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How Does PEL Work?

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Note: This information was archived in April 2009. For the current information, see http://environment.fhwa.dot.gov/integ/related.asp.

PEL works on multiple levels:

Essentially, PEL weaves consideration for planning and the environment throughout the transportation decision-making process (see Figure 1).

Figure 1: Weaving Planning and Environment Linkages
The figure shows the transportation decision-making process and how the linking planning and NEPA and Integrated Planning concepts weave throughout the process. Highlighted concepts in the process include intra-agency and inter-agency coordination, and data sharing and analysis.

While planning and the environment can be linked at almost any stage of the decision-making process, the most effective way for linkages to work is to coordinate as early as possible and ensure consistency with initial transportation plans as project planning moves forward. PEL should then be carried forward into project development, environment review (NEPA-level or similar state environmental review process), design, and ultimately construction, maintenance, and operations.

Integrated Planning

Over the last 10 years, partner agencies have placed increased focus on integrating their planning. Integrated planning is the connection between resource conservation and management plans and transportation planning. While resource data can be integrated at any stage of the transportation process (e.g., planning, project development, design, construction, maintenance), early integration is best since it is much more difficult to fully connect resource agency goals and priorities at later stages. Inconsistent or incompatible goals and priorities among transportation and resource agencies typically pose a major source of conflict and delay.

Integrating respective planning efforts helps develop consensus on how best to confront inconsistencies and generally produces significant time and money saving benefits for transportation decision-making. This type of collaborative planning offers opportunities to see and act on broader scale patterns and trends in our communities, regions, and ecosystems that are simply missed if environmental and community aspects are only addressed at the project level.

Linking Planning and NEPA

Considerable attention has also been given to Linking Planning and NEPA, which can be defined as the connection between system-level planning and project-level decisions. It lays the foundation for key information such as (1) the Purpose & Need for the action; (2) a reasonable range of alternatives for meeting the stated need; (3) a description of the affected environment; and (4) the anticipated environmental impacts.4

Many states have participated in FHWA Linking Planning and NEPA workshops and developed action plans to tie their planning and environmental processes together more tightly, in more helpful and reinforcing ways that yield process efficiencies and better outcomes.

Mechanics

Separate from establishing the relationships needed to make PEL work, the mechanics for linking planning and environment are easy. PEL uses information developed during one planning process as the starting point for the next.

The information mutually agreed to be transferred between planning and the environmental process can be one of three types: data, analyses, or decisions. Examples of each type of information include:

Documentation

A key to linking planning and the environment is "documentation." The information developed in the planning process must be documented in a way that is both useful and acceptable to environmental partners and vice versa.

In integrated planning (the linkage of resource agency plans to long-range transportation plans), at least two key elements should be documented. First, the long-range plan should include specific documentation of how resource agency goals and priorities are incorporated into the transportation plan. Second, the data sets used to integrate environmental considerations into the transportation plan should be documented. A major challenge for integrated planning is the degree of completeness and compatibility of the data, (usually the GIS data layers) that are available. However, identification of assumptions and modeling based on known information will enable durable decisions to be made in planning, with the level of data that exists. Too frequently, type, unavailability, or lack of data becomes an excuse to avoid decisions when, in fact, partial or tiered decisions may be appropriate. Documenting the data sets that were used and the conclusions drawn from them during the integrated planning phase of PEL will help avoid confusion and potential inconsistency during the linking planning and NEPA phase.

Successful linking of planning and NEPA requires comprehensive and acceptable documentation from the planning process to the NEPA process. This level of documentation will typically exceed what is generally required to meet the legal requirements and/or best practice for long-range planning. NEPA is a procedural law, meaning that the legal standard used is based on the quality and completeness of the process to reach decisions. The Environmental Assessment (EA) or Environmental Impact Statement (EIS) will be judged by the standards applicable under the NEPA regulations and guidance from the Council on Environmental Quality (CEQ). Therefore, any planning data or decisions incorporated in these documents must meet NEPA and CEQ standards.

The intent is not to require NEPA studies during the transportation planning process. Rather the goal is to document planning-level information to NEPA standards so this information can be appended or referenced in the final NEPA document. While this may create additional work during planning, the documentation helps avoid revisiting decisions or re-doing work under NEPA.

Planners must understand the documentation standards required. Transportation planners should meet with the environmental professionals that do the NEPA review to agree on standards. This is not a "one size fits all" discussion. The type and level of documentation may be very different for each step of planning based on the type of information (data, analyses, or decisions) transferred and how it will be used. For example, documentation for the needs analysis of a specific project included in the long-range plan is very different from what is required to eliminate an alternative during any NEPA analysis.


4 NEPA and transportation: need and strategies for early involvement. Elaine Somers, U.S. Environmental Protection Agency. Road Ecology Center eScholarship Repository, John Muir Institute of the Environment, University of California, Davis. 2001.

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Updated: 12/03/2012
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