Equivalent Approach: North Carolina PEL Process
The North Carolina Department of Transportation has undertaken a major process improvement with the goal of integrating the long range transportation planning process with the project development process. In North Carolina, the long range transportation planning process is called the Comprehensive Transportation Planning process and leads to the development of Comprehensive Transportation Plans (CTPs). In MPOs, federally required Metropolitan Transportation Plans are the fiscally constrained subsets of a CTP. The project development process is handled through the Section 404/NEPA Merger 01 process or other means to follow the National Environmental Policy Act (NEPA) and its state counterpart, the State Environmental Policy Act (SEPA).
The Integration Project was designed through the work of a multi-agency “Integration Team” from 2005 to 2007. This work resulted in the identification of 8 linkages between long range planning and project development, where products from the CTP process could inform or serve as the starting point for NEPA/SEPA. The identified linkages are:
|Long Range Planning||Project Development (NEPA/SEPA)|
|Problem Statement||linked to||Purpose and Need|
|Alternatives analysis||linked to||Alternatives selected for detailed study|
|Unreasonable solutions||linked to||Alternatives selected for detailed study|
|Multi-modal analysis||linked to||Multi-modal alternatives|
|Community impacts assessment||linked to||Land use|
|Land use||linked to||Indirect and cumulative effects|
|Public involvement||linked to||Public involvement|
|Mitigation opportunities||linked to||Mitigation needs and opportunities|
In 2008, an “Integration Implementation Team” (IIT) was formed to direct the implementation of the Integration Project. This team is comprised of representatives from NCDOT, FHWA, the US Army Corps of Engineers, the US Fish and Wildlife Service, a Metropolitan Planning Organization, and a Rural Planning Organization. Under the leadership of the IIT, small working groups have been tasked with designing best standards and practices for accomplishing the goals of integration. NCDOT has identified the following measures of success for the Integration effort:
- Identification of viable projects that meet the community's needs, address mobility needs, and are environmentally sensitive;
- Time savings (due to use of CTP-related information to replace, inform, or enhance work during the NEPA process); and
- Better predictability of cost and scheduling.
Alignment with EDC Equivalence Criteria
The equivalent should be institutionalized within the department (i.e. it is a formal process or tool available statewide).
The integration project is still under development with only one aspect of it (the Problem Statement to Purpose and Need linkage) currently in the implementation stage. The NCDOT has developed a guidance document and templates on the process for developing a problem statement during the CTP process that contains information that can be useful in the development of a Purpose and Need statement in the NEPA process. Training has been developed and conducted for NCDOT Planning staff and NEPA practitioners as a part of the implementation process for this linkage. The development of best practices and process standards for the Problem-Statement/Purpose and Need linkage is complete. Tools have been created and are currently being used, including procedures, guidance, and examples.
Currently, three teams have been established to identify an implementation strategy and tools for the following linkages:
- Alternatives and Scenario Analysis (ASA),
- Community Impact Assessments (CIA), and
- and Cumulative Effects (ICE).
The goal of the ASA team is to develop a standardized process for conducting long range transportation planning alternatives and scenario analysis that provides documentation standards and useful information for determination of alternatives selected for detailed study in the NEPA/SEPA process. The “Unreasonable Solutions” and “Multi-modal Analysis” linkages have been incorporated into the general ASA linkage. The goal of the CIA team is to develop a process to perform and document considerations of community issues during the CTP development and enable the transfer of related data and information to the NEPA practitioners for use in the document development. The ICE team seeks to develop a process and best practices for long range transportation planning that provides documentation and useful information for Indirect and Cumulative Effects analysis in the NEPA process. The teams are expected to develop training modules and implementation tools that can be used to accomplish the integration of these linkages into the processes of NCDOT for long range transportation planning and project development.
NCDOT is also in the final stages of developing a Public Involvement toolkit and guidance for use in transportation planning and project development. All processes associated with the Integration Project will be institutionalized within the department's processes upon implementation. The IIT is developing a communications plan as well as a plan to roll out associated new processes in a manner that is seamless and easily fits into the existing organizational structure.
The equivalent must provide information on how to consider and document the following:
- The early and continuous coordination with Federal, Tribal, State, and local transportation, environmental, regulatory, and resource agencies.
- Coordination efforts with the public and stakeholders.
- Description of planning scope, vision statement, and steps needed to scale the vision statement to a project-level purpose and need statement.
- Alternatives that were considered, selected and rejected; criteria and process used for selecting and rejecting alternatives.
- Explanation of planning assumptions, including forecast year, traffic volumes, policy, and data as well as consistency of those planning assumptions with the long-range transportation plan.
The Integration project will accomplish the aspects of “Criteria 2” through the implementation of the following linkages:
- Public Involvement (Toolkit);
- Problem Statement to Purpose and Need;
- Alternatives and Scenario Analysis; and
- Community Impact Assessments.
Criteria 2a and 2b are also being accomplished through the implementation of NCDOT's Unified Public Engagement Plan (UPEP), which was adopted by the NCDOT during the summer of 2011. The UPEP addresses coordination with Federal, Tribal, State, and local officials as well as the general public and other stakeholders for the planning and project development processes.
The equivalent may also provide information on how to consider and document the following:
- Analysis of the affected environment and environmental consequences. Document those resources reviewed and not reviewed, and the level of detail.
- Potential strategies for broad-scale mitigation.
- Description and/or analysis of potential cumulative effects.
- A method of documenting FHWA's approval, in order to support the use of planning information in NEPA, that indicates that PEL principles were applied to FHWA's satisfaction.
The Integration project will accomplish some aspects of “Criteria 3” through the implementation of the following linkages:
- Indirect and Cumulative Effects;
- Alternatives and Scenario Analysis; and
- Community Impact Assessments.
More information on the NCDOT Integration Project can be found at the following website:http://www.ncdot.org/doh/preconstruct/tpb/IP/default.html.