Can project-level EJ analysis be qualitative in nature?
For projects that FTA determines require an EJ analysis (i.e., those for which impacts rise above a certain threshold such that there is a potential for EJ impacts), a qualitative assessment alone is not sufficient to demonstrate that a proposed investment (strategy) would not have a disproportionately high and adverse impact. Any qualitative assessment should be accompanied by complementary quantitative analysis. No single analysis activity tells the entire story. FTA encourages grantees to use a variety of tools to develop a more realistic understanding of the benefits and burdens of the transportation system and any disproportionately high and adverse impacts on EJ populations. Data collection to get to know one’s community, to articulate needs and priorities, and to consider possible impacts should be corroborated through the public involvement process. Analytical tools are an important component for creating a baseline to work from, to inform decision-making, and to monitor progress over time.