How to Write a Better Purpose and Need Statement

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TRANSPORTATION
PLANNING
1
Transportation Planning
Monitor existing conditions
 Forecast future population and
employment growth; projected land uses
 Identify transportation problems and
needs; strategies to address those needs
 Develop long-range plans and short-range
programs

2
Transportation Planning
Estimate the impact of recommended
future improvements on environmental
features, including air quality
 Develop a financial plan for securing
sufficient revenues to cover the costs

3
Transportation Planning Process
4
Metropolitan Planning
Metropolitan Planning Organizations
(MPOs)
 Urbanized areas with population > 50,000
 Federal Planning Regulations
 3-C Planning Process

◦ Continuing
◦ Cooperative
◦ Comprehensive
5
Ohio’s MPOs
6
MPO Role and Members
Members include local governments, DOT
officials, transit agencies
 Board is responsible for transportation
decision-making
 Staff provide analyses and
recommendations

7
Metropolitan Planning

MPO Long-Range Plan (LRP)
◦
◦
◦
◦
◦
◦
20-year planning horizon
Includes all major/capacity adding projects
Includes all modes
Fiscally constrained
Air Quality conformity
Approved by MPO Board
8
Metropolitan Planning

Transportation Improvement Program
(TIP)
◦ 4-year duration, adopted every 2 years, can be
amended
◦ Comprehensive listing of projects and phase
of implementation
◦ Consistent with Long-Range Plan
◦ All federally-funded projects
◦ Air Quality conformity
9
Statewide Planning
ODOT is lead agency
 Statewide assessment
 Coordination with Metropolitan Planning
Organizations
 Rural Planning Organizations and other
stakeholders

10
Statewide Planning

ODOT’s rural consultation process
◦
◦
◦
◦
Local government coordination
Public outreach for statewide planning
Transit planning coordination
Locally-developed, coordinated transit-human
services transportation plans
◦ TRAC process

Rural Planning Organizations
11
Statewide Planning
ODOT’s Long-range Transportation Plan
is Access Ohio 2040
 Statewide evaluation of transportation
networks
 Trends impacting transportation and
impacted by transportation
 No fiscal constraint requirement

12
Statewide Planning
Statewide Transportation Improvement
Program (STIP)
 4-year duration
 Consistent with statewide long-range plan
 All federally-funded projects
 All other regionally significant projects
 Fiscally constrained

13
Linking Planning and NEPA
14
Purpose & Need
Planning Phase of Project Development Process
Policy & Guidance






FHWA Technical Advisory (T6640.8a)
 10/3/87
Purpose & Need in Environmental Documents
 9/18/1990
FHWA/FTA Joint Guidance on Purpose & Need
 7/23/2003
Development of Logical Termini
 11/5/1993
FHWA Guidance-Linking Planning and NEPA
 2/22/2005
CEQ 40 Most Asked Questions
 ceq.hss.doe.gov/nepa/regs/40/40p3.htm
16
Federal Law & Regulations
National Environmental Policy Act of 1969
The purpose of this Act are: To declare a national policy
which will encourage productive and enjoyable harmony
between man and his environment; to promote efforts which
will prevent or eliminate damage to the environment and
biosphere and stimulate the health and welfare of man; to
enrich the understanding of the ecological systems and
natural resources important to the Nation
 Established a systematic, interdisciplinary
approach for decision-making
 Study, develop, and describe appropriate
alternatives to recommended courses of action
17
CEQ Regulations
 40 CFR 1500.1 (c) - Purpose
 Ultimately…it is not better documents but
better decisions that count. NEPA’s purpose is
not to generate paperwork - even excellent
paperwork - but to foster excellent action.
 40 CFR 1502.13 - Purpose and Need
 The statement shall briefly specify the
underlying purpose and need to which the
agency is responding in proposing the
alternatives including the proposed action
18
CEQ Regulations
 40 CFR 1502.14 - Alternatives
 Heart of the environmental document
 Agencies shall:
“…evaluate all reasonable alternatives, and for
alternatives which were eliminated from detailed
study, briefly discuss the reasons for their having
been eliminated.”
19
FHWA Regulations
 23 CFR 771.111(f)
…the action evaluated in each EIS or finding of
no significant impact (FONSI) shall:
 Connect logical termini
 Have independent utility
 Not restrict consideration of alternatives for
other reasonably foreseeable transportation
improvements
 Guidance and Policy for preparation of P&N
based upon 40 CFR 1500 and 23 CFR 771
20
FHWA Definition
Purpose
 States concisely and clearly why the undertaking is
being proposed
 Articulates intended positive outcomes
Need
 Transportation problem(s) to be addressed
 Defines causes of existing problems
 Factual, quantifiable data
21
FHWA Guidance
FHWA Technical Advisory (T6640.8A)
(10/30/1987)
Guidance for Preparing and Processing
Environmental and Section 4(f) Documents
www.environment.fhwa.dot.gov/projdev/impTA6640.asp
Section II - Part B Purpose & Need for Action
 Describe location, length, termini, proposed
improvements, etc.
 Identify and describe the transportation or other
needs which the proposed action is intended to
satisfy (e.g., provide system continuity, alleviate
traffic congestion, and correct safety or roadway
deficiencies)
22
FHWA Guidance
FHWA Technical Advisory (T6640.8A)
Section V - Part D
 Clearly demonstrate that a "need" exists and define
the "need" in terms understandable to the public
 Forms the basis for the “No Build" discussion in
the Alternatives section and assist with the
identification of reasonable alternatives and
selection of the preferred
23
FHWA Guidance
FHWA Technical Advisory (T6640.8A)
 On projects where a law, Executive Order, or
regulation mandates an evaluation of avoidance
alternatives, explanation of the project need
should be more specific so that avoidance
alternatives that do not meet the stated project
need can be readily dismissed
24
FHWA Guidance
Purpose & Need in Environmental Documents
 A clear and well-justified P&N explains to the
public and decision-makers why expenditure of
funds is necessary and worthwhile
 Priority being given to the action relative to other
needed highway projects is warranted
 Although significant environmental impacts may
be expected, P&N should justify why impacts are
acceptable
25
FHWA Guidance
FHWA/FTA Joint Guidance on P&N
(7/23/2003)
www.environment.fhwa.dot.gov/guidebook/Gjoint.asp
 Lead agency has the authority and responsibility
to define 'purpose and need' for NEPA analysis
 For Federal-Aid (FHWA Title 23 US Code funded)
projects, lead federal agency is FHWA
26
FHWA Guidance
 Joint-lead or cooperating agencies should afford
substantial deference to the lead agency's
articulation of a project’s P&N
 P&N is the cornerstone for the alternatives
analysis, but should not discuss solutions
 Care should be taken to ensure P&N is not so
narrow as to unreasonably point to a single
solution
27
FHWA Guidance
 Logical Termini
 Rational end points for a transportation
improvement
 Rational end points for review of environmental
impacts
28
FHWA Guidance
Guidance on the Development of Logical Project Termini
(11/5/1993)
www.environment.fhwa.dot.gov/projdev/tdmtermini.asp
 In developing a project which can be advanced
through stages of planning, environmental,
design, and construction, the project sponsor
needs to consider a “whole” or integrated project
 Should satisfy an identified need and consider the
context of the local area’s socioeconomics and
topography, future travel demand, and other
planned infrastructure improvements
29
FHWA Guidance
 Proposed improvements may miss the mark by
only peripherally satisfying the need or by causing
unexpected side effects which require additional
corrective action
 “Segmentation" may occur where a transportation
need extends throughout an entire corridor but
environmental issues and needs are discussed for
only a segment of the corridor
30
FHWA Guidance
 Three general principles at 23 CFR 771.111(f) used
to frame a highway project:
 Logical termini connection should be of
sufficient length to address environmental
matters on a broad scope
 Independent utility or significance
 Reasonable expenditure even if no
additional transportation improvements in
the area are made
 Consideration of alternatives for other
reasonably foreseeable transportation
improvements is not restricted
31
FHWA Guidance
LINKING PLANNING & NEPA
(2/22/2005)
www.fhwa.dot.gov/hep/plannepalegal050222.htm
 A sound transportation planning process is the
primary source of an undertaking’s P&N
 P&N is where planning and NEPA intersect
32
FHWA Guidance
LINKING PLANNING & NEPA
 The following information from planning studies
can be used in the P&N:
 Goals and objectives from the transportation
planning process
 Results of analyses from management systems
(e.g., congestion, pavement, bridge, and/or
safety)
33
FHWA Guidance
LINKING PLANNING & NEPA
 With proper documentation and public
involvement, a P&N derived from the planning
process can legitimately narrow the alternatives
analyzed for NEPA
34
FHWA Guidance
LINKING PLANNING & NEPA
 Alternatives eliminated during the planning
process because they do not meet P&N, can be
omitted from the detailed analysis of alternatives
in the NEPA document
 Explain the rationale for elimination of
alternatives in the NEPA document
35
FHWA Guidance
 A statement of the transportation problem
 Not solution-based
 Based on articulated planning factors and
developed through a certified planning process
36
FHWA Guidance
 Specific enough so range of alternatives developed
offer solutions to the transportation problem
 Not so specific as to "reverse engineer” a solution
 May reflect other priorities and limitations in the
area (i.e. environmental resources, growth
management, land use, and economic
development)
37
Logical Termini
 Transportation problem begins and ends
 Federal Actions shall not be segmented
 Does not preclude phasing of construction
under a single NEPA action
 State/Municipal boundaries are not end points
38
Independent Utility
 Establishes independent significance
 May be implied by logical termini
 May need to be specifically addressed
 Distinct from project construction phasing
 Demonstrates that the project is not dependent on
any other action
39
Problems vs. Symptoms
Alternatives should align solutions to the
underlying problems
Typical Problem
 Lack of transportation
options
 Demand that exceeds
system capacity
 Through traffic on
residential streets
 Lack of system or route
continuity
 Safety
 Infrastructure in disrepair
 Need for access to
developing land
Transportation Solutions










Transit improvements
Bicycle and pedestrian facilities
Traffic control improvements
Law Enforcement
Access management
Transportation demand management
strategies
Traffic calming
Increased capacity along existing facility
Reconstructed roads, bridges
Construction of new roads
Alternatives should align solutions to the
underlying problems
Typical Problem
 Lack of Transportation
options
 Demand that exceeds
system capacity
 Through traffic on
residential streets
 Lack of system or route
continuity
 Safety
 Infrastructure in disrepair
 Need for access to
developing land
Transportation Solutions










Transit improvements
Bicycle and pedestrian facilities
Traffic control improvements
Law Enforcement
Access management
Transportation demand management
strategies
Traffic calming
Increased capacity along existing facility
Reconstructed roads, bridges
Construction of new roads
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