1、iPreparing High-Quality NEPA Documents for Transportation ProjectsAASHTO PRACTITIONERS HANDBOOKThe Center for Environmental Excellence by AASHTO produces the Practitioners Handbooks. The Handbooks provide practical advice on a range of environmental issues that arise during the planning, development
2、, construction, and operation of transportation projects.Each Handbook is developed by the Center in cooperation with an ad-visory group that includes representatives of the Federal Highway Ad-ministration (FHWA), the Federal Transit Administration (FTA), state departments of transportation, and oth
3、er agencies as appropriate. The advisory group for this handbook also included representatives of the consultant community.The Handbooks are primarily intended for use by project managers and others who are responsible for coordinating compliance with a wide range of requirements. With their needs i
4、n mind, each Handbook includes: A background briefing; Key issues to consider; and Practical tips for achieving compliance.In addition, key regulations, guidance materials, and sample doc-uments for each Handbook are posted on the Centers web site at http:/environment.transportation.orgPREPARING HIG
5、H-QUALITY NEPA DOCUMENTS FOR TRANSPORTATION PROJECTSThis handbook describes good practices for improving the quality of en-vironmental documents prepared for transportation projects under the National Environmental Policy Act (NEPA).Issues covered in this handbook include:Before the NEPA Process Bui
6、lding the NEPA document team Planning the NEPA document Planning the NEPA document review processOverall Document Quality Page layout Writing quality and style Document structure Navigation Summary and abstracts Presentation of data Figures Visualizations Use of appendices References Electronic publ
7、icationCompliance with NEPA and Related Requirements Purpose and need Alternatives Methodologies Commitments Regulatory compliance and permitting Responses to comments on NEPA documents Changes during the NEPA processAmerican Association of State Highway and Transportation Officials15July 2014Center
8、 for Environmental Excellence by AASHTOii Using the Transportation Planning Process to Support the NEPA ProcessCopyright 2014, Center for Environmental Excellence by AASHTO (American Association of State Highway and Transportation Officials). All Rights Reserved. This book, or parts thereof, may not
9、 be reproduced in any form without written permission of the publisher. Printed in the United States of America.This material is based upon work supported by the Federal Highway Administration under Cooperative Agreement No. DTFH61-07-H-00019. Any opinions, findings, and conclusions or recommendatio
10、ns expressed in this publication are those of the Author(s) and do not necessarily reflect the view of the Federal Highway Administration. 2014 by the American Association of State Highway and Transportation Officials. All rights reserved.Duplication is a violation of applicable law.1Preparing High-
11、Quality NEPA Documents for Transportation ProjectsThe purpose of this handbook is to help practitioners bridge the gap between the theory and practice of producing high-quali-ty National Environmental Policy Act (NEPA) documents. In general, a high-quality NEPA document is one that: Is readily under
12、standable by all audiences, including those without technical expertise Provides key information in an easy-to-navigate format Focuses on pertinent information and avoids unnecessary bulk Includes supporting technical information in appendices Meets all legal requirementsThis handbook focuses on pre
13、paration of environmental impact statements (EISs) and environmental assessments (EAs), because those documents tend to be more complex and therefore present greater challenges in achieving both readability and legal sufficiency. Many of the tips in this handbook also apply to documented categorical
14、 exclusions (CEs).This handbook is accompanied by a separate document, Examples of Effective Techniques for Improving the Quality of Environmental Documents (2014), which contains excerpts from recent NEPA documents issued by FHWA and FTA. The examples illustrate the techniques described in the Prac
15、tical Tips section of this handbook.1Key Issues to ConsiderExpectations for the NEPA Document What type of NEPA document will be prepared (EIS, EA, or CE)? Who are the audiences for the NEPA document and what are their expectations? Have the lead agencies provided any specific direction regarding th
16、e format or content of this document? Is there a strong commitment to preparing a high-quality document? Will another federal agency be adopting the document? Does that agency have specific requirements that need to be met by this document? Have the resource agencies provided input regarding the for
17、mat and content of the document? Is it expected that there will be litigation challenging the document? Are there any legal sufficiency issues that will require special attention? What is the desired schedule for the NEPA process and project delivery?1 The examples document is available, along with
18、this Practitioners Handbook, on the Center for Environmental Excellence by AASHTO website at http:/environment.transportation.org.Overview 2014 by the American Association of State Highway and Transportation Officials. All rights reserved.Duplication is a violation of applicable law.2 Preparing High
19、-Quality NEPA Documents for Transportation ProjectsOrganization and Format How will the main body of the document be organized? Will it follow the standard format in the Council on Environmen-tal Quality (CEQ) regulations or a modified formate.g., combining chapters? What page layout techniques will
20、 be used to enhance readability? Have the lead agencies provided specific direction regarding the format or organization of the documente.g., set a page limit? Will the summary chapter be circulated as a stand-alone document? What documents, if any, will be incorporated by reference? Will the docume
21、nt include appendices, and if so, what technical reports, correspondence, or other documents will be included in the appendices? Will any technical reports be included in the project file but not in the appendices? What are the lead agencies (and resources agencies) expectations about the level of d
22、etail in the main body vs. the appendices? In what formats will the document be published (paper, electronic, etc.)? Does the page layout work well in each of these publication formats?Writing Quality and Style What steps will be taken to ensure quality writing and a consistent writing style in the
23、NEPA document? At what point in the review cycle will writing quality be addressed, and who is responsible for this review? Will a “lead editor” (sometimes called an “editor-in-chief”) be assigned to manage the preparation of the NEPA docu-ment? Are there specific issues or processes that will be es
24、pecially challenging to explain clearlye.g., complex methodolo-gies or legal requirements? Is there a need to assign a technical writer (in addition to the subject-matter experts) to assist in drafting or reviewing certain chapters or technical reports?Graphics What kinds of graphicscharts, maps, ph
25、oto-simulations, aerialswill be used in the document? Are there some issues that are especially important to convey visually, and what visual tools are best suited for those topics? What steps will be taken to ensure a consistent appearance for all graphics and maps? For example, will standard base
26、maps and figure templates be developed? Will the team include a graphic designer, GIS specialist, or both to support this work?Data For each major topic in the document, what data will be presented in the main body of the document? What data will be in an appendix or incorporated by reference? What
27、technical reports will be prepared? Are there any major topics for which a supporting technical report will not be prepared? Where will data sources, methodologies, and other technical aspects of the data be explained? To what extent does this explanation need to be in the main volume? What kinds of
28、 data are important to the regulatory agencies that will be reviewing and commenting on the document? What can be done to ensure that their data needs are met? 2014 by the American Association of State Highway and Transportation Officials. All rights reserved.Duplication is a violation of applicable
29、 law.3Preparing High-Quality NEPA Documents for Transportation ProjectsNEPA Compliance What decisions need to be made by the lead agency (and by any other agencies that may adopt this NEPA document)? What information should be included in the NEPA document to support those decisions? What are the es
30、sential elements of the projects purpose and need, and how can those elements be communicated most clearly? What facts underlie the projects purpose and need? Is it possible to communicate those facts visually? What process was used to develop and screen alternatives? How can you tell the story of t
31、hat process most effectively? What is important for the reader to know about the alternatives carried forward for detailed study? How can you best convey the key differences among those alternatives? What technical terms need to be explained in order for the reader to understand the impacts analysis
32、? Where will those terms be introduced? What important commitments have been made, such as environmental mitigation commitments? How will those com-mitments be communicated to the reader? What important changes occurred during the NEPA processe.g., changes in methodology, new alternatives, new data?
33、 Where will these changes be described in the final NEPA document?Regulatory Issues and Permitting Processes What regulatory requirements and permitting processes need to be specifically discussed when comparing alternatives and describing project impacts in the NEPA document? How will the NEPA docu
34、ment demonstrate compliance with consultation requirements under other lawsfor example, Section 106 of the National Historic Preservation Act? Are there any regulatory requirements that play an important role in the choice among the alternativesfor example, Section 4(f) of the U.S. Department of Tra
35、nsportation Act? Are there cross-cutting regulatory issues? For example, issues that involve a tension between different requirements, such as Section 4(f) and Section 404? What aspects of regulatory compliance are best documented in appendices?Background BriefingThis section summarizes regulations,
36、 guidance, and other materials that provide direction regarding the organization, con-tent, and readability of NEPA documents.CEQ REGULATIONS AND GUIDANCEThe Council on Environmental Quality (CEQ) regulations and guidance identify a range of good practices for achieving read-ability and brevity in N
37、EPA documents:2 Focusing on significant issues Discussing issues in proportion to their significance Using a format that allows for clear presentation of the alternatives2 CEQ, “Forty Most Asked Questions Concerning CEQs National Environmental Policy Act Regulations,” 46 Fed. Reg. 18026 (March 23, 1
38、981); CEQ, “Final Guidance on Improving the Process for Preparing Efficient and Timely Environmental Reviews Under the National Environmental Policy Act,” 77 Fed. Reg. 14473 (March 12, 2012). 2014 by the American Association of State Highway and Transportation Officials. All rights reserved.Duplicat
39、ion is a violation of applicable law.4 Preparing High-Quality NEPA Documents for Transportation Projects Identifying the methodologies used in the analysis Including explicit references to scientific sources used in the analysis Providing “reasonable and proportionate” responses to comments Placing
40、technical discussions in appendices Incorporating by referenceAttachment 1 to this handbook includes excerpts from the CEQ regulations and CEQ guidance documents discussed in this section.FHWA AND STATE DOT GUIDANCEIn 2006, FHWA issued a memorandum encouraging efforts to improve the quality of NEPA
41、documents. The 2006 memoran-dum embraced the recommendations included in a report prepared by FHWA, AASHTO, and the American Council of Engi-neering Companies (ACEC), Improving the Quality of Environmental Documents.3This report identified three core principles to guide the preparation of high-quali
42、ty NEPA documents: Tell the Story: Tell the story of the project so that the reader can easily understand the purpose and need for the project, how each alternative would meet the project goals, and the strengths and weaknesses associated with each alternative. Keep It Brief: Keep the document as br
43、ief as possible, using clear, concise writing; an easy-to-use format; effective graphics and visual elements; discussion of issues and impacts in proportion to their significance; and an appendix for supporting information. Meet Legal Requirements: Ensure that the document meets all legal requiremen
44、ts in a way that is easy to follow for regulators, technical reviewers, and courts.Several state DOTs contributed to the Improving the Quality of Environmental Documents publication and have issued their own guidance or training documents that incorporate and build upon recommendations in this book,
45、 including the following: The Washington State Department of Transportation developed the Reader-Friendly Toolkit, a comprehensive manual that provides specific suggestions on issues such as page layout, figures, clear writing, and appendices. The California Department of Transportation has develope
46、d annotated outlines for use in preparing EAs and EISs. The outlines are required to be used for federal-aid highway projects in California. The outlines include a standard format and chapter organization; they also provide specific instructions for the content that should be included in each chapte
47、r and in major sections within those chapters. The Colorado Department of Transportation has issued a manual that provides detailed instructions for preparing all types of NEPA documents. The NEPA manual includes guidance on quality assurance/quality control (QA/QC) proce-dures for use by agency sta
48、ff in reviewing CEs, EAs, and EISs. The Ohio Department of Transportation has developed training on the preparation of quality environmental documents for both in-house staff and consultants. The Oregon Department of Transportation and FHWAs Oregon Division Office jointly produced a memorandum, “NEP
49、A Document Dos and Donts, 2nd Edition,” which includes tips for NEPA document preparers on issues such as read-ability, formatting, figures and tables, and terminology, as well as tips on each of the standard chapters in an EIS. The Oregon Department of Transportation also has developed an EIS template based on Californias annotated outlines.3 FHWA, AASHTO, and ACEC, “Improving the Quality of Environmental Documents” (2006). 2014 by the American Association of Sta
