The Circular does not eliminate the use of “thresholds” for determining the presence of an EJ population. The Circular cautions grantees not to be too reliant on thresholds to serve as a “bright line” for identifying impacted populations. A very small minority or low-income population (statistically “insignificant”) in the project, study or planning area does not eliminate the possibility of a disproportionately high and adverse effect on these populations. For instance, you could have a project with a geographic unit of 20% EJ population, which may not trigger further analysis compared to a 35% regional EJ population. Disregarding that geographic unit could be short sighted because it is possible there could be a disproportionate impact on the 20% EJ population for a given factor. If you were strictly enforcing a 50% EJ population threshold, this area would have been missed. EJ determinations are ultimately based on effects, not on population size; therefore, it is important to consider the comparative impact of an action among different population groups. Furthermore, meaningful identification and public involvement of EJ populations is the core principle of an effective EJ analysis.