FTA does not require a stand-alone EJ analysis for the S/TIP. Chapter IV of the Circular describes how environmental justice considerations at the planning level, which extend to the S/TIP, are addressed primarily through data collection and comparative analysis, and public engagement.

As projects are prioritized from the plan into the S/TIP, and then selected from the S/TIP for implementation, it is assumed that a S/TIP would be equally reflective of EJ considerations as the plan from which it is derived. FTA expects that projects that primarily benefit an EJ community would be equally likely to move forward into implementation as any other project.