Should discussions about populations, such as the elderly, children, or the disabled be included when addressing Environmental Justice and Title VI?
A. Yes. Within the framework of Executive Order 12898 on Environmental Justice, the USDOT Order 5610.2 addresses only minority populations and low-income populations, and does not provide for separate consideration of elderly, children, disabled, and other populations. However, concentrations of the elderly, children, disabled, and other populations protected by Title VI and related nondiscrimination statutes in a specific area, or any low-income group ought to be discussed. Documentation should support group designation as low-income or minority. For community impact assessment, concentrations of the elderly, children, the disabled, or similar population groups, e.g., female head of household, possibly have experienced exposure to adverse impacts. Segments of the community, including minority and low-income populations, or an entire community may be impacted. They should be routinely investigated, analyzed, mitigated, and considered during decision making, similar to investigations of
