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Purpose & Need Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Why Have a P&N? Defines: Why the project was initiated/proposed
Defines: Why the project was initiated/proposed Transportation Needs Existing and Future Conditions Logical Termini/Independent Utility Justifies: Impacts Selection of the Preferred Alternative Expenditure of funds Written P&Ns not required for C-level CE projects Must still be justified based on quantified data [2] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Overall Purpose Guide development, evaluation and elimination or advancement of alternatives Does not discuss or included solutions Obtain stakeholder/public input and acceptance Manage controversy Ensure decisions are legally defensible [3] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Project History Provides current status of the undertaking
How the project was initiated Background of previous studies Long range planning, MPO studies, etc. Funding status [4] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Purpose Statement Clear and concise
Typically one or two sentences in length States intended positive outcomes 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 Congestion, crashes, and roadway geometrics [5] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Need Elements Existing transportation problem(s)
Quantified/factual data Needs can include: Congestion Crashes Roadway Geometrics Facility Deficiencies Emergency Repairs Access [6] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Goals and Objectives No longer completed in EnviroNet
Will be removed from P&N Tab as part of a future deployment Considered to be part of secondary needs Based on a community’s perspective Considers Aesthetic Design Consistent with local development plans Considered optional and discretionary Not a deciding factor in alternative development [7] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Summary Restate the purpose statement Highlight need elements
[8] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Logical Termini and Independent Utility
Transportation problem(s) begins and ends Rational end points Independent Utility Typically derived from logical termini Does not rely on separate actions [9] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Just the Facts Eliminate FLUFF Opinions do not count Based on data
Avoid subjective words: May, maybe, likely, could Avoid words with legal interpretations Significant Segment Hazardous [10] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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End Result Defines existing transportation problem(s)
Creates a baseline to evaluate and eliminate or advance alternatives Identified needs help establish logical termini and independent utility Does not restrict consideration of alternatives for other transportation improvements [11] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Project File All decision-making must be documented
Documentation can include: Bridge Condition Rating Traffic Data Crash Data Project Related Correspondence District Acceptance (D1) OES Acceptance (D2 and D3) Follow ODOT NEPA File Management and Documentation Guidance [12] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Alternatives Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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CEQ - 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.” [14] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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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… [15] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Alternatives Analysis
Integral element of project decision-making Part of the environmental document Justifies selection of the preferred alternative and the elimination of other alternatives Must identify how the preferred was selected Make the process reader-friendly [16] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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No-Build Alternative Considered and discussed as part of analysis
Considered and discussed as part of analysis Carried forward through project planning and development Illustrates existing conditions Sets the stage for developing alternatives Baseline to compare with other alternatives Documented in the CE Discuss why not feasible and prudent [17] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Alternatives Considered
Other alternatives developed Documented in the CE Provide a clear description of what it does Explain why an alternative was eliminated: Did not meet P&N If meets P&N, what other factors were involved? Who was involved in decision-making? At what point was the alternative(s) eliminated? [18] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Preferred Alternative
Discuss why selected How does it meet P&N? Did other factors contribute? Who was involved in decision-making? [19] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Alternatives Tab - EnviroNet
[20] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Alternatives Tab - EnviroNet
[21] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Alternatives Tab - EnviroNet
[22] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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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 satisfies P&N Focus on environmental impacts Other considerations can be included [23] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Points to Remember More detailed analysis may be needed to explain the rationale for selecting the preferred alternative Project may be controversial Consider agency and public views Justify completed studies Utilize impacts matrix [24] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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Project File All decision-making must be documented
Documentation can include: OES or District Acceptance (AER/FS) Project Related Decision-Making Feasiblity Study Alternative Evaluation Report Follow ODOT NEPA File Management and Documentation Guidance [25] Categorical Exclusion Training Class – Presented by the Office of Environmental Services
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