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Transportation for Communities - Advancing Projects Through Partnerships


Applications - Linking MPO Planning and NEPA

Linking MPO Planning and Environmental Review picture

When a transportation improvement project is being considered, many residents believe that the bulldozers will arrive tomorrow. In contrast, the MPO Long Range Plan is often viewed as part of the distant and uncertain future. Linking long range planning and environmental review can help overcome this public confusion and focus stakeholder engagement as well as save time and money.

The graphic above illustrates the close correlation between actions in transportation planning and those in the NEPA process. Planning starts with the community context and is grounded in strong public and stakeholder involvement. Using this planning data can inform NEPA about community support for a project and potential controversial areas. The public is often frustrated when planning decisions are changed during NEPA. Additional details and effectively linking the two processes can help the public understand the relationship between the plan and the project. Environmental screening initiated in long range planning enables advanced mitigation of environmental and community impacts.

In order to effectively integrate planning and NEPA, documentation is essential. This record keeping allows decisions made in planning to be supported during NEPA without the need for re-do loops. This challenge to integration can be addressed through data and tools as well as documented decisions.

Linking planning and NEPA allows projects to move more quickly by building on existing decisions and taking advantage of prior work; thus, reducing the redundancy in decision making. When NEPA practitioners and planners collaborate to successfully integrate the products from long range planning into the consideration of project alternatives, project development is more efficient, programming is more realistic, and early protection of the environment is possible. This application identifies the data, analysis, and decisions that transfer between the processes as well as the individual key decisions that they support.

To get a snapshot of each Key Decision, roll over the Decision Guide graphic below. Click on any individual Key Decision to access detailed information including: purpose and anticipated outcomes; partner roles; integration with external planning processes; linkages across phases; questions to assist decision makers; and data, tools, technologies that support the decision.

Key Decisions that are grayed-out have no specific relevance to the individual Practical Application or topic area but are still accessible from this graphic.

Dg-darkgrey-titlebar-corner-left LONG RANGE TRANSPORTATION PLANNING

LRP-1

Project specific information gathered in scoping the LRTP is transferred to the ENV-1 for inclusion in project scoping.

LRP-1 Approve Scope of LRTP Process
LRP-2

The regional vision and goals informs the project scope at ENV-1.

LRP-2 Approve Vision and Goals
LRP-3

The evaluation criteria and methods used in LRP, along with associated metrics, is considered in the development of project evaluation criteria at ENV-5.

LRP-3 Approve Evaluation Criteria, Methods and Measures
LRP-4

Transportation deficiencies, especially those in the project area, inform purpose and need for ENV-3.

LRP-4 Approve Transportation Deficiencies
LRP-5

At this key decision information from the Programming / Fiscal Constraint Phase is introduced into the LRTP decision making process.

LRP-5 Approve Financial Assumptions
LRP-6

The approved range of strategies from LRP provides a regional context for scoping environmental review (ENV-1).

LRP-6 Approve Strategies
LRP-6

The approved range of strategies from LRP provides a regional context for scoping environmental review (ENV-1).

LRP-6 Approve Strategies
LRP-7

The basis for the elimination of specific scenarios in long range planning (including associated data and level of detail) informs the determination of an appropriate study area for the project at ENV-4. This information may also be used for documentation purposes at ENV-6.

LRP-7 Approve Plan Scenarios
LRP-8

The adopted preferred plan scenario identifies the strategy used to address the transportation deficiency as well as the project concept that will be used for programming. This information informs the selection of alternatives at ENV-7.

LRP-8 Adopt Preferred Plan Scenario
LRP-9

Air Quality conformity analysis is done within the air quality process in order to validate that the preferred scenario meets current conformity requirements.

LRP-9 Adopt Finding of Conformity by MPO
LRP-10

The adopted LRP informs the scope of environmental review (LRP-1). Any advance mitigation strategies and agreements inform avoidance, minimization and mitigation incorporated at ENV-8, ENV-12 and ENV-15.

LRP-10 Adopt LRTP by MPO
LRP-11

Approval of the conformity analysis is essential information to inform the Draft EIS at ENV-8.

LRP-11 Approve Conformity Analysis

Dg-darkgrey-titlebar-corner-left PROGRAMMING

PRO-1

This key decision establishes the revenue basis for both the fiscal constraint of the long range plan as well as the funding sources for the TIP.

PRO-1 Approve Revenue Sources
PRO-2

This key decision establishes a consistent methodology for estimating project costs for both the long range transportation plan and the TIP.

PRO-2 Approve Methodology for Identifying Project Costs and Criteria for Allocating Revenue
PRO-3

This key decision establishes the list of projects drawn from the long range plan or corridor planning process that will be considered for funding in the TIP.

PRO-3 Approve Project List Drawn from Adopted Plan Scenario or Solution Set
PRO-4

At this key decision, the approved project list is prioritized using the methodology previously developed.

PRO-4 Approve Project Prioritization
PRO-5

At this key decision project priorities are compared to available funding within program restrictions to select those projects to be included in the TIP.

PRO-5 Reach Consensus on Draft TIP
PRO-6

At this key decision, the MPO adopts the TIP. Before the MPO can do this, comments on the draft TIP must be addressed and a final TIP must be produced.

PRO-6 Adopt TIP by MPO
PRO-7

The Governor or designee should ensure that the TIP meets other state and federal requirements so that the TIP can be incorporated into the STIP and be in agreement with the state document.

PRO-7 Approve TIP by Governor and Incorporate into Draft STIP
PRO-8

At this key decision the draft STIP is developed to release for public comment.

PRO-8 Reach Consensus on Draft STIP
PRO-9

In order to meet federal requirements, the STIP must meet conformity and fiscal constraint, where required.

PRO-9 Approve STIP with respect to Conformity and Fiscal Constraint

Dg-darkgrey-titlebar-corner-left CORRIDOR PLANNING

COR-1

This is a crucial first step of corridor planning.

COR-1 Approve Scope of Corridor Planning Process
COR-2

The full range of deficiencies and opportunities within a corridor are defined at this key decision.

COR-2 Approve Problem Statements and Opportunities
COR-3

At this key decision a broad range of transportation, community, and environmental goals are considered which are specific to the corridor.

COR-3 Approve Goals for the Corridor
COR-4

In order to provide a clear linkage to the environmental review process, this key decision defines the acceptable level of detail for the corridor study analysis.

COR-4 Reach Consensus on Scope of Environmental Review and Analysis
COR-5

At this key decision, evaluation criteria, methodology and performance measures are approved that will allow decision-makers to compare solutions that address the corridor's opportunities and problems and are consistent with the approved corridor goals.

COR-5 Approve Evaluation Criteria, Methods and Measures
COR-6

A range of approved solution sets for the corridor results from this key decision.

COR-6 Approve Range of Solution Sets
COR-7

At this key decision, a preferred solution set is adopted for inclusion in the Corridor Plan.

COR-7 Adopt Preferred Solution Set
COR-8

At this key decision priorities for implementation of the individual solutions are established.

COR-8 Approve Evaluation Criteria, Methods and Measures for Prioritization of Projects
COR-9

Individual projects within the adopted preferred solution set are ranked in order to identify the appropriate sequencing for implementation.

COR-9 Adopt Priorities for Implementation

Dg-darkgrey-titlebar-corner-left ENVIRONMENTAL REVIEW/NEPA MERGED WITH PERMITTING

ENV-1

Project specific information from LRTP scoping (LRP-1), the regional vision and goals (LRP-2) and the adopted LRTP (LRP-10) inform the scope of the environmental review. The approved range of strategies (LRP-6) provides a regional context.

ENV-1 Reach Consensus on Scope of Environmental Review
ENV-2

This key decision is required to satisfy the legal requirement of publishing a Notice of Intent (NOI) to inform partners and the public of the commencement of the environmental review phase.

ENV-2 Approve Notice of Intent
ENV-3

Transportation deficiencies from the regional analysis (LRP-4) provide the basis for the traffic analysis and forecast required for purpose and need. The purpose and need should be consistent with the regional vision and goals (LRP-2).

ENV-3 Approve Purpose and Need/Reach Consensus on Project Purpose
ENV-4

Regional data along with specific scenarios that were eliminated in the planning phase (LRP-7) inform identification of the initial project study area.

ENV-4 Reach Consensus on Study Area
ENV-5

The evaluation criteria, methods and measures for comparing alternatives is informed by that used in LRP-3 specific to this need and project concept.

ENV-5 Approve Evaluation Criteria, Methods and Measures
ENV-6

The identification of the full range of alternatives should be consistent with those approved in LRP-7.

ENV-6 Approve Full Range of Alternatives
ENV-7

The preferred plan scenario from LRP-8 informs the alternative carried forward in order to preclude inconsistencies with region-wide multimodal improvements.

ENV-7 Approve Alternatives to be Carried Forward
ENV-8

An advance mitigation strategy and agreements from the LRTP (LRP-10) should inform conceptual mitigation incorporated in the Draft EIS.

ENV-8 Approve Draft EIS with Conceptual Mitigation
ENV-9

This key decision is required to satisfy the regulatory requirement for Section 404 permitting that the public receive notice of a permit application.

ENV-9 Approve Resource Agency Public Notice
ENV-10

The preliminary design of the preferred alternative/LEDPA must be validated with the adopted LRTP (LRP-10) to ensure consistency, fiscal constratint and that air quality conformity is maintained. Plan amendment may be required.

ENV-10 Approve Preferred Alternative/
LEDPA
ENV-11

This decision is a required procedural step in the Section 404 permitting process. At this step, a final determination of jurisdictional waters of the United States in the project area is made.

ENV-11 Approve Final Jurisdictional Determination
ENV-12

An advance mitigation strategy and agreements from the LRTP (LRP-10) should inform avoidance and minimization for the LEDPA.

ENV-12 Reach Consensus on Avoidance and Minimization for the LEDPA
ENV-13

A final EIS is approved that meets all legal requirements and addresses comments received on the Draft EIS.

ENV-13 Approve Final EIS
ENV-14

At this step in the environmental review phase, the Record of Decision is issued.

ENV-14 Approve the Record of Decision
ENV-15

An advance mitigation strategy and agreements from the LRTP (LRP-10) should inform avoidance, minimization and compensatory mitigation incorporated in permit conditions.

ENV-15 Render Permit Decision and Approve Avoidance and Minimization
 

The Transportation for Communities Approach

Linking MPO planning with the environmental review process under NEPA provides consistency between the selected project alternative and the adopted long range transportation plan. TCAPP provides the structure needed to identify those key decisions in long range transportation planning and environmental review that must remain coordinated and/or consistent in order to avoid the associated risks of re-do loops and other inefficiencies that impact funding and schedules.


Because the Decision Guide identifies specifically what information should be transferred between phases and for what purpose at individual key decisions, practitioners interested in collaboration as a means to link MPO planning and NEPA will find the support needed. Supporting information includes:

  1. The roles and interests of decision makers and key participants
  2. Information that should be transferred at individual key decisions
  3. Supporting data, tools, and technology for collaboration between the phase

Federal support for the concept

Federal law and guidance clearly supports linking planning and NEPA. SAFETEA-LU supports the integration of planning and NEPA through implementing guidance and regulations for planning (see AASHTO CEE - Environmental Considerations in Planning) The National Environmental Policy Act and the Council on Environmental Quality regulations encourage linking planning and NEPA (see 40 CFR Chapter V Section 1501.2 Apply NEPA early in the process). In addition, existing case law upholding the use of planning products in the NEPA process, support linking of planning and NEPA. Legislation and guidance encourage collaboration between planners and NEPA practitioners in order to achieve several benefits including:

  • Increased consultation among partners
  • Identification of potential broad scale mitigation opportunities
  • A clear authority to use planning level analyses and decisions during NEPA

For additional guidance see FHWA Planning and Environment Linkages Website.

Decision Making Partner Interests in Long Range Planning and Environmental Review

The Decision Guide data is based on considering all partner interests in transportation decision making: in other words, the specific perspective or values that a decision making partner brings into the process. For example, FHWA has an "interest" in ensuring that the requirements of the federal regulations are met. The Decision Guide considers the identified interests of the four partners and of the stakeholders in each phase of transportation decision making. The table below allows you to compare the interests of each partnering agency in both long range planning and environmental review. An understanding of interests may provide additional understanding for efforts to integrate these two phases.

Agency Partner Interests in Long Range Planning Partner Interests in Environmental Review
FHWA
  • Is collaborative and inclusive with stakeholders and the public
  • Reflects the community vision and goals
  • Protects the use of public funds
  • Meets all legal and regulatory requirements
  • Meets air quality conformity
  • Is collaborative and inclusive with stakeholders and the public
  • Built on the foundation of previous processes
  • Correctly/accurately describes the process.
  • Meets legal and regulatory requirements
DOTs
  • Considers state needs and deficiencies equally with other concerns
  • Considers how proposed uses affect functional classification and system ownership
  • Reflects interconnectivity decisions that will not adversely affect the state's system
  • Does not create a problem for design, maintenance, operations, and expansion
  • Conforms with the TIP/STIP
  • Meets air quality conformity
  • Is collaborative and inclusive with stakeholders and the public
  • Is comprehensive and fully disclosed
  • Incorporates input from regulatory agencies and other partners
  • Builds on previous processes
  • Begins after funding has been identified for a project
  • Based on an agreement among all partners as to the content of the NEPA document
  • Reflects streamlining through meaningful participation by all with attention to budget and schedule
  • Meets FHWA approval
MPOs
  • Is fiscally constrained
  • Meets federal regulations
  • Conforms to air quality requirements
  • Is developed with broad consultation
  • Ensures equity (political, geographic, social)
  • Promotes consistency between transportation improvements and state/local planned growth and economic development patterns (land use)
  • Explores all possibilities and is realistic
  • Increases the accessibility and mobility for both people and freight
  • Enhances integration and connectivity across modes for people and freight
  • Emphasizes the preservation of the existing transportation system
  • Promotes efficient system management and operation
  • Increases the safety of the system for all users
  • Increases the security of the system for all users
  • Addresses the economic vitality of the area
  • Promotes energy conservation and quality of life
  • Protects and enhances both the human and natural environment
  • Is well documented in order to inform planning processes
  • Follows a public participation process
  • Is consistent with the program and long range transportation plan or identifies the reason for any changes.
  • Is consistent with regional information relied upon to develop the long range plan such as land development and conservation planning
Resource Agencies
  • Incorporates conservation planning
  • Incorporates and document large scale avoidance and minimization
  • Consider indirect and cumulative impacts/land use issues
  • Builds on the foundation of previous planning processes
  • Is legally sufficient
  • Is coordinated with other permitting requirements (e.g. Clean Water Act)
  • Follows an appropriate sequence - avoid, minimize, mitigate
  • Addresses a true need/deficiency
  • Based on an agreement among all partners as to the content of the NEPA document
  • Is inclusive of the public and stakeholders

RISKS AND RISK MANAGEMENT
TCAPP provides several resources to assist in risk management of efforts to link MPO planning and NEPA. The table below can help guide you to the appropriate area of the site.

Risks Risk Management Strategies

Overcoming The Different Scale of Information in Planning and NEPA

Overcoming the different scales of planning and NEPA can be a challenge. Planning solutions are meaningful at a systems level while NEPA analysis is more detailed, smaller in scale, and greater in precision. While some decisions can be transferred directly from planning to NEPA, other decisions can only be used to inform the environmental review process. Tiered decision making, using sub-area or corridor studies, can help refine the level of analysis to more easily address the requirements within the NEPA process. Scale is also a factor in the specific tools used to support analysis at the regional and project level.

Use Sub-area and Corridor Studies: For some projects, one way to minimize the scale issues of linking planning and NEPA is to conduct additional planning studies, such as sub-area and corridor studies. These studies allow planners to gather additional details on the project, including potential environmental impacts. This additional level of detail allows a tiering down of decision making. See Corridor Studies application.


Use Supporting Tools and Technology: Although the tools most often used for a systems-level analysis are not sufficient for analysis at the project level, there are supporting technologies that reduce the need for duplicative efforts. Capacity analysis and the use of simulation modeling are two areas where the scale difference may be bridged. For additional potential supporting technologies, visit the Tools and Technologies section of the site.

Increased Demand on Staff and Agency Resources

Linking planning and NEPA is sometimes perceived as requiring additional work of the MPO staff and resource agencies where resources are limited. This demand is often magnified by a lack of understanding of the individual agency processes and requirements. Collaboration, either through formal agreement or informal working relationships, can improve these challenges over time. The NEPA process requires strong documentation; therefore, one essential requirement is for good, standardized documentation of information (data, decisions and analysis) that are to be passed from LRP to NEPA in order to avoid revisiting decisions made in planning.

Develop Cooperative Agreements: In some cases, cooperative agreements between planning partners may aid in the availability of staff and resources. MOU/MOA represent formal ways to establishing decision making relationships and sharing of resources, but there are many other less formal ways to collaborate. Some state DOTs fund positions at resource agencies to support transportation needs. This strategy can support planning activities as well as project involvement during NEPA. See Collaboration Assessment for strategies related to cooperative agreements. (Organizational Support, Decision Making Authority, Shared Goals.


Increase Collaboration between Planners, NEPA Practitioners, and Resource Agencies: Linking planning and NEPA requires that NEPA practitioners and resource agency representatives understand and accept the analyses and decisions made during planning. One way to accomplish this is for partners to know, understand, and accept each other's interests. The Decision Guide identifies where individual partners' interests are integral to the decisions being made so they can be engaged so their participation can be focused. In this way increased collaboration, communication, and coordination between partners establishes a process that is efficient and effective.


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