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Environmental Review Toolkit

Planning and Environment Linkages

PEL in Practice: Examples from Discussions with States

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PEL in Practice: Examples from Discussions with States

This is a compendium of interviews with certain state departments of transportation (DOTs) regarding their Planning and Environment Linkages (PEL) implementation. The DOTs provided valuable insights and lessons learned that informed the development of the Federal Highway Administration’s (FHWA’s) PEL Guidebook. These summaries are not comprehensive descriptions of the state DOT PEL efforts, but rather provide highlights and key takeaways from FHWA’s discussions with these states.

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Arkansas Department of Transportation

Interstate 30 PEL Study

The Arkansas Department of Transportation (ArDOT) employed Planning and Environment Linkages (PEL) approaches to study improvements to I-30, an approximately 6.7 miles through portions of Little Rock and North Little Rock, Arkansas, that had been identified in the Metropolitan Planning Organization’s (MPO’s) Long Range Plan for many years. The I-30 project was part of a larger package of projects under “Connecting Arkansas,” a 2012 sales tax to fund 36 identified projects. The I-30 Corridor project was the first design-build project and the first PEL study in the state. The I-30 Corridor was selected for a PEL study in part because the corridor area had issues with traffic congestion, roadway safety, structural and functional roadway deficiencies, navigational safety, and structural and functional bridge deficiencies, and required consideration of numerous alternatives including heavy rail, bridge replacement, elevated lanes, high-speed rail, and High Occupancy Vehicle (HOV) lanes.

ArDOT recognized the PEL process as a method to identify and address potential issues early in the project planning process that could impact project delivery and complicate the design-build process. ArDOT selected the I-30 corridor for a PEL study to accelerate the project delivery process, increase stakeholder involvement, and allow for more comprehensive consideration of the environment and a full range of project alternatives. The I-30 PEL study employed a screening process to narrow the range of alternatives, as well as collecting public and stakeholder input through public meetings and a Stakeholder Advisory Group (SAG).

Under most circumstances, ArDOT uses a traditional planning process in which the planning office conducts the initial study with assistance and subsequent review by the environmental office. However, in the case of the I-30 PEL study, ArDOT’s environmental office was more involved earlier in the process of identifying alternatives, allowing for more confidence in developing improvements and recommendations. ArDOT used the PEL process to lay the groundwork for the identification of the project’s purpose and need, reasonable alternatives, and public feedback before initiation of a review under the National Environmental Policy Act (NEPA). ArDOT engaged in extensive community engagement, asking for feedback on the corridor. This was a critical and ultimately effective process, given the broad range of possible alternatives for the corridor travelling through a central business district.

ArDOT also used the I-30 PEL study to engage resource and regulatory agencies early in the planning process. Stakeholders and agencies, including the U.S. Army Corps of Engineers (USACE), had been involved early in project planning and identification of project purpose and need. A PEL working group met four times during the process, providing feedback before the NEPA review began. The PEL approach was helpful because it kept resource agencies engaged throughout this process. Having an established timeline for deliverables throughout the PEL process helped keep agencies engaged, to a degree that is not always possible for longer-term schedules. ArDOT has since borrowed this engagement process for other projects.

The PEL study was completed in May, 2015, and the FHWA Arkansas Division Office signed the final NEPA document in February 2019. Concurrent with the NEPA review process, ArDOT issued a request for firms interested in completing the design-build project, and selected a design-builder in January 2019. Using a PEL study in combination with design-build methods allowed ArDOT more opportunities for innovation, providing confidence that the project could be more efficiently built within project footprint. Feedback from proposers indicates that, because the PEL process resulted in the development and dissemination of some project information prior to the NEPA review, they were better able to understand the project earlier in the project development process.

Key Takeaways

  • ArDOT conducted a PEL study for the I-30 corridor to facilitate the delivery of the project through a design-build contract by using PEL as a tool to identify and address early in the planning process issues that could impact project delivery.
  • The PEL process was an effective tool for keeping resource agencies and the public engaged early and consistently.
  • Using a PEL study in combination with design-build methods allowed ArDOT more opportunities for innovation, providing confidence that the project could be more efficiently built within the project footprint.

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Arizona Department of Transportation

Flexibility in Choosing a PEL Approach

The Arizona Department of Transportation (ADOT) determines whether to use PEL, a Tier 1 NEPA study, or a Tier 2 NEPA study on a case-by-case basis and has successfully taken advantage of the flexibility to determine which aspects of the PEL process to apply to its projects. ADOT utilizes aspects of PEL in its planning processes, specifically around alternatives analysis. Generally, ADOT uses PEL when it is looking to narrow a range of alternatives, or if funding for a NEPA review has not yet been secured. In 2011, ADOT developed a PEL checklist and questionnaire, which was informed by the practices in other states and mirrors FHWA’s PEL Questionnaire. ADOT is also in the process of developing PEL guidance for project managers. ADOT has completed several successful PEL studies, but has had to overcome challenges, including staff changes that can lead to the loss of institutional knowledge and can limit staff awareness of their approach.

Based on experience, ADOT does not use PEL in every circumstance. For example, ADOT does not use PEL for Categorical Exclusions (CEs), as part of the Long-Range Transportation Plan process, or on existing corridors. ADOT has determined that it does not need to use PEL on every study, instead focusing the practice on when alternatives analysis is required, a new corridor alignment is being studied, or when there is significant uncertainty in project scope or location. Even when not formally engaging in the PEL process, ADOT studies reflect elements of PEL approaches, including environmental overviews and coordination with agencies early in the process to determine if there are constraints on design from impacts to resources such as historic sites, endangered species, and sensitive areas. To assist in its approach, ADOT uses a Geographic Information System (GIS) tool to collect data to support planning and a performance-based program, including an environmental resources data layer. This tool is used to collect background data and overlay it with project components, helping to understand drainage, safety needs, and environmental risks as project scope is identified.

Two examples of ADOT’s successful use of aspects of the PEL process are the Interstate 10/Interstate 17 “Spine” Corridor Master Plan and the Interstate 11 Corridor Master Plan. ADOT worked with the Maricopa Association of Governments (MAG), which served as the lead, over a four-year process to develop ADOT’s I-10/I-17 “Spine” Corridor Master Plan. MAG conducted an effective and extensive outreach process within the corridor in several stages. MAG and ADOT took the appropriate steps to satisfy PEL requirements, benefiting from the ability to conduct this outreach in advance of long-term decisions. ADOT reviewed the workplan with partner agencies, helping guide MAG to follow a PEL process so that all stakeholders would be comfortable signing off on the Master Plan. For the I-11 project, ADOT initially conducted a PEL study, which helped to reduce the range of alternative alignments. ADOT then moved to a Tier 1 Environmental Impact Statement (EIS) process, focusing on the reduced range of alignments.

Key Takeaways

  • ADOT uses a PEL checklist to help determine whether a PEL approach is appropriate, considering factors such as whether an alternatives analysis is involved, whether an environmental assessment (EA) or EIS will be required under NEPA, whether a new corridor or new corridor alignments are being studied, or whether there is significant uncertainty about location. ADOT uses a Geographic Information System (GIS) tool to collect data to support planning and a performance-based program, including an environmental resources layer.

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Colorado Department of Transportation

A PEL Handbook

The Colorado Department of Transportation (CDOT) has incorporated PEL guidelines and planning processes into its procedures for transportation planning. CDOT often looks to the PEL process as a method to identify priorities, justify funding for projects, and accelerate project delivery. CDOT conducts PEL outreach to provide overviews of the PEL process to MPOs and other partners. CDOT initially developed a PEL Handbook in 2012 to provide specific guidance and recommend best practices for developing PEL studies for transportation projects in Colorado. This Handbook was updated in 2016, after further PEL studies were undertaken by CDOT and agency staff recognized additional best practices. The CDOT Handbook provides practitioners (CDOT staff, local governments, and regional planning agencies) with step-by-step guidelines for how to conduct a PEL study, with examples of projects, processes, and scopes of work. It also outlines relevant policy, requirements, and guidance that apply to the PEL process.

The CDOT Handbook provides guidance on the PEL process at a high-level, including how to determine if a PEL study should be undertaken, who should be involved, and when to coordinate with FHWA. For developing the PEL study itself, CDOT has identified four key steps:

  1. Draft purpose and need
  2. Understand the existing and future transportation systems
  3. Identify a reasonable range of alternatives
  4. Conduct an environmental evaluation

The CDOT Handbook notes that these steps are important to accelerate decision-making and lead to cost-effective solutions, minimized duplication of efforts, and quicker project implementation as the project moves to environmental review. It addresses the common question of how to transition PEL into NEPA. For example, if CDOT determines it needs to include more extensive alternatives analysis during the PEL phase in order to develop more detailed design for eventual inclusion in NEPA review and the PEL study is not transitioned into the NEPA process within a few years, CDOT will revisit a PEL study to address any conditions that have changed. At completion, a PEL study that has followed CDOT’s process will include a section on what the project might look like and what funding sources could potentially be pursued.

CDOT works closely with the FHWA Colorado Division Office and depends on the Division Office’s guidance concerning statutory changes, regulatory revisions, and policy implementation. The CDOT PEL process includes four “check-in points” with FHWA. CDOT also has partnering agreements with several agencies and has funded liaison positions at the U.S. Fish and Wildlife Service (USFWS) and Colorado Department of Public Health and Environment that support PEL implementation.

Key Takeaway

  • As a frequent and institutionalized PEL practitioner, CDOT has identified best practices and lessons learned and developed an easy-to-use, straightforward guidance document for users. As an agency with a sophisticated PEL process, CDOT can offer practitioners examples of how to effectively integrate PEL into agency procedures or to conduct a PEL study for the first time. CDOT also has partnering agreements with several agencies and has funded liaison positions that have supported PEL implementation.

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Montana Department of Transportation

A Business Process to Link Planning Studies and Environmental Reviews

In 2009, the Montana Department of Transportation (MDT) developed a report, “Business Process to Link Planning Studies and NEPA/MEPA Reviews,” to provide guidance to MDT and its partners on how to link transportation planning, NEPA, and Montana Environmental Policy Act studies. The report presents a Corridor Planning Process for MDT and partners such as MDT Division of Rail, Transit and Planning; MDT Engineering Division, USACE, USFWS, and others. MDT developed this process to strengthen its planning process by increasing coordination with the public and other agencies early in planning. Around the same time, MDT moved its environment group into the planning group within the agency. Despite initial challenges, this organizational change has led to better interagency coordination.

MDT’s PEL process also leads to the development of specific products that can be used in the environmental review process. Corridor Planning Studies developed per MDT’s process can be used to:

  • Identify project purpose and need
  • Define the general travel corridor/mode
  • Conduct preliminary screening of alternatives
  • Describe the environmental setting
  • Assess preliminary impacts and potential environmental mitigation

One key component of the Business Process is a “transition form” completed at the end of a planning study that serves to document key issues that the project development team will need to know. The Business Process helps determine if there is an apparent need, and if the project is financially feasible. MDT has learned that starting projects with a strong purpose and need, as well as coordination with resource agencies, is very important.

Involvement and education of stakeholders is critical in moving the right projects forward. Projects may encounter delays if stakeholders are not engaged early. MDT approaches public outreach as a request for information about the corridor, rather than telling the public what MDT intends to do. MDT engages in routine communication with resource agencies and attributes much of its success to these positive relationships. Resource agencies support MDT in ensuring that it is forming project purpose and need in a way that the project is manageable and fundable. Close coordination with the FHWA Montana Division Office has contributed to much of MDT’s success in incorporating planning principles into the environmental process.

Key Takeaway

  • By prioritizing coordination with local projects and stakeholders, documentation of purpose and need, early development and screening of alternatives, and early development of environmental mitigation concepts, MDT’s “Corridor Planning Process” has been a helpful process for considering projects where the need and financial feasibility are uncertain, and for informing stakeholders of upcoming projects.

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Michigan Department of Transportation

Determining When to Use PEL

The Michigan Department of Transportation (MDOT) has been widely using PEL studies since 2013. MDOT has developed its own decision-making tool to determine when PEL efforts are appropriate, as well as a “How to Guide” to direct PEL practitioners across the state. As a result, PEL has been embraced as a key tool by transportation planners who are confronted with projects that may have been studied previously, but lack agreement from stakeholders on a preferred outcome. MDOT also has found PEL to be a good tool for operational analyses, including complete streets plans, road safety audits, and pedestrian considerations. MDOT has invested effort in gaining trust and buy-in from internal and external stakeholders on its PEL process.

MDOT uses a decision-making checklist to help determine when the PEL process is appropriate. The checklist asks practitioners to consider:

  • Whether the problem or need for the project has been identified
  • Whether alternative solutions will need to be developed
  • If the project is operational or capacity building
  • If the agency has been engaged with the community
  • If a project is not in the 5-year transportation plan, it may be appropriate for PEL; if it is, then it is likely appropriate to initiate the NEPA process.

MDOT’s PEL process is community-focused and offers a streamlined way to determine which alternatives may be acceptable to the community, to identify funding, and to establish next steps. Although achieving local consensus can be a challenge, MDOT has found the PEL process can be helpful. MDOT’s PEL guidance also uses established PEL terminology, the FHWA PEL Questionnaire, and other common concepts and language, because the agency has found a significant benefit of the PEL process is providing insight into what is needed for NEPA compliance during project development.

MDOT’s Division Street PEL study, completed in 2016, is illustrative of the outcomes that can be achieved through Michigan’s PEL approach. Before the PEL effort began, numerous past studies had resulted in a series of proposed solutions and no consensus among stakeholders. The Division Street PEL study used PEL approaches for public engagement, helping to create an understanding among the project stakeholders, and the public, of the limitations involved in many potential project alternatives that may have been considered or recommended in past studies but that did not fully consider environmental impacts. Additionally, even when partner agencies were unable to fully engage in meetings, they worked with MDOT to provide input in other ways. Ultimately, the Division Street PEL study recommended a series of improvements for which funding has not yet been identified, but the PEL study has already led to several more modest, yet important, safety improvements along Division Street.

The I-275 Western Wayne County project provides another example of coordination with resource agencies using PEL. The community was applying for grant funding to build a new interchange, and MDOT became involved due to the NEPA review required for federal aid. Because the community had defined the problem and solutions based on a previous study, MDOT was able to use PEL to get stakeholders and agencies in alignment on the problem and alternatives. Ultimately, the community determined that the project had too many impacts and declined to pursue it.

A final example is the I-94 Interchange Improvement project. This example illustrates how MDOT has used PEL to develop deliverables for less complex independent projects so that they that can be moved forward more easily. The FHWA Michigan Division Office initially recommended an EA for modifying an interchange. However, the Division Office also recommended the PEL process, which included extensive outreach, analysis of land use implications, and selection of a preferred alternative. The PEL study informed the NEPA process and allowed for the determination that the proposed action qualified for a CE, rather than a full EA because many uncertainties were addressed during the PEL Study.

Key Takeaway

  • Michigan’s experience with PEL shows that incorporating environmental considerations into the planning process, creating a robust process for stakeholder engagement, and carefully considering alternatives often results in clearly-defined projects that are ready to advance into the NEPA review when funding becomes available.

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North Carolina Department of Transportation

Integration Initiative

The North Carolina Department of Transportation (NCDOT) has undertaken a major process improvement with the goal of integrating its long-range transportation planning process with its project development process. This integrated process results in comprehensive transportation plans (CTPs), which ensure compliance with federal and state environmental permitting and review laws. This “Integration Initiative” was designed through the work of a multi-agency Integration Team. This effort resulted in the identification of 8 linkages between long-range planning and project development, where products from the CTP process could inform or serve as the starting point of the environmental review process. An “Integration Implementation Team” directed the implementation of the Integration Initiative, leading small working groups in designing best standards and practices for accomplishing the goals of integration. NCDOT made a significant investment in developing this program and its tools and has created a culture of change within the agency and with resource agencies.

NCDOT’s “Integration Initiative” process results in a problem statement that can serve as the basis of purpose and need. It can also be used to screen out alternatives and serve to bring forward a preferred alternative for further study in the NEPA process. NCDOT believes that a key benefit of creating an institutionalized process such as the Integration Initiative is that it compiles limited but sufficient information on several projects early in the process, while individual studies would provide more detailed information on a single project. NCDOT has a 3-2-1 goal: three years for an EIS, two years for an EA, and one year for a CE. NCDOT is in the process of reviewing the integration process to recommend potential changes to comply with the Fixing America’s Surface Transportation (FAST) Act, although no adjustments have been made yet.

NCDOT has strong relationships with resource agencies through development of their “Merger Process,” which pulls data out of the planning process for use in the environmental review stage. NCDOT’s “Merger Process” requires a series of concurrences from key resources agencies. Thus, resource agencies are assured that any input they provide during the planning process is not final and can be reviewed again during the review or approvals process, which has been found to be effective in eliciting participation from resource agencies early in the process.

Tools and approaches that are particularly helpful to the process of screening alternatives early on are:

  • GIS layers that capture relevant environmental features
  • Potential lists of committee members and stakeholders for community input
  • Development of protocols for working with various resources agencies

Key Takeaways

  • NCDOT’s “Integration Initiative” links long-range planning with project development. It frontloads PEL components into the long-range planning process to accelerate project delivery down the line.
  • NCDOT began using formal agreements and Memoranda of Understanding (MOUs) to document informal understandings.

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Pennsylvania Department of Transportation

PennDOT Connects

In 2016, the new Pennsylvania Department of Transportation (PennDOT) Secretary issued a policy incorporating land use and community issues into the planning process and set executive meetings to review progress and provide feedback. This policy motivated the development of the “PennDOT Connects” initiative. “PennDOT Connects” follows the PEL approach and has strong public and local official support and coordination. Prior to “PennDOT Connects,” PennDOT created a process in 2009-2010 linking planning and NEPA, which provided guidance, a process framework, and a variety of GIS layers for screening early on to identify potential for resources to be impacted. The intent was to consider environmental screening prior to programming a project in the transportation plan.

PennDOT also has developed a Transportation Program Development and Project Delivery Process and its Regional Long Range Plan Guidance, which together were identified by FHWA as an overall equivalent approach to the FHWA PEL Questionnaire. This approach links the project planning and delivery process to improve efficiency in the identification, coordination, and advancement of Pennsylvania’s transportation program.

PennDOT has noted that the Project Development Process requires that the preliminary engineering phase involve the consideration of environmental impacts and the provision of documentation that supports later environmental studies. PennDOT’s guidance document for Developing Regional Long Range Plans also highlights the importance of linking planning and NEPA, and the steps for doing so. These steps give more background on preliminary screening, development of purpose and need, and screening alternatives.

The Bayfront Parkway Study was completed in the summer of 2017 and provides a recent example of PennDOT’s use of PEL principles. The project itself, Bayfront Parkway Multimodal Improvements, was included in the MPO Erie County 2042 Long Range Transportation Plan (March 2017). The Bayfront Parkway Study was a proactive study on economic development impacts, and demonstrates aspects of the PEL approach through extensive community outreach, identification of purpose and need, and development of alternatives. Success is attributed to strong support from the district executive, involvement of the city and county, and the Secretary of Transportation and Economic Growth’s help with securing funding.

Key Takeaways

  • The Bayfront Parkway Study illustrates PEL principles in practice through extensive community outreach, identification of purpose and need, and development of alternatives.
  • The PennDOT Connects initiative is an example of PennDOT’s support for PEL principles, and the agency’s collaborative and integrated approach incorporating environmental, community, and economic goals early in the transportation planning process.

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Utah Department of Transportation

Developing a PEL Tool

The Utah Department of Transportation (UDOT) has developed its own Utah Planning and Environmental Linkage (uPEL) tool, using initial FHWA funding. uPEL is a GIS-based tool that brings together datasets early in the transportation planning process, helping agencies consider environmental, community, and economic issues at the same time. uPEL integrates with UPLAN, UDOT’s off-the-shelf GIS platform, and is aimed towards coordinating data sharing with other resource agencies. Depending on the data available, the tool can perform an impact analysis with sensitivity information or provide broad context and understanding.

The original intent of uPEL was to serve as a comprehensive planning tool for UDOT, looking at the full spectrum of environmental resources UDOT would evaluate for NEPA, including present conditions, in order to determine appropriate class of action, generate simple purpose and need, and develop project descriptions. UDOT found that because of the way data is characterized in the uPEL system, it did not provide sufficiently specific information. UDOT also was not able to develop separate MOUs with resource agencies in order to keep data up to date in the uPEL system. Therefore, UDOT is not currently using uPEL.

Nonetheless, two UDOT projects that demonstrate PEL principles include the SR-73 Corridor Planning Study and the Wasatch Choices 2040 and 2050 regional visioning projects. Although not a federally funded project, the SR-73 Corridor Planning Study reflected PEL principles through consideration of project traffic impacts, development of purpose and need, and consideration of alternatives analysis. The Wasatch Choices 2040 planning study served as a foundation to the Mountain Accord, which has developed into a major inter-agency planning effort with joint leadership and UDOT participation. The study considered transportation needs, environmental concerns, and economic issues. The project was not structured as a formal PEL process, but it did involve pre-planning and consideration of regional needs prior to the NEPA process. These projects have been identified as “state of the practice” by FHWA in demonstrating best practices in agency, public, and local stakeholder involvement, as well as early development and screening of project alternatives.

Key Takeaway

  • Even if a state is not using a full PEL process, it can develop tools that support linkages between planning and environmental reviews. To be effective, such tools requires both an initial investment, ongoing maintenance, and a commitment to effective coordination with resource agencies.

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Washington State Department of Transportation

Practical Solutions Performance Framework

The Washington State Department of Transportation (WSDOT) has implemented a Practical Solutions Performance Framework aimed at helping WSDOT make strategic investments and develop plans accordingly, reflecting PEL principles. Additionally, WSDOT led the I-405 Corridor Program project with four other “co-lead” agencies—Federal Transit Administration (FTA), FHWA, King County, and Sound Transit, the regional transit agency. This project demonstrated several PEL principles. For this project, WSDOT and its partners developed a structured public involvement program and established a formal organization, with a three-level committee structure: political, citizen, and technical (transportation and resource agencies). WSDOT used this process to address concerns from resource agencies about increased workload.

WSDOT’s Practical Solutions Performance Framework aims to deliver near-term, low-cost solutions. WSDOT considers the environmental context during planning so that it can deliver “the right project, in the right place, at the right time.” The projects often focus on state of good repair. Projects that use the framework often result in efficient NEPA decisions. WSDOT planning studies incorporate the following three elements that link environmental considerations to planning:

  1. Meeting WSDOT’s internal environmental priorities (e.g., noise walls, habitat connectivity, stormwater requirements) so that the planning team can anticipate these project elements
  2. Expanded identification and analysis of environmental justice and Title VI of the Civil Rights Act concerns
  3. Environmental regulatory screening

Key Takeaway

  • WSDOT has incorporated environmental context into the planning process through its Practical Solutions Performance Framework, and has now developed an Environmental Planning and PEL Handbook.

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