Are there recommended practices for capturing accurate data on transient EJ populations?
FTA’s EJ circular defines low-income population as “any readily identifiable group of low-income persons who live in geographic proximity, and, if circumstances warrant, geographically dispersed or transient persons who will be similarly affected by a proposed DOT program, policy, or activity.” Environmental Justice considerations apply to transient populations (homeless, migrant workers legally working in the U.S., etc.), or dispersed populations (Native Americans). The transitory nature of a transient population makes it more difficult to collect and access reliable data about their presence and movement. In order to consider transient populations, who may also have limited English proficiency, be sure to consult a variety of resources such as planning offices, NGO service providers like churches, homeless shelters, medical clinics, and food banks, as well as local job centers and school districts. HUD also maintains a Homelessness Data Exchange.