etod Score A Proposed Rating System for Equitable Transit-Oriented Development

Transcription

1 etod A Proposed Rating System for Equitable Transit-Oriented Development Introduction: Purpose & Need for a TOD Rating System The Boston area is home to the oldest subway system in the nation and many of the city s most celebrated and thriving neighborhoods owe their successful urban design to the accessibility provided them by the city s public transportation system. These communities were transit-oriented well before the expression had a meaning of its own, and as a result many of the unique virtues of transit-oriented development (TOD) in these neighborhoods continue to be taken for granted. The MBTA system includes more than 250 rapid transit and commuter rail station areas and over 1,000 additional bus stops. The MBTA service district covers 175 municipalities, equal to 3,244 square miles and a serviceable population of over 4.6 million residents. While transit-rich neighborhoods (the area within one-half mile of a transit station) cover only 3.5% of the metropolitan area s land, they are home to 22% of all residents and 30% of all households. TOD opportunities abound: according to a 2012 MAPC report, since 2000, nearly 15,000 housing units located near transit hubs have either been completed or are under construction. Despite a wealth of TOD investment in recent years, mixed-use development around MBTA station areas in metropolitan Boston has proceeded more slowly than needed to meet demand for living, working and shopping in transit-rich neighborhoods. Many factors combine to slow the pace of TOD including lack of infrastructure, high costs of land acquisition, volatile community and neighborhood support, regulatory barriers like zoning restrictions, and a lack of policy leadership to ensure that land use goals and greenhouse gas reduction goals are met at least in part by encouraging dense, mixeduse development near transit. Many of these issues, sometimes confronting developers in tandem, make it much harder to implement land-use plans that would produce greater reductions in household costs and vehicle miles traveled (VMT). Page 1

2 Yet another issue with the potential to stall TOD in greater Boston s transit-rich neighborhoods is concern about whether such development will catalyze or contribute to gentrification and displacement of both local residents and local businesses. Especially when existing or planned stations are located in neighborhoods where the demand for affordable or moderate cost rental housing exceeds supply, residents are concerned that new, market-rate TOD will drive up rents and drive out the residents who need and use transit. Greater Boston needs not just TOD but equitable TOD. Equitable TOD is an intentional approach to TOD designed to ensure that the coordinated transportation, urban design, land use, development and investments made near commuter rail and rapid transit stations and the bus network are directly benefiting lowand moderate-income households and communities of color and connecting them to jobs and to opportunities to improve the quality of their life. Policy and planning in greater Boston need to simultaneously promote and catalyze more transit-oriented development while ensuring that such TOD meets the needs of a broad cross-section of those who do and will live, work and shop in the region s many transit-rich neighborhoods. Yet local and state government and community groups lack any objective way of assessing which station areas and what types of transit-oriented development can best serve both regional and local needs. They need an assessment tool for better understanding which transit-rich neighborhoods and which specific projects proposed for those neighborhoods are the right kind of TOD and specifically of equitable TOD. To meet this need for an equitable TOD assessment tool, the Dukakis Center for Urban and Regional Policy at Northeastern University and the Center for Transit Oriented Development (CTOD) have collaborated on this project, working with an equity advisory committee of government and non-profit partners. Akin to the well-known LEED rating systems that measure various green aspects of buildings and neighborhoods, the goal of this collaboration is to develop a metric for measuring the capacity for equitable transit-oriented development within a given public transit station area. It builds on CTOD s national experience in identifying and defining effective and high performing TOD, particularly CTOD s Performance-Based TOD Typology, and its work in developing TOD typologies for many transit systems. The etod Rating System also incorporates the efforts of the Dukakis Center to better measure and understand transit and TOD equity. As a result, this rating system is designed to identify neighborhoods and districts with built, social, and transit attributes that reduce driving, encourage higher transit ridership, and promote transit equity and accessibility. By providing a specific definition of high-performing, equitable TOD, this system can be used to catalyze and direct rapid policy change in support of both specific development projects and broader initiatives intended to plan or improve transit-rich neighborhoods. Page 2

3 Framework for Developing an Equitable TOD Rating System TOD-related performance can be indicated by many factors. Reducing an area s vehicle miles traveled (VMT) has been a major initiative undertaken by many local regional transit agencies throughout the country. In the Boston region, the Metropolitan Area Planning Council (MAPC) and others have identified VMT reduction and increasing transit ridership as two of its major goals for TOD. While not a comprehensive measure, VMT is an important proxy for measuring which neighborhoods are likely to generate the most transit riders, promote walking and biking, lower household transportation costs, and reduce greenhouse gases. One promising strategy for reducing VMT is to champion a common understanding of what constitutes exemplary TOD. Quantifying and disseminating this definition throughout transportation policy circles establishes a common baseline and replicable understanding of what constitutes a high-quality TOD project. While the performance of TOD can be measured in a relatively straightforward matter by assessing whether it helps reduce driving and increase transit use it is more difficult to measure the performance of equitable TOD. One approach could be to identify a high level measure of equity and assess whether specific characteristics of station areas and projects can be shown to increase equity as so measured. But that approach would require development of a unitary metric for equity in the context of transportation, land use and TOD and while such an approach was considered, it was ultimately rejected because of the difficulty of defining and quantifying the extent to which equity was improved or not. Figure 1: Rating System Framework with Separate TOD and Equity Outcomes Page 3

4 Instead, this project has focused on identifying a set of neighborhood characteristics that could be shown to contribute both to TOD performance in the traditional sense and to improved social equity. Figure 2: Rating System Framework with Unitary TOD and Equity Outcomes In this unitary framework, the group of characteristics that are simultaneously related both to TOD performance (lower VMT and greater transit usage) and greater social equity have been identified by building on work by the Dukakis Center that identifies a set of core riders who are the most likely to use transit. Core riders are important to TOD performance because they have been demonstrated both to drive less and use transit more, so station areas with more of these transit oriented neighbors are more likely to produce the travel characteristics associated with successful TOD. At the same time, a number of the socioeconomic and demographic groups who constitute a disproportionate share of transit users are also important from an equity perspective and so ensuring that TOD is oriented toward these groups also ensures that the TOD will further the objectives of equitable regional development. Work by the Dukakis Center and others has identified at least five populations that can be characterized as core transit riders: Households that do not have a vehicle Renters Lower income households People of color Immigrants Page 4

5 Figure 3: Comparison of Boston MSA and Public Transportation Commuter Demographic Characteristics (ACS 5 year Table S0802) 60.0% 50.0% Boston-Cambridge-Quincy MSA Public Transportation Commuters 40.0% 30.0% 20.0% 10.0% 0.0% People of Color Hispanic/Latino Foreign born Income at/under $25,000 Income below 150% of poverty Renters No vehicle available These groups of core transit riders have been identified by analyzing travel survey data, (such as the analysis of the 2009 National Household Travel Survey by Chu et al 2012) and on-board surveys of MBTA and other transit riders, as well as American Community Survey data on public transportation commuters. As shown in Figure 3, the core rider groups of renters, members of zero-vehicle households, immigrants, people of color and lower income households represent a significantly higher share of those who report using public transportation to commute to work than their share of the regional population. In developing of this rating system, we along with the equity advisory committee debated whether or not race and ethnicity should explicitly be included or whether to focus on core ridership attributes such as transit dependency/vehicle availability (zero vehicle households), housing tenure (renter status) and income. In this proposed version, as explained below, race and ethnicity and immigration status have not been incorporated into the station area rating system. These factors unlike vehicle ownership, housing tenure and income cannot easily be affected either by TOD development choices or by public policy more broadly. The racial/ethnic composition of a station area may change due to changes in transit service and TOD development, but it is far more difficult to orient TOD toward accomplishing such changes. The factors chosen for inclusion in the rating system can be influenced by specific planning and policy decisions (e.g. less parking and car sharing can influence the number of zero vehicle households and use mix and policies can promote production of rental housing and of housing affordable to lower-income families). Page 5

6 Equitable Transit Oriented Development (TOD) Rating System: etod The extent to which both the transit and development in TOD are oriented to both transportation and equity outcomes cannot be distilled to a single factor. Instead, it is a function of activity-based, demographic, and accessibility-related characteristics in a given neighborhood. A station area rating system therefore needs to include a blend of metrics linked to desired public outcomes (e.g. lower VMT, equitable access to transit). These measures of the built and social environments are then combined into a composite transit orientation index for each station area that can be readily compared to others in the region. For purposes of transparency and consistency, the chosen elements should be readily understood and available for ongoing analysis into the future, even as conditions are expected to change. The etod TOD rating system proposed here is based on the concept that successful and equitable transit-oriented development depends on the interplay of all three of the words in the acronym TOD: 1) A focus on the availability, quality and use of public transit(as well as other nonautomobile means of transportation) 2) A focus on orientation toward transit oriented neighbors who make up the core of transit ridership 3) A focus on the characteristics of development in the neighborhoods surrounding the MBTA station Transit Orientation Development focus on the availability, quality and use of transit focus on "transit oriented neighbors" who make up the core of transit ridership focus on characteristics of development context in the nearby neighborhoods The rating system considers measures to capture each of these areas (Transit, Orientation, Development). The purpose is to generate a rating system that will allow for relative comparisons across the region, while also identifying the strengths and opportunities presented within individual station areas. Page 6

7 By definition, TOD needs to be located near a transit station. The etod system defines a transit station area as the half-mile buffer around a subway or commuter rail station. Because the system is also designed to evaluate TOD suitability along high frequency bus routes, a similar half-mile buffer was included around selected bus stops along certain segments of the MBTA s key bus routes. 1 Neighborhoods outside of the station areas are not eligible for ratings under this system. The primary goal of the etod rating system is to assess which station areas are amenable to equitable transit-oriented development. In order to choose the station area characteristics most important in determining successful and equitable TOD, we focused on measurable attributes statistically associated with less driving, measured as VMT per household in each station area. In Massachusetts, local VMT data is available, allowing the development of the etod rating system. But since VMT data are not available nationally, the system does not directly rely on the availability of such data. Instead, the rating system is comprised of attributes that our research has established are correlated with stations areas in which residents drive less. For each identified station area attribute, points are calculated based on the quintile distribution of that attribute (i.e. the lowest quintile is scored as 1, and the highest quintile as 5 ). Transit Transit is scored through the following three measures: 1) Transit Accessibility: The Transit Access Shed index (TAS), developed by the Center for Neighborhood Technology, is a 100 point scale which calculates the size of the area that passengers who board at a given station area can easily access using transit in 30 minutes, scaled by the frequency of transit service at that station; 2) Transit Connectivity: The Transit Connectivity Index (TCI), also developed by the Center for Neighborhood Technology, is a 100 point scale measuring access to and the frequency of transit service at a bus or rail stop location and within the surrounding neighborhood; 3) Transit Use: Transit use is measured as the percentage of workers who use transit, bike, or walk to work (ABC: anything but cars) in the station area, as reported by the American Community Survey (ACS). Per our calculations, the transit ratings for MBTA station areas vary from a low score of 3 to a high score of stations score the minimum possible transit score; all of them 1 The MBTA has designated 15 of its busiest bus routes as Key Bus Routes, each of which operates at a high frequency (7 days a week) to meet passenger demand in high-density corridors. Page 7

8 are Commuter Rail stations. 36 stations score the maximum possible transit score; unsurprisingly, most of them are rail and bus stations located in the downtown core. Orientation 2 Orientation is scored through the following three measures: 1) Transit Dependency: The percentage of zero-vehicle households in the station area (since persons living in households without a car are far more likely to use transit than those in households with cars and serving transit-dependent populations is an important component of equity); 2) Income: The percentage of households with incomes under $25,000 in the station area (since lower income households are more likely to use transit and serving lower income residents is an important component of equity); 3) Rental housing: The percentage renters in the station area (since renters are more frequent users of public transportation than home owners). The orientation ratings for MBTA station areas vary from a low score of 3 (once again, mostly Commuter Rail stations, but also several stations on the Green D Line that goes to affluent suburbs) to a high score of 15 (found at many bus stops, as well as surface Green B and E Line stops). Development A station area s development is scored through measures related the following four measures: 1) Walkability: The independently developed Walk of the station s location (using latitude and longitude), as this measures important destinations within walking distance of the station as well as urban form, and is well-correlated with lower household driving; 2) Residential density: The number of households per residential acre in the station area is used as a measure of how many people live in the station area; 3) Employment gravity: The Employment Gravity measure, developed by the Center for Neighborhood Technology, assesses the quantity of and the distance to all employment destinations, relative to any location within the region. 4) Affordability: Affordability is assessed scores derived from the H+T Index developed by CNT, which measures the percent of income spent on transportation in the station area. 2 The orientation aspect of TOD refers to a project s ability to orient travel behavior towards public transportation. When analyzing a specific TOD project, for example, planners may point to a reduced number of parking spaces in successful TOD projects that discourage automobile travel to these destinations. At the station area level, we believe that the best way to describe a station area s transit orientation is to consider characteristics of the area s residents and take into account how transit oriented the residents travel behaviors are. Page 8

9 Category FINAL REPORT DECEMBER 2012 The development context rating varies between MBTA station areas from a low score of 4 to a high score of 20. Most of the lowest-scoring stations are Commuter Rail stops, and the highest-scoring are mainly bus stops. etod Rating System Summary All ten metrics are added together, establishing a comparable etod for each station area. Metric Measure Transit Orientation Development Distance Depth of Service Use Transit Dependency Transit Access Shed Index (TAS) Transit Connectivity Index (TCI) Percentage workers who use transit, bike, or walk to work (ABC) Percentage of 0-car households Lower income Percentage of households with income <$25,000 Housing Ownership Percentage renters Walkability Walk Residential density Households per residential acre Employment gravity Employment Gravity Measure Affordability Percent of Income Spent on Transportation In order to better visualize the resulting overall etod score as well as the sub-scores, the score can be presented in the form of a radar graph. Each axis of the radar graph represents one of the three sub-scores: transit, orientation, and development context. Transit and orientation are on scales with a maximum of 15 points; development is on a scale with a maximum of 20. The theoretical maximum possible score (15/15/20) is shown with the outside triangle; the filled-in shape inside the triangle shows how much of the possible score the station receives. This representation allows for a quick analysis of the strengths and weaknesses in the transit station area. Two stations with the same total score can have very different shapes on the radar graph composed of the sub-scale scores (compare, for example, the radar graph for Dudley on the left, which has a lower sub-score for Development, to that for Maverick, on the right, which has a lower sub-score for Transit). Dudley Station Silver Line Maverick Station Blue Line Page 9

10 Station Area Comparisons Using these measures, it is possible to compare a given area s performance relative to other stations by comparing the scores. Because of their inherent advantages, stations closer to downtown Boston are generally going to score significantly higher than others further out in the system. But this does not necessarily mean that more distant stations should not be eligible for consideration, especially since the greatest potential to reduce VMT often lies in suburban communities. The overall score ranges from a minimum of 10 points to a maximum of 50 points. The score is then divided into four groups, which correspond to changes in average VMT measures: etod Range Mean VMT per day per household Description Transit-Oriented Transit-Supportive Transit-Related Transit-Adjacent The lowest- and highest-scoring stations are listed in the table below. Lowest Rated Stations (scoring 10 points) Ballardvale (commuter rail) Cohasset (commuter rail) Halifax (commuter rail) Kingston (commuter rail) Littleton / Rte 495 (commuter rail) Nantasket Junction (commuter rail) Norfolk (commuter rail) North Billerica (commuter rail) North Scituate (commuter rail) North Wilmington (commuter rail) Rowley (commuter rail) Silver Hill (commuter rail) South Acton (commuter rail) South Weymouth (commuter rail) Southborough (commuter rail) Wilmington (commuter rail) Highest Rated Stations (scoring points) Mass. Ave Station (50) (rapid transit) Symphony Station (50) (rapid transit) Huntington Opera Pl (rapid transit) Northeastern (rapid transit) Hynes Station (rapid transit) Massachusetts Comm. Ave (bus) Tufts Medical Ctr (rapid transit) Washington Tufts Med Ctr (bus) Yawkey (commuter rail) Page 10

11 Combined Transit Orientation Some locations may be strong on one or more of the TOD measures but weaker on the others. The figures below show different station areas evaluated based on their individual metrics. It is possible to compare the region s corridors and stations for their relative levels of overall transit orientation, but also on individual strengths as well. Given the measure s relationships to VMT, this combined transit orientation score is linked to performance, thereby providing a holistic measure of those conditions that contribute to ridership both now and, more than likely, into the future. The etod rating system will use this measure to help inform and prioritize those station areas with strong existing assets as well as future opportunities (e.g. development, access improvements, mixed-income housing). The charts below illustrate the possible differences in Transit, Orientation, and Development scores between stations. Because every station has different strengths, it s possible to monitor them individually over time as conditions improve, remain the same or deteriorate. For instance, Jackson Square on the Orange Line performs well from transit and orientation perspectives, but not in terms of development. On the other hand, a station like Maverick on the Blue Line has a higher development score because of its location, but lacks in access to more frequent transit. Both station area residents are well-oriented towards transit. The rating system methodology is designed to identify these opportunities and strengths under existing conditions and can be updated as communities foster change. Jackson Square Orange Line Maverick Station Blue Line Ultimately the composite and disaggregated etod s give an indication of the relative transit supportiveness of a station area along with possibilities for enhancement. Places that are high on development and transit, but low on orientation, for instance, should be prime places for new affordable or workforce housing projects given their high levels of accessibility. Other areas may exhibit high proportions of transit-oriented populations, yet lack adequate transit or neighborhood serving retail and services. These communities would be best suited for enhanced service and potential mixed-use or commercial development. Page 11

12 Summary of Station Area Ratings The purpose of this etod Rating System is to highlight neighborhoods and districts with existing attributes that grant greater accessibility to transit-reliant populations, promote higher transit ridership and reduce household vehicle miles traveled (VMT). The scoring allows a user to drill down and discover the strengths and weaknesses of any particular station area and address those issues. Places that are transit-oriented for example, should be considered as places where new development would better optimize the existing network by bringing more users to transit-rich neighborhoods. Furthermore, those new households would enjoy reduced transportation costs and greater accessibility to regional destinations. Below is a map of the region that shows how the stations and stop areas break out by their etod. Map 1: Boston Regional etod s Page 12

13 Map 2: Central Boston Region etod s Page 13

14 Transit-Oriented Stations The map below shows the station and stop areas with etod s above 41. Each of these stations has shown that they are strong in each of the Transit, Orientation, and Development categories and are thus prime spots for future equitable development to promote walking, biking, transit and a reduction in driving as well as lower transportation costs and greater access to employment for lower to middle income households. Map 3: Transit-Oriented Stations Some examples of Transit-Oriented Stations include Yawkey Station on the Framingham/Worcester Commuter Rail, Dudley Station on the Silver Line, and Maverick Station on the Blue Line. Page 14

15 Station Name Station Type Transit (x/15) Orientation (x/15) Development (x/20) etod (x/50) etod Description Yawkey Commuter Rail: Framingham/ Worcester Transit- Oriented Dudley Bus: Silver Line Transit- Oriented Maverick Rapid Transit: Blue Line Transit- Oriented

16 Transit-Supportive Stations The map below shows the station and stop areas with etod s between 31 and 40. While these areas do not perform at the level of the Transit-Oriented stations, their moderate to high scores in the Transit, Orientation, and Development categories make them prime locations for future development. Given that they are outside central Boston and Cambridge, they are, in most cases, more affordable. This makes Transit- Supportive station areas ideally suited for workforce housing and, potentially, new employment centers. Each station however should be checked on its individual merits to decide what kinds of projects are best moving forward. Map 4: Transit-Supportive Stations Some examples of Transit-Supportive Stations include Jackson Square on the Orange Line, Lynn Station on the Newburyport/Rockport Commuter Rail, and Morton Street Station on the Fairmount Commuter Rail. Page 16

17 Station Name Station Type Transit (x/15) Orientation (x/15) Development (x/20) etod (x/50) etod Description Jackson Square Rapid Transit: Orange Line Transit- Supportive Lynn Commuter Rail: Newburyport/ Rockport Transit- Supportive Morton Street Commuter Rail: Fairmount Line Transit- Supportive

18 Transit-Related Stations The map below shows the station and stop areas with etod s between 21 and 30. These transit neighborhoods and districts have below average VMT scores and might be strong on one metric of the Transit, Orientation, and Development categories, but are likely to be deficient in others. Performance in individual categories should be checked prior to targeting these areas for investment. In many of these station areas, it might be appropriate to focus on affordable housing solutions due to low Orientation scores. Map 5: Transit-Related Stations Some examples of Transit-Related Stations include Roslindale Village on the Needham Commuter Rail, Melrose Cedar Park on the Haverhill Commuter, and North Quincy Station on the Red Line. Page 18

19 Station Name Station Type Transit (x/15) Orientation (x/15) Development (x/20) etod (x/50) etod Description Roslindale Village Commuter Rail: Needham Line Transit- Related Melrose Cedar Park Commuter Rail: Haverhill Line Transit- Related North Quincy Rapid Transit: Red Line Transit- Related

20 Transit-Adjacent Stations The map below shows the station and stop areas with etod s between 0 and 20. These have very low VMT scores and might be strong on one metric of the Transit, Orientation, and Development categories, but are likely to be very deficient in others. A large amount of these stations are commuter rail stations with less frequent all-day service, which limits their potential to promote transit lifestyles. They also tend to be located in affluent bedroom communities with smaller shares of transit dependent populations and suburban built environments less conducive towards higher ridership. Map 6: Transit-Adjacent Stations Some examples of Transit-Adjacent Stations include Newton Center on the Green Line, Stoughton Station on the Providence/Stoughton Commuter Rail, and West Concord Station on the Fitchburg Commuter Rail. Page 20

21 Station Name Station Type Transit (x/15) Orientation (x/15) Development (x/20) etod (x/50) etod Description Newton Center Rapid Transit: Green Line Transit- Adjacent Stoughton Commuter Rail: Providence/ Stoughton Transit- Adjacent West Concord Commuter Rail: Fitchburg Line Transit- Adjacent

22 Analyzing Station Areas Once a station area is discussed as a possible target for policy intervention or development, the rating system allows analysis of each of the metric sets. Transit, Orientation, and Development categories can be compared at each station and specific targeted interventions can be identified for implementation. An example of this process might be best explained through the following process. 1. Choose a station for evaluation 2. Determine its etod 3. Determine its Transit, Orientation, and Development scores 4. Identify the appropriate suite of implementation strategies Map 6. Verndale Bus Stop on Line #66 Page 22

23 Development Category Orientation Transit FINAL REPORT DECEMBER 2012 The etod score for the Verndale Street at Harvard Street frequent bus stop is 40 points or Transit-Supportive, just one point from being Transit-Oriented. On the subscales, the Verndale Street at Harvard bus stop scores 12/15 at Orientation, 17/20 in Development, and 11/15 at Transit. The spider diagram below illustrates its individual TOD scores compared to one another while the chart shows the scores for individual metrics. This more detailed analysis highlights deficiencies or areas for improvement. The access to transit is relatively low since there are only two lines serving the area, the #66 bus and the Green Line. The number of regional jobs that a station area resident can get to in a 30 minute period is also limited. Reflecting this constrained transit access, the percentage of income spent on transportation (38%) is relatively high here as well. These findings suggest that the area may be a lower priority for near-term development. A more appropriate intervention in the area in the near-term could be enhanced transit service. With greater regional accessibility, Verndale Street s scores would improve and elevate its priority status for development to Transit-Oriented. Verndale Harvard St. Metric Value Measure Distance 82 3/5 Transit Access Shed Index (TAS) Depth of Service 95 4/5 Transit Connectivity Index (TCI) Use 62% 4/5 % workers who use transit, bike, or walk (ABC) Transit Dependency 41% 4/5 % of 0-car households Lower income 25% 3/5 % of households with income <$25,000 Housing Ownership 77% 5/5 % renters Walkability 91 4/5 Walk Residential density Employment gravity 21 du/ac 5/5 Households per residential acre 147K 4/5 Employment Gravity Measure Affordability 38% 4/5 Percent of Income Spent on Transportation Page 23

24 A Final Note - Analyzing Specific Projects The proposed rating system operates at the level of the station area or neighborhood surrounding a transit station and provides important information about attributes of the station area that affect its suitability for equitable TOD. Another desired use of an equitable TOD rating system is for the evaluation of specific TOD projects that are in the planning stage, so that such projects can be scored and different ideas for specific development projects (such as the proposed mix of uses) can be compared. In considering how best to develop a rating system for specific equitable TOD projects, we came to realize that there is no single answer to the question of whether a proposed TOD project is or is not a good equitable TOD project. Instead, the answer is contextspecific: if a TOD project provides what is missing in its station area, the project should be deemed a better project for purposes of planning and the provision of financial incentives. By using the sub-scores, the etod rating system can help planners, policymakers and community groups both design and assess specific TOD projects (as well as transportation investments) to assess the extent to whether they add a missing component to a station area and thus improves its suitability for equitable TOD. We hope in the future to develop a complementary project-level equitable TOD rating system that builds from the etod station area system and more explicitly weighs and scores different components of TOD projects and the extent to which they are responsive to the strengths and weaknesses of their host station area as presented in the etod for that station area. Page 24