Environmental Review Toolkit
Planning and Environment Linkages

Linking Planning and NEPA Managers Workshop

Portland, Oregon

Final Draft of Action Plan
May 9-11, 2006

Overall Decision-Making Process
Strengths of Existing Process Weaknesses/ Shortcomings Strategies Short Term Action Plan Responsible Person(s) Action Date
Existing transportation planning and project development process is delivering projects. Process is repetitive and takes too long. The longer a project takes, the more turnover of involved public and other parties, increasing likelihood that decisions will be reopened.

Sense of urgency to change the process is lacking, as is clarity about what to do next. Linking Planning and NEPA is one of many changes the agencies would like to make — not necessarily a priority.
Give high level consideration, in planning, to issues that are most likely to cause project delay — e.g., endangered species, cultural resources.

Give early attention to projects that are likely to require EIS in next 5 to 10 years before a project is included in the STIP. Concentrate on "sticky" issues, potential problem areas.
     
For ODOT and resource agencies, CETAS has led to strong relationships, trust, understanding, early integration, shared missions. CETAS makes process/decisions more transparent, issues are addressed early, projects are advanced more smoothly, decisions are better. CETAS provides a forum to expand discussion beyond individual projects. MPOs are not part of the CETAS discussion.

ODOT is accustomed to dealing with project level environmental detail and may not know high level concerns of resource agencies.
Find a way to include MPOs in early environmental consideration.

Identify planning level contact at resource agencies.

Take TSPs to CETAS for "pulse check" on the projects contained in the plan.
     
Cumulative impacts are considered as part of statewide planning goals and comprehensive planning. This analysis assumes that all projects in plan will be built, which is unrealistic due to fiscal constraints. Give greater emphasis to making plans "holistic" and fiscally constrained.      
Collaborative process for ODOT Bridge Program led to environmental performance standards. Illustrates a good approach to bundling projects. Some environmental data gathered for Bridge program was invalid, not used. ODOT had to redo wetland data. No concurrence from resource agencies. Some expectations were not delivered. Resource agencies took risk — are not sure it was a good thing. Approach led to more work later, and was not well staffed for best outcome. Invite resource agencies to suggest performance measures — using GIS data — for System Planning (i.e., clean air planning emissions budget model)      
Transit has informal (non-CETAS) process for collaboration with resource agencies that works.          
  Regulatory framework is not well understood. Agencies have own nomenclature making communications difficult. Need to expand knowledge base cross-agencies and cross-disciplines.

USDOT agencies offer differing process requirements and guidance.
Develop and conduct cross-discipline, cross-agency training for managers, professionals on environmental process, environmental requirements, and planning process, terminology, requirements, roles and responsibilities.

Convene workshops, discussion groups on roles and responsibilities, protocols, procedures, how to break down silos, barriers to communication, to produce mutually beneficial implementation tools.

Monitor effectiveness/efficiencies, and updates as appropriate.

Develop common description of nomenclature.
Conduct planning and NEPA "101" training

Develop and distribute "white papers" and case studies.

Develop/refine glossary of terms
Andy Johnson
Lidwien Rahman
 
Objective 1: Goals and Objectives
Strengths of Existing Process Weaknesses/ Shortcomings Strategies Short Term Action Plan Responsible Person(s) Action Date
Oregon's comprehensive planning process creates a goals framework.

In ODOT Regions 1, 2, and 3, Environmental Project Managers are involved in Refinement Planning
Disconnect between long range planning and project planning — i.e., project decision criteria do not relate to goals in plan. Update TSP guidance to show how environmental goals can be incorporated into planning. Include the establishment of a collaborative process to reach consensus on goals and objectives on environment, communities, transportation in System Planning and Refinement Planning. Involve all interested parties in developing guidance.

Take steps to ensure that TSP guidance is understood and followed in scopes of work and decision criteria.

Use goals and objectives developed in System Planning to guide the refinement of plans, NEPA documents and transportation projects. In Refinement and Project Planning, show the relationship to original framework of goals and objectives from System Planning.

Involve ODOT Environmental Project Managers in both System Planning and Refinement Planning statewide.

Engage community in deciding what's important during planning.
Develop model TSP scope of work language for goals and objectives. Send to the "Small Core Group"* in draft. Andy Johnson July 15
Draft paragraphs for a letter that agency leaders could send out to express support for and benefits of linking planning and NEPA. Submit draft to the "Small Core Group". Dave Unsworth May 31
Disseminate Federal guidance on SAFETEA-LU Section 6001 to all affected agencies with joint cover letter. Linda Gehrke
Michelle Eraut
Summer/ Fall 2006
Share commonly used project-level environmental goals and objectives with planners, both within and outside ODOT. FTA will look at goals from a transit perspective and will provide examples. Susan Haupt
Linda Gehrke
Bridget Wieghart (or Ross Roberts)
July 1
Objective 2: Problem Definition
Strengths of Existing Process Weaknesses/ Shortcomings Strategies Short Term Action Plan Responsible Person(s) Action Date
    Develop problem statement for each project during System Planning, following current TSP guidelines. Include approval of problem statements as part of TSP and RTP approval.

Involve appropriate Federal agencies, CETAS, Steering Team, affected local governments in defining problems to be addressed during Refinement Planning that is likely to lead to an EIS or EA.

Make problem statements more focused, more detailed, as a project advances, but don't change problem statement in fundamental ways.

If refinement Planning is to lead to EIS in 1 to 2 years, carry problem definition to meet NEPA Purpose and Need requirements.

Develop guidance on the development of problem statements in System and Refinement Planning. P&N must be broad enough to not prematurely preclude the Least Environmentally Damaging Practicable Alternative.
Send reminder to MPOs that developing problem statements is part of transportation system planning. Raise need for problem statements in next year's UPWP instructions.

Include this step in Refinement Planning guidance (see objective 7).
Akin Owosekun
Satvinder Sandhu
Ned Conroy
 
Objective 3: Range of Alternatives and Environmental Analysis
Strengths of Existing Process Weaknesses/ Shortcomings Strategies Short Term Action Plan Responsible Person(s) Action Date
  Preferred alternative identified in pre-NEPA Refinement Planning causes redundancy, confusion, and wasted time/funds. Often have to backtrack to reconsider alternatives in NEPA that were previously considered and rejected. Two options available for Refinement Planning studies:
  1. Define a range of alternatives, not a preferred alternative, in a way that will hold up under NEPA, or
  2. Select a preferred alternative in a way that will hold up under NEPA.
Develop guidance on how to do choose between these, on appropriate level of environmental analysis, and on how to prepare scoping document as end product. Scoping document to include public/agency process, alts considered and rejected and why, alternative(s) recommended for advancement, and unresolved issues.
Create Refinement Planning guidance and include procedures so decisions can stand up through NEPA. Include guidance on selecting the alternatives to be considered, environmental and other relevant analyses, "red flag" items, appropriate level of detail, collaboration with other agencies, documentation of decisions. ODOT, resource agencies and MPOs and transit agencies should all be involved. (See Objective 7.)

Provide "model" statement of work for refinement planning and EIS/EA for selecting alternative in Refinement Planning. Get signoff from USDOT agencies.
Lidwien Rahman
Bonnie Heitsh
Andy Johnson
Susan Haupt
Amy Gibbons
Jerry Marmon
Tracey White
Michelle Eraut
Ross Roberts
John deTar
 
  Lack of clarity on level of environmental analysis is a challenge when evaluating alternatives under CETAS. How much analysis is enough? How much data is needed? How accurate? What needs to be done to make this project acceptable? Risk assessment?
Amend ODOT Transportation System Planning guidelines to address environmental analysis, including screening criteria. Interview stakeholders/users of the guidelines. Determine content of the update. Lisa Nell  
Use goals and objectives to identify alternatives and evaluation criteria.

Identify known resources in System Planning. Engage community in discussion about context — what's important?

Use Eco-Province Priorities (EPP) to help inform System Plans. Make EPP information understandable and accessible to planners and project development.
     
Develop framework for implementing SAFETEA-LU Section 6001 (guidance, compliance). Hold quarterly State/transit/MPO coordinating meetings. Satvinder Sandhu
Ned Conroy
Michelle Eraut
May 12
Increase environmental staff participation in System and Refinement Planning. Send e-mail to MPOs on the use of CETAS as forum for planning. Susan Haupt  
  Lack of proper documentation of decisions in planning — who decided what and why on the basis of what analysis/information. MPOs could require lead agencies to give information on where a project came from, and what alternatives/impacts were considered.

Update TSP Guidelines.
ODOT, resource agencies, MPOs to update TSP guidelines Lisa Nell  
In transit, environmental work is routinely done in planning — doing NEPA and planning together. Get informal head nod from resource agencies at planning stage. For highways, elected officials (and public) are unwilling to spend resources on project details needed to secure commitments.

No system to account for benefit of spending $ up front.
       
Objective 4: Environmental Data Management System
Strengths of Existing Process Weaknesses/ Shortcomings Strategies Short Term Action Plan Responsible Person(s) Action Date
    Develop a strategic plan for developing EDMS to include:
  • Inventory of data and gaps.
  • Plan for filling gaps.
  • Resource agencies to provide data on resources and guidance on proper use of data to lead to approval. Secure common understanding on how good the data is and what it can be used for.
  • Data manager for each layer
  • Collaboration between environment, planning and GIS experts.
  • Data centrally located and accessible by web, with regular updates. Standardized format.
  • Data maintenance process.
  • Coordination with other Oregon GIS activities.
  • Development of intergovernmental agreements.
  • Training on how to use GIS and what data mean.
Create Steering committee for Strategic Plan. Milt Hill June 6
Amend Draft Strategic Plan to include: Milt Hill July 1
  • Query data owners and data users, and assess needs. Users Committee to evaluate tools, focus groups for special needs. Multiple agency participation.
  • Apply for AASHTO peer exchange program funds, FHWA/FTA capacity building funds, or FTA research funds to learn about Florida and other State efforts to develop environmental database.
  • Estimate costs, benefits for recommended EDMS, to justify request for funding. Justify in terms of cost savings, efficiency, time savings, efficiency, broader community planning benefit.
Susan Haupt
Michelle Eraut
 
Develop templates for ARCGIS products (i.e., template for Refinement Plan maps).   July 1
Conduct GIS assessment and develop inventory of available data. Michelle Eraut  
Send out existing "cheat sheets" on data sources to all interested agencies. Ned Conroy
Susan Haupt
 
Objective 5: Mitigation and Conservation
Strengths of Existing Process Weaknesses/ Shortcomings Strategies Short Term Action Plan Responsible Person(s) Action Date
Private banking is improving Not enough banks.

Land acquisition procedures take a long time — land often sold to others. Need other tools to make banking effective.
Identify which resources and agencies may be impacted that require mitigation. Identify resources and agencies that could require mitigation John Marshall  
Obtain data on environmental resources for use in planning — i.e., baseline inventory. Identify what banks exist, opportunities. Identify existing/proposed recovery plans and strategy recovery areas in data base. (see Objective 4)      
Conduct cross-training. Identify priority training needs and training strategy.    
Allow for advanced land purchases for conservation and mitigation. Get clarification from USDOT if mitigation purchases (Eco-Province Priority) can occur and propose SAFETEA-LU technical amendment if necessary. Linda Gehrke  
Assume all wetlands are jurisdictional for system planning purposes.      
Develop list of resource agency contacts for MPOs Set up programmatic mechanisms and protocols. Send out examples and web links.    
Take programmatic approach to conservation and impact mitigation during planning. Create holding capacity/credit areas before projects are developed. Identify programmatic approaches in other states    
Objective 6: Staff and Budget Constraints
Strengths of Existing Process Weaknesses/ Shortcomings Strategies Short Term Action Plan Responsible Person(s) Action Date
ODOT is funding resource agency positions. Difficult to involve resource agencies in planning.

Smaller MPOs do not have a relationship or interaction with resource agencies.
Identify corridors with greatest challenges and involve resource agencies in those. Develop environmental checklists for planning projects similar to part 3 prospectus for refinement planning/CE checklist. Bill Ramos, FTA
Susan Haupt
 
Transportation agencies have worked with resource agencies enough that they can predict their issues.   Empower ODOT environmental managers and staff to work on planning.

Contract out environmental reconnaissance

Fund additional resource agency liaisons

Continue to refine CETAS to make it more efficient.

Develop outcome based performance standards.

Develop evaluation/feedback loops to evaluate processes. Monitor and report out the effectiveness and efficiencies.

Seek additional funds.
"Small Core Group"* to put together a program, take to Environmental Leadership Team in ODOT, planning business line, other agency managers. Identify needed resources.    
Include reconnaissance report in standard model contract scopes. Susan Haupt  
Identify funding opportunities (e.g., bridge program, FTA, private partners, counties, MPOs).    
Prepare legislative advocacy plan, grant applications.    
Objective 7: Refinement Planning and Tiered NEPA Process
Strengths of Existing Process Weaknesses/ Shortcomings Strategies Short Term Action Plan Responsible Person(s) Action Date
Planning in general has incorporated environmental considerations. No formal process linkage between planning and NEPA.

Planning sometimes ends up occurring during project development.

Definition and desired outcomes of various process steps (Refinement Planning) is unclear.
Clarify what refinement planning is, how it differs from a tiered NEPA process, desired outcome (preferred alternative, a range of alternatives?) Create working group to define Refinement Planning and the elements/outcomes of Refinement Planning. Develop model statement of work. (See Objective 3.) Lidwien Rahman
Bonnie Heitsh
Andy Johnson
Susan Haupt
Amy Gibbons
Jerry Marmon
Tracey White
Michelle Eraut
Ross Roberts
John deTar
 
Develop guidance and training. Involve FTA and FHWA and other agencies. Establish contact with other agencies that will be involved in reviewing ODOT guidance on appropriate use of Refinement Planning and tiered NEPA. Lisa Nell  
Identify in TSP which projects are likely to benefit from Refinement Planning would be useful. Ask MPOs to inventory needs for Refinement Planning and to include Refinement Planning studies in their UPWPs. Add to next year's UPWP instructions. Develop a list of Refinement Planning studies.    
    Provide CETAS agencies an opportunity to participate in Refinement Planning likely to result in EIS or EA.. Inform MPOs of CETAS and the availability of this forum.    


*Next Steps for Completing and Securing Approval of the Action Plan:

  1. PB will send Final Action Plan to participants in Managers Workshop and Executive Seminar
  2. Susan Haupt will convene a Small Core Group to polish the Action Plan, roll out to other Stakeholders, and monitor/report on implementation. Members to include: Susan Haupt, Andy Johnson, Amy Gibbons, Ned Conroy, Michelle Eraut, John deTar, Bridget Wieghart, Milt Hill, Lidwien Rahman, Rick Williams, Mike McCabe.
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