«Prepared for: American Association of State Highway and Transportation Officials (AASHTO) Standing Committee on the Environment Prepared by: ICF ...»
Effective Project Management for NEPA
American Association of State Highway
and Transportation Officials (AASHTO)
Standing Committee on the Environment
The information contained in this report was prepared as part of NCHRP Project 25-25,
Task 27 National Cooperative Highway Research Program, Transportation Research
This study was requested by the American Association of State Highway and Transportation Officials (AASHTO), and conducted as part of the National Cooperative Highway Research Program (NCHRP) Project 25-25. The NCHRP is supported by annual voluntary contributions from the state Departments of Transportation. Project 25- 25 is intended to fund quick response studies on behalf of the AASHTO Standing Committee on the Environment..The report was prepared by Chris Paulsen of ICF Consulting was the Principal Investigator. Tanvi Lal of ICF Consulting and Marie Venner of Venner Consulting, Inc. provided support. The work was guided by a task group chaired by Brent Jensen which included Kelly Dunlap, Bill Hauser, Tim Hill, Shane Marshall, and Neel Vanikar. The project was managed by Christopher Hedges, NCHRP Senior Program Officer.
Disclaimer The opinions and conclusions expressed or implied are those of the research agency that performed the research and are not necessarily those of the Transportation Research Board or its sponsors. The information contained in this document was taken directly from the submission of the authors. This document is not a report of the Transportation Research Board or of the National Research Council.
Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by NCHRP, the Transportation Research Board or the National Research Council.
Page ii Table of Contents List of Acronyms
1.1 Study Overview and Purpose
1.2 Literature Search
1.3 Web-based Survey and Findings
1.4 Telephone Interviews
1.5 Concerns Related to Managing NEPA Projects
1.6 Concerns Related to Project Management
1.7 Training and Tools
1.8 Organization of the Remainder of this Report
2 The Role of the NEPA Project Manager
3 Importance of Project Management in the NEPA Process
4 Earlier Decision-making: Linking Planning and NEPA
4.1 SAFETEA-LU and Long-Range Planning
4.2 Planning and Environmental Linkages
4.6 Guidance for Implementing Planning and Environmental Linkages
4.7 DOT Examples of Linking Planning and NEPA
4.8 Getting Started – FHWA Resources
5 Scoping Process Improvements at DOTs
5.1 Scoping for NEPA
5.2 Importance of Scoping
5.3 Documentation of the Scoping Process
5.4 DOT Scoping Process Examples
6 Management of the NEPA Phases
6.1 Purpose and Need
6.2 Development and Consideration of Alternatives
6.3 Affected Environment
6.5 Mitigation and Permitting
6.6 Public Involvement - A Clear, Open, Transparent Process
6.7 Context Sensitive Solutions
6.9 Preparing Quality Documents
7 Project Management
7.1 Risk Management: What is it? How to Approach it
7.2 Schedule Management
7.4 Systems to Manage Project Work, Environmental Permits and Activities........... 76
7.3 Human Resources Management
7.4 Training: Know NEPA and Inter-relating Processes
Page iii List of Exhibits Exhibit 1. Geographic Distribution of In-Depth Telephone Interview Participants.............3 Exhibit 2. Exhibit Risk Types Covered in a FDOT Risk-Based Graded Approach Analysis
Exhibit 3. Florida DOT Risk-Based Graded Approach Worksheet
Exhibit 4. Florida DOT Risk-Based Graded Approach Worksheet
Appendix A – Annotated Bibliography Appendix B – Web-based Survey and Respondents Appendix C – Telephone Interview Questions and Respondents Appendix D – State DOT NEPA Manuals
Page v EMS Environmental Management System EO Executive Order EPA US Environmental Protection Agency EPD Environmental Programs Division (MDSHA) EPIC Environmental Permits, Issues and Commitments (TxDOT) ESA Endangered Species Act EST Environmental Screening Tool ETDM Efficient Transportation Decision-Making Process (FDOT) ETRACK NYSDOT Tracking Database ETS Environmental Tracking System FDOT Florida Department of Transportation FEIS Final Environmental Impact Statement FHWA Federal Highway Administration FONSI Finding of No Significant Impact FTA Federal Transit Administration GIS Geographic Information System HOV High-Occupancy Vehicle HOT High-Occupancy/Toll ITD Idaho Transportation Department iPM Integrated Project Management (VDOT) KYTC Kentucky Transportation Cabinet LEDPA Least Environmentally Damaging Practicable Alternative LOS Level of Service MDE Maryland Department of Environment MDOT Michigan Department of Transportation MDSHA Maryland State Highway Administration MMRR Mitigation Monitoring and Reporting Record (Caltrans) Mn/DOT Minnesota Department of Transportation MoDOT Missouri Department of Transportation MOA Memorandum of Agreement MOU Memorandum of Understanding MPO Metropolitan Planning Organization NCDOT North Carolina Department of Transportation NCHRP National Cooperative Highway Research Program NDOT Nevada Department of Transportation Page vi NEPA National Environmental Policy Act NHI National Highway Institute NHPA National Historic Preservation Act NJDOT New Jersey Department of Transportation NMDOT New Mexico Department of Transportation NPDES National Pollutant Discharge Elimination System NYDOT New York State Department of Transportation ODOT Ohio Department of Transportation ODOT Oregon Department of Transportation PAM Permits, Agreements, and Mitigation (Caltrans) PDCA Plan-Do-Check-Act PD & E Project Development and Environmental Manual PDF Portable Document Format PDP Project Development Process PEAR Preliminary Environmental Analysis Report (Caltrans) PEL Planning and Environmental Linkage PennDOT Pennsylvania Department of Transportation PM Project Management/Project Manager PMP Project Management Plan PMRS Project Management and Reporting System (WSDOT) PPMS Program Project Management System (NMDOT) PRSM Project Resourcing and Schedule Management (Caltrans) PS&E Plans, Specifications, and Estimates PSR Project Study Report QA/QC Quality Assurance/Quality Control QFD Quality Function Deployment QP Quality Planning RE Resident Engineer ReTRAC Reno Transportation Rail Access Corridor ROD Record of Decision ROW Right-of-Way
SAFETEA-LU Safe, Accountable, Flexible, Efficient Transportation Equity Act:
A Legacy for Users SCOE Standing Committee on the Environment (AASHTO) SDDOT South Dakota Department of Transportation Page vii SHOPP State Highway Operation and Protection Program (Caltrans) SMART Specific, Measurable, Agreed To, Realistic, and Time-Constrained Performance Standards SQL Standard Query Language STEP UP Strategic Transportation, Environmental and Planning Process for Urbanizing Places (Colorado DOT) STIP Statewide Transportation Improvement Program STRAHNET Strategic Highway Network TDOT Tennessee Department of Transportation Transportation Equity Act for the 21st Century TEA-21 TIP Transportation Improvement Plan TPR Transportation Planning Region TxDOT Texas Department of Transportation U.S.C. United States Code USCG US Coast Guard USFWS US Fish and Wildlife Service USGS United States Geological Survey VDOT Virginia Department of Transportation VDRPT Virginia Department of Rail and Public Transportation VE Value Engineering WSDOT Washington State Department of Transportation
Page viii1 Introduction
The objective of the National Cooperative Highway Research Program (NCHRP) Project 25-25(27) “Effective Project Management for NEPA” (National Environmental Policy Act1) is to develop guidance on effective project management practices to facilitate the NEPA project development process. Sound and effective project management is the key to the successful delivery of a state’s transportation program. However, it is very difficult for a project manager to understand fully the issues and concerns related to every environmental factor addressed during the NEPA process, and little guidance is available that addresses the nexus of project management and NEPA management.
Project managers need more information on tools, tips and approaches used successfully to facilitate the NEPA project development process. Our research approach to NCHRP 25-25(27) involved a literature and internet search, a web-based survey of state Departments of Transportation (DOTs) and Federal Highway (FHWA) division offices, followed by in-depth telephone interviews with state DOTs and FHWA division environmental managers, engineering project managers, and planners involved at various phases of project development and program management.
In November 2007, a review of initial findings with the panel and discussion about the most appropriate form for the guidance, the panel decided on a “best of both” approach, organizing the manual both around key decision points in the NEPA process and project management principles.
1.1 Study Overview and Purpose NCHRP 25-25(27) seeks to apply effective project management to the NEPA process to deal with uncertainty and risks, avoid delays, and prevent cost overruns. The project was designed to offer assistance to state DOT Project Managers to inject efficiencies into the key phases of the NEPA process to accurately scope, schedule and cost the environmental component of the project development process to minimize delays, contention, and cost overruns.
This study is not intended to provide comprehensive guidance on conducting all aspects of the NEPA process and the reader is referred to the full text of the regulation, guidance, and other sources, many of which are provided with hyperlinks in the text.
This study focused on those areas that project managers interviewed for this project identified as the most challenging or where there are the most often overlooked opportunities for injecting efficiencies into the NEPA process. Key areas include the linking planning and NEPA process, scoping, development of purpose and need, identification and analysis of a “reasonable range of alternatives”, and overall project management skills such as managing project schedules, budget and risk management.
1.2 Literature Search The purpose of the literature review was to identify, compile and document readily available reports, publications, tools, guidance, training programs, and successful practices that are available to state DOT project managers who work in the NEPA context. Few agencies have guidance for project management techniques but many DOTs now have a guidance manual for conducting the NEPA analyses and related components.
Page 2 Alternatives development and screening (DOTs - 43%; FHWA - 75%) Mitigation planning (DOTs – 54%; FHWA - 30%) Permits and approvals (DOTs - 62%; FHWA - 30%) Inadequate number of DOT environmental staff (DOTs – 33%; FHWA – 62%) Mid-project change in personnel at the resource agencies and accompanying changes in interpretations of environmental regulations (DOTs – 64%; FHWA – 46%) Project funding (DOTs – 49%; FHWA – 77%) Request for difficult, impossible or unreasonable level of detail (DOTs – 79%; FHWA – 40%) Change in project scope requested by local agencies and the public (DOTs – 36%;
FHWA 60%) *Percentage based on a rating of difficult or very difficult Note: Not all respondents answered all questions.
In all, we received 50 responses to the online survey – 37 from the DOTs and 13 from FHWA division offices. In a few instances, we received multiple responses from different staff within the same agency. Although it was not the intent of the survey to provide statistically valid results, the response rate was quite good for a survey of this nature.
The survey respondents were professionally diverse and representative of varied roles in managing the NEPA process. Some of those represented include environmental planners, environmental program managers, engineering managers, and environmental specialists. Appendix B – Web-based Survey and Survey Respondents Exhibit 1. Geographic Distribution of In-Depth provides a list of all the web-based Telephone Interview Participants survey respondents.
1.4 Telephone Interviews Another goal of the web-based survey was to identify practitioners willing to Telephone participate in a follow-up telephone Interviews interview. We developed the interview questions to focus on those issues of greatest concern identified by the survey respondents, to add more indepth information and perspective, and to identify and document successful practices and lessons learned in integrating NEPA management and project management. The general interview questions are provided in Appendix C – Telephone Interview Questions and Participants, but were expanded on an interview-by-interview basis based on the individual respondent’s answers.
In all, seven FHWA experts and nine DOT experts participated in the telephone interviews. Exhibit 1. Geographic Distribution of In-Depth Telephone Interview Page 3 Participants, shows the distribution of in-depth telephone interview participant and a list of the interview participants is provided in Appendix C - Telephone Interview Survey and Participants. Although the interviewees were less geographically diverse than those that responded to the web-based survey, they are professionally diverse and representative of varied roles in the NEPA process.