 10 SR 509 NEPA RE-EVALUATION

2. What are the Phase 1 Improvements and how do they compare with the 2003 FEIS Alternative C2? The purpose and need of the proposed action remains the same as described in the 2003 FEIS. The purpose of the proposed action is to improve regional highway connections with an extension of SR 509 to serve current and future transportation needs in southwest King County and to enhance southern access to Sea-Tac Airport. The project area is shown in Figure 1. The proposed action is needed to create system linkages, accommodate travel demand and capacity needs, and improve intermodal relationships. The SR 509 freeway currently terminates at S 188th Street and does not connect to the regional transportation highway system; this leaves a major gap in the system. As a result, local streets and major transportation routes like I- 5 are at or over capacity given current travel demand. This situation is expected to worsen as travel demand for Sea-Tac Airport and major roadways increases. FHWA issued a ROD in 2003 for the SR 509 Project FEIS that analyzed the extension of the SR 509 corridor. The 2003 SR 509 Project ROD selected Alternative C2. Alternative C2 included a six-lane extension of SR 509 from S 188th Street to I-5. New interchange improvements were proposed at four locations: S 188th Street, S 200th Street, 24th Avenue, 28th Avenue S, and I-5. A four-lane limited access roadway (South Access Road) was also proposed to connect SR 509 at 24th Avenue S/28th Avenue S with the Sea-Tac Airport Terminal Drive system, and an interchange on the South Access Road was proposed at S 200th Street. Improvements on I-5 included adding northbound and southbound collector-distributor (C/D) lanes between SR 509 and SR 516, and adding auxiliary lanes between SR 516 and S 320th Street. Interchange improvements which included a new undercrossing of I-5 to connect to Veteran s Drive were also proposed at SR 516. The Phase 1 Improvements are essentially a subset of the improvements that were proposed in the 2003 FEIS (Table 1 and Figure 2). The Phase 1 Improvements would include a four-lane SR 509 extension (compared to six lanes as analyzed in the 2003 FEIS) from S 188th Street to I-5. Interchange improvements would occur at three locations (compared to four locations as analyzed in the 2003 FEIS): S 188th Street interchange, 24th Avenue S/28th Avenue S, and I-5. In addition, there would be no South Access Road or interchange at S 200th Street, and improvements on I-5 would be less extensive than those proposed in the 2003 FEIS (see Figure 3). The Phase 1 Improvements also assumes that the extension of SR 509 between S 188th Street and I-5 would be fully tolled. A toll point would be located on SR 509 south of the 24th Avenue S/28th Avenue S interchange. Figure 3 provides an overlay comparison of the Phase 1 Improvements and the 2003 FEIS. SR 509 NEPA RE-EVALUATION 11

Figure 2 Design Components of FEIS Preferred Alternative (Alternative C2) and Phase 1 Improvements 12 SR 509 NEPA RE-EVALUATION

Figure 3 Overlay Comparison of Alternative C2 and the Phase 1 Improvements SR 509 NEPA RE-EVALUATION 13

3. What methods were used to analyze Phase 1 Improvements? How do they differ from those used for the 2003 FEIS Alternative C2? Since 2003, when WSDOT conducted an environmental justice analysis of the SR 509 Corridor Completion/I-5/South Access Road, the discipline of environmental justice has evolved. Federal and state guidelines continue to refine definitions of disproportionately affected populations and the methodology for conducting an environmental justice analysis. For example, the 2003 environmental justice analysis used Council on Environmental Quality Guidelines, which qualified a census block group as an environmental justice community if 50 percent or more of its population were minority and/or low-income. Only two of the census block groups in the project area met the 50 percent threshold in 2003. FHWA has subsequently issued guidance which, among other things, clarifies that states should avoid relying on thresholds to identify environmental justice communities. FHWA and WSDOT require that project teams examine the demographics of affected communities and identify low-income, minority, and limited English proficient populations. Based on our demographic analysis, there are environmental justice populations in all 16 census block groups in the study area. Environmental justice analyses also evaluate effects to limited English proficient populations because there is some overlap between impacts to these populations and other environmental justice groups. The 2003 FEIS environmental justice analysis did not discuss impacts to limited English proficient populations. Table 2 highlights the key threshold differences between the 2003 analysis and this re-evaluation. Even though the threshold for identifying an environmental justice community has changed, the research questions and methodology have not changed significantly. Specifically, the approach to determining if a project would have a disproportionately high and adverse effect to environmental justice populations remains the same. Table 2. Comparison of Demographic Analysis Methods Population Type Alternative C2 Phase 1 Improvements Threshold Minority Low-Income Are at least 50% of residents in this census block group minority? Are at least 50% of residents in this census block group low-income? Are there minority residents in this census block group? Are there low-income residents in this census block group? Limited English Proficient Not analyzed Are there residents who are limited English proficient in this census block group? Overall Findings 13 specific census blocks may be environmental justice populations All census block groups include environmental justice populations Study Area To analyze potential construction and operation impacts of the expanded SR 509 facility on environmental justice populations, we used the same study area as the 2003 environmental justice analysis, which included the geographic area within 1/2 mile of the project alignment. Figure 4 shows the SR 509 study area. SR 509 NEPA RE-EVALUATION 14

Project Alignment Figure 4: SR 509 Study Area SR 509 NEPA RE-EVALUATION 15

To analyze potential benefits and adverse effects of tolling on environmental justice populations, we examined the forecasted travelshed for the future SR 509 tolled facility. The travelshed is the geographic area from which users of the future SR 509 tolled facility will originate. The tolled portion of the new SR 509 facility does not exist today, so WSDOT had to make educated assumptions about where users of the future SR 509 extension will originate. WSDOT used regional traffic models to make these educated assumptions (SR 509 NEPA Re-Evaluation Transportation Discipline Report, WSDOT 2017). Figure 5 shows the travelshed for the future SR 509 extension. The geographic boundaries of the SR 509 travelshed are SR 518 in Tukwila to the north and SR 18 in Federal Way to the south, the shoreline to the west and 140 Avenue SE in Renton and Kent to the east. Data Collection The 2003 FEIS used the Census data available at that time, which were from the 2000 Decennial Census. To show how demographics in the project area have changed since the 2003 FEIS, we compared the demographic data from the 2000 Census to the most recently available demographic data from the American Community Survey. Sources of data to inform this Phase 1 Improvements analysis of potential effects and benefits include the following: American Community Survey data, 2011-2015 (U.S. Census Bureau) Demographic data from the Washington State Office of the Superintendent of Public Instruction for the 2015 2016 school year Reports on current distribution of Good To Go! passes in the SR 509 travelshed (the geographic area from which SR 509 users are expected to originate). We used these data to identify potentially affected populations and neighborhoods in the project study areas. Public Involvement Public involvement with communities in the study area has influenced the scope of Phase 1 Improvements. Members of the public have had an opportunity to review multiple design options, varying from the 2003 FEIS Alternative C2 to options that would use a much smaller footprint and have substantially fewer impacts. Through this outreach and engagement, WSDOT was able to achieve consensus on the Phase 1 Improvements. Since introducing the Phase 1 Improvements in 2015, WSDOT has held two rounds of public open houses (December 2015 and April 2017). Over 70 people attended each round of open houses. For each round of open houses, WSDOT mailed postcards to nearly 20,000 households and local businesses. WSDOT distributed meeting notices in English, Vietnamese, and Spanish and secured paid advertising in local and ethnic media publications, including: Korea Daily: translated advertisement in Korean-language newspaper Runta News: English-language advertisement on English-language website for Somali/East African audiences La Raza: translated advertisement in Spanish-language newspaper Seattle Chinese News: translated advertisement in Chinese-language newspaper Seattle Viet Times: translated advertisement in Vietnamese-language newspaper Highline Times: web advertisements on local website serving Burien Federal Way Mirror: web advertisements on local website serving Federal Way Kent Reporter: web advertisements on local website serving Kent Tukwila Reporter: web advertisements on local website serving Tukwila Seattle Times: print and web advertisements in regional news publication 16 SR 509 NEPA RE-EVALUATION

Figure 5: SR 509 Travelshed SR 509 NEPA RE-EVALUATION 17

In addition, WSDOT formed a Steering Committee comprised of staff from the local jurisdictions in the study area and an Executive Committee composed of elected officials from jurisdictions within the study area. WSDOT has held six Steering Committee meetings and three Executive Committee meetings (December 2015 May 2017). In addition, to consult with environmental justice communities on the project, WSDOT scheduled and conducted stakeholder interviews with 10 community-based organizations and social service providers representing communities and populations in the study areas. These include the following stakeholders: Asian Counseling and Referral Services Child Haven Des Moines Food Bank Kent HOPE Kent Youth and Family Services Salvation Army Des Moines Sea Mar Community Health Centers - Des Moines Medical Clinic Somali Youth and Family Club White Center Food Bank Workforce Development Council of Seattle/King County These organizations also helped distribute emails about the April 2017 open houses to their constituents and clients. As part of this environmental justice analysis, we studied summaries from these stakeholder interviews, as well as summaries from the public open houses and Steering Committee and Executive Committee meetings. We looked for issues of concern for low-income, minority, and limited English proficient populations to explore further in this environmental justice analysis. We used outcomes from this public involvement to identify potentially affected populations, neighborhoods, social resources, public services, and community cohesion in the study areas; potential benefits and adverse impacts of the Phase I improvements; and potential mitigation for adverse impacts. The public involvement process also informed development of mitigation for the potential adverse effects of tolling. The following summarizes questions and concerns from public involvement activities for Phase 1: In general, the public has understood the need for tolling, but some have expressed surprise or frustration about the cost of the project. Residents requested that WSDOT not take away any existing lanes on I-5 for this project. A few people expressed concerns regarding air quality associated with the project, especially in light of its proximity to the airport and flight path. Community members wondered about the effects of airplanes and transportation projects on human health and environmental justice. There have been several questions about the construction schedule and staging. Specifically, community members have inquired about how construction will affect the I-5 and SR 516 traffic and neighborhoods near the project. Community members have asked when Phase 2 improvements could happen. Community members have expressed concern about the need for funding from the local jurisdictions and whether that is realistic. 18 SR 509 NEPA RE-EVALUATION

Attendees asked about mitigation for visual and noise impacts to the surrounding neighborhoods. ENVIRONMENTAL JUSTICE A few property owners have had specific questions about right of way acquisition, including timeline and whether their property is likely to be affected. Tribal Consultations Tribes are considered environmental justice populations, and WSDOT engages with potentially affected Tribes through government to government consultation. Prior to the 2003 FEIS, WSDOT consulted the Muckleshoot Indian Tribe and the Duwamish Tribe to secure information about traditional cultural properties, culturally sensitive locations, fish passage, or other effects to Tribes within or adjacent to the project area. These consultations did not result in the identification of traditional cultural properties in the study area, nor did WSDOT identify other potential effects to Tribes as a result of the project. Since then, WSDOT has continued to keep Tribes informed of project updates but is not engaging in ongoing consultation on this project. Analytical Techniques and Models This environmental justice discipline report uses similar analytical techniques and models to the 2003 FEIS. To identify potential impacts on minority or low-income populations, as well as limited English proficient residents, we met with project team members and reviewed technical reports to find answers to the following questions: How would construction and operation potentially adversely affect these populations? Would any of these adverse effects be different from those evaluated in the 2003 FEIS? How would construction and operation specifically benefit these populations? Are any of these benefits different from those evaluated in the 2003 FEIS? We identified potential new adverse effects or benefits and isolated the new project effects that would affect people differently, such as noise or increased traffic congestion. Next, we determined whether any adverse effects or benefits would disproportionately affect lowincome or minority populations. We used EJScreen, an environmental justice mapping and screening tool developed by the U.S. Environmental Protection Agency. We mapped the geographic areas that will be affected by the project and EJScreen provided us with demographic and environmental information for these areas. This allows comparison of the minority and poverty status of those who would be affected by the Phase 1 Improvements to those not affected by the project. New to this evaluation, we also compared limited English proficient status of those who would be affected by the project to those not affected. Table 10 in this document summarizes the outcomes from this analysis. The next step was to determine whether any of these effects met the U.S. Department of Transportation (USDOT) definition of a disproportionately high and adverse effect. According to USDOT, a disproportionately high and adverse effect on minority and low-income populations is an adverse effect that: Is predominantly borne by a minority population and/or a low-income population, or Will be suffered by the minority population and/or low-income population and is appreciably more severe or greater in magnitude than the adverse effect that will be suffered by the nonminority population and/or non-low-income population. In determining whether there will be disproportionately high and adverse effects to low-income, minority, or limited English proficient populations, we also considered the following: SR 509 NEPA RE-EVALUATION 19

Are there reasonable and feasible measures to avoid or minimize disproportionately high and adverse effects? Are there any project benefits that would affect low-income or minority populations? Did WSDOT modify the project to avoid or minimize disproportionately high and adverse effects? Methods to Analyze Tolling The 2003 FEIS did not analyze tolling. To identify potential impacts of the toll and the all-electronic toll system on low-income, minority, and limited English proficient populations, we created demographic maps of the travelshed for the Phase 1 Improvements. The travelshed is the geographic area from where we expect users of the new SR 509 extension will originate. Since the Phase 1 improvements will be a new facility, WSDOT made educated estimates about the travelshed, based on regional traffic models (SR 509 NEPA Re-Evaluation Transportation Discipline Report, WSDOT 2017). The geographic boundaries of the SR 509 travelshed are SR 518 in Tukwila to the north and SR 18 in Federal Way to the south, the shoreline to the west and 140 Avenue SE in Renton and Kent to the east. The travelshed maps used demographic data from EJScreen, a recently developed tool managed by the U.S. Environmental Protection Agency. We created three demographic maps of the travelshed: lowincome populations in the travelshed, minority populations in the travelshed, and limited English proficient populations in the travelshed. To evaluate whether the effect of tolls and all-electronic tolling on low-income populations would be considerably more severe or greater in magnitude than the adverse effects suffered by the general population, we did the following: Compared cost of the toll for low-income households to the cost for average households. The analyst calculated the average cost of the toll per year per user and compared the percentage of household income the toll would represent for different types of households (e.g., below federal poverty level, median household income). Estimated costs in additional travel time, vehicle operating costs, and transit fees of using untolled alternate routes and travel modes (such as transit). Using traffic forecast models, we compared forecasted travel times during peak periods and midday. Estimated costs in travel time and vehicle operating costs for unbanked or underbanked 1 individuals to reach a customer service center in Seattle, Bellevue, or Tacoma to load the Good To Go! pass. Estimated surcharges from using video tolling instead of a Good To Go! pass for unbanked or underbanked individuals. Examined the distribution of Good To Go! passes to see if there are any differences between geographic areas that have higher Good To Go! pass penetration compared to geographic areas with lower Good To Go! pass usage. 1 The Federal Deposit Insurance Corporation (FDIC) defines unbanked as those adults without an account at a bank or other financial institution, and no ability to conduct transactions electronically. Underbanked individuals have limited access to mainstream financial services and typically rely on non-traditional forms of finance, including check cashing services, loan sharks, and pawnbrokers. The FDIC estimates there are 10 million unbanked or underbanked individuals in the U.S., the majority of which are immigrants and/or individuals with low incomes. 20 SR 509 NEPA RE-EVALUATION

Methods to Analyze Indirect and Cumulative Effects For the purposes of NEPA, an indirect effect is one that is caused by the proposed action and is reasonably foreseeable, but would happen later in time or in another location. Indirect effects could include changes in the pattern of land use, population density, or growth. Cumulative effects are either those that come from risk over time or effects caused by multiple projects in one geographic area. We examined whether the Phase 1 Improvements could affect community cohesion or linkages that people in a community have with their neighbors and social resources like schools, community centers, recreational facilities, churches, and other gathering places. It is important to examine the level of community cohesion in an affected neighborhood and determine the extent to which the project might adversely affect or improve that cohesion. For this study, we reviewed regional transportation plans such as Transportation 2040 (Puget Sound Regional Council) and Sound Transit 2 and 3 to identify reasonable and foreseeable projects separate from this project that could benefit or impact neighborhoods, social resources, or environmental justice populations. This analysis included current tolled facilities, such as the SR 167 HOT Lanes from Puyallup to Renton, and planned tolled facilities near the study area, such as the extension of the I-405 express toll lanes from Bellevue to Renton. We also coordinated with the authors of the Phase 1 Improvements Cumulative Effects analysis to identify reasonable and foreseeable projects that could affect non-tolled alternate routes. SR 509 NEPA RE-EVALUATION 21

4. What has changed in the affected environment since 2003? Distribution of Environmental Justice Populations The 2003 FEIS environmental justice analysis used a different approach to analyzing demographic data. For example, it identified neighborhoods as environmental justice communities if 50 percent or more of the population of the census block was minority or low-income. Today, we avoid using thresholds to define neighborhoods as environmental justice communities, and instead examine the demographics of affected areas to identify environmental justice populations. The 2003 FEIS reported minority population data at the block level and used multiple indicators, such as average rent, to extrapolate poverty data at the block level. Today, the U.S. Census Bureau estimates minority and poverty data at the block group level. As such, it is not possible to use the data reported in the 2003 FEIS environmental justice analysis to compare conditions today with conditions in 2003. Instead, we used census block group-level data from the U.S. Decennial Census in 2000 and compared them to estimates from the American Community Survey from 2015. Figure 6 shows the census block groups in the study area. Table 3 compares demographic conditions in 2000 to 2017. Our analysis shows that, since 2000, the percentage of individuals identifying as a minority increased in some cases, substantially in 15 of the 17 census block groups in the study area that existed in 2000. Overall, the percentage of individuals identifying as a minority has increased from 39 percent to 44 percent in the study area since the 2003 FEIS. The percentage of individuals with incomes at or below the federal poverty level increased in 14 of the 17 census block groups. The percentage of individuals with incomes at or below the federal poverty level remained the same in the study area as a whole, at 13 percent percent. A minority is an individual who identifies himself as Black (a person having origins in any of the black racial groups of Africa); Hispanic (a person of Mexican, Puerto Rican, Cuban, Central American or South American, or other Spanish culture or origin, regardless of race); Asian (a person having origins in any of the original peoples of the Far East, Southeast Asia, the Indian subcontinent, or the Pacific Islands); American Indian/Alaskan Native (a person having origins in any of the original peoples of North America and who maintains cultural identification through tribal affiliation or community recognition); or some other race. A low-income person is an individual whose household income falls below the federal poverty guidelines, as defined by the U.S. Department of Health and Human Services. For 2017, the federal poverty guideline for a household of four in one of the 48 contiguous states and Washington D.C. is $24,600. The U.S. Census Bureau also have made some changes in how they collect and report data since 2003, which means that, in many cases, we are comparing actual data to estimates. For example, the minority data from the 2000 U.S. Decennial Census are actual data collected from each person living in the census block group at the time of the census. Minority data from the 2015 American Community Survey are estimates based on 5-year averages, generated from surveys of a sample of residents living in the census block group from 2011 to 2015. Although American Community Survey data are estimates, for the purpose of this analysis, we find the estimates more useful than using 2010 Census data alone, because 2010 Census data is nine years old (it was collected in 2009). We note in the sources under Table 3 whether the percentages reflect actual data or estimates. 22 SR 509 NEPA RE-EVALUATION

Figure 6: Census Block Groups in the SR 509 Study Area SR 509 NEPA RE-EVALUATION 23

24 SR 509 NEPA RE-EVALUATION

Table 3. Comparison of Minority and Low-Income Populations in the Study Area Census Block Group Percent Identifying as Minority Percent Individuals at or below poverty level 2003 a 2017 b 2003 c 2017 e 284024 60% 90% 29% 18% 285001 21% 20% 0% 1% 285002 20% 32% 15% 7% 287001 26% 54% 12% 16% 288011 17% 22% 3% 10% 288012 32% 58% 6% 19% 288013 52% 64% 21% 7% 288023 42% 76% 5% 34% 288024 26% 84% 0% 40% 289021 64% 73% 32% 44% 289023 51% 50% 16% 43% 289024 33% 43% 3% 16% 289025 53% 75% 13% 25% 290034 28% 63% 6% 12% 290041 43% 65% 17% 22% 291011 n/a 43% n/a 14% 291021 n/a 63% n/a 12% 291023 n/a 45% n/a 10% 298011 19% 63% 4% 9% 300035 34% 74% 4% 10% Average for Study Area 39% 44% 13% 13% King County 32% 32% 8% 10% a Source: U.S. Census Bureau Census 2000 (2001) b Source: U.S. Census Bureau 2011-2015 American Community Survey 5-Year Estimates (2016) c Source: U.S. Census Bureau Census 2000 (2001) (estimated) e Source: United States Census Bureau 2011-2015 American Community Survey 5-Year Estimates (2016) Figures 7 and 8 show the current distribution of minority and low-income populations in the study area. The red line on each map shows the alignment of the Phase 1 improvements. The yellow-shaded portion of each map is the geographic area within ½ mile of the project alignment. SR 509 NEPA RE-EVALUATION 25

Project Alignment Numbers in legend are percentages Figure 7: Percent Minority in the SR 509 Study Area 26 SR 509 NEPA RE-EVALUATION

Project Alignment Numbers in legend are percentages Figure 8: Percent Low-income in the SR 509 Study Area SR 509 NEPA RE-EVALUATION 27

Table 4 further breaks down the populations of each Census block group by race and ethnicity. ENVIRONMENTAL JUSTICE Table 4. Race and Ethnicity of Populations in the Study Area Census Block Group 284024 285001 285002 287001 288011 288012 288013 288023 288024 289021 289023 289024 289025 290034 290041 291011 291021 291023 298011 300035 White (Not Hispanic) Black Native American or Alaskan Native Asian Native Hawaiian or Pacific Islander Two or More Races Hispanic 10% 52% 0% 14% 0% 13% 12% 80% 2% 6% 3% 0% 6% 9% 68% 9% 0% 5% 0% 3% 17% 46% 11% 0% 8% 14% 8% 15% 78% 5% 2% 3% 4% 2% 8% 42% 0% 0% 10% 0% 5% 43% 36% 8% 5% 6% 2% 9% 37% 24% 29% 1% 5% 16% 18% 7% 16% 35% 1% 7% 0% 5% 37% 27% 4% 0% 31% 0% 3% 38% 50% 25% 1% 20% 3% 1% 0% 57% 4% 2% 21% 0% 10% 12% 25% 14% 0% 6% 2% 0% 53% 37% 12% 0% 2% 0% 8% 41% 35% 18% 2% 6% 1% 6% 37% 57% 17% 0% 13% 0% 8% 5% 37% 25% 2% 16% 0% 8% 14% 55% 5% 0% 13% 1% 12% 16% 37% 22% 0% 7% 3% 27% 8% 26% 7% 1% 7% 0% 0% 53% We verified the data from the U.S. Census and American Community Survey with data from the Washington Office of Superintendent of Public Instruction, which collects and archives demographic information from all public schools in the state. Data from the 2015 2016 school year includes the percentage of students identifying as a minority in each of the five elementary schools in the study area and the percentage of students eligible for free- and reduced-price lunches, which is a proxy for lowincome status. Data on minority-identifying students is available for the 2003 2004 school year at the elementary school level, but is not available on eligibility for free- and reduced-price lunches. Table 5 compares conditions in 2003 to the present. These data echo the results of the demographic analysis and show that the percentage of students identifying as a minority has increased from 56 percent in 2003 to 77 percent today. 28 SR 509 NEPA RE-EVALUATION

Table 5. Comparison of Data for Students Enrolled in Public Elementary Schools in the Study Area Elementary School Percent of Students Identifying as Minority Percent of Students Eligible for Free- and Reduced-Price Lunch 2003 2017 2003 2017 Des Moines 41% 59% Not available 50% Gregory Heights 37% 60% Not available 53% Madrona 83% 93% Not available 82% Midway 62% 91% Not available 75% North Hill 43% 55% Not available 50% Average for all elementary schools in study area 56% 77% Not available 63% Source: Washington Office of Superintendent of Public Instruction (2016) Consideration of Limited English Proficient Populations Table 6 shows the percentages of limited English proficient households in the study area. In the study area as a whole, 11 percent of residents have limited English proficiency. Table 6. Percentage of Limited English Speaking Households in the Study Area Census Block Group 2017 Re-evaluation 284024 25% 285001 11% 285002 1% 287001 3% 288011 2% 288012 9% 288013 0% 288023 3% 288024 12% 289021 21% 289023 9% 289024 4% 289025 36% 290034 13% 290041 13% 291011 1% 291021 2% 291023 6% SR 509 NEPA RE-EVALUATION 29

Table 6. Percentage of Limited English Speaking Households in the Study Area Census Block Group 2017 Re-evaluation 298011 0% 300035 18% Study Area 11% Source: American Community Survey Five-Year Estimates, 2015 (estimated) We confirmed limited English proficient populations with 2015 2016 transitional and bilingual data available from the state Office of the Superintendent of Public Instruction. Table 7 shows the percentage of transitional or bilingual students in study area schools. A limited-english proficient person is an individual who has difficulty speaking, reading, writing, or understanding the English language and whose difficulties may deny that individual the opportunity to meaningfully engage in the transportation decision-making process. This definition applies to an individual who: Was not born in the United States; Speaks a native language other than English and comes from an environment where a language other than English is dominant; or Comes from an environment where a language other than English has had a substantial effect on that individual s English-language proficiency. Table 7. Percentage of Transitional or Bilingual Students in the Study Area Schools School Name Percentage of Transitional or Bilingual Students Des Moines Elementary 13% Gregory Heights Elementary 23% Madrona Elementary 52% Midway Elementary 42% North Hill Elementary 12% Average for all elementary schools in study area 30% Source: Washington Office of Superintendent of Public Instruction 2016 Report Card. Date Accessed: April 26, 2017 Figure 9 shows the distribution of linguistically isolated individuals in the study area. Linguistically isolated is a U.S. Census term that refers to individuals who reported speaking English not very well or not at all. Figure 10 shows the percentage of linguistically isolated Spanish speakers in census block groups in the study area. According to EJ Screen, 6 percent of households in the study area are linguistically isolated (EJ Screen, 2014). The U.S. Department of Justice recommends translating materials for each eligible limited English proficient language group that constitutes 5 percent or 1,000 individuals, whichever is less, of the population eligible to be served or likely to be affected (WSDOT, 2007). These data indicate that, at the very least, WSDOT should translate all public outreach materials into Spanish. Interviews with service providers in the study area confirmed the need for Spanish interpretation and translation. Service providers in the study area discussed the language diversity in the area, with one provider noting there were 27 languages spoken by their clients. Providers recommended WSDOT also consider interpretation and translation services for Cambodian, Chinese, Russian, Samoan, and Vietnamese. 30 SR 509 NEPA RE-EVALUATION

Project Alignment Numbers in legend are percentages Figure 9 : Percent Linguistically Isolated in the SR 509 Study Area SR 509 NEPA RE-EVALUATION 31

Project Alignment Figure 10: 5%+ Spanish Speakers in the SR 509 Study Area 32 SR 509 NEPA RE-EVALUATION

Potential Users of Tolled Portion of SR 509 ENVIRONMENTAL JUSTICE With the addition of tolling with Phase 1 Improvements, we also have to consider whether environmental justice populations would be users of the SR 509 extension. This section provides an overview of the SR 509 travelshed (the geographic area from which SR 509 users are expected to originate), including the demographic profile of these users. Figure 11 shows the percent of residents in each census block group in the SR 509 travelshed who identify as minority. Figure 12 shows the percent of residents in each census block group in the SR 509 travelshed who have incomes at or below the federal poverty level. Figure 13 shows the percent of residents in each census block group in the SR 509 travelshed who are linguistically isolated. Figure 14 shows the percentage of residents in each census block group who are linguistically isolated and speak Spanish at home. According to EJ Screen, 985 households in the travelshed are linguistically isolated and speak Spanish at home (EJ Screen, 2014). EJ Screen reports languages for households, rather in than individuals, but since a household often includes more than one person, it is safe to assume there are at least 1,000 individuals in the SR 509 travelshed who are linguistically isolated and speak Spanish at home. Based on Department of Justice guidance, WSDOT should translate information about tolling into Spanish. No other language meets the Department of Justice threshold, but 5,491 individuals in the travelshed report they are linguistically isolated. WSDOT should consider translation and interpretation in other languages, if needed. SR 509 NEPA RE-EVALUATION 33

Figure 11: Percent Minority in the SR 509 Travelshed 34 SR 509 NEPA RE-EVALUATION

Figure 12: Percent Low-Income in the SR 509 Travelshed SR 509 NEPA RE-EVALUATION 35

Figure 13: Percent Linguistically Isolated in the SR 509 Travelshed 36 SR 509 NEPA RE-EVALUATION

Figure 14: 5%+ Spanish Speakers SR 509 NEPA RE-EVALUATION 37