Nurturing An Environmental Perspective
A scan tour of seven States sheds light on best practices for honoring environmental commitments in transportation projects.
When developing a transportation project, the sponsors of the project identify and analyze the impacts on the natural and human environment. They outline how they plan to mitigate those impacts through environmental commitments, incorporating these into documents required by the National Environmental Policy Act (NEPA) or in the mandated permits for the project. Such commitments, clearly delineated in the final NEPA decision document or in the permits, must be integrated into the project design, executed during construction, and then maintained during operation.
Successfully implementing environmental commitments is a challenge because often the commitments are made early in the design and planning phases, but the information is not conveyed effectively during the construction and operation phases. Personnel in the State department of transportation (DOT) and contractors responsible for actually building the highway may not be aware, for example, that a project calls for special provisions to minimize runoff or preserve a historic building. The challenge is to ensure that commitments to protecting environmental and cultural resources are honored during construction through continuous communication.
In late 2002, the Office of Project Development and Environmental Review at the Federal Highway Administration (FHWA) sponsored a domestic scan tour to review State practices for implementing environmental commitments. By reviewing successful processes, procedures, and methodologies, the scan team's goal was to provide a framework for helping States benefit from the experiences of other DOTs.
All transportation projects require environmental analyses, but a project's potential impact on the environment often determines the extent of analysis and the types of documents required. Local geography, topography, and demographics are among the factors that influence the determination of specific commitments and the methods for implementation.
The FHWA scan team visited Colorado, Indiana, Kentucky, New Jersey, New York, Texas, and Wyoming. The seven States vary in the size and maturity of their transportation systems and offer a diversity of approaches, proving that success can be achieved in many ways.
The Scan Team
Because the decisionmaking processes for NEPA and issuing permits involves the coordination of many Federal and State agencies, FHWA strived to ensure that the composition of the scan team reflected a cross section of those involved in these processes.
The team consisted of representatives from FHWA's Office of Project Development and Environmental Review, FHWA Division Offices, State DOTs, the U.S. Environmental Protection Agency, the U.S. Department of Transportation's Volpe National Transportation Systems Center, the American Association of State Highway and Transportation Officials, and the American Road and Transportation Builders Association. With expertise in areas from transportation engineering to environmental protection, the team was able to cover a broad range of issues during its State visits.
After the site visits, the team identified several common themes. The first critical element in implementing environmental commitments is the adoption of a strong environmental ethic that permeates the entire organization. By institutionalizing the commitment, DOTs can ensure that environmental documents and permits are implemented on a continuous basis. When leadership embraces and promotes the ethic, staff at all levels and areas of expertise are empowered to seek out innovative opportunities for environmental stewardship. As a result, stewardship becomes the way of conducting business.
Although adopting and institutionalizing an environmental culture may take years, several States already are experiencing the success that stems from a strong environmental ethic. According to Mary Ivey, acting director of the Environmental Analysis Bureau at the New York State Department of Transportation (NYSDOT), a top-down commitment and a pervasive environmental culture are keys to success.
"New York has had strong leadership with a commitment to doing good things for the environment," Ivey says. "We developed an environmental ethic that changed the culture at NYSDOT. And the longer we have this ethic out in front of people, the more they buy into it and recognize new opportunities in their daily work."
Ivey says that environmental enhancements and best practices offer gains everywhere across the department—from design and construction to maintenance. Projects need not have large price tags. She cites several low-cost environmental projects, such as creating access to fishing sites, partnering with communities to add street amenities (decorative fences, historic lighting, etc.), building fish ladders to facilitate upstream migration, and planting flowers in highway rights-of-way.
"One of the favorites around here is that we are building nesting boxes for peregrine falcons on bridges and scheduling construction work to avoid disrupting nesting females," she adds.
Transportation staff members must understand the importance of environmental commitments. Many States have developed staff positions focused solely on environmental compliance. Most often, States introduce the position of environmental coordinator during a project's development phase, yet realize the full value of the position when the responsibilities extend into the construction and maintenance phases.
The Texas DOT (TxDOT), for example, initially managed environmental commitments in the environmental affairs division, but found that staff members in the maintenance and construction offices were not reading and understanding the information in the same ways.
"After meeting with construction and maintenance staff," says Dianna Noble, director of environmental affairs at TxDOT, "we realized that we needed to find new ways to ensure follow-through. One strategy was that the director of engineering operations in Austin sent a memorandum to the district engineers in each of our 25 district offices directing them to assign an individual from maintenance and construction to assume responsibility for ensuring that environmental commitments made in the planning and design phases are carried out through the construction and maintenance phases." This ensured that the entire staff was involved in the environmental approach.
Keeping staff and contractors up-to-date on environmental issues also is important. The scan team observed that many States conduct training for employees in areas that traditionally lie outside their scope of knowledge, such as NEPA training for design and construction engineers.
According to Noble, Texas continuously reviews and updates training courses to ensure that the department relays the most current environmental information to staff at all levels, from designers to maintenance and construction personnel.
"In the past," she says, "the environmental ethic rested solely with people in the environmental field, but that's absolutely not the case now. We don't just stop with an introduction to environmental issues; we continue developing and offering advanced training courses, always raising the bar as our people gain experience."
Inviting consultants, contractors, and representatives from resource agencies to participate in training courses and discuss specific issues adds depth and helps ensure a more complete understanding of the environmental commitments.
In addition to training, pertinent information must be accessible to practitioners. State DOTs prepare guidance documents in many different formats. The key to effectiveness is that they are reader-friendly, accessible to the appropriate staff, and provide relevant information.
- Several States rely on pocket guides for use onsite. Small, portable, and accessible to DOT field staff and contractors, pocket guides can educate project staff and assist with specific resource issues in the field.
- Providing more detailed information than pocket guides, guidelines and manuals explain requirements and regulations while emphasizing the State's initiatives for complying with commitments. Manuals and guidelines may be issue-specific, such as focusing on endangered species or erosion control, or they may detail a procedural function.
- Many States have begun to use videos to describe guidelines and regulations in a manner that may be more appropriate for their audience.
Cradle-to-grave communication during transportation projects enables States to create a variety of approaches to assure that commitment guidelines are understood throughout planning and design and into construction and maintenance. Detailing the environmental commitments in the NEPA documents is only the first step. Planning sheets and commitment summaries are two mechanisms that, when used properly, can communicate commitments in detail. Forms, meetings, and field reviews also are effective means of ensuring that commitments are transmitted to construction and maintenance staff.
The most effective and efficient means to ensure that environmental commitments are communicated from one phase of a project to another is the use of tracking mechanisms. Many States have developed databases, forms, and lists to monitor implementation and ensure good communication among departments.
Databases provide a clearinghouse for project information including documentation, status of implementation, and records of completion of environmental commitments. They are useful tools that include all phases of the project through maintenance. Using a Web-based system for environmental audits that tracks projects and their major milestones assures consistency in statewide environmental information and implementation of commitments.
Forms are a static type of tracking used to follow a project's commitments through its lifetime. Forms ensure that information is implemented, not forgotten, but their success depends on consistent transmission from one project phase to another. Including a summary of mitigation commitments in both the NEPA document and the plans is one means to ensure implementation.
Lists often are used to track commitments to protect specific resources like cultural artifacts or endangered species. A State should use a variety of lists to delineate the commitments made for each resource affected by a project.
Any final decision on a transportation project must consider the best interests of the public. FHWA requires transportation agencies to involve the public in an open, cooperative, and collaborative process throughout all stages of a project.
According to Timothy Stark, an environmental services engineer with the Wyoming Department of Transportation, the department recently revamped its system for public involvement. The department expanded and decentralized responsibility for communicating with the public by assigning field contacts—known as public involvement coordinators—in each district office.
"When a citizen contacts us with a question about a project, I pass the information along to the local public involvement coordinator in the field office for followup," Stark says. "That followup could entail a phone call or even a personal visit to talk with the caller. In the past, we couldn't have done that."
The public appreciates the extra effort. "Since we reorganized our process for public involvement in fall 2002," Stark says, "we have received numerous calls from the public, not with comments on any particular project, but simply expressing appreciation for our new way of doing business."
Another aspect of public involvement is context-sensitive design, which involves engaging all stakeholders in a collaborative, interdisciplinary approach to developing a transportation facility that considers the total context within which the project will exist. (See "A New Approach to Road Building," page 18.)
State DOTs must build credibility and trust not only with the public, but also with other Federal and State agencies. Each State DOT visited during the scan recognized that it is essential to receive input and agreement from resource agencies on proposed environmental commitments. Early and continuous communication with other agencies will help identify and resolve issues relating to a project. Through interagency meetings, programmatic agreements, and memoranda of understanding, DOTs and resource agencies have developed both issue-specific and process-wide approaches.
Based on the lessons learned during the scan, the team recommends five best practices:
Proactive efforts at all levels of an agency. Instilling stewardship in an agency requires both top-down and bottom-up approaches. When DOT leadership adopts an environmental ethic, the agency should encourage staff from all divisions to demonstrate the same environmental awareness. When staff members understand environmental impacts and their consequences, they adopt an increased sense of responsibility for a project's environmental impacts.
Cradle-to-grave communication. Beginning with the project development and design stages, and continuing on through construction and maintenance, commitments should be communicated clearly among all project staff. Other tools may include specific documentation, agency initiatives, and tracking mechanisms. Although placing environmental coordinators in each district office may be resource-intensive, this practice helps ensure the successful implementation of environmental commitments.
Education and training. Staff members at State DOTs first must understand and believe in the importance of compliance before they can demonstrate an environmental ethic. Education and training will help employees and contractors recognize problems and know how to avoid or mitigate them. Accessible and updated documentation (e.g., manuals and guides) also facilitates addressing specific issues effectively.
Strong stakeholder relationships. For a project to be successful, stakeholders must support a DOT's efforts and strive to reach a consensus on implementing the project. Communication with resource agencies, citizen groups, and others must be a priority. Such interaction provides opportunities for stakeholders to develop trust and respect for the agency. DOTs should share their accomplishments with the public and continue to build upon their relationships with constituents.
Learning from the past. The best practices showcased during the scan are the products of time, energy, and a strong commitment to the environment. Not all best practices are new techniques; many have been in place for years, but continue to evolve and become more effective as an agency embraces them, learning from failures and building on successes.
Successful implementation of environmental commitments is one important way that State DOTs exemplify environmental stewardship, earn the respect and trust of other Federal and State resource and regulatory agencies, and keep their promises to the American public.
Ruth Rentch is an environmental protection specialist with FHWA's Office of Project Development and Environmental Review in Washington, DC. In addition to being the lead for the domestic scan on environmental commitment compliance, Rentch also is the FHWA headquarters lead for the FHWA Alternate Dispute Resolution system mandated by the Transportation Equity Act for the 21st Century (TEA-21). Her current emphasis on environmental streamlining and stewardship includes maintaining and updating the FHWA Environmental Streamlining Web site; issuing the monthly FHWA newsletter, "Successes in Streamlining"; collecting and disseminating data on transportation project times; and serving as the headquarters contact for several priority projects related to Executive Order 13274. Prior to her present position, Rentch was employed by the Maryland State Highway Administration in the Office of Real Estate. She has a bachelor's degree in biology/education from the University of Delaware.
Rachael Barolsky is a program and policy analyst with the U.S. Department of Transportation's Volpe National Transportation Systems Center in Cambridge, MA. Barolsky's work focuses on environmental streamlining initiatives and transportation planning efforts within Federal agencies such as FHWA, the Federal Transit Administration, and the National Park Service. Upon earning both a bachelor's and master's degree in energy and environmental policy from Boston University, Barolsky worked at the White House Council on Environmental Quality.
For more information about incorporating environmental considerations into transportation projects, visit www.fhwa.dot.gov/environment/strmlng/index.htm. For more about the scan tour, contact Ruth Rentch at 202-366-2034 or firstname.lastname@example.org.