1. WRITING A BETTER PURPOSE AND NEED A COMMON SENSE APPROACH Kevin E. Davis Environmental Supervisor ODOT-OES

2. What’s the Purpose?

3. What’s the Need?

4. Is there a Purpose and Need?

5. FHWA Definition  Purpose States concisely and clearly why the project is being proposed and articulates the positive outcomes that are intended  Need Describes the key transportation problem(s) to be addressed and, to the extent possible, explains the underlying causes of those problems

6. CEQ Definition  40 CFR 1502.13 The statement shall briefly specify the underlying purpose and need to which the agency is responding in proposing the alternatives including the proposed action

7. Importance of P&N  The P&N, in many ways, is the most important chapter of an environmental document  Explains to the public and decision- makers that the expenditure of funds is necessary and worthwhile, and that the priority the project is being given relative to other needed highway projects is warranted

8. Importance of P&N  Justifies why significant environmental impacts are acceptable based on the importance of the undertaking  Serves as the cornerstone for the Alternatives Analysis, but is not designed to discuss solutions to a transportation problem

9. Importance of P&N  Avoid developing an ill-conceived project  Defines transportation problems and objectives  Coordinate and communicate with stakeholders  Manage controversy

10. Importance of P&N  Justifies impacts  Guide development of and evaluate alternatives  Establish logical termini and independent utility  Ensure decisions are legally defensible

11. Transportation Needs

17. Economic Development How does it fit?  Most (if not all) communities have a vision for how they want their communities to evolve and prosper  A desired outcome of a majority transportation project is the facilitation of growth/economic development  However, transportation facilities are rarely the sole cause of economic development

18. Economic Development How does it fit?  Transportation infrastructure and other public infrastructure collectively help determine the growth of a community  Provision of transportation infrastructure can facilitate the changing of land uses, which can lead to community growth/economic development

19. Economic Development How does it fit?  When growth/economic development is part of the P&N, identify sources to support this information, such as:  MPO Long Range Transportation Plan or Comprehensive Transportation Plan  County and/or municipal land development plans or visioning documents

20. Economic Development How does it fit?  When growth/economic development is desired, the Purpose Statement should not be written as: “the purpose is to promote growth/economic development.”

21. Economic Development How does it fit?  The Purpose Statement should be grounded in transportation: “The purpose is to provide transportation infrastructure to support community development as identified in [a plan].”

22. Economic Development How does it fit?  Do not include in P&N if economic development can not be substantiated  Focus on the transportation problems  Avoid defining a purpose so broad that it requires consideration of a vast range of non-transportation alternatives in order to promote economic development

23. Putting it all together!

24. Basic Ingredients  Project History  Status of the undertaking  Background of previous studies  Legislative mandates (i.e. earmarks)  Long range plans, MPO studies, etc  Purpose Statement  Clear and succinct  Intended positive outcomes  The “driver” behind the undertaking

25. Basic Ingredients  Need Elements  Transportation problem(s)  Existing, Future, and Desired Conditions  Goals and Objectives  Desired outcomes  Important to consider  Summary

26. Basic Ingredients  Logical Termini  Transportation problem begins/ends  Rational end points  Independent Utility  Interaction with intersecting elements  Does not rely on separate actions

27. “Just the Facts”  Eliminate FLUFF  Opinions do not count  Factual data  Words to avoid:  May, maybe, likely, and could; subjective  Significant, segment, and hazardous;  Legal interpretations

28. What we’re looking for  Categorical Exclusion projects  One or two paragraphs per need element  EA or EIS projects  Can be more detailed  No more than three to five pages of text  Tangible, quantifiable data  Comprehensive, specific, and concise

29. End Result  Defines the transportation problem(s)  Needs establish logical termini and independent utility  Creates a baseline to evaluate, eliminate or advance alternatives  Does not restrict consideration of alternatives for other transportation improvements

30. THANKS FOR COMING!  Always contact respective ODOT District  You can always contact ODOT-OES  Erica L. Schneider - AEA Policy  Kevin E. Davis - Environmental Supervisor  Libby Rushley - NEPA/Document Review  ODOT Districts 1, 2, 3, 7, 8, 12  Amber Hewitt - NEPA/Document Review  ODOT Districts 4, 5, 6, 9, 10, 11