Is EJ required if the project is locally funded?
For locally funded projects which do not require a NEPA analysis, a project-level EJ analysis is not performed. However, It is imperative that any recipient of FTA funding consult FTA Circular 4702.1B to ensure that the undertaken project complies with the necessary Title VI guidance, as the project may trigger specific Title VI requirements. In general, FTA encourages an inclusive and thorough planning and project development process to yield the best outcomes for all interested and affected parties. FTA urges caution in electing to implement projects outside of the broader transportation planning process for this reason and because failure to include a project in the transportation planning process precludes it from utilizing future federal funding.