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Environmental Review Toolkit
 

Linking Planning and NEPA Managers Workshop

Salt Lake City, Utah

Third Draft of Action Plan
September 16, 2004

  Strengths of Existing Planning Process Weaknesses/ Shortcomings Potential Strategies Short Term Action Plan
A
Planning & Project Development Process

Corridor studies are used to help determine project concepts, purpose and need, evaluation of alternatives, and impacts. Most EIS projects have corridor study or other assessments to help scope NEPA document, estimate costs.

Both UDOT and WFRC have undertaken efforts to improve link between planning & NEPA. WFRC white paper offers menu of ideas.
There are gaps in linkage between Planning and NEPA — no real continuum.

No systemic process for looking at environmental factors in planning/corridor studies. Un-obvious impacts can be overlooked.

Work towards a more structured process. Recommend ways to define a long range planning and pre-STIP process that move NEPA considerations earlier and that aligns NEPA with decisions. Explore how MPOs might be involved.

Find common ground with UDOT/WFRC “wish list” of linking planning & NEPA items; expand working group to take the next step.
  • MPOs
  • UDOT, FHWA, UTA and other transit providers
  • EPA, USACOE, DEQ?, other environmental representatives
  • Local governments and agencies
Establish a task force, with commitment at the executive level, to develop a more structured long-range planning and pre-STIP process. Form work groups, as appropriate, to address the specific topics within the Action Plan and to monitor implementation.

Reconvene the participants from the Executive Session to present the Action Plan and to provide the foundation for follow up on the approved Action Plan items.

Need to use NEPA more as a means of “informed decision-making,” rather than just a compliance process.

Need to bring NEPA principles more into the MPO process/Pre-STIP stage (e.g., environmental resource considerations).
Pursue the idea of an MOA with involved/cooperating agencies:
  • roles and responsibilities
  • agreement on funding arrangements
  • review process/identify changes
  • develop common goals, articulate benefits of change
  • commitment and consistency to a structure (e.g., routine series of steps at key milestone decision points)
  • develop “best” coordination mechanism
    • committees? working groups?
    • geographic scope?
    • frequency?
  • dispute resolution process
  • right information for early involvement
Two-Tier Agreement:(1) agencies agree to work together to define a process.(2) then hash out specifics on implementing the process and identified proceduresLook at examples of NEPA/404 agreements around the country to get good ideas for how the MOA could work.
Planning decisions “stick” most of the time. In many cases, much of the work in the corridor studies are redone in NEPA

Public Involvement in Corridor Studies — documentation not carried through to NEPA
Need to make the process more seamless within the organizations as well as among agencies.

Create project file for public involvement (other issues?) — starting in corridor studies — carry through to NEPA.
Promote more integration of planning & NEPA staff within UDOT and within FHWA.

Also need to bring the UDOT Regions into the Linking Planning & NEPA discussion
  • develop a way to involve UDOT Regions, MPOs, UTA and other transit providers
  • includes coordination with PM in the Regions
  • use environmental/planning coordination meetings within UDOT to raise these topics
  • put the topic on the agenda for the next bi-monthly meeting with the Regions
Starting to initiate land use and transportation inter-relationships (Envision Utah) — appropriate uses in appropriate places. There is substantial uncertainty regarding future land use, especially in undeveloped areas. There are also issues related to sustainability of development. Consider framework to incorporate land use, transportation, and environmental planning that involves local jurisdictions, using data to inform the process. In both rural and urban areas. Use variable land use scenarios to develop appropriate transportation planning alternatives (impacts, etc.)
  Pay little attention to interactions between land use, transportation, and the environment — not easy. Integrate available data on resources to help guide land use and transportation planning decisions. Establish what data is available, who needs it, and how to get it to them. Include environmental resource agencies. [See page 4, Analysis in Planning, Strategies and Short Term Action Plan]
  Dialogue between local agencies and transportation agencies is weak. For example, no mechanism to explore the land use impacts on transportation and vice versa.   Use “Envision Utah’s” visioning process to advance dialogue on the transportation/land use relationships.

Use advisory committees to involve local governments in corridor studies and address land use implications.
B
Collaboration

Resource agencies have interest and desire to be involved early.
Interagency collaboration in planning is sporadic. Contacted for information, more than collaboration. Develop approach to provide “True and meaningful” participation of resource agencies in planning.

Method to obtain constructive resource agency feedback and consideration.
  • Input on fatal flaws.
  • Don’t send “out of the blue” materials, need a system.
Convene a meeting between transp. and resource agencies to mutually determine:
  • what information is most valuable at each step for resource agencies to be able to give meaningful input
  • how to work together better given resource constraints.
  • level of buy-in wanted in the planning effort.
F+WS/UDOT/FHWA coordinate meetings, identify issues and agency roles in the pre-NEPA stage. F+WS would like to do more. Resource agency participation — beyond air quality — not able to participate effectively.
  • Lack of resources (e.g., EPA’s 404 people are inundated.)
  • Lack of clarity on role
  • Different missions
  • Not geared to look at broad level
  • Hard to figure out which projects are important
  Research other states’ experience with funding resource agency positions to give transportation projects priority attention early in the process.
    Find a way to engage FTA more in the process. Investigate ways for FHWA to act as FTA’s agent with guidance from FTA
  Resource agencies feel their concerns are ignored. Develop team approach for considering/evaluating environmental effects early, consensus on purpose and need, narrowing range of alternatives based on environmental and other parameters. Consider aspects of the Central Utah Project (CUP) and Colorado Model as a model for interagency collaboration; concurrence points and conditions (i.e., purpose and need, range of alternatives, environmental evaluation); level of detail. Collaboration on work plans for each resource.
  Need to improve trust between resource agencies and transportation agencies. Consider planning and environmental "teaming" in corridor studies and NEPA. Identify a pilot corridor study (possibly I-15 in Davis County) to develop and explore improved process and collaboration techniques with resource agencies.
  Resource agencies perceive that planners give more heed to local government issues than environmental issues. Where does this get factored into decision-making? Should make choices concurrently. Provide opportunities for meaningful interface between public and environmental agencies at key steps (e.g., trade-offs of affected resources, hearing each other out). Also, identify lessons learned from Southern Corridor, SR-10, and other corridor studies.
C
Analysis in Planning

Starting to use GIS layers — land use, social, and environmental elements.
Need tools to better manage sheer volumes of data (e.g., knowledge-based tools.) Develop continuing program to enhance GIS database to assist with planning/NEPA interface [e.g., map resources].

Need to bring the agencies that produce the data on environmental resources to the table (they are not here).
UDOT has funding grant ($200k) on GIS; although there are competing priorities for these $’s, could use to merge planning and environmental layers. Coordinate with similar MPO efforts in order to pool resources.
Environmental resource agencies are willing to buy into a project scope early, at less detailed level of analysis — doing so now for Central Utah Project. Resource agencies do not feel they get information needed to make meaningful comments. Resource agencies need to know environmental information available to planning and where it came from. Need confidence in analysis, understanding, ownership. Bring in existing NEPA training (e.g., NHI courses) for planners. Could also include 404 training (EPA course). Conduct training on planning for environmental analysts. In addition, resource agencies could do “show and tell” sessions with planners at transportation agencies to facilitate exchange of ideas on missions, regulations, who to contact.
      The “404/SA Group” could also be utilized to open this dialogue, discuss cross-cutting issues. Can widen e-mail distribution list to include transportation agencies, add these issues to agendas.
For capacity projects and corridor studies, environmental factors are considered in alternatives screening in planning (obvious factors). Not sure how to weigh conflicting resource issues in planning (e.g., local politics).

Avoidance alternatives may not receive enough attention.
Help planners do a better job of developing Purpose & Need in Corridor Studies.

Come up with an acceptable definition of a “reasonable alternative” (look at case law for examples) for Utah.
Utilize UDOT’s guidance paper on P&N. Market to planners, consultants, MPOs
  Need to identify the “right questions” on land use, secondary, cumulative impacts — and when they should be addressed. At a regional scale, prepare a Cumulative Impacts Assessment that can be used as the foundation for a number of follow-on NEPA projects
  • Colorado Springs Example
  • Need to find funds to implement
Corridor management should be a consideration in the process — manage demand and need, corridor “visioning” with local government buy-in.
Develop an approach for analyzing Secondary Impacts (Land use; Property values; water consumption and quality)

Develop an approach for analyzing Cumulative Impacts.
  • Geographically — How Broad (e.g., watershed?)
  • Who is responsible for “past sins” — How far back?
  • Reached point of no return?
  • Land Use / Secondary
What types of impact need to be included? (water, AQ, EJ?)


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