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I.2: Determining if your project has disproportionate adverse effects

For most FEMA hazard mitigation projects, adverse effects to nearby populations are generally temporary, limited to annoyances associated with construction activities. In addition, most hazard mitigation projects also reduce potential hazardous conditions, resulting in long-term beneficial effects to nearby populations. However, especially if there are low-income or minority populations nearby, you should consider the full range of potential adverse effects resulting from your project.

To trigger Executive Order 12898, the effects of the project must be both adverse, and effect a low-income or minority population more so than it would the general public (disproportionate). Any adverse effects that appreciably put a minority or low-income population at an increased health risk, or appreciably affect their physical or economic well being, will trigger Executive Order 12898. Here are some examples of projects that could result in disproportionate adverse effects to minority:

Consider the construction of a retention pond on land that is the only recreational playing field and community gathering place in a Hispanic neighborhood. The project involves totally replacing this community area with the retention pond. In this instance, the project will result in both short-term adverse impacts to the Hispanic community (effects of nearby construction), and long-term adverse impacts (effects associated with loss of community area). In this case, project alternatives, increased public involvement, or mitigation may be necessary to minimize impacts to the social community.

Consider the acquisition and demolition of 22 upscale houses in a small, isolated, low-income, rural town comprised of 100 residences. Due to surrounding land use and property ownership, most of the residents have chosen to relocate to the next closest town 15 miles away. As a result, the tax-paying population is expected to decrease by 20 percent, placing a greater financial burden on the remaining residents to support municipal revenues. In this case, public involvement, mitigation, or the development of alternatives may be helpful in minimizing the extra burden to the remaining low-income population.

The applicant should not immediately discount a proposed project if there are potential adverse impacts to low income or minority populations, especially if they are short term. Often the long term benefits provided by the project outweigh any short term adverse impacts during construction. For example, a flood damage reduction project may have significant short term adverse impacts to the project area due to increased noise, dust, traffic delays, and general inconvenience. In the long-term however, the community could benefit as a result of the project by alleviating the financial and emotional burden of repetitive losses due to flooding. Some communities have elected to highlight the fact that the primary beneficiaries of a proposed project would be low income or minority residents.

Last Updated: 
07/24/2014 - 16:00
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