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FHWA > Every Day Counts > Shortening Project Delivery > Shortening Project Delivery Toolkit > Planning and Environment Linkages > PEL Questionnaire Equivalent

Shortening Project Delivery Toolkit

PEL Questionnaire Equivalent

Agency: Tennessee Department of Transportation (TDOT)
Equivalent Approach: Tennessee Environmental Streamlining Agreement

Overview

Beginning with the passage of the Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) and continuing through the adoption of the Safe Accountable Flexible Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU), recent transportation legislation has placed an emphasis on improving the linkage between transportation planning and the National Environmental Policy Act (NEPA) analysis. This emphasis has led to greater consideration of environmental factors during the planning stage, increased communication and cooperation between transportation and environmental agencies, and the inclusion of environmental performance measures in state-wide and metropolitan area plans.

The Federal Highway Administration (FHWA) defines Planning and Environment Linkages (PEL) as “an approach to transportation decision-making that considers environmental, community, and economic goals early in the planning stage and carries them through project development, design, and construction.”1

According to the FHWA website, the Office of Planning and Office of Project Development and Environmental Review developed the PEL program in 2006 as an umbrella approach to help agencies integrate transportation and environmental planning processes and to streamline their project-development and environmental review processes. Originally, the program was focused on providing technical assistance and guidance, along with conducting workshops to help state and local agencies link the planning and environmental review processes. More recently, the program has been expanded to promote a more integrated and collaborative approach to transportation decision-making in order to support FHWA priorities such as Every Day Counts, Eco-Logical, Context Sensitive Solutions, and Green Highways.2

Every Day Counts

In 2010, FHWA introduced the Every Day Counts (EDC) initiative in an effort to identify and deploy innovative approaches to shorten project delivery time, enhance the safety of roadways, and protect the environment. In order to accomplish these goals, the EDC initiative has been organized around three pillars:

As part of the overall EDC effort, PEL has been identified as one of the ten initiatives (See Figure 1) to be included in a toolkit that will address shortening project delivery time. Under EDC, FHWA is encouraging transportation agencies to conduct transportation planning studies at the corridor or subarea level, with the intent of using directly, or by reference, the information developed during these “PEL studies” in a subsequent NEPA document.

However, in order for the PEL study to be viable in the NEPA phase, an approach or procedure in the planning process must provide interested Federal, Tribal, State, and local agencies as well as the public the opportunity to participate in the development of the analysis. It is important that decisions made during the PEL phase be documented in a form that is identifiable and available for review during the NEPA scoping process, be appended to or referenced in the NEPA document, and be accepted by the NEPA lead agencies.3 FHWA introduced the PEL Questionnaire as a tool to aid transportation agencies with incorporating PEL principles into their planning and environmental review processes.

PEL Questionnaire

The PEL Questionnaire is an adaptation of a questionnaire jointly developed by the Colorado Department of Transportation and FHWA Colorado Division Office to ensure that planning information and decisions are properly documented in order to be utilized in the NEPA process. Recognizing that several states have developed processes, procedures, and tools comparable to the PEL Questionnaire, FHWA established the following criteria for identifying and recognizing equivalent approaches. An equivalent approach is a process and/or consultation technique that fulfills a similar purpose as the PEL Questionnaire. In order to be considered an equivalent approach, the process and/or tool must satisfy the following criteria:

Criteria 1:
The equivalent should be institutionalized within the department (i.e. it is a formal process or tool available statewide).
Criteria 2:
The equivalent must provide information on how to consider and document the following:
  1. The early and continuous coordination with Federal, Tribal, State, and local transportation, environmental, regulatory, and resource agencies.
  2. Coordination efforts with the public and stakeholders.
  3. Description of planning scope, vision statement, and steps needed to scale the vision statement to a project-level purpose and need statement.
  4. Alternatives that were considered, selected and rejected; criteria and process used for selecting and rejecting alternatives.
  5. Explanation of planning assumptions, including forecast year, traffic volumes, policy, and data as well as consistency of those planning assumptions with the long-range transportation plan.
Criteria 3:
The equivalent may also provide information on how to consider and document the following:
  1. Analysis of the affected environment and environmental consequences. Document those resources reviewed and not reviewed, and the level of detail.
  2. Potential strategies for broad-scale mitigation.
  3. Description and/or analysis of potential cumulative effects.
  4. A method of documenting FHWA's approval, in order to support the use of planning information in NEPA, that indicates that PEL principles were applied to FHWA's satisfaction.

Determination of PEL Questionnaire Equivalent

Beginning in 2004, TDOT began working closely with resource and regulatory agencies to develop a coordinated approach to streamline the planning and environmental phases of the transportation project development process. This coordinated approach is documented in the Tennessee Environmental Streamlining Agreement (TESA) which was formally adopted by TDOT and multiple agencies in 2008. The following outlines the key components of the TESA process and how it satisfies the PEL Questionnaire equivalency criteria.

Tennessee Environmental Streamlining Agreement

In an effort to establish a coordinated planning and project development process for transportation projects in Tennessee, TDOT developed the Tennessee Environmental Streamlining Agreement (TESA) for the Environmental and Regulatory Coordination of Transportation Projects. The goal of the TESA process is to ensure significant resource/regulatory agency, Metropolitan Planning Organization, and other stakeholder participation and involvement early and throughout the transportation project development process.

This streamlined environmental process is intended to achieve the timely and efficient identification, evaluation, and resolution of environmental and regulatory issues. TESA establishes one decision-making process for identifying and addressing agency issues at four key points (concurrence points) during the planning and NEPA process. Concurrence Points are “checkpoints” within the project development process where TDOT requests formal concurrence and the participating agencies provide concurrence or non-concurrence, before the project proceeds to the next step. The four TESA concurrence points are:

The TESA process was conceived to identify issues early in the project development process, where the greatest flexibility for addressing the concerns exists, thus ensuring that basic issues surrounding purpose and need, the study area, and the range of alternatives can be resolved prior to the development and review of an environmental document.

As outlined in the TESA document4, the purpose of the process is to:

The TESA process meets all of the required criteria and all but one (3c. Description and/or analysis of potential cumulative effects) of the recommended criteria for determining PEL questionnaire equivalents (See Figure 2). The following sections describe the TESA process and how it aligns with the FHWA criteria.

Future PEL Enhancements

TDOT is currently looking at opportunities to enhance and improve the TESA process during the earliest stages of the planning process. TDOT recently engaged the American Association of State Highway and Transportation Officials (AASHTO) Center for Environmental Excellence to assist the Department in looking at PEL best practices and to improve the linkages between the planning and environmental processes. Currently, TDOT is piloting the development of an enhanced Needs Assessment process to better define the need for a project, community issues, and the surrounding context, prior to the development of a TPR. This improved Needs Assessment process is intended to encourage better engagement of agencies, local officials, and other stakeholders at the earliest stages of the planning process. As conceived, TDOT's new PEL process would create a consistent approach and report format to better align the Needs Assessment, the Transportation Planning Report, and the environmental document, allowing each to serve as the foundation for the next phase. The new Needs Assessment is intended to be used by MPOs and Rural Planning Organizations throughout the state and should establish a consistent planning approach which will allow consideration of cumulative effects on a project-by-project basis, as well as at the community or regional level.

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1 FHWA Planning and Environmental Linkages website
2 Planning and Environmental Linkages Program Annual Report Fiscal Year 2010
3 FHWA Planning and Environmental Linkages website
4 Tennessee Environmental Streamlining Agreement
5 Tennessee Environmental Procedures Manual

For questions or feedback on this subject matter content, please contact Jody McCullough or Marisel Lopez-Cruz.

Updated: 1/13/2012

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