Is there a certain percentage of minority or low-income populations that triggers an EJ analysis?
Some states use a threshold of a certain percent to identify EJ populations. We do not use a threshold for several reasons. • Our populations tend to be very diverse. We seldom have neighborhoods heavily populated by one minority so usually do not have “EJ communities”. • The use of a threshold eliminates further analysis and could result in an unknown disproportionate adverse impact. • We feel our more thorough methodology is consistent with the intent of Executive Order 12898, Title VI and FHWA’s guidance. We worked cooperatively with our local FHWA division to develop our guidance and to make sure it is consistent with FHWA policy. In addition, our local FHWA division developed a guide –Environmental Justice: What You Should Know. FHWA intended the guide to assist its Division staff (working with project teams) in developing an appropriate approach for Title VI Environmental Justice analysis and an effective public involvement strategy. The guide’s material also provides a framewor
