|Environmental Review Toolkit|
|NEPA and Project
|Section 4(f)||Water, Wetlands,
|Accelerating Project Delivery|
The 3.4-mile study corridor addressed in the EIS was partially located in the City of Hermann, Missouri, which is part of Gasconade County on the south side of the river. The portion of the project corridor located on the north side of the river was in Montgomery County, immediately south of the City of McKittrick.
Gasconade County Demographics
County Population: 15,342
Racial and Ethnic Composition:
Although the focus of the engineering study and EIS was the actual Route 19 Missouri River Bridge, the study corridor extended beyond the north and south bridge approaches to allow for the development of a full range of preliminary alternatives. Specifically, the study corridor extended from the Route 19 / Route 94 intersection located approximately one mile north of the bridge to a point on Route 19 approximately two miles south of the bridge. The project area also extended approximately one mile east and west of Route 19. The actual proposed improvements, however, covered a shorter distance within that total corridor. The closest other bridges to the Route 19 Missouri River Bridge are located at distances of 27 miles to the east and 40 miles to the west.
Montgomery County Demographics
County Population: 12,136
Racial and Ethnic Composition:
South of the Missouri River, Route 19 is a four-lane facility denoted as Market Street in downtown Hermann. For a short distance immediately south of the bridge, Route 19 is a divided boulevard before becoming an undivided facility with street parking south to the Frene Creek Bridge, at which point it resumes as a two-lane undivided facility. Within downtown Hermann, Route 19 is bounded by commercial and residential uses, while areas to the north of the river and south of the downtown are characterized primarily as agricultural lands.
The structural deficiency of the Route 19 Missouri River Bridge was identified as one of the key "need factors" prompting the study. Prior to completion of bridge rehabilitation in 1998, the National Bridge Inventory rated the existing bridge as structurally deficient, giving it a sufficiency rating of 18 on a scale of 100. MoDOT classifies bridges with sufficiency ratings below 50 as candidates for replacement, and due to its existing low rating, the Route 19 Missouri River Bridge was considered to be a high priority for replacement.
Another critical "need factor" that was identified was the overall geometric deficiency of the bridge. Based on its classification as a minor arterial and the relatively high volume of traffic expected in the design year, the existing 20-foot width of the bridge with two 10-foot lanes and no shoulders is considered to be substandard. According to MoDOT's Project Development Manual, new bridges should be as wide as or wider than the adjacent approach roadway which, in this case, is 44 feet on the north approach or 24 feet wider than the existing bridge. The existing bridge's substandard travel lane width was determined to create unsafe driving conditions for opposing traffic, particularly in the case of large vehicles.
The Route 19 geometric and structural deficiencies were also found to affect traffic operations on the bridge. Specifically, the speed limit on the bridge was posted 20 mph less than for the remainder of the highway, and 40 mph less for trucks. When wide vehicles that extend into the oncoming lane cross the bridge, the opposing traffic must often be stopped before entering the bridge. There were also safety issues on the bridge identified, with difficult accessibility for emergency vehicles to access accidents. In addition, safety issues associated with bicyclists attempting to cross the bridge en route to or from a recreational trail located north of the project were identified.
How Project Development Advanced to the NEPA Process
The NEPA process for the Route 19 Missouri River Bridge project took 24 months, from Notice of Intent (NOI) to Record of Decision (ROD). The bridge assessment deficiencies and resulting low rating, the efforts of the local transportation committee, federal support and an increased needfor a higher capacity bridge due to local economic growth led to the proposed action presented in the EIS. This project was advanced directly to the NEPA process without extensive advanced planning, primarily due to the urgency of the need for improvement.
NEPA EIS Process
Shortly after the NOI was issued in May 1998, public information and agency meetings were held and a total of three newsletters were prepared prior to each public information meeting and the public hearing as a means to solicit public involvement and support. Other sources of distribution included news releases and articles in numerous local papers, radio stations, and television stations. A telephone information line with a toll-free number was also established, which continued to remain in service until the Final EIS was approved and Record of Decision was issued as a means to discuss ideas and concerns outside of the public meetings. Another source for public involvement was the information repositories at the Hermann City Hall and Hermann Advertiser-Courier office. This allowed residents to drop off comment cards between meetings and provided topic discussions for future public meetings.
An important element of the public involvement process used during preparation of the EIS was the project advisory committee (PAC), which consisted of representatives from local and county government, area businesses, resource agencies, and study area residents. The PAC served in an advisory role to the project team and acted as a liaison to study area residents. The PAC specifically provided input during data gathering, development and refinement of alternatives, and impact analyses. A total of three PAC meetings were held between July 1998 and the spring of 1999.
Key Factors of the NEPA Process
The PAC worked parallel with a group of community business leaders who comprised the local Transportation Corporation. This Corporation helped push for the bridge's high priority status. They were responsible for developing funding schemes to ensure that the bridge would receive a twenty percent match from the state and sixty percent match from the federal government. Their solution was to create a toll bridge that would allow the locals to contribute their twenty percent match.
The Route 19 Missouri River Bridge project was advanced as a merged NEPA — Section 404 process. A nationwide permit was required for impacts associated with the new bridge piers borings while an individual permit was required for impacts to wetlands north of the river. Both the Army Corps of Engineers and the Coast Guard participated in the NEPA process as Cooperating Agencies.
There was no opposition to this project either politically or locally. Due to the low bridge inventory rating and safety issues associated with the existing substandard design of the bridge, all parties understood that major improvements were necessary. The only major debatable issues that were raised related to saving the existing bridge and making the new bridge with a four-lane capacity.
A group called the Brush and Palette Club (BPC), a well-known and well-established group with a statewide reputation for its preservation efforts, joined with Trail.net, another well-known preservation group, to preserve, maintain, and promote the use of the bridge as a pedestrian corridor to the KATY Trail State park across the Missouri River. However, neither of the two groups was financially able to accept the responsibility of acquiring and maintaining the bridge and no other groups were identified. Therefore, once the construction of the new bridge is finished, it is intended that the old one will be demolished. That decision is also consistent with regulatory limitations regarding structures over the railroad that crosses underneath the current and proposed bridges.
Another group of residents thought that traffic would move better if the new bridge consisted of four lanes and would keep with the existing cultural and visual continuity of the area. However, since the approach roadway immediately to the north of the bridge and again south of the town of Hermann consisted of only two lanes, a change in the number of lanes would not be necessary or appropriate. This reasoning was also based on 20-year traffic projections for the area that showed that the number of vehicles on the highway would likely decline. The reason that the highway had originally been constructed with four lanes in the City of Hermann itself was because the city was built as a replica of its sister city in Germany, which had four lanes.
The comments received during the NEPA process were addressed and, if warranted, incorporated into the proposed action presented in the EIS. The Draft EIS was approved in February 1999, followed by a public hearing in March 1999. The Final EIS was approved a year later in February 2000. The Record of Decision was then issued in May 2000.
The Preferred Alternative "5-W1" included the construction of a new bridge approximately fifty feet west of the existing bridge and the recent reconstruction of Route 19 on elevated causeway on the north side of the bridge. The proposed improvements would include reconstruction and realignment of a portion of the elevated causeway on the north side of the river so that it would align with the new bridge. On the south side of the river, the highway would be realigned to its intersection with Route 100 in downtown Hermann. The new bridge and the reconstructed segment of Route 19 north of the bridge would have two 12-foot travel lanes (one in each direction), with paved shoulders north of the bridge and a protected bike lane on the bridge. South of the bridge, the highway would continue to have four lanes, although the intersection with Route 100 would be restriped for designated turning lanes. A toll booth being proposed by the local Transportation Corporation would be located immediately to the north of the bridge.
Together, these strategies would fully address the structural and operational deficiencies motivating the project, while minimizing environmental impacts at a slightly reduced cost. This alternative was considered to provide the best balance among social, economic, and natural resource impacts, and would be consistent with input received from study area residents.
Other Alternatives Considered
Aside from the Preferred Alternative, two other alternatives were seriously considered in the EIS. They included a No-Build Alternative, which was limited to routine pavement maintenance, and "Alternative 5-E1," which was generally similar to the Preferred Alternative. Although not selected, the No-Build Alternative was used as the baseline to evaluate improvements resulting from the Preferred Alternative as well as "Alternative 5-E1". A variety of other alternatives were initially considered as well, but they were rejected without detailed study.
"Alternative 5-E1" included the same basic improvements as the Preferred Alternative, although the new bridge would be constructed fifty feet east of the existing bridge instead of to the west. In order to connect the new bridge to Route 19, "Alternative 5-E1" required the construction of a slight S-curve to the north of the bridge. In contrast, the Preferred Alternative would result in a straight alignment of the approach roadway and direct connection with the bridge. While both alternatives would be safe, driver expectancy on the Preferred Alternative was considered to be more consistent than that of "Alternative 5-E1" due to the elimination of an S-curve to the north. As a result, "Alternative 5-E1" was not selected as the Preferred Alternative.
Environmental and Other Issues
Summary of Environmental Issues
There were several issues associated with the Preferred Alternative. These included: removal of the existing Route 19 Bridge; potential adverse impacts to five threatened or endangered species; a loss of 0.8 acres of wetlands; loss of 2.7 acres of floodplain; and the relocation of one business. Of these issues, only the potential impacts to the existing bridge were considered controversial.
Key Players in the NEPA Process
The most prominent issue in the project was related to cultural resources. The Missouri State Historic Preservation Office (SHPO) was very involved in the entire evaluation process. Not only was a portion of the City of Hermann a registered historic district, known as the Hermann Historic District, but the Route 19 Missouri River Bridge was determined eligible for inclusion on the National Register of Historic Places. The Preferred Alternative was determined not to directly impact upon the Hermann Historic District, but it was concluded that removal of the bridge would have an adverse effect.
A number of comments received during the NEPA process supported preserving the existing Route 19 Missouri River Bridge. As a result, MoDOT agreed to preserve the bridge if a responsible group or agency could be found that was willing to accept ownership of it, along with responsibility for maintenance, liability and repair of the bridge. Details of MoDOT's responsibilities for advertising for a responsible party to take possession of the bridge, as well as requirements for any transfer of ownership of the bridge and demolition in the event that such responsible party was not found were provided in a Memorandum of Agreement (MOA) between FHWA, MoDOT, the SHPO and the local Transportation Corporation. The MOA also ensured that the SHPO would be allowed to provide input on the design of the new bridge.
The impacts to the Route 19 Missouri River Bridge met the criteria for preparation of a programmatic Section 4(f) evaluation rather than for a more detailed and time consuming individual Section 4(f) evaluation. This streamlined process eliminated the need to coordinate with the U.S. Department of Interior regarding impacts to the bridge and associated mitigation, and kept interagency coordination between the agencies that were directly involved in the process.
Although five federally listed threatened or endangered species were identified as possibly existing in the project area, it was determined that the only species that could potentially be impacted by the Preferred Alternative was the pallid sturgeon. In response to FHWA's request for concurrence from the Fish and Wildlife Service (FWS) through the Section 7 consultation process, FWS did not concur with FHWA's findings of no adverse impacts to the pallid sturgeon. While listed on the Endangered Species list, the relative abundance of this fish one mile upstream and downstream of the existing structure was unknown and required an additional biological assessment in order for the FWS to potentially concur. At the time of the issuance of the ROD for this project, informal Section 7 consultation regarding the pallid sturgeon was continuing, although construction of the bridge could not occur until an opinion as to whether the fish would be adversely affected by the project was issued by the FWS. This status has not changed since that time.
In terms of wetland impacts, construction of the Preferred Alternative would result in the permanent reduction of some functions of a 0.1-acre emergent wetland that will be spanned, temporary impact to 0.6 acres of wetlands, and filling of 0.1 acres of an excavated deepwater aquatic habitat, thereby totaling 0.8 acres of impact. In the case of floodplains, it was determined that the proposed improvements would have no significant long-term impacts on natural and beneficial floodplain values despite the loss of 2.7 acres of floodplain.
The only relocation that would be required is the replica of a steamboat Pilot House built in the 1970s to house the original wheel of a steamboat that operated on the Missouri River during the 1920s. The Pilot House does not meet eligibility criteria for the National Register.
Design of the approach roadways was completed in the spring of 2002. At this time, the design phase of the Route 19 Missouri River Bridge is ongoing. Currently, there is concern that the status of this project could be suspended due to funding issues. Therefore, there is no construction date set and plans for the demolition of the present bridge are also on hold.
The Route 19 Missouri River Bridge Project showed that the NEPA process could be expedited by:
These two factors are discussed in detail below.
Actively Engage in a Detailed Public Involvement Strategy and Build Local Support
A detailed public involvement plan provided project area residents, local government officials, and state and federal review agencies with ample participation opportunities. Additionally, a large amount of information about the project was disseminated to the public and local agencies, much of which focused on the project's high priority.
Local Transportation Corporation Activity
An important element of the public involvement process was the formation of the PAC and the local Transportation Corporation. Whereas the PAC was organized and led by MoDOT and its consultant, the local Transportation Corporation was entirely created and implemented by local citizens taking an active role in the process. The Transportation Corporation, in particular, played a vital role in promoting and financing the local share of this high priority project.
The proactive public involvement process pursued during this project engaged the local citizens, enabled them to be active participants in the NEPA process, and gave the local community an opportunity to voice their ideas and concern about the project. Overall, these factors helped maintain and build local support for the project, which ultimately contributed to the timeliness of the NEPA process. In the end, it was the local support and public's recognition of the need for the project that was most effective in allowing the NEPA process to proceed relatively smoothly and quickly.
Stimulate Effective Interagency Coordination
"There was unilateral support from federal and state level agencies."
–Buddy Desai, CH2M HILL consultant
Although the project is essentially an in-kind bridge replacement project, a decision was made to prepare a full EIS from the outset due to the extensive rehabilitation that would otherwise be required to effectively fix the problems on the bridge, the number of environmental issues involved, and the existence of a memorandum by FHWA and the Coast Guard requiring that an EIS be prepared for all projects where there are historic issues and navigable waters involved. The decision to prepare an EIS from the outset avoided the potential need to initiate the EIS process at a later stage at the specific request of the review and regulatory agencies.
There was a significant amount of interagency coordination during this project. The Route 19 Missouri River Bridge project was conducted using a merged NEPA — Section 404 process, with the Army Corps of Engineers and the Coast Guard serving as Cooperating Agencies. This merged permit was an attempt to integrate the overall environmental review and approval for the project by aligning the key components and requirements of both the NEPA and Section 404(b)(1) permit processes at appropriate stages. This was a formalization of responsibility, but not a relinquishment of agency rights.
"Key tasks had deadlines that were specifically assigned and strictly adhered to due to pre-deadline communication, post deadline praise, and professionalism of those involved. Early and continued involvement with outside agencies allowed us to obtain face to face signatures on critical documents instead of the usual‘Snail Mail’ method where documents seem to fall into a black hole for months at a time."
–Mark Giessinger, MoDOT
A major component of this merged process was the integration and involvement of the Army Corps of Engineers during the preparation and review of the actual EIS documents, rather than waiting to solicit their detailed participation in the later permitting stage. The Corps concurred with the purpose and need for the project as well as the range of alternatives early on during EIS preparation. When later applying for the 404 permits, the efforts needed to obtain them were less time consuming as well. While this merged NEPA — Section 404 process had been used for other projects in Missouri in the past, this was one of the first projects in which the process truly had a successful streamlined outcome. Both the Corps and Coast Guard were present at the public hearings with their own booths available to answer questions raised by the general public.
"One of the reasons for the rapid development of this EIS was that no 4(f) involvement with the Department of Interior was required ... a programmatic 4(f) was developed."
–Peggy Casey, FHWA
The City of Hermann is a high profile community due to its number of festivals and popular recreational and cultural resources. One of the biggest concerns was the fact that, not only was a portion of the city a historic district, but the bridge was eligible for the National Historical Register. After much cooperation with the State Historic Preservation Office, a Memorandum of Agreement (MOA) was signed, documenting the coordination of possible demolition, designs for the new bridge, and construction-related issues in order to protect the Hermann Historic District. This process moved relatively smoothly and the project was advanced using a programmatic Section 4(f) evaluation rather than the more time-consuming individual Section 4(f) evaluation requirements.
Interagency coordination was overseen and assisted by the environmental consultant. The consultant's role was critical in addressing environmental issues and other project complexities in an effective and timely manner. The consultant helped drive the proactive process of decision making between the PAC, the local Transportation Corporation, the federal agencies, and the state resource agencies.