Planning and Environment Linkages
Linking Planning and NEPA
FY 2005/Quarter 4
Between October 1 and December 31, 2005, the Volpe Center interviewed 17 of the 19 Federal Highway Administration Division Offices (FHWA/DO) that participated in the Linking Planning and NEPA: Towards Streamlined Decisionmaking workshop to discuss the status of linking planning and National Environmental Policy Act (NEPA) efforts in their states. Findings from the following state interviews are provided in this quarterly report, which focuses on activities occurring between July 1 and September 30, 2005 (FY05Q4):
- New Jersey
- New Mexico
- South Carolina
- South Dakota
This section provides the themes that emerged from the workshop participant interviews.
Workshops Were Generally Well Received
The majority of interviewees reported that the workshops were helpful. Some DOTs reported that the workshops served to "jump start" the process of evaluating the strengths and weaknesses in the agency's planning and project development process. In addition, metropolitan planning organizations/rural planning organizations (MPOs/RPOs) who attended the workshops found that the workshops provided a much-needed opportunity to bring the parties together to discuss each agency's mission, responsibilities and priority issues. However, some DOTs were already in the process of or had already developed strategies and initiatives to better integrate NEPA into the planning and project development process, and found the workshop materials too basic for the audience.
Treating the State Action Plan as a Living Document
Several state DOTs have modified or improved the State Action Plan since the workshop was held to better tailor it to the agency planning and program development process. DOTs are employing various approaches to refine and implement the Action Plans. Some states, such as Arkansas, Colorado, New Mexico and Pennsylvania, are contracting with consultants to re-evaluate the plan and develop implementation strategies and programs. In other states, FHWA Environmental Streamlining grants have been or will be used to address action items.
Change Resulting from the Workshops
Several states have aggressively pursued the program objectives, and have begun to implement many actions. However, seven states have admitted that the progress behind Linking Planning and NEPA may have lost some momentum since the workshop. Reasons for inactivity include: shifting and competing agency priorities; staff attrition; reorganization; and, the short timeframe for implementation since the workshops.
Dedicated Staff Are Needed to Implement Change
Successfully linking planning and NEPA efforts requires changes to organizational processes, organizational structures, and/or cultures. Individual or team champions are in place at the majority of DOTs to facilitate the necessary changes. In addition, many state DOTs are achieving success by funding positions at resource agencies and initiating cross-functional interagency staff rotations.
Measures of Effectiveness Are Needed
Nearly all states indicated that measures of effectiveness for the Action Plans are difficult to identify and apply. Possible measures may include how successfully the project advances through the environmental review process, reduced redundancy of work and "scope creep," and positive feedback from the Federal and state resource and regulatory agencies.
Communication and Collaboration Are Critical
Most states (13 out of 19) reported that intra- and interagency communication and collaboration have improved since the workshops through monthly or quarterly meetings. Because coordination efforts have been successful, Memoranda of Understanding/Memoranda of Agreement (MOU/MOA) that were initially considered as mechanisms to formalize new agency relationships have become a longer-term action item, and are not solely required to develop collaboration.
Manuals, Tools, and Techniques Are Beneficial
Several states are revising their project development manuals to reflect integration of environmental issues into the transportation decision-making process. DOTs are also developing tools to inform and systematize the transportation decision-making and environmental planning process, including:
- Shared Geographic Information System-based environmental databases to identify and prioritize critical resource issues and develop constraint maps;
- Environmental checklists to improve project scoping/screening and to identify projects warranting early coordination and concurrence points (e.g., Purpose and Need, alternatives analysis) with resource agencies;
- Environmental mitigation developed on a corridor-wide or watershed basis
- Pilot Projects to test the processes developed to better link planning and NEPA
- Incorporation of indirect and cumulative impact analysis into the planning process.
Providing Trainings and Workshops
Trainings, workshops, and peer exchanges are valuable activities to assist state DOTs implement Action Plans. Many state DOTs are cross training planning and environmental staff. Current and future training topics include: the NEPA review process, Context Sensitive Solutions (CSS), public involvement, the transportation planning and project development process, and GIS. In addition, state DOTs are planning workshops with MPOs/RPOs and state and Federal resource agencies on key issues such as Purpose and Need.
State DOTs provided numerous examples of innovative initiatives that demonstrate a wide array of practices they are developing to better integrate planning and NEPA activities. The initiatives are organized into the following three categories:
- Geographical Information Systems
- Process Improvements
- Formal Lines of Communication
Geographical Information Systems
Arkansas — Environmental Geographic Information System
The Arkansas State Highway and Transportation Department (AHTD) Environmental GIS (EGIS) is an element of the Cursory Reviews for Planning Program. EGIS is used to identify environmental constraints during the project development process. Following the workshop, AHTD established a data sharing group, involving Federal and state resource agencies that now meets quarterly. AHTD believes that its corridor preservation effort has progressed due to the strong GIS department.
California — Blueprint Project
The Sacramento Council of Governments (SACOG) Blueprint Project for smart growth involves overlaying GIS data layers (e.g., greenspace, agricultural land, rivers and streams) to accurately represent the existing environment as the project Purpose and Need is developed. The Blueprint Concept Map depicts a way for the region to grow through the year 2050 in a manner that is generally consistent with the seven draft Smart Growth Principles1. The Blueprint project existed prior to the workshop; the State Action Plan identified that they would expand and improve the program.
SACOG is also continually engaging the resource agencies in the Blueprint Project by providing opportunities for agencies to confirm or revise the environmental data being utilized. From this experience, SACOG has learned that there is a need to communicate with local governments and the Federal and state resource agencies early and often, and the organization is scheduling additional interagency meetings. Next steps for SACOG include integrating a land use component into the project design. The upcoming Transportation Improvement Program (TIP) will also reflect concurrence with the Blueprint Project objectives.
SACOG is currently working to spread the word on the positive results that have been achieved and the lessons learned are being used to help SACOG develop a more comprehensive planning process. A website has also been developed to provide information and increase public involvement in the Blueprint Project and process — http://www.sacregionblueprint.org/.
Colorado — Strategic Transportation, Environmental and Planning Process for Urbanizing Places
The Colorado North Front Range MPO (NFR/MPO) — Strategic Transportation, Environmental and Planning Process for Urbanizing Places (STEP UP) project is an environmental streamlining pilot project that was designed to evaluate procedures and develop tools that would improve transportation, land use and environmental planning early on. STEP UP takes a regional approach to transportation planning. The project was introduced in 2003 to better integrate environmental issues into the planning process. Colorado's workshop participants are key stakeholders in STEP UP, including: Colorado DOT (CDOT), FHWA, the MPOs and the Federal and state resource agencies.
Similar to FDOT's Efficient Transportation Decision-Making (ETDM) process, STEP UP utilizes a GIS-based interactive database to prioritize and screen projects. The resource and local agencies review the environmental database and screen projects for major issues and flaws before the project goes into the TIP. The data is used to generate maps depicting potential growth areas and impacts to critical environmental resources. The information provided or reviewed by participating agencies is available to CDOT, and the database includes potential transportation improvement projects. Land use planning is also part of the STEP UP pilot project2. The objective is for local agencies to use the information developed through the planning process as the project is refined, reducing duplication of effort. The process also includes a Regional Cumulative Effects Assessment (RCEA) element, making it unique in this regard.
CDOT sees the potential for statewide application of STEP UP, beyond MPOs' primary use. Proposed corridors are identified in the visioning process, when needs are identified, and a corridor Environmental Assessment (EA)/Environmental Impact Statement (EIS) project will be used to test the STEP UP pilot project. The NFR/MPO is currently utilizing and revising the process. Phase II of STEP UP involves further development of the GIS tool and will be commenced in Spring 2006. Agencies are currently working to resolve issues such as database ownership and maintenance responsibilities.
Advance Project Planning Report
South Carolina DOT's Advance Project Planning Report (APPR) is an in-depth document, which addresses Purpose and Need, project alternatives, and environmental impacts, and it provides project cost estimates. The APPR goals are two-fold: to provide MPOs and RPOs with information to assist their decisionmaking to determine a project's potential benefits and impacts to the human and natural environments before advancing the project; and to facilitate the project development process once a project is funded by identifying/screening environmental issues of concern and providing this information early in the process, and prior to inclusion of the project in the Statewide Transportation Improvement Program (STIP). The APPR utilizes GIS to screen/identify potential project-related environmental impacts and it is distributed to the Federal and state resource agencies for review and comment.
Idaho — Corridor Planning Guidebook
The Idaho Transportation Department (ITD) is developing a Corridor Planning Guidebook (CPG). Although the CPG existed prior to the workshop, participants committed to updating and revising the document as a strategy in the State Action Plan. ITD Planning and Environmental Sections are designing the CPG to bring parts of the project development process together into a single process. The CPG will assist in the determination of whether to advance the project as an environmental document or to include the project in the corridor plan/study, or both. The guidebook contains a matrix to facilitate this decisionmaking process.
The CPG is currently an internal agency document that may become publicly available in the future. ITD is committed to updating the guidebook and has included it in the FY06 Statewide Planning and Research Workplan for the upcoming fiscal year. The CPG will include the principles of Linking Planning and NEPA, which the agency is already addressing during the corridor planning process. ITD noted that the workshops helped to move the process along, for example, by involving the Federal and state resource agencies.
Maine — Enhanced Scoping Process
Maine DOT's (MDOT) Planning and Environmental Sections are jointly developing the "enhanced scoping process" (ESP) to identify environmental "red flags" during the project development process for select projects. ESP involves collecting data on existing conditions regarding every aspect of the project (environmental resources and transportation infrastructure), with the objective of obtaining the information early on in the process, and reducing repetitive data gathering. ESP involves an interactive user-friendly interface that may be available in the near future. The process is not specifically listed in the State Action Plan, however the Action Plan identifies a need for better information.
New Mexico — Project Evaluation Report
Since the workshop, New Mexico DOT (NMDOT) Planning and Environment has been revising an internal process for the agency's Project Evaluation Report (PER) to prioritize issues and conduct preliminary environmental analysis. District Engineering/Design staff are also involved in the process. The agency is working to improve the PER (including project definition, Purpose and Need, consultation with resource and regulatory agencies and public involvement) before projects are included in STIPs and TIPs.
PERs are prepared within the four- to ten-year planning timeframe and include a checklist of factors to be considered during the project development process (e.g., historic/archaeological resources) and preliminary environmental analysis. PERs have advantages and disadvantages and are not prepared for all projects. For example, NMDOT has determined through experience that the cost-estimating element needs to be improved. The agency is working to address indirect and cumulative impacts and develop corridor-based environmental mitigation strategies (similar to wetlands banking approach). In the future, the GIS environmental overlays for the constraints mapping will be better defined. NMDOT is also working towards extending the use of the PER to MPO/RPO projects and expanding the PER to serve as a starting point for NEPA analysis.
NMDOT has determined that there are opportunities to better link planning and NEPA at the long-range planning phase and in the project definition phase. The agency is working to improve the transition from the long-range plan to the corridor plan to identify projects that are a priority for the corridor. The STIP process is concurrently under review since the more in-depth environmental analysis occurs later in the project development process, during Phase 1 of the STIP. For NMDOT, the PER initiative is less about process and more about getting the right people involved in the project at the right time. The draft PER process has undergone several rounds of internal review with NMDOT leadership and has been approved in concept. Meetings are ongoing to refine the details and a Request for Proposals will be issued in Spring 2006 for a consultant to re-develop the PER and to develop guidance for linking planning and NEPA.
South Dakota — Concept to Construction
Concept-to-Construction (C-to-C) is a new internal South Dakota DOT process that has been implemented to obtain consistency in the project scoping and cost estimating process. Prior to the workshop, SDDOT began developing the process. C-to-C is designed to communicate and track environmental commitments made during project development. Documenting and sharing the results and decisions within SDDOT is also part of the C-to-C process.
Although SDDOT has only five to eight active EAs at any one time and has never done an EIS, the agency has determined that linking planning and NEPA can improve the EA review process where resource agency input is needed. A C-to-C Module consisting of a database of project information is currently being developed.
Tennessee — Interagency Agreement
Tennessee DOT (TDOT) is developing the Tennessee Interagency Agreement (TIA) and process to improve decisionmaking by providing better information to Planning. The TIA will modify the existing project development process, and it will identify steps where Federal and state resource agencies should become involved. The TIA will include guidance on public participation, dispute resolution, early environmental fieldwork, and long-range planning. GIS-based screening criteria will be applied on a case-by-case basis. Once the TIA is in place, MOAs with the resource agencies will be developed to address specific projects.
Formal Lines of Communication
South Carolina — Liaison and Interagency Coordination Effort
In December 2004, South Carolina DOT held a follow-up conference with Linking Planning and NEPA as the theme. The conference was well attended by Federal, state and local transportation and resource agencies including FHWA, U.S. Fish and Wildlife Service, U.S. Army Corps of Engineers, South Carolina Department of Natural Resources, MPOs and Council of Governments. One result was the decision to meet regularly regarding agency processes and to form the Liaison and Interagency Coordination Effort (LICE).
LICE serves as the vehicle to share information and members meet every other month to discuss the environmental permitting and transportation decision-making processes. Areas of overlap in permit requirements are also identified in the process. In December 2005, another follow-up conference will be held to discuss next steps. Project-specific meetings for those projects requiring an EA or EIS are also discussed.
The following recommendations to improve the Linking Planning and NEPA: Towards Streamlined Decisionmaking workshop are derived from the FY05 Quarter 4 Workshop participant interviews:
- Post the State Action Plans and detail state DOT practices on the website to be developed as part of the Linking Planning and NEPA follow-up support.
- Create a "Re: NEPA style" information exchange website or link; this feature will facilitate the exchange of successes, lessons learned, and contact information among state DOTs and the Federal and state resource agencies.
- Tailor presentation materials to the agency's level of integration of planning and NEPA issues; in particular the full integration states need more advanced materials.
- Provide guidance for measuring the effectiveness of State Action Plans.
- Provide Mitigation tracking tools (or offer guidance) to monitor environmental commitments made during the NEPA review process.
- Answer how much NEPA documentation is needed before the NEPA review process commences and who should pay for that work.
- Provide an additional "push" from FHWA to assist state DOTs implement Action Plans.
- Support trainings, workshops, and peer exchanges on related topics (e.g. planning and NEPA, public outreach, GIS, etc.)
back to top
1 The Smart Growth principles are transportation choices, mixed-use developments, compact development, housing choice, and diversity, use of existing assets, quality design and natural resources conservation. (back)
2 See STEP UP Model Planning Process flowchart contained in Phase 1 Report, May 2005 http://www.nfrmpo.org/pdfs/PhaseIReport_v4.pdf (back)
For questions or feedback on this subject matter content, please contact Jody McCullough or Marisel Lopez-Cruz.