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MEMORANDUM SUBJECT: Identification of Schools within 200 meters of U.S. Primary and Secondary Roads
FROM: Meredith Pedde, Office of Transportation and Air Quality/Assessment and Standards

Division Chad Bailey, Office of Transportation and Air Quality/Assessment and Standards Division
TO: Docket EPA

- HQ
- OAR
- 2011
- 0135 **Introduction** The purpose of this memo is to describe the approach used in EPA’s analysis of students and schools in close proximity to primary and secondary road s in the United States, which is presented in section II.B.7 of the preamble to the Notice of Proposed Rulemaking (NPRM). The data used to create Table s 1
- 4 in th is memo are provided as an attachment to this memo. **Methodology** EPA obtained public school data from th e U.S. Department of Education’s Institute of Education Sciences National Center for Education Statistics (NCES)
. 1 

### At the time this analysis was done, the most recent public school data available was for the 200 9
– 2010 school year . These are the data us ed in our analysis. For each U.S. school (K

- 12), the data include the latitude and longitude , a unique NCES assigned ID, total number of students, number of students by race, and the number of students eligible for the free and reduced school lunch progra m s . EPA obtained and used the U.S. Census Bureau’s 2010 TIGER/Line® Shapefiles for primary and secondary roads. According to the technical documentation for the 2010 Census TIGER/Line® Shapefiles, “Primary roads are generally divided, limited

- access highways within the Federal interstate highway system or under state management. These highways are distinguished by the presence of interchanges and are accessible by ramps, and may include some toll highways.” 2 

### The technical documentation defines secondary roads as “main arteries, usually in the U.S. Highway, State Highway, or County Highway system. These roads have one or more lanes of traffic in each direction, may or may not be divided, and usually have at

- grade intersections with many other roads and driveways. They often have both a local name and a route number.” 3 

### EPA imported the school data into ArcMap 10.0 as a set of geocoded points using the latitude and longitude provided in the schools dataset. EPA also imported the primary and secondary road

1 http://nces.ed.gov/ccd/bat/ 2 http://www.census.gov/geo/www/tiger/tgrshp2010/TGRSHP10SF1.pdf 3 http://www.census.gov/geo/www/tiger/tgrshp2010/TGRSHP10SF1.pdf

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shapefiles into ArcMap 10.0 and then created 200 meter buffers around th ose roads. The school point data w ere intersected with the 200 meter road buffers to determine which schools a re within 200 m eters of U.S. primary and secondary road s . 4 

### Of the 99,804 U.S. schools in the dataset, 23,978 (24%) were identified to be located within the 200 meter buffer s of U .S. primary and secondary roads. 5 

### Of the 23,978 schools within 200 meters of a primary or secondary road, 1,649 are near primary roads and 22,329 are near secondary roads , representing 1.7% and 22.4% of total schools, respectively
. This method of det ermining which schools are within 200 meters of primary or secondary road s underestimate s the total number of schools from the edge s of road s since the road shapefiles are line data
– not polygon data . The line data represents the center line of a road (i .e., the center line between both directions of traffic), whereas polygon data would represent the area the roads encompass (i.e., the edge s of a road )
. I n situations where there are six lanes of traffic in each direction, for example, approximately 40 meters of the 200 meter buffer s could be the road itself, resulting in the intersection analysis only identifying schools that are within approximately 160 meters of the edge of the road
. **Analysis of Racial Demographics** Using SAS 9.1, EPA evaluated the racial composition and Hispanic status of the 49,136,240 students at the 99,804 U.S. schools, by number and percent of total students. This data is presented in Table 1. Table 1: Number and Percent of Students by Race and Hispanic Status at a ll U. S. Schools 6

**American Indian/Alaskan**  **Native Asian/Pacific** 

**Islander Black**  **Hispanic White**  **Two or More**  **Races No Race** 

**Reported Total** 

**Number of**  **Students** 584,756 2,461,820 8,166,410 10,775,975 26,311,473 334,459 501,347 49,136,240

4 This approach does not consider the physical footprints of the schools, but represents each school as a discrete point in space. As such, the intersection of school points with roadway buffe rs represents an indicator of proximity to roadways with a degree of measurement error. Two primary sources of measurement error can be present. First, it is unknown where on school property each latitude/longitude coordinate represents (e.g., front offi ce, school center). Second, schools have area in space not represented by a point, which may lead to some underestimation of the number of schools near major roads (i.e., where one wing of a school is nearby, but the coordinates are not).” 5 182 of these 23,978 schools were identified as ‘ temporarily closed ’ and 97 were identified ‘ to be operational within two years. ’ N either of these types of schools had any student enrollment information (i.e., these 279 schools had total students of 0), so there are no students from these types of schools included in the student racial or SES analysis. 6 In the dataset used here, rac e designations refer to non
- Hispanic s tudents. Hispanics are enumerated separately.

### 3 **Percent of Total**  1.19% 5.01% 16.62% 21.93% 53.55% 0.68% 1.02% 100.00%



### EPA also evaluated the racial composition and Hispanic status of students at only the 23,978 schools within the 200 meter buffer s of U.S. primary and secondary roads. Table 2 shows the number of students, by race, at these schools, as well as the percent of students by race.

Table 2 : Number and Percent of Students by Race and Hispanic Status at U.S. Schools within 200 meters of Primary and Secondary Roads, by Road Type
**American Indian/Alaskan**  **Native Asian/Pacific** 

**Islander Black**  **Hispanic White**  **Two or More**  **Races No Race** 

**Reported Total** 

**Primary Road**  **Number**

**of Students**  6,242 56,105 175,128 244,618 313,169 9,216 7,409 811,887

**Percent of Total**  0.77% 6.91% 21.57% 30.13% 38.57% 1.14% 0.91% 100.00%

**Secondary Road**  **Number**

**of Students**  121,373 278,209 1,535,625 1,213,743 5,943,786 33,899 92,338 9,218,973

**Percent of Total**  1.32% 3.02% 16.66% 13.17% 64.47% 0.37% 1.00% 100.00%

**Primary and**  **Secondary Roads**  **Number**

**of Students**  127,615 334,314 1,710,753 1,458,361 6,256,955 43,115 99,747 10,030,860

**Percent of Total**  1.27% 3.33% 17.05% 14.54% 62.38% 0.43% 0.99% 100.00%



### The data in Tables 1 and 2 shows that minorities are overrepresented at schools located within 200 meters of primary and secondary roads, wit h the overrepresentation being lar gest among students at schools located within 200 meters of primary roads. The highlighted cells in Table 2 indicate that a race is overrepresented i n the student population for either the set of schools within the 200 meter buffer s of primary roads, secondary roads, or primary and secondary roads combined, as compared to

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the racial distribution of students attending all of the 99,804 schools in the U. S. 7 

### For example, Black students represent 21.57% of students at schools located within 200 meters of a primary road, whereas Black students represent 16.62% of students in all U.S. schools. Hispanic students represent 30.13% of students at schools locate d within 200 meters of a primary road, whereas Hispanic students represent 21.93% of students in all U.S. schools. Figures 1
- 3 presents cumulative distributions of the demographic compositions of student bodies schools near primary and secondary roads compared with all U.S. schools . Figure 1 depicts the cumulative (percentile) distribution s of the percentage of nonwhite and Hispanic students for schools near pri mary roads, secondary roads, and all schools . Consistent with the tabular data presented in Tables 1 and 2, across the entire distribution of schools, those near primary roads have higher nonwhite student fractions than other schools. Figure 1
– Cumulative Distribution of Student Nonwhite Percentages for Schools Near and Far from Major Roads

7 The highlighted race proportions in Table 2 were tested against the corresponding race’s proportion in Table 1 to determine if the difference in the race’s proportion i n the observed populations (i.e., the race distributions for the schools within 200 meters of primary, secondary, and primary and secondary roads combined) and the whole U.S. population of schools is statistically significant. Using a chi

- square goodness of fit test , the differences in the highlighted percentages in Table 2 and the corresponding percentages in Table 1 were all statistically significant (p < 0.0001).

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Figure 2 depicts the cumulative (percentile) distributions of the percentage of Hispanic students for schools near primary and secondary roads, and for all schools . Consistent with the tabular data presented in Tables 1 and 2, across the entire distribution of schools, those near primary roads have higher Hispanic student fractions than other schools. Figure 2
– Cumulative Distribution of Student Hispanic Percentages for Schools Near and Far from Major Roads 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%**% N** **o n** **w h** **i t** **e o** **r H** **i s** **p a** **n i** **c S** **t u** **d e** **n t** **s**

**Perc entile**  **of Schools** Ne ar Pr imary R oa ds Ne ar Seconda ry Ro ad s Al l Sc hool s

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**Analysis o f Free and Reduced**  **- Price Lunch Eligibility**  To evaluate the socioeconomic status of students who attend schools within 200 meters of primary and secondary roads , EPA used SAS 9.1 to evaluate the number of students who are eligible for the U.S. Department o f Agriculture’s free or reduced

- price school lunch program. Children from families with incomes at or below 130 percent of the poverty level are eligible for free meals. Those with incomes between 130 percent and 185 percent of the poverty level are eli gible for reduced

- price meals. 8

8 United States Department of Agriculture: Food and Nutrition Service, National School Lunc h Program Fact Sheet. Obtained from: http://www.fns.usda.gov/cnd/Lunch/AboutLunch/NSLPFactSheet.pdf , September , 20 10 . For the period July 1, 20 10 , through June 30, 20 11 , 130 percent of the poverty level is $2 8 , 665 for a family of four; 185 percent is $ 40 , 7 93
.

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%**% H** **i s** **p a** **n i** **c s** **t u** **d e** **n t** **s**

**Pe rcentile**  **of Schoo**  **ls** Near P rimary R oa ds Near S eco nda ry

Ro ad s Al l Sc hool s

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Table 3 shows the number and percent of students that are eligible for fr ee or reduced

- price school lunches o ut of the 49,136,240 students at all 99,804 U.S. schools, by number and percent of total students. Table 3 : Number and Percent of Students Eligible for Free or Reduced

- Price Lunch at a ll U.S. Schools

**Free Lunch Eligible**  **Reduced**  

** Price Lunch** **Eligible Total Free or** 

**Reduced**   ** Price Lunch** **Eligible Number**  **of Students**  18,684,568 3,738,839 22,423,407

**Percent of**  **Total** 38.03% 7.61% 45.64%



### EPA also evaluated the number of studen ts eligible for free or reduced

- price school lunches at only the 23,978 schools within the 200 meter buffer s of U.S. primary and secondary roads. Table 4 shows the number and percent of students, by lunch program eligibility, at these schools, by road type.

Table 4: Number and Percent of Students Eligible for Free or Reduced

- Price Lunch at U.S. Schools within 200 meters of Primary a nd Secondary Roads, by Road Type

**Free Lunch Eligible**  **Reduced**  

** Price** **Lunch Eligible**  **Total Free**

**or Reduced**  **** **Price Lunch**  **Eligible Primary**  **Road Number of** 

**Students** 323,223 55,792 379,015 **Percent of Total**  39.81% 6.87% 46.68%
**Secondary Road**  **Number of**

**Students** 3,587,928 732,779 4,320,707 **Percent of Total**  38.92% 7.95% 46.87%

### 8 **Primary and**  **Secondary Roads**  **Number of**

**Students** 3,911,151 788,571 4,699,722 **Percent of Total**  38.99% 7.86% 46.85%



### The data in Tables 3 and 4 shows that students eligible for the free and reduced

- price lunch program are overrepresented at schools located within 200 meters of primary and secondary roads. The highlighted cells in Table 4 indicate that free and/or reduced

- price lunch eligibility is overrepresented in the student population for the set s of schools within the 200 meter buffer s of primary roads, secondary roads, and primary and secondary roads combined, as compared to the free and/or reduced

- price lunch eligibility distribution of st udents attending all of the 99,804 schools in the U.S. 9 

### For example, a t schools located within 200 meters of a primary road or secondary road, 46.85% of students are eligible for either free or reduced

- price lunches, whereas nationally, 45.64% of students are eligible for either free or reduced

- price lunches. Figure 3 depicts the cumulative (percentile) distributions of the percentage of students eligible for free/reduced

- price lunches for schools near primary and secondary roads, and for all schools
. Consistent with the tabular data presented in Tables 1 and 2, schools near primary roads tend to have higher fractions of eligible students, though the association is inconsistent across the distribution. Notably, the majority of schools located near prim ary roads have student populations of which >50% are eligible for free or reduced price lunch. Figure 3
– Cumulative Distribution of Percentage of Student Eligible for Free or Reduced

- Price Lunches for Schools Near and Far from Major Roads

9 The highlighted free and/or reduced

- price lunch eligibility proportions in Table 4 were tested against the corresponding free and/or reduced

- price lunch eligibility ’s proportion in Table 3 to determine if the difference in the eligibility ’s proportion i n the observed populations (i.e., the free and/or reduced

- price lunch eligibility distributions for the schools within 200 meters of primary, secondary, and primary and secondary roads combined) and the whole U.S. population of schools is st atistically significant. Using a chi

- square goodness of fit test , the differences in the highlighted percentages in Table 4 and the corresponding percentages in Table 3 were all statistically significant (p < 0.0001).

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The data and results are presented in the attached Microsoft Excel workbook, “School s Near Roads Analysis for the Tier 3 NPRM docket .” The first worksheet, ‘All U.S. Schools,’ lists each of the 99,804 U.S. schools and its associated location and site informat ion (school name, address, county, state, latitude, longitude, NCES assigned School ID) demographic data (the num ber of students who identify as American Indian/Alaskan Native; Asian/Pacific Islander; Black; Hispanic; White, non

- Hispanic; Two or more Races ), school lunch program eligibility data , and total enrollm ent data. The second worksheet, ‘Schools in 200m Buffers,’ lists each of the 23,978 schools within 200 meters of a primary or secondary road (1,649 are near primary roads and 22,329 are near secon dary roads). The data identifies each school’s site information (school name, address, county, state, latitude, longitude, NCES assigned School ID) demographic data ( the number of students who identify as American Indian/Alaskan Native; Asian/Pacific Isla nder; Black; Hispanic; White, non

- Hispanic; Two or more Races), school lunch program eligibility data , and total enrollment data. The data also identifies the name of the road the school is within 200 meters of, whether that road is identified as a primar y or secondary road , and the U.S. Census Bureau ’s ID for the road segment
. **Summary**

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%**% S** **t u** **d e** **n t** **s E** **l i** **g i** **b l** **e f** **o r** **F r** **e e** **/ R** **e d** **u c** **e d** **P r** **i c** **e L** **u n** **c h** 

**Pe rcenti**  **le o**  **f S chool**  **s** Near P rimary R oa ds Near S eco nda ry

Ro ad s Al l Sc hool s

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On a population

- wide basis, there are millions of students attending classes in locations likely to have poor air quality resulting from the emissions of vehicles on the nearby roads.
T he analyses described above provide evidence that schools near major roads include student populations which have higher percentages of nonwhite racial minorities and of recipients of free or reduced

- price lunches. These analyses suggest that children in these demographic groups experience worse air quality, and as such, have potential for elevated risks of adverse health outcomes. Overall, this analysis indicates that nonwhite and low SES students are likely to experience significant ben efit as a result of the proposed standards.