Developing Purpose and Need Guidance - Ohio Department of ......traffic diversion, time of day...

Office of Environmental Services

April 2018

Guidance for Developing Purpose and Need

Addressing Transportation Problems by Identifying Needs

OES-Policy-April 2018

- 1 - | P a g e Guidance for Developing Purpose and Need April 2018

Table of Contents

Chapter Page #

Introduction 2

Legal Requirements 3

Linking Planning and NEPA 3

Importance of Purpose and Need (P&N) 4

Preparation and Development

When Does P&N Development Begin?

When is a P&N Required?

Who is Involved in P&N Development?

How is the P&N Formatted?

Why is Identifying Primary and Secondary Needs Important?

Need Element Definitions

4

5

5

6

7

10

12

Logical Termini and Independent Utility 17

Public Involvement 18

Points to Remember 18

This guidance replaces the ODOT-OES P&N Quick Guidance that was released on July 6, 2017



Introduction

This guidance is written for transportation

professionals, environmental specialists and project

managers that prepare and review Purpose and

Need’s (P&N) for ODOT projects. Furthermore, this

guidance is designed to ensure those involved in the

NEPA decision-making process and P&N development

are able to:

a) Recognize the importance of having a P&N

b) Identify at what point in ODOT’s Project

Development Process (PDP) a P&N is prepared

c) Identify transportation based needs

d) Identify Primary and Secondary Needs and how

that is key for integrating Performance Based

Project Development (PBPD) into the P&N

e) Provide a baseline to effectively develop,

evaluate and eliminate or advance alternatives

The P&N specifies the purpose as to why the project

has been initiated and identifies the transportation

needs (problems) to be addressed based on the

analysis of quantified data. The P&N for a project

must be established prior to the development of

alternatives and serves as a baseline in the

development, evaluation and elimination or

advancement of alternatives, including selection of

the preferred. The analysis conducted for the P&N

can be used to justify impacts and project

prioritization.

Identifying needs can be part of the overall

transportation planning process prior to a project

being programmed.

Initial transportation

planning studies and

technical reports prepared

by Local Public Agencies

(LPAs), Metropolitan

Planning Organizations

(MPOs), or others can be

used to establish a P&N

prior to programming a

project

Development of the P&N

can begin as early as the

initiation of NEPA studies

conducted as part of the

Planning Phase of ODOT’s

PDP

The P&N is based on

analysis of various data

sources that can include

traffic studies, crash

records, bridge/culvert

inspection reports or other

technical type documents

As the project advances

through the PDP the project

scope becomes more

refined, and as a result, the

P&N evolves

The P&N is not FINAL until

the environmental document

is approved



Legal Requirements

The P&N is a critical element of the environmental

process that is necessitated by the National

Environmental Policy Act of 1969 (NEPA).

The P&N is required documentation in accordance

with existing Council on Environmental Quality (CEQ)

regulations at 40 CFR 1502.13 (CEQ) and Federal

Highway Administration (FHWA) regulations at 23 CFR

771.111(f).

Based on the regulations above, the FHWA Technical

Advisory T 6640.8A directs State DOT’s to “identify

and describe the proposed action and the

transportation problem(s) or other needs which it is

intended to address.” The Technical Advisory

highlights factors that may be helpful in establishing

a project’s need that includes safety, transportation

demand and legislative mandates.

Linking Planning and NEPA

Initial planning activities and studies conducted as

part of the overall transportation planning process for

a project are sources of information that can be used

to develop a P&N. Detailed forecasts of vehicle miles

of travel, travel demand, highway and travel speeds,

traffic diversion, time of day characteristics, and

traffic accident rates are data that can be provided.

The overall planning process can also help estimate

the benefits and costs associated with highway and

transit projects when developing the P&N.

https://ceq.doe.gov/index.html

https://ceq.doe.gov/index.html

http://www.ecfr.gov/cgi-bin/text-idx?SID=e3e37707b2d6a191b5ab1e76ae4292ba&mc=true&node=se40.37.1502_113&rgn=div8

https://www.ecfr.gov/cgi-bin/text-idx?SID=a72a717393b6b00ee4498c586611166d&mc=true&node=se23.1.771_1111&rgn=div8

https://www.ecfr.gov/cgi-bin/text-idx?SID=a72a717393b6b00ee4498c586611166d&mc=true&node=se23.1.771_1111&rgn=div8

https://www.environment.fhwa.dot.gov/projdev/impta6640.asp#pn

https://www.environment.fhwa.dot.gov/projdev/impta6640.asp#pn



Importance of P&N

Establishing and defining the P&N is a necessary task

that is started as part of the transportation planning

process or begins as early as the initiation of NEPA

studies. The P&N is essential as it plays a key role in

determining the range of alternatives that will be

considered, including selection of the preferred. The

P&N is also instrumental in illustrating that a No Build

alternative will not solve an existing transportation

problem.

A well-defined P&N is especially important for

projects that may be subject to other laws (e.g.

Section 404 of the Clean Water Act or Section 4(f) of

the Department of Transportation Act) that require

sound justification of impacts. Furthermore, the P&N

is used to support ODOT’s process of acquiring right-

of-way from public and/or private interests. Without

establishing a sound P&N for a project, it becomes

difficult for ODOT to successfully justify acquistion of

right-of-way through the appropriations process.

Preparation and Development

Although a P&N is not required for planning or

corridor studies, these documents may provide

relevant data that pertains to transportation needs.

The level of detail needed to develop a P&N depends

on the type of project and level of complexity. An

adequate level of detail is needed in order to describe

how the proposed action was initiated, how the

transportation needs were identified, and to define

logical termini and independent utility.

Environmental Impact Statements (EIS) and

Environmental Assessments (EA) typically require a

greater level of detail than Categorical Exclusion (CE)

level documents.

An adequate level of detail

is needed in order to

describe how the proposed

action was initiated, how

the transportation needs

were identified, and to

define logical termini and

independent utility



When does P&N development begin?

Although the framework of a P&N may be established

prior to programming, development of the P&N begins

during the Planning Phase of ODOT’s PDP, (Scoping

Task 1.3.H). As part of this phase, initial project

development includes:

Identification or refinement of project scope

Scoping activities to determine if environmental

resources are present

Identification of potential impacts to the human

and natural environment

Collecting and analyzing existing and future

transportation conditions

These activities help further define a project’s P&N,

which is a critical element needed to advance to the

next phases of the PDP that involve developing

feasible alternatives, Stage 1 Design, cost estimates,

NEPA approval, etc. If a P&N is not properly

developed, this can lead to the development of an ill-

conceived project or alternatives that do not address

needs.

When is a P&N required?

Projects designated as C1 and C2 CEs (typically

PDP Path 1 or Path 2 projects) do not require

preparation of a P&N based on FHWA rulemaking

Although these low level projects do

not require a written P&N,

quantified data is still obtained to

support the need for a project and

the project must still be justifiable.

Supporting data may be

uploaded to the EnviroNet

project file for C-listed

projects

http://pdp.dot.state.oh.us/General/TaskTemplateReader.aspx

http://pdp.dot.state.oh.us/General/TaskTemplateReader.aspx



Projects designated as D-listed CEs (typically

PDP Path 3 or Path 4) require that a P&N be

written in EnviroNet (see formatting, page 7).

These types of projects can have complex issues

associated with impacts that may require a

certain level of analysis relevant to the P&N.

The exception are Disposal of Excess Right-of-

Way projects or projects with unusual

circumstances that are elevated to a D1.

Projects that require an EA or EIS, (typically PDP

Path 5) must also have a P&N. These are formal

stand-alone documents submitted to ODOT-OES

via the EnviroNet project file. These types of

projects typically have a higher level of complex

issues and impacts that involve in-depth analysis

and project management team collaboration.

While PDP Paths are loosely correlated with the

level of environmental document, it does not

match up exactly. For example, if a Path 3 project

is designated as a C2 CE, no P&N is required. A

Path 2 project that requires a D1 CE due to impacts

would require a written P&N.

Who is Involved in P&N Development?

ODOT District Role

As part of the Planning Phase of the PDP, specific

activities are conducted (i.e. secondary resource

review, initial field investigations) to establish

project scope and identify potential impacts. Once

scoping activities are completed, establishment of

transportation needs are based on studies conducted.

This process is designed to include district Subject

Matter Experts (SMEs) that are familiar with safety

concerns, engineering requirements, design,

environmental regulations, etc.

The P&N for D-listed CEs is

considered FINAL upon

approval of the CE

P&N format for EA’s and

EIS’s is not incorporated in

EnviroNet

For these projects, the P&N

is considered FINAL once

the FONSI or ROD has been

issued

Districts can prepare P&Ns

for projects designated as

D1 CEs, as well as review

and accept DRAFT P&Ns for

D1 CEs prepared by a

consultant or a Local Public

Agency (LPA), prior to the

development of feasible

alternatives to ensure

quality control



Based on a project’s complexity, the district or LPA

may task a consultant to prepare the P&N, which may

include additional research and/or analysis of data.

These activities assist in the identification of

transportation needs. As the P&N progresses, the

district and/or LPA seeks local stakeholder

concurrence that the needs identified are appropriate

and that concerns are addressed.

ODOT-OES Role

The OES Policy Staff can advise and assist with P&N

development. This can include defining/identifying

primary and secondary needs, logical termini and

independent utility. All DRAFT P&Ns for D2 and D3

CEs, and EA’s and EIS’s are reviewed and accepted by

OES Policy early in the PDP process (Planning Phase)

prior to the development of feasible alternatives.

Local Public Agencies (LPA) and Consultants

A pre-qualified consultant can perform technical

studies as well as prepare the P&N on higher level

projects on behalf of ODOT or an LPA. All P&Ns

prepared by an LPA or consultant must be accepted

by OES or the District (as determined by CE level).

How is the P&N Formatted?

To ensure consistency when developing a P&N, the

following format has been incorporated into

EnviroNet (ODOT’s Environmental Documentation

System) for D-listed CE’s. For EA’s and EIS’s this

format is followed in a stand-alone document.

Project History

This section provides essential background and

context on the existing facility and a detailed account

of how the project was initiated and developed. This

can include a summary of prior investigations/studies

All DRAFT P&Ns for D2 and

D3 CEs, and EA’s and EIS’s

are reviewed and accepted

by OES early in the PDP

process (Planning Phase)

prior to the development of

feasible alternatives

The Project Description

does not suffice as Project

History

When citing prior studies in

Project History, do not

include statements that

specify a preferred

alternative or solution

http://ceform.dot.state.oh.us/



completed to date (e.g. traffic, safety, planning

activities, inspection reports, etc.), funding status,

land use and zoning considerations, transportation

demand, and legislative mandates. The intent of this

section is to provide an account that substantiates

project development.

Purpose Statement

The purpose statement is comprised of one or two

sentences that articulates the project’s primary

objective.

The Purpose defines the transportation

problem(s) to be addressed

Multiple purposes may correlate with needs

identified. For example, if the needs identified

include congestion, roadway geometrics, and facility

deficiencies, the purpose of a project may be to

improve mobility and access.

Reference to solutions or prescriptive outcomes is not

included, meaning the purpose statement is not

written to indicate a particular action (e.g. replacing

a two-lane bridge with a four-lane bridge or

replacement rather than rehabilitation) provides a

desired result to correct the transportation problem.

Rather the statement identifies the problems to be

addressed.

Need Elements

This section of the P&N is the main component that

defines the transportation problem. Need elements

are derived from ODOT maintained databases (e.g.

speed/congestion data) and/or quantified data

obtained through technical analysis of traffic studies,

crash records, roadway geometric data, etc.

Purpose Statement Examples

An intersection improvement

project:

The purpose is to improve

mobility and safety at the

intersection of US Route 30

and Davis Boulevard

A bridge rehabilitation,

reconstruction, or replacement

project:


facility deficiencies and

roadway geometrics to

maintain connectivity over

the Scioto River

New roadway on new

alignment or interstate

widening/new interchange

projects:


mobility, system linkage and

access between IR 71 and IR

75 to facilitate current

economic growth within

Hamilton County



It is imperative that SMEs (specifically engineers)

be involved in the analysis of these data to ensure

the needs identified are truly causing a

transportation problem.

When establishing needs, the focus is on those critical

elements necessary for the project. Critical need

areas are defined as primary needs. Additional needs

that are identified as part of the project, but are not

necessarily critical, are considered secondary needs.

Identifying a project’s primary and secondary needs

as part of the P&N reduces time spent on technical

studies/reports, data analysis, and expenditure of

funds on designing a practical solution. The goal is to

incorporate a collaborative approach that involves

engineers, environmental specialists, project

managers, etc.

Primary needs are existing or future conditions that

are truly causing a transportation problem. These

needs MUST be addressed to the extent feasible in

order to satisfy the P&N and typically are the majority

of the project’s needs.

Secondary needs are existing or future conditions

that may or not meet standards but are not the cause

of localized or system failures. Essentially, these are

elements that may or may not be addressed by the

project based upon the cost and impacts they create.

Secondary Needs can also be based on a community

perspective that considers aesthetic design and/or

are consistent with local development plans.

These are considered optional and discretionary

and include items that typically are a result of the

overall NEPA planning process. They are not the

deciding factor in alternative development.

The ‘Need’ is quantified

data that supports the

purpose statement

Common Primary Needs

Mobility/Congestion

Safety

Facility Deficiencies

Previously, Goals and

Objectives was included

within the P&N format, but

is now considered to be

part of secondary needs

This section will be

removed from the P&N Tab

of D-listed projects as part

of a future EnviroNet

enhancement



For example, a municipality may have approved a

Complete Streets Master Plan in which components

may be considered Secondary Needs to incorporate

during alternative development.

Secondary needs can be addressed during the

Preliminary Engineering (PE) Phase of the PDP (usually

in the Feasibility Study) if warranted based on the

balancing of benefits vs. costs and/or environmental

impacts.

Why is identifying Primary and Secondary

Needs Important?

The majority of projects typically have one or two

well defined needs, which is better than several

poorly defined or poorly-justified needs. Avoid the

temptation to include poorly supported needs to

simply “bulk up” the P&N, which will make it harder

to defend. It is best to stick with one or two well-

supported needs.

During the Planning Phase, quantified data obtained

from technical studies, along with stakeholder input,

helps identify a project’s primary and secondary

needs.

Need elements are essential to Performance Based

Project Development (PBPD), which is a design

philosophy promoted by FHWA and adopted by ODOT.

The emphasis of PBPD is improving existing conditions

or “Designing Up”, essentially improving the system

but not necessarily meeting every design standard.

Using this concept is a practical way to stretch public

dollars and avoid designing solutions that cannot be

funded.

ODOT’s L&D Manual Volume

1- Section 1000 defines PBPD

as:

“…a planning and design

philosophy being promoted

by FHWA and State

Departments of

Transportation. The general

premise of PBPD is that

proposed improvements

should be targeted and right

sized based on project

specific needs. It is

understood that no one

project is more important

than the overall system.

Consequently, savings

obtained from targeted PBPD

solutions on specific projects

can be reinvested in the

overall system.”



The underlining philosophy of PBPD is that it is better

to build many “good” projects rather than just a

couple of “perfect” projects or no project at all due

to funding constraints.

Once the P&N is refined and accepted early in ODOT’s

PDP, the design solutions explored during

development of alternatives will focus on the primary

needs in order to satisfy the P&N. The intent is to

focus on what is truly causing the problem (primary

needs) versus what may not be up to standard but is

not causing undue issues (secondary needs).

Therefore, the Need Elements section includes:

Well-defined primary and secondary needs based

on quantified data from technical analysis

(needs are identified as primary or secondary

within this section)

Existing and future conditions associated with

primary and secondary needs (this will assist in

determining if a need is primary or secondary)

Do not quantify the desired condition as the intent

is to improve existing transportation problems and

not achieve a specific metric. For example, LOS C

may be the standard to achieve on Urban Arterials,

however, reducing LOS from F to D improves the

condition even if C is not met.

Subsequent Preliminary Engineering activities such as

the Feasibility Study, Alternative Evaluation Report,

Structure Type Study, etc., will identify solutions that

address the primary and secondary needs. Secondary

needs identified may be addressed if the relative

costs and impacts can be justified.

Definitions (including data sources) for common and

less common needs associated with transportation

projects, are provided on the following pages.

Critical Success Factors

(CSF)

CSFs are defined metrics

established by ODOT that

measure the condition or

rating of a particular

aspect of the

transportation system

Metrics to be considered as

part of P&N development are:

System Conditions

(Bridges, Pavement

Conditions, Maintenance,

and Travel Time

Reliability)

Safety (Fatalities, Serious

Injuries, and Crashes)

Considering CSF’s as part

of project development

incorporates ODOT’s goal

of providing safe and

reliable transportation

infrastructure, and to

achieve maximum return

and investment



Mobility: The ability to meet traffic demand and

level of ease in moving people, goods, and

services

Although closely associated with congestion,

access, and connectivity, characteristics of

mobility include traffic flow, “reasonable” travel

time, lost time, and type and condition of

transportation system. This need is typically

identified during the overall planning process with

respect to all modes of travel (e.g. transit, rail,

aviation).

Congestion: Occurs as use increases, and is

characterized by slower speeds, longer travel

times, and increased vehicular queueing

This need is supported by quantified data that

identifies the cause of congestion and identifies

existing and future congestion. The cause of

congestion can be traffic influencing events,

traffic demand, and/or physical highway features.

These causes lead to recurring congestion that

consists of predictable back-ups caused by a

location that is over-capacity, such as an

interchange or lack of access management.

Typical Data Sources to

Include for Mobility

Average daily hours of

travel per person

Average minutes per mile

Average vehicle minutes of

delay

Total passenger and ton-

miles traveled

Travel rate index (how

much time is added to a trip

during rush hour conditions

compared with free-flow

conditions)

A range of measures can

define congestion

Level of Service (LOS)

Volume-to-Capacity (V/C)

Vehicle Hours of Delay

Typical Data Sources to

Include for Congestion

Certified Traffic Plates

No Build Traffic Data

Mainline LOS

SHIFT Counts/Growth Data

Traffic Analysis Software

(Travel Demand Model and

Highway Capacity Manual)



Facility Deficiencies: Existing transportation

system, including roads, bridges, and culverts

that are in disrepair or deteriorated condition,

or that have substandard roadway geometrics

This need is supported by data maintained by

ODOT and/or LPA’s. The majority of data is stored

within ODOT’s Pavement Management System,

Structure Management System, and Maintenance

Management System. These data bases include

Pavement Condition Rating (PCR), Bridge

Condition Rating, Bridge General Appraisal

Ratings, and Structurally Deficient Ratings. This

need may also include sub-standard design (e.g.

vertical or horizontal curves, turning radius, etc.)

that does not meet standards.

Safety: Reduction of serious injuries and

fatalities based on accepted engineering

practices and quantified data to support the

overall surface transportation planning process

Safety is rarely the sole need for a project and is

almost always related to some other need, such as

facility deficiency or congestion. Establishing

safety as a need involves a two-step process to

understand if the project is within a safety priority

location:

1. The first step involves reviewing the Safety

Integrated Project (SIP) maps which can be

found on ODOT’s Highway Safety Webpage. If

the study area includes a high crash/high

priority location(s) (represented by a red dot),

or a low priority area (represented by a blue

dot), additional analysis and consideration is

required.

Typical Data Sources to include

for Facility Deficiencies

Bridge Inventory Reports

Bridge Inspections

Culvert Inspections

PCR Forms

System Conditions is a CSF

metric ODOT uses to

measure General Appraisal

ratings for bridges,

pavement distress on

priority, general and urban

roadways, and roadway

maintenance operations

Safety is a CSF metric that

ODOT uses to measure the

number of motor vehicle

crashes on ODOT-maintained

roadways that includes

fatalities, serious injuries,

non-serious injury and

property damage

https://www.dot.state.oh.us/Divisions/Planning/ProgramManagement/HighwaySafety/HSIP/Pages/MapRoom.aspx



If after analysis and consideration of data obtained

safety is considered a need, the second step would

not be necessary. However, if the location is not on

the SIP map, proceed to the second step:

2. This step involves reviewing the most recent

three years of crash data within the project

study area corridor. Completing this task is

accomplished using ODOT’s GIS Crash Analysis

Tool (GCAT) that is used to understand the

crash types included in the SIP maps.

If a high crash location is identified, a pattern of

crashes exist, or there have been fatal or serious

injury crashes within the project study area, safety

will most likely be a need.

In accordance with ODOT’s PDP, all project P&N’s

that identify safety as a need are required to analyze

proposed alternatives as part of the Feasibility Study

(FS) and the Alternatives Evaluation Report (AER)

using Highway Safety Manual (HSM) methodologies

(HSM may not cover every situation, such as

quantifying deficient super elevation). This

requirement is intended to reduce identifying safety

as a need if not supported by data.

System Linkage: Provides a link between

existing facilities to alleviate congestion or

provide an alternate route not currently

available (likely associated with mobility,

congestion and/or access)

Although not as common, System Linkage can be a

primary or secondary need. The need may be

identified within local or regional long-range

transportation or development plans. Existing land

uses within the area can be a factor in determining

if System Linkage is a need.

Crashes are typically a

symptom of another known

deficiency, such as:

Congestion

Facility Deficiencies

Roadway Geometrics

Crash data is collected by

law enforcement agencies

such as the Highway Patrol

and County Sheriffs

Crash reports are made

available to ODOT by the

Ohio Department of Public

Safety

The ODOT Office of Systems

Planning and Program

Management is responsible

for collecting and

organizing this data



Early endeavors may include preparation of

Origin/Destination (OD) and Access Management

Studies.

Access: Providing access to land parcels/uses

adjacent to all manner of roadways and/or

improving the flow of traffic along heavily

traveled corridors

Although not as common, access can be a primary

or secondary need, and is closely associated with

mobility and congestion. The need derives from

the proactive management of existing

transportation networks to provide efficient

modes of travel and safety. Access is aimed at the

preservation of functional integrity and overall

operational viability of street and road systems.

Another need element that has become more relevant

of late is Economic Development.

Economic Development: Based on a master

plan/vision for community growth and

prosperity that may be tied to planned

infrastructure, but is primarily based on planned

land use changes that are tied to employment,

schools, commercial and business development

Existing and/or planned transportation facilities are rarely the sole factor for economic development needs. However, transportation infrastructure and public transportation modes influence community growth and facilitate land use changes.

Transportation projects can be drivers of development in the benefits they bring to job creation, commercial/business development, accessibility to places of business, and efficiency of travel for goods and freight.

ODOT maintains an

analytics tool/database to

determine OD



In order for Economic Development to be considered

a primary need, the P&N must focus on existing

transportation problems that are keeping

development from taking place or that may be

worsened when development is realized. This focus

will help avoid defining a broad purpose that may

require a vast range of transportation and/or non-

transportation alternatives for promoting economic

development.

Sources for determining if ecomomic development

would be considered a need on a project are:

Zoning and Development Master Plans

Regional Planning Studies

Origin Destination Studies

Local Economic Plans/Visioning Documents

Access Management Studies

Corridor Freight Studies

Sustainibility Studies

If Economic Development is a Need, the Purpose

Statement is not:

The purpose is to promote growth/economic

development

It must reflect a transportation focus (problem):

The purpose is to provide transportation

infrastructure, and improve mobility and access

to support planned community

growth/development as identified in the [plan]



Logical Termini and

Independent Utility

Logical Termini

Establishing logical termini is largely determined by

quantified data that indicates where the

transportation problem begins and ends.

For example, a project with an identified facility

deficiency supported by pavement condition ratings

begins where the pavement condition is poor and in

need of improvement, and ends where the pavement

is in better condition.

Independent Utility

Independent Utility establishes a project’s

independent significance. A project is considered to

have independent utility when it can be constructed

without relying on other projects to be constructed

within or adjacent to the project area. In other

words, the project cannot be dependent upon another

project in order to function. It must be a usable and

reasonable expenditure of funds even if no additional

transportation improvements in the area are made.

Please note Independent Utility is different from

project construction phasing. Portions of a multi-

phase project that depend upon other phases of

the project do not have independent utility.

Projects phased for construction are evaluated as

a single undertaking with one P&N and one

environmental document. Phases of a project that

would be constructed even if the other phases

were not built can be considered as a separate and

complete project with independent utility.

City boundaries, municipal

end points, county lines,

etc. are not used as logical

termini end points



Public Involvement

For projects designated as D-listed CEs, EA’s or EIS’s,

stakeholders, the public, and resource agencies are

provided the opportunity to participate in the review

and/or refinement of the P&N as part of Public

Involvement (PI) activities. This can begin as part of

the transportation planning process, at the initiation

of NEPA studies, or during different stages of the PDP,

as appropriate. Obtaining input is valuable in assisting

the project management team to be aware of project

elements that may be of concern to the local

community or key stakeholders.

All decision-making regarding P&N development are

documented and shared with all interested parties to

ensure issues are resolved as early as possible.

The level of involvement is determined by the

sponsoring agency based on the project’s type and

complexity. The methods used and the timing of PI is

flexible, and the lead agency(s) coordinate

beforehand regarding when and in what form PI will

occur. All outreach and PI activities must be

publicized and may occur in the form of public

workshops or meetings, solicitations of verbal or

written input, postings on project website,

distribution of printed materials, or any other

involvement technique.

Points to Remember

Why is a P&N Needed?

It is required by law. Furthermore, a well-written and

well-justified P&N helps validate the expenditure of

public funds and impacts upon the human and/or

natural environment.

Please refer to ODOT’s

Public Involvement Manual

for additional information

regarding PI requirements

https://www.dot.state.oh.us/Divisions/Planning/Environment/NEPA_policy_issues/PUBLIC_INVOLVEMENT/Pages/default.aspx

https://www.dot.state.oh.us/Divisions/Planning/Environment/NEPA_policy_issues/PUBLIC_INVOLVEMENT/Pages/default.aspx



The P&N provides a baseline to develop and

adequately evaluate, eliminate and advance project

alternatives. Establishing a solid P&N that defines

existing and future transportation problems enables

alternatives to be designed that address primary

needs and includes secondary needs, if practical.

Level of Detail

The level of detail can vary and is dependent on

project type and complexity. Transportation projects

classified as a CE will have less complicated and

detailed needs than those projects classified as an EA

or EIS. It is not unusual for higher level CEs (especially

D2 or D3) to have an extensive project history and/or

need elements.

A brief discussion of one or two paragraphs per need

element for CE projects typically suffices, whereas EA

or EIS projects typically involve complex

environmental and engineering decisions that require

a more detailed discussion. The P&N for EA or EIS

projects typically comprise 3-5 pages of text.

Documentation

All supporting analyses, quantified data (existing and

future conditions) and acceptance documentation are

uploaded to the P&N Section of the project file in

EnviroNet. The appropriate dropdown options are

available to properly upload Bridge Condition Rating,

Crash Data, LOS Data, Pavement Condition Rating,

and Traffic Data. Other data (e.g. economic data) not

listed as dropdown options can be uploaded and

named appropriately. This includes relevant mapping,

illustrations, photographs, charts, graphics, and/or

spreadsheets associated with the P&N.

Avoid writing long, verbose

and hard to follow P&N’s as

they will be harder to

defend than those written

in a concise, succinct and

focused manner

Follow existing ODOT NEPA

File Management and

Documentation Guidance to

ensure proper naming

conventions are used

http://www.dot.state.oh.us/NEPA-Assignment/Documents/ODOT%20NEPA%20File%20Management%20and%20Documentation%20Guidance.pdf



Date post:	27-Jun-2020
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