- Developing NEPA-Ready Purpose and Need Statements
Transportation corridor studies typically contain a general statement of a future vision for the corridor that is focused on transportation goals. This vision statement may be able to be re-used during NEPA analysis as the project purpose and need statement if it contains certain elements, including consideration of specific goals for the corridor, multiple objectives (beyond transportation); vetting by agencies and the public; and a more specifically defined corridor geography. The figure below illustrates the differences between a typical corridor study vision and goals and NEPA purpose and needs statement. If the study direction changes significantly between the development of the corridor vision and the inception of NEPA analysis, it may become necessary to develop a new purpose and need statement.
Typical Approach to Corridor Study Vision and Goals NEPA Document Purpose and Need
- General goals
- Based on limited data
- May not be vetted
- General geography
- Specific goals
- Multiple objectives
- Based on more extensive analysis
- Vetted by agencies and the public
- Specific geography
FHWA has suggested a list of considerations in a Purpose and Need Statement in Guidance for Preparing and Processing Environmental and Section 4(f) Documents. The list is not all-inclusive and is only meant as a guide.
- Project Status;
- System Linkage;
- Transportation Demand;
- Social Demands or Economic Development;
- Modal Interrelationships;
- Safety; and
- Roadway Deficiencies.
Caltrans assembled the Purpose and Need Quality Team to improve the process of preparing well-defined purpose and need statements for transportation projects. This team created a purpose and need website with guidance and tools on purpose and need statements to help planners, designers, and managers prepare quality purpose and need statements that are appropriate to each stage of project planning and delivery.
The Idaho Corridor Planning Guidebook (2006) outlines the steps needed to produce a written statement of purpose and need for corridor projects. This statement should be an “umbrella” statement for the corridor based on the identification of needs and deficiencies. The statement should reflect the principles of context sensitivity by encouraging the consideration of land use, transportation, environmental, and infrastructure needs in an integrated manner.
- Agency Coordination
Early coordination with partner agencies, especially resource agencies, is a key to linking planning and NEPA. Allowing resource agencies to have early input into the development of corridor strategies creates a “scoping opportunity” to identify agency concerns and major resource issues that could result in fatal flaws in environmental impact analysis.
Resource agencies may not be able to make decisions or sign off on products during corridor planning as the level of detailed analysis may not be sufficient. However, their input can help reduce the likelihood of unforeseen resource issues delaying project development, and can result in more environmentally sensitive projects.
Suggestions for implementing this coordination include:
- Define the study area. The geographic boundaries of the study area will affect which resource agencies need to be involved.
- Identify appropriate agencies for corridor context. The appropriate agencies should be determined based on the context and the likely resource issues, but typically include Federal, Tribal, state, and local environmental, regulatory, and resource agencies (such as those responsible for land use management, natural resources, environmental protection, conservation, and historic preservation).
- Document input. Collect input from agencies regarding possible resource issues affecting the study area and possible permits that may be required. Consider whether it is appropriate to develop early ideas for mitigations. Document all input received.
Through the Community and Environmental Transportation Acceptability Process (CETAP), the Riverside County Transportation Commission (RCTC) identified four corridors for highway and transit improvements and set up a partnership to allow a close working relationship with state and Federal resource agencies. This partnership enabled the agencies to work together to narrow the list of possible corridor alternatives. Procedural changes were encouraged during the transportation planning process for faster review of materials. The agency developed a Multispecies Habitat Conservation Plan to help identify and screen resource issues in the affected corridors.
SR 79 Realignment Project. At the U.S. Fish and Wildlife Service (USFWS), the 1994 NEPA/404 MOU provided a venue for regulatory agencies along with representatives from the local transportation commissions and municipalities to coordinate early in the project planning process. The NEPA 404/MOU is an agreement between Caltrans and several Federal agencies designed to foster agreement on NEPA review among the signatory agencies. Through the application of this process in the SR 79 Realignment Project, an environmentally harmful project alternative alignment was identified early and removed from consideration. A key factor in allowing the identification of resource issues was the availability of clear maps showing how project alternatives overlay with sensitive resources.
Caltrans Preliminary Environmental Analysis Reporting Process. The Caltrans Preliminary Environmental Analysis Report (PEAR) process allows project sponsors to provides the initial environmental evaluation of a project and alternatives and is done systematically to get resource and environmental regulatory agencies involved with the process. A PEAR documents the issues likely to arise during the NEPA or CEQA stage; but it is not the appropriate vehicle for conducting and reporting detailed environmental analyses.
Central Orange County Corridor Major Investment Study. The Central Orange County Major Investment Study includes a Technical Working Group with representatives from and other stakeholder agencies such as the Federal Highway Administration (FHWA), the Army Corps of Engineers (ACOE), the California Department of Transportation (Caltrans), the Orange County Flood Control District and the Southern California Association of Governments (SCAG). These agencies have not been able to provide decisions or sign-off during the planning phase, but are helping to identify major resource issues / fatal flaws in selecting corridor strategies.
The Sacramento Area Council of Governments (SACOG) provides an example at the regional level in California of early coordination with agencies in linking planning and NEPA. SACOG engages resource agencies to identify sensitive environmental areas during the development of the regional transportation plan.
The Florida Department of Transportation (FDOT) Efficient Transportation Decision Making (ETDM) effort involved development of a process for early and continuous resource agency input into FDOT environmental review, decision-making, and permitting process to make project delivery more efficient and less costly. The Agency Agreements page displays a list of Master Agreements and Funding Agreements, which have been executed by the FDOT and state and federal agencies participating in the ETDM Process.
The Oregon Department of Transportation (ODOT)’s Collaborative Environmental and Transportation Agreement for Streamlining (CETAS),established a formal working committee with representatives from ODOT and 10 Federal and state transportation, natural resource, cultural resource, and land use planning agencies. The goal of the CETAS group is to identify and implement collaborative opportunities to help each participating agency realize its mission through sound environmental stewardship, while providing for a safe and efficient transportation system. CETAS focuses on communication, participation, and early involvement in Environmental Assessments (EA) and Environmental Impact Statements (EIS) for ODOT. As a result of CETAS, ODOT has added resource agency data, such as land use, to its existing transportation system geospatial data which helps ODOT avoid and minimize environmental impacts and delay during project planning and design.
The Parker Road Corridor Study is a pilot project in Denver, Colorado in which CDOT worked closely with resource agencies to identify potential environmental impacts from the Parker Road corridor. This study demonstrated the value of using a team approach to corridor planning, consisting of meeting face-to-face with resource agencies and developing a strong working relationship. The open dialogue led to management-level support by agencies and an eventual signing of a planning and environmental linkages (PEL) partnering agreement. The partnering agreement is a statewide agreement of 15 signatory agencies committed to the principles of PEL.
The Regional Outer Loop Corridor Feasibility Study is an evaluation of an outer loop network of transportation routes around the Dallas-Fort Worth region. The North Central Texas Council of Governments (NCTCOG) led the stakeholder outreach and engaged resource agency partners through the Transportation Resource Agency Consultation Environmental Streamlining (TRACES) initiative, a regional effort to improve communication and consultation with environmental resource agencies to the transportation planning process. NCTCOG also collaborated with resource agencies for their expertise and technical tools.
The Montana Department of Transportation (MDT) engaged with resource agencies in the Libby North Corridor Study to discuss possible improvement options. These discussions were documented and recommendations noted. By working with its partners, MDT identified improvements that met public safety and environmental goals. MDT obtained information from the public and resource agencies prior to initiating formal environmental review.
- Public Involvement
By engaging the public in developing a vision for the corridor, project sponsors can help create a sense of ownership among members of the public which may reduce public opposition during NEPA review. Documentation of public involvement can be included in the NEPA record.
Early public outreach may not be feasible for all corridor studies given the resource investment required. However, early outreach may ultimately prove cost effective if it helps avoid opposition, delay, and the need for additional analysis later in the project.
In the I 710 Freeway Major Corridor Study, the first round of public involvement was insufficient and opposition to the project was significant. This required LA Metro to develop a more inclusive public participation process, with a special emphasis on local residents and businesses, designed to give local residents ownership over the outcome. The principle notion behind this community-based approach is that communities experiencing the I 710-related problems on a day-to-day, first-hand basis are best suited to generate ideas and recommendations for solutions. The community engagement process also established a tiered community participation structure. The Tier 1 Community Advisory Committee (CAC) structure provided forums for locally affected communities to voice concerns regarding issues affecting the I 710 and suggest opportunities for improvement to the freeway while the Tier 2 Corridor level Advisory Committee is a corridor-wide committee that includes the chairpersons of all the Tier I CACs, as well as appointees from the environmental, academic, labor, and business communities.
A comprehensive public participation process was conducted and documented for the South Orange County Major Investment Study, completed in October 2008. This process was applied in all phases of the study, including development of the Purpose and Needs Statement, identifying initial improvement alternatives, and developing the Locally Preferred Strategy. OCTA also solicited feedback on their outreach efforts and sends updates to those who sign up the study mailing list.
The current Central Orange County Corridor Major Investment Study includes a Stakeholders Working Group with representatives from residential, educational, business, entertainment, and health care communities throughout the study area. Additionally, the Speakers Bureau program at OCTA provides free presentations to local civic, business, and professional organizations with the goal of educating Orange County residents on transportation initiatives and project planning.
During the Community and Environmental Transportation Acceptability Process (CETAP), the Riverside County Transportation Authority held over 20 public information meetings over a four-year period and documented these meetings for use in the project development phases of later studies.
The Idaho Corridor Planning Guidebook (2006) includes public participation guidelines for Corridor Planning (see Appendix A). The U.S. 20 Ashton to Montana State Line Corridor Plan3 by the Idaho Transportation Department included extensive public involvement for the analysis of various improvements.
Appendix C of the Montana Department of Transportation (MDT)’s Corridor Study Process to link planning studies and NEPA/Montana Environmental Policy Act (MEPA) reviews provides guidance for documenting public involvement.
Documentation of corridor study products and decisions can help reduce the level of effort required during environmental analysis. Documentation of stakeholder and public outreach and decisions made during the corridor process may be included in the NEPA Administrative Record.
In some cases, data analysis developed during the corridor stage planning stage can be documented and reused during NEPA analysis. However, this may not always be feasible given that corridor studies may not have the carefully defined geographic boundaries and the detailed data analysis required for NEPA review. Time gaps between the completion of the corridor study and the beginning of NEPA analysis also may create a challenge.
The Parker Road Corridor Study in Denver, Colorado emphasized documenting transportation planning and environmental review linkages, including a matrix of resource agency comments and concerns CDOT documented planning-level analysis it could use to inform subsequent NEPA analysis in a questionnaire. The questionnaire was included in the final study report so planning decisions might serve as a starting point for staff entering future NEPA studies.
The Regional Outer Loop Corridor Feasibility Study is an evaluation of an outer loop network of transportation routes around the Dallas-Fort Worth region. The North Central Texas Council of Governments (NCTCOG) is documenting its outreach and planning decisions, including the study’s guiding principles, objectives, and performance measures. The agency created a database that tracks public comments and response. NCTCOG also is compiling a comprehensive history of alternatives development, analysis, and recommendations so planning decisions may be relied upon in subsequent NEPA studies.
What is Linking Planning and NEPA?
Linking planning and NEPA involves including environmental considerations in transportation planning and carrying decisions and products made during the planning process into the NEPA process.1
This linkage can lead to a seamless decision-making process that minimizes duplication of effort, promotes environmental stewardship, and reduces delays in project implementation by promoting early coordination of planning and environmental staff. Linking planning and NEPA also can avoid some of the problems associated with traditional approaches to environmental analysis in the project planning stage.
This website provides resources and best practices for project sponsors in the SCAG region who are seeking to better link planning and NEPA in major transportation corridor studies and area plans.
Best practices highlighted below come from a variety of sources, including the FHWA Environmental Review Toolkit, FHWA sponsored peer exchange workshop,2 and an April 2010 SCAG workshop on the update of SCAG’s procedures for Regionally Significant Transportation Investment Studies to better link planning and NEPA. Additional resources are listed at the end of this section.
On-Line Resources for Linking Planning and NEPA
The FHWA Environmental Review Toolkit website is a comprehensive source for best practices in linking planning and environmental analysis. The Planning and Environment Linkages (PEL) section contains a catalog of case studies on effective practices for Long-Range Planning, Corridor Planning, and Linking Planning and NEPA.
The Colorado Department of Transportation has developed an interactive Linking Planning and NEPA Training website. This on-line training provides useful guidance to integrate NEPA information into statewide and regional transportation planning processes. The training also takes the participant step by step through the contents of a potential corridor or area plan to illustrate and describe how information typically related to a NEPA process can be effectively incorporated into the planning process.
The Idaho Corridor Planning and NEPA Integration Guide (2004) describes five different approaches to integrating planning and NEPA – ranging from a fully integrated corridor plan, where NEPA is part of the work effort, to a precorridor planning/NEPA approach for projects that have not been designated as part of a corridor plan.
NEPA Process Wheel
2 FHWA Peer Exchange on Using Corridor Planning to Inform NEPA Summary Report. December 2009.
3 FHWA Peer Exchange on Using Corridor Planning to Inform NEPA Summary Report. December 2009.