Environmental documentation can be a source of delay for project development when stakeholders find National Environmental Policy Act (NEPA) documents difficult to comprehend, they are unnecessarily lengthy, do not meet legal requirements, or omit important information. Existing recommendations and recent experience will be used to address the minimally necessary and sufficient material that comprises the NEPA document, what is considered documentation that supports (but need not be included in) the document, and what materials are important to retain for an administrative record to demonstrate project decisions were not arbitrary and capricious.
Producing quality environmental documentation and reducing NEPA document size will increase efficiency and effectiveness by: (1) reducing the amount of work and resources required to produce such documentation, (2) saving considerable time and money while improving the quality of NEPA documents, (3) refocus efforts on "counting what counts" and "telling the story," and (4) efficiency is increased while maintaining appropriate consideration for the environment.
Current State of Practice
This EDC initiative to implement quality environmental documentation will promote existing recommendations and current best practices to simplify and expedite the development of environmental documents, saving time and money. It will focus on ensuring that the good efforts for project purpose and need, consideration of alternatives, and impacts, are appropriately documented and effectively included in the NEPA document.
Best practices in developing and documenting purpose and need, alternatives analysis, and impacts make clear presentations in plain language using effective visual elements. Document writers focus on information that is relevant to the project decision, keeping the document as brief as possible. The Purpose and Need should be specific and provide an understandable conceptual framework for the NEPA analysis. It supports the screening process in selecting the reasonable alternatives for further evaluation of their cost and impacts. The Purpose and Need should be the credible basis for the decision recorded in a Record of Decision or a Finding of No Significant Impact.
Right sizing documents to keep them brief and readable is promoted in existing recommendations. These include: (1) using clear, concise writing, (2) preparing effective summaries, technical reports, and other documentation but including them in the project file, (3) choosing a flexible, easy-to-use document format, and (4) summarizing information and using pictures and effective graphics to communicate complex issues or comparisons, (5) separating technical information or high-volume materials into appendices or incorporating by reference, (6) including only the most relevant information in the document for compliance and decision making, (7) making the level of detail on a topic related to the relative importance and degree of harm of the topic to the project, (8) incorporating by reference when possible and appropriate (rather than including in the body of the NEPA document).
Support and Available Tools
There are a wide range of tools available to assist Division Office and State DOTs to assist in the creation, expansion or revision of programmatic approaches including:
- FHWA Streamlining Website, Purpose and Need:
- FHWA Streamlining Website, Alternatives:
- FHWA Streamlining Website, Documentation:
- AASHTO Handbook on Maintaining a Project File
- AASHTO Handbook on Purpose & Need, Alternatives
- The 2006 joint AASHTO/ACEC/FHWA document Improving the Quality of Environmental Documents