PURPOSE & NEED Categorical Exclusion Training Class

Definition  Articulates why the action is being proposed and intended positive outcomes  Explains existing transportation problem(s) to be addressed and the underlying causes 2 Categorical Exclusion Training Class

Why Have a P&N?  Most important part of the environmental document that helps define:  Why expenditure of funds is worthwhile  Priority of the project relative to other needed highway projects is warranted  Justifies the project to stakeholders, the public, and decision-makers  Justifies significant environmental impacts 3 Categorical Exclusion Training Class

Why Have a P&N?  Cornerstone of the Alternatives Analysis  Guides development, evaluation, and elimination of alternatives  Do not discuss solutions  Defines transportation problems/objectives  Coordinate/communicate with stakeholders  Manages controversy  Establishes logical termini/independent utility  Ensures decisions are legally defensible 4 Categorical Exclusion Training Class

Format

Project History  Provides a background of previous studies  Illustrates how the project was initiated and what has been done to date  Legislative mandates  Part of long range plans, MPO studies, etc  Current status of the undertaking 6 Categorical Exclusion Training Class

Purpose Statement  Clear and concise  Typically one or two sentences in length  State the intended positive outcomes  Example statement for a widening project The purpose of the proposed project is to improve mobility, safety, and access along a heavily traveled portion of US 23 between Worthington and Delaware by addressing existing transportation needs  For this example, the needs are congestion, crashes, and roadway geometrics 7 Categorical Exclusion Training Class

Need Elements  Existing transportation problem(s)  Data that is factual and quantified  Discuss existing, future, and desired conditions  Needs can include:  Congestion  Safety/Crashes  Roadway Geometrics  Facility Deficiencies  Emergency Repairs  Access 8 Categorical Exclusion Training Class

Goals and Objectives  Optional  Part of a project’s desired outcomes  Improves pedestrian access; develops a gateway, opens up areas for economic development, etc.  Important to consider  Oftentimes part of a communities visioning document or master plan 9 Categorical Exclusion Training Class

Summary  Restate the purpose statement  Highlight the need elements 10 Categorical Exclusion Training Class

Logical Termini and Independent Utility  Logical Termini  Transportation problem begins/ends  Rational end points  Independent Utility  Interaction with intersecting elements  Does not rely on separate actions 11 Categorical Exclusion Training Class

“Just the Facts”  Eliminate FLUFF  Opinions do not count  Factual and quantified data  Avoid subjective words:  May, maybe, likely, could  Avoid words with legal interpretations  Significant  Segment  Hazardous 12 Categorical Exclusion Training Class

Recommended Length  Categorical Exclusions  One or two paragraphs per need element  EA or EIS  More detail  No more than three to five pages of text  Be comprehensive, specific, and concise 13 Categorical Exclusion Training Class

End Result  Defines existing transportation problem(s)  Creates a baseline to evaluate, eliminate or advance alternatives  Identified needs help establish logical termini and independent utility  Does not restrict consideration of alternatives for other transportation improvements 14 Categorical Exclusion Training Class

Project File  All decision-making must be documented  Documentation can include  Bridge Condition Rating  Certified Traffic Data  Crash Data  Project Related Correspondence (OES Decision)  Follow the NEPA Assignment File Management and Documentation Guidance 15 Categorical Exclusion Training Class

Alternatives Categorical Exclusion Training Class

CEQ Regulations 40 CFR “This section is the heart of the environmental impact statement…it should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decisionmaker and the public.” 18 Categorical Exclusion Training Class

CEQ Regulations Agencies shall: (a)…explore and objectively evaluate all reasonable alternatives and …briefly discuss the reasons for their having been eliminated (b) Devote substantial treatment to each alternative considered…including the proposed action so that reviewers may evaluate their comparative merits (d)Include the No-Build alternative (e) Identify the agency’s preferred alternative or alternatives, if one or more exists… 19 Categorical Exclusion Training Class

Alternatives Analysis  Critical element of the environmental document  Part of the decision-making process  Must be clear and concise  Justifies selection of the preferred alternative and the elimination of other alternatives  23 CFR (a)(1)  Critical to illustrate how the preferred was selected over other alternatives  Someone unfamiliar with the project should be able to read this section and follow the process 20 Categorical Exclusion Training Class

No-Build Alternative  Considered and discussed as part of analysis  Carried forward as part of the environmental process and project planning and development  Illustrates existing conditions  Sets the stage for developing alternatives Baseline to compare with other alternatives  Documented in the CE 21 Categorical Exclusion Training Class

Remarks  Discuss how each alternative was developed  Include rationale for developing, evaluating, and eliminating alternatives  Explain how and why an alternative was eliminated:  Criteria used  Who was involved in establishing criteria  Who was involved in the decision-making  At what point were alternative(s) eliminated  If an alternative is eliminated because it does not meet the P&N, explain accordingly 22 Categorical Exclusion Training Class

22 Categorical Exclusion Training Class

23 Categorical Exclusion Training Class

Project File  All decision-making must be documented  Documentation can include  OES Approval  Evaluation Matrix  Alternatives Mapping  Project Related Correspondence (OES Decision)  Feasiblity Study  Alternative Evaluation Report  OES Review Comments  Follow the NEPA Assignment File Management and Documentation Guidance 24 Categorical Exclusion Training Class

Points to Remember  Discussion must clearly and concisely demonstrate the decision-making process  Why No-Build is not feasible and prudent  How and why each alternative eliminated  Why the Preferred Alternative was selected  Alternatives Analysis tied to P&N  Preferred Alternative must meet P&N  Focus on environmental impacts  Other considerations can be included 25 Categorical Exclusion Training Class

Points to Remember  Depending upon a project’s type and complexity, more detailed analysis may be needed to explain the rationale for selecting the preferred alternative  Consider agency and public views  Justify completed studies  Utilize impacts matrix  Very important if proposed undertaking and subsequent alternatives are controversial 26 Categorical Exclusion Training Class