National Environmental Streamlining Initiatives
Summary of Peer Exchange on Improving Transportation Decisionmaking
through Planning, NEPA, and Project Development Linkage
Baltimore, Maryland
May 22 - 23, 2001
Background
On May 22 and 23, 2001, the U. S. Department
of Transportation (DOT) hosted a peer exchange in Baltimore, Maryland, for
state transportation departments to share information about how they are linking
the planning and project development processes in order to improve transportation
decisionmaking. This meeting was held at the request of the Washington State
Department of Transportation (WSDOT) and organized collaboratively among WSDOT,
the Maryland State Highway Administration, and the U.S. DOT.� Seventeen people
attended, including planning and environment representatives from seven state
DOTs (California, Florida, Indiana, Maryland, North Carolina, Oregon, and
Washington); representatives from the U.S. DOT Federal Highway Administration
(FHWA) Office of NEPA Facilitation, FHWA Office of Metropolitan Planning,
FHWA Office of Statewide Planning, FWHA Eastern Resource Center, Federal Transit
Administration (FTA) Office of Planning, and the U.S. DOT Volpe Center; a
representative from the Center for Transportation and the Environment; and
one facilitator.� Click here for a list of participants. The purpose of the meeting was three-fold:
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Share information on state
practices in linking planning, NEPA, and project development.� Learn what
states are doing, what is working, and what obstacles states are facing as
they implement new processes.�
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Identify commonalties and legitimate
differences in state experiences.
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Reach conclusions and recommendations
on how states can overcome obstacles.
This paper presents a summary of findings
from the meeting, brief descriptions of the strategies implemented by the
seven states, opportunities for better linking the planning and NEPA processes,
and proposed next steps for U.S. DOT and the seven participating states.
Factors for Success
The seven state DOTs that attended this peer
exchange are pioneers in linking the planning and NEPA processes in order
to make planning and project development seamless, more connected, and more
systematic.� At this meeting participants shared detailed information about
their work with other states for the first time.� Participants found that
there are real differences between states and regions within states, and that
states are faced with unique challenges, such as differences in habitat, species,
and the amount of control exerted by local and regional governments.� However,
the participants also found that they face many common obstacles.� To overcome
these obstacles, participants shared valuable lessons learned that can be
applied to other areas of their work as they attempt to streamline the transportation
decisionmaking process.
States can use the participant-identified
lessons learned listed below to develop new approaches to transportation decisionmaking.�
Other states can consider focusing on these issues when they work to improve
the linkages between the planning and NEPA processes.� In implementing these
lessons, however, states must consider a variety of both institutional and
technical factors.
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Transportation agencies need
to understand why they have to change their planning and project development
processes and what that change will look like.� Resource agencies also need
to be convinced that they need to change the way they coordinate with transportation
agencies.�����
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Transportation agencies need
to become environmental stewards.� Linking the planning and project development
processes is intended to incorporate transportation and environment considerations
so that agencies can make better decisions.
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Agency management needs to
demonstrate commitment to improving the transportation decisionmaking process
by endorsing the new process and supporting it with an adequate allocation
of resources.�
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Relationships between agencies
are the cornerstones to improving the transportation decisionmaking process.�
Agencies must build strong relationships to instill trust, improve cooperation,
and eliminate turf wars.� Relationships need to be made at the management
level as well as the staff level due to staff turnover.�
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Education within and between
agencies is necessary.� Agencies need to understand their own and others'
priorities, roles, and responsibilities in the transportation decisionmaking
process.
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Agencies need to be involved
early in the planning and project development processes.� In addition, their
agreements must be in writing so that they are adhered to throughout the process.���
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Agencies need to develop a
data-driven process in order to create standardized systems.� Information
technology, such as Geographic Information Systems, can aid in improving decisions
by identifying critical resources.��
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Time frames need to be set
and concurrence or coordination points established in the decisionmaking
process.
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Periodic meetings need to be
held in order to facilitate relationship building and keep the process moving
forward.
State Strategies
Each of the seven participating states shared
more detail about the particular strategy they are implementing to improve
decisionmaking.� The discussions included information about the motivating
forces for developing each strategy.� In addition, each state identified the
challenges and successes they face.� For many states, it is too early to ascertain
the success of implementing each new strategy.� Each state's strategy is described
below.
California - Partnership Agreement
In February 2001, the California Resources
Agency, California Environmental Protection Agency, and California Business,
Transportation, and Housing Agency signed a partnership agreement to identify
program areas in which additional cooperation between the agencies will more
successfully integrate statewide goals of enhanced mobility with those of
environmental protection.� The purpose of the agreement is to have the participating
agencies engage in concerted, cooperative, and collaborative program relationships.�
The agreement outlines an inclusive process intended to anticipate problems,
promote open decisions, provide sensitivity to a variety of influences, and
accelerate the overall transportation planning and development processes.�
The desired outcome is a well-integrated and carefully crafted project planning
and environmental process that recognizes the authorities and involvement
of regulatory agencies, the needs of the community, and the burdens and benefits
to the environment.� The motivating forces behind this agreement are largely
political.� First, the public demands and expects government agencies to work
together in their best interest.� Second, there is a need to deliver promised
projects, including Governor Davis' Traffic Congestion Relief Program.�
Based on their coordinated efforts, the California
agencies have identified several lessons learned that can be used to improve
the decisionmaking process, including:�
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Earlier and more meaningful
resource agency and community involvement in local and regional planning decisions.
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Staff resources to other agencies.
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Meaningful consideration of
environmental and community issues in developing Regional Transportation Plans,
Metropolitan Transportation Plans, and Interregional Transportation Strategic
Plan so that fatally flawed projects are not forwarded.
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Consideration of the duplication
of authority and oversight in some environmental review processes, e.g. California
Department of Fish and Game's enforcement of the California Endangered Species
Act covers approximately the same species and purposes as the U.S. Fish and
Wildlife Service's and National Marine Fisheries Service's enforcement of
Endangered Species Act.
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Recognition of other agency
and project processes.
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Coordination between Federal
and state-level environmental laws.
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Identification of pre-mitigation
and dual-purpose project opportunities.
Florida - Environmental Transportation decisionmaking
Process
In February 2000, an Executive Summit was
held in Atlanta for Florida and Federal agencies to garner support and commitment
to create a new process for Environmental Transportation decisionmaking (ETDM).�
Florida's ETDM process will bring agency interaction into the early stages
of transportation planning.� Avoidance and minimization strategies are identified
earlier, and the cost impacts for these strategies can be built into the long-range
transportation plan (LRTP).� Interaction occurs through a multi-agency Environmental
Technical Advisory Team (ETAT) established for each of the seven Florida DOT
(FDOT) districts.� The ETAT will consist of 12 to 20 representatives from
agencies with statutory responsibility for transportation, land use, and ecosystem
planning, permitting, or consultation on projects, and will seek a proper
balance between these competing perspectives.� The ETAT will screen projects
prior to the LRTP and as projects enter FDOT's Work Program. During Project
Development, the ETAT role shifts from advisory to permit coordination.� Many
of the ETDM process details still need to be developed, including how FDOT
and MPOs will interact with Water Management Districts.���
The motivating forces behind the development
of the ETDM Process were Section 1309 of Transportation Equity Act for the
21st Century (TEA-21) and political endorsement and support from
senior-level management at FDOT and FHWA's Southern Resource Center and Florida
division office.� All agencies recognized that the process needed to be improved
in order to protect and enhance Florida's resources.� ETDM has achieved several
successes thus far, including:
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Agreement from all agencies
at the Executive Summit to commit time and money to developing the ETDM Process.
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Regularly scheduled meetings
over a 13-month period that are well documented and shared with all the participants.
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Access to a highly developed,
centralized database of digital information about the state's resources, which
is maintained at GeoPlan Center at the University of Florida.�
- Albeit successful, Florida has faced a number of challenges throughout the development
of the ETDM Process, including:
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Getting the right people to
the table - people who are knowledgeable, experienced, confident in their
ability to speak on behalf of their agency, and willing to consider new ways
of doing business.
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Finding the necessary time
and travel budgets for participating agencies.� The ETDM Process would have
not have been possible without the commitment from agency heads at the Executive
Summit.
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Effectively achieving the ETAT
rational tradeoffs required between transportation, land use, and ecosystem
planning.� The tradeoff process is still untested.
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Calculating cost/benefit ratios.�
Savings and cost avoidance measures can be discussed in concept but are difficult
to quantify.� This issue could grow in importance as the cost of implementation
becomes larger.
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Actually implementing the ETDM
process within FDOT, other agencies, and the MPOs.� Years of momentum and
the comfort associated with the status quo will have to be overcome.
Indiana - Streamlined Environmental Impact Statement
Procedures
The Indiana DOT (INDOT), in coordination
with FHWA and FTA, recently developed draft Streamlined Environmental Impact
Statement (EIS) Procedures.� The procedures will allow the documentation developed
by FHWA and FTA, in compliance with NEPA, to serve as a substantial part of
the documentation required by other permitting and funding agencies in accordance
with applicable laws and regulations.� More than 10 agencies are involved
in the process.� These procedures establish a coordinated environmental review
process with time limitations, concurrent reviews, and a dispute resolution
process.� The resulting decisionmaking process identifies and addresses regulatory
agency issues at three key milestones: purpose and need; conceptual alternatives
and alternatives retained for detailed study; and selected action and conceptual
mitigation.� Rather than separate corridor/feasibility studies being prepared
before the NEPA process, major corridor/scoping studies are initiated as Environmental
Assessments (EA).� The EA/corridor process engages the public and regulatory
agencies in developing and commenting on the purpose and need for the overall
corridor, mode choice, and preliminary and conceptual alternatives of projects
of independent utility.
INDOT has identified several challenges to
improving the decisionmaking process, including:
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The need to educate and clearly
explain the new process to the regulatory agencies as well as the public.�
This has been accomplished through a series of meetings with the public, elected
officials, and mid-level and executive level regulatory staff.
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The need to overcome internal
resistance to change.� While most involved parties feel that the existing
process is inefficient, wasteful, costly, and not inclusive of all parties
in the decisionmaking process, there does exist some internal resistance
to accept the new process.
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The need to protect against
any legal challenge to the new process.� Both INDOT and the FHWA field office
in Indiana feel that this is a legally defensible process, but anytime a new
process begins it can attract litigation.�
Maryland - Streamlined Project Planning Phase
Maryland formed an interagency team in 1999
to develop strategies for implementing the environmental streamlining provisions
of TEA-21 in its existing project planning process.� The streamlined process
was finalized in 2000 and focuses on the project planning phase of project
development.� Under the new process, the Maryland State Highway Administration
(SHA) will continue to obtain environmental and regulatory resource agency
concurrence and comments at three key project planning milestones: purpose
and need, alternatives retained for detailed study, and SHA's selected alternative
and conceptual mitigation.� Two major field and office meetings are held with
the resource agencies during the development of the purpose and need statement
and the preliminary conceptual alternatives.� Once a project reaches the alternatives
retained for detailed study step, the agencies will determine whether formal
concurrence points are still necessary.��
SHA's streamlined process includes numerous
other aspects.� First, it includes MPO coordination and designation of a MPO
as a "commenting" agency at formal concurrence points.� Second, the process
incorporates smart growth requirements.� Third, Section 106 requirements are
incorporated per the recent Advisory Council on Historic Preservation regulations.�
Fourth, references to aquatic resources include all resources (natural, socio-economic,
and cultural).� Fifth, resource avoidance, minimization, and mitigation discussions
were moved earlier in the process and are now discussed for all alternatives
studied in detail, not just the preferred alternative.� Sixth, a preliminary
Maryland Department of the Environment and Army Corps of Engineers Section
404 permit will be issued (conditioned on further avoidance and minimization
and the subsequent submission of a mitigation plan) shortly after location
approval is received from FHWA.� Lastly, a four-step conflict resolution process
was included as an appendix to the streamlining procedures.
The focus of Maryland's effort was to explicitly
incorporate various agency coordination and regulatory requirements into a
single, unified process, thereby improving the overall timeliness of project
decisions.� SHA wanted to reduce permit delays and make better and faster
decisions.� The new environmental streamlining process has achieved many successes.�
SHA has now:
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Been able to reach interagency
consensus at purpose and need, Alternatives Retained for Detailed Study, and
SHA's Selected Alternative and Conceptual Mitigation by employing the formal
concurrence process.�
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Begun to view conflict resolution
as a positive tool used for resolving disagreements, and has used the process
on several projects, particularly during alternatives development.�
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Developed better working relationships
with resource agencies and garnered more knowledge about various agency mandates
and roles in the process.�
Through this process, however, SHA has also faced some
obstacles, including:
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Staffing shortages, both internally
and within resource agencies.� SHA is learning about and using the flexibility
that exists for funding positions in other agencies.� SHA executed interagency
funding agreements with the Army Corps of Engineers and the U.S. Environmental
Protection Agency, and will soon execute one with the U.S. Fish and Wildlife
Service.�
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Balancing the need to shorten
the project planning process with the need to incorporate more resource agency
and public involvement throughout the process.����
North Carolina - Memorandum of Agreement
In 1997, North Carolina DOT's (NCDOT) leadership
changed, and the new management began supporting the concept of environmental
stewardship.� A major part of the environmental stewardship effort has been
to identify ways to partner early with resource agencies, blurring the line
between systems planning and project planning.� North Carolina will implement
four Federal pilot projects to test environmental streamlining implementation
strategies.� The implementation of a 404/401 merger process is the cornerstone
for much of NCDOT's environmental streamlining effort.� A signed memorandum
of agreement between FHWA, the Army Corps of Engineers, and NCDOT currently
outlines the process.� The agreement is under revision to make the NC Department
of Environment and Natural Resources (DENR) a formal partner.� This agreement
breaks the regulatory process into five key decision points.� Any project
taken through the merger process does not progress unless the merger signing
agencies are all in concurrence.� Once a concurrence point is passed, the
process cannot loop back to that decision except under extraordinary circumstances
(e.g., new regulations).� This process has been extremely successful and is
a basic component of most of the other strategies implemented or under consideration.�
Recently, DENR, NCDOT, and the Army Corps of Engineers jointly sponsored a
formal process improvement workshop focused on the permitting process.� Data
gathered from 45 process participant interviews may lead to the development
of one- and three-year plans for joint initiatives.
NCDOT and its partners have faced many obstacles
and learned many lessons from their coordination efforts. Below is a list
of obstacles and descriptions of how the obstacles are being overcome.�
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Lack of a common mission and
set of goals among the agencies.� NC agency senior management is working together
to improve the process.� NC agencies are defining goals at a senior management
staff retreat with a follow-up staff retreat to define working relationship.�
In addition, agencies are signing a Secretarial Memorandum of Understanding
(MOU) outlining mutual responsibilities and commitments to process improvement.�
DENR and NCDOT are also developing an MOU for the provision of wetland mitigation
through the Wetlands Restoration Program.�
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Lack of understanding of agency
roles and responsibilities within the process.� To overcome this obstacle,
DENR and NCDOT have jointly developed guidance on secondary/cumulative impacts
and are having discussions on appropriate grandfathering for NCDOT projects
in the legislative and regulatory process.�
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Imbalance in NCDOT's investment
strategy.� At this time, NCDOT has not implemented any successful strategies,
but there have been substantial efforts to educate legislators on the problems
caused by NCDOT's unbalanced investment strategy.�
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A substantial number of roads
with purpose and need statements based on economic development.� Instead,
purpose and need statements prepared by systems planners are based on systems
plan land use and deficiency analysis.� To further improve purpose and need
statements, NCDOT is developing a pre-TIP process for initiating the merger
process prior to programming for projects with the potential for high environmental
impacts.�
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New or revised environmental
regulations.� NCDOT has not implemented any successful strategies, but discussions
are underway to identify the appropriate place in the project development
process to grandfather projects from new state legislation.
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High mitigation requirements.�
This obstacle is being overcome by identifying the need and potential sources
for mitigation during systems planning.� In addition, NC agencies are developing
an MOU with the DENR Wetlands Restoration Program and permitting process improvement
recommendations to develop a mitigation plan merger process.� The process
will have concurrence points and will be coordinated with the NEPA/permitting
merger process.
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Lack of staff resources.� To
combat this problem, NCDOT is funding 23 positions at Federal and state agencies.�
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Poor communication to local
and state officials.� NCDOT is repeating simple and direct key messages in
every possible forum.� In addition, there have been senior management joint
DENR/NCDOT presentations on partnership and the obstacles to improve communication.�
Oregon - Vision for Joint Environmental and Transportation
System Stewardship
Oregon DOT's (ODOT) approach to linking planning
and NEPA is to address the NEPA process during the planning stage for large
projects that have a significant modal or location aspect to be determined.�
ODOT then conducts further environmental documentation and analysis when projects
become funded and are developed for construction.� Concurrent with addressing
NEPA earlier in the transportation planning process, ODOT has undertaken a
significant partnering initiative with regulating agencies.� In January 2001,
10 Oregon and Federal agencies signed the Vision for Joint Environmental
and Transportation System Stewardship in Oregon Collaborative Environmental
Agreement.� The goal of this group is to identify and implement collaborative
opportunities that help each participating agency meet their mission of environmental
stewardship, while providing for a safe and efficient transportation system.
Thus far, one project has been completed
and two are currently going through the process.� The first location project
raised many questions regarding the adequacy of the level of detail of the
data.� The other two projects have not yet hit critical points where the level
of detail has been tested.� ODOT acknowledges that a second NEPA document
will likely be required for these projects.� However, ODOT expects to derive
cost savings from implementing this new approach because the first NEPA study
will be conducted without detailed engineering design (primarily relying on
available resource data) and without detailed mitigation planning.� The cost
of these documents is less, and the time is shorter to produce them, than
a NEPA document that tries to do them all at once.� For the second NEPA document
a high level of detail can be developed on a smaller number or even only one
alternative, making the second document cheaper to develop.����
Washington - Moving NEPA to the Corridor Planning Stage
Washington DOT's (WSDOT) approach to reinventing
NEPA is to determine mode and location for the NEPA process during the Corridor
Planning stage.� An interdisciplinary Project Management Team then manages
the corridor planning project.� WSDOT is establishing a steering committee
to guide the EIS/Alternatives Analysis.� The Steering Committee is made up
of resource agencies, local officials, and other stakeholders who share perspectives
and work together to develop, analyze, and select alternatives.� There will
be concurrence points on purpose and need, screening criteria, alternatives,
and the preferred alternative.� The resulting document will have less detail
than a traditional EIS.� A corridor level Record of Decision (ROD) is the
end of the NEPA process.� Additional environmental analysis and detail are
developed after the ROD and during the design phase for meeting permit requirements
and commitments.� The primary motivating force for the process change was
to avoid the duplication that occurs by doing a planning study, involving
the local community, deciding on an alternative, and then duplicating the
work under NEPA once project funding has been secured.� Duplication caused
previously dismissed alternatives to be resurrected during the NEPA process,
causing confusion and anger in the communities involved.
WSDOT's approach has so far improved stakeholder
involvement and reduced duplication.� For example, resource agency staff can
provide their perspective, listen to other people's perspectives, and see
the compromises involved in the decisionmaking process.� Additionally, local
officials, agencies, and other stakeholders who traditionally have been involved
in corridor planning get to hear and consider resource agency perspectives
early in decisionmaking.
WSDOT has faced a number of obstacles in
implementing the new process, including:
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Lack of resource agencies staff
to actively participate in the pilot projects.� WSDOT has funded positions
in the resource agencies, but policy-level staffing needed to inform the decisionmaking
process is still scarce.
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Demands by EIS reviewers for
design-level detail.� The intent of the new process is to tier the decisionmaking
process by focusing first on the mode and location decision, leaving many
design details until the later design process.� However, some resource agency
reviewers feel that it is not possible to make the location decision based
on generalized data with minimal field data collection and the potential for
land use change.
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Indecision by WSDOT and FHWA
on whether post-ROD environmental work will need to be completed.� WSDOT's
process relies upon the FHWA NEPA process being completed upon corridor ROD
approval.� Further environmental analysis work will still take place during
the design process.� FHWA believes that follow-up EISs or EAs would be required
for each project.� WSDOT is currently evaluating options for streamlining
this process.
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Higher than expected completion
times and costs on smaller-scale pilot projects.� The complex I-405 Corridor
Program pilot project, however, has proceeded on an accelerated schedule.�
The rise in cost and time on smaller-scale projects is due to getting resource
agency participants up to speed, resolving disputes on purpose and need statements,
and analyzing many alternatives.
Opportunities for
Improvement
The following are ways identified by state
DOT participants in which FHWA and states need to work together to improve
the linkage of planning and NEPA.
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Improve the Planning Process.�
States must have well-developed planning process for the rest of the process
to work.� Systems planning will identify the deficiencies in the system and
set priorities.� Planning should incorporate the intent of policy, be robust
enough (i.e., data-driven) to encompass consideration of broad impacts, and
result in durable direction.� The planning process should have "standing"
in the NEPA process; decisions made during the planning process should be
considered valid and used to inform NEPA decisionmaking when they derive
from a public process that fully considers purpose and need, alternatives,
and public and environmental concerns. Effective planning includes getting
agencies involved earlier in the planning process, having the right information
and people in the appropriate decision points, making the right decisions
in planning so that we do not have to revisit them, and documenting in the
planning process why it is not reasonable to carry an alternative forward.
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Use Systems Planning More Effectively.� What is the fit between large-scale, long-term planning
and project development and small-scale, short-term planning and project development?�
Systems planning can be the vision plan and does not have to be time or fiscally
bound.� Systems planning sets the context of conceptual alternatives at the
project and systems levels.
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Address When to Issue a Notice of Intent.� When do you issue the Notice of Intent (NOI) so that
you scope issues and do not have to revisit ideas that are raised later in
the process?� If you start with an Environmental Assessment (which results
in a purpose and need statement and a set of alternatives) and then shift
to an EIS and issue an NOI, how do you avoid re-opening dismissed alternatives?�
Transportation practitioners need to have a discussion of what is at risk
if you do not issue NOI at any given point.� If you foresee Federal action
down the line, what are the risks of starting or not starting the process?�
What is the payoff or disincentive to communities for building in environmental
issues in early stages?
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Provide Guidance on Purpose and Need Statement.� What is a legitimate purpose?� What level of specificity
is needed for the purpose and need statement?� Who should be involved?
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Provide Guidance on Determining Impacts and Range of
Alternatives.� What are the sequence
of identifying impacts and the range of alternatives?� What level of detail
is needed for impacts?� How do you address secondary impacts?
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Address Needs of Corridor Planning Transportation.�
Agencies need to set broad context decisions.� It is necessary
to have approval on a package of solutions to address a corridor problem so
that the agency can segment the projects.� In the past, transportation agencies
have been criticized for segmentation.� In addition, corridor planning often
requires agencies to look beyond a 20-year period.� It is difficult to look
beyond a 20-year period when your plan must be fiscally constrained.
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Improve Programmatic Efforts.� How do we ascertain environmental agency buy-in when
they have participated in programmatic efforts, such as habitat preservation
planning, in order to apply the results to project development decisions?�
Are there incentives transportation agencies can use to get environmental
agency buy-in, such as helping with workloads or environmental stewardship
benefits?��
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Provide Guidance on Resource Management.� How can environmental agencies better use reimbursed
positions?� Transportation agencies need to set priorities for reimbursed
positions.�
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Identify Roles and Responsibilities of Participating
Agencies.� It is critical to get
commitments from key agencies at the senior management level.� How can state
DOTs motivate resource agencies?� To what extent can transportation agencies
set expectations for resource agencies that give real direction, identify
interests, and specify objectives?� All agencies need to improve relationships
and build trust so that technical results generated by transportation agencies
are accepted as valid and not re-tested.
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Discuss Role and Strength of MPOs.� The role and strength of MPOs varies from state to state.�
However, no MPOs are viewed as being very strong in influencing land use decisions
that drive transportation demand and in considering the environmental implications
of their transportation plans, and their role is uncertain.� Does the MPO
structure support systems planning and project development?� Experience will
vary from state to state.� The goal is to have the MPOs work in partnership
with state DOTs in planning, understand their role and responsibility for
delivering projects, take a regional view, and be responsive to environmental
issues.
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Need Technical Assistance from FHWA.� States would like assistance from FHWA field offices
to link the planning and NEPA processes.� However, barriers exist between
FHWA planning and project development staff and processes.� FHWA should consider
professional development training programs for their staff.
Proposed Next Steps
At the conclusion of the two-day meeting,
the group proposed a series of next steps to further educate each other and
the U.S. DOT of ongoing efforts to improve the transportation decisionmaking
process.� First, the group would like FHWA to prepare a distribution package
describing the approaches states are taking to improve the decisionmaking
process.� The package should be distributed to other states via FHWA's website.�
FHWA should then monitor the use of the approaches.� The group would like
to continue discussion of the issues discussed during the Peer Exchange and
reconvene through conference calls to discuss the issues.� Members of the
group have offered to adopt issues to address and to develop solutions to
which the group should respond.� In general, the group would like to broaden
the transportation decisionmaking process discussion to other state and Federal
agency staff.
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