Must there be a neighborhood or community of minority, or low-income groups in order for there to be a Title VI and Environmental Justice effect?
No. The Executive Order 12898 on Environmental Justice and the DOT Order (5610.2) on Environmental Justice refer exclusively to “populations,” while the White House distribution memo refers to both “communities” and “populations.” The DOT Order defines each “population” as: (1) any readily identifiable group of minority persons or low-income persons who live in geographic proximity; or (2) geographically dispersed persons, such as migrant workers or Native Americans. Therefore, depending on the context and circumstances, a proposed action could cause a disproportionately high and adverse effect on a population even in cases where there are no clearly delineated neighborhoods or communities. Neighborhood and community boundaries and impacts, however, should be considered in planning, programming, and project development activities, whether there are minority or low-income populations involved or not. Most importantly, the public should always be involved in defining “neighborhood” and “
