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Must there be a neighborhood or community of minority, or low-income groups in order for a Title VI and Environmental Justice effect to exist?

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Must there be a neighborhood or community of minority, or low-income groups in order for a Title VI and Environmental Justice effect to exist?

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A. No. The Executive Order 12898 on Environmental Justice and the USDOT Order 5610.2 on Environmental Justice refer exclusively to populations, while the White House distribution memo refers to both communities and populations. The USDOT Order defines a population as: • any readily identifiable group of minority or low-income persons who live in geographic proximity; or • geographically dispersed persons, such as migrant workers or American Indians. Therefore, depending on the context and circumstances, a proposed action could cause a disproportionately high and adverse effect on a population even in cases that lack clearly delineated neighborhoods or communities. Neighborhood and community boundaries and impacts, however, should be considered in planning, programming, and project development activities, whether or not there are minority or low-income populations involved. Most importantly, the public should always be involved in defining neighborhood and community through the public-i

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