Planning & Environmental Linkage (PEL)
Faith Duncan, IDOTFelecia Hurley, IDOTJohn Sherrill, IDOT
Jon-Paul Kohler, FHWA
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
What is PEL?Planning and Environment Linkages (PEL) represents a collaborative and integrated approach to transportation decision-making that:
1) considers environmental, community, and economic goals early in the transportation planning process, and
2) uses the information, analysis, and products developed during planning to inform the environmental review process
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
PEL is a tool that links transportation planning
to NEPA processing
FHWA’s PEL Timeline2005: SAFETEA-LU requires increased consideration of environment in statewide & metropolitan planning
• 2005: FHWA and FTA issue guidance encouraging stronger linkages between transportation planning and NEPA processes
• 2007: FHWA and FTA issue final transportation regulations Transportation Planning Studies and Project Development 23 CFR 450.212 and 450.318, and PEL Guidance in Appendix A
2011: FHWA promotes PEL through Every Day Counts PEL QuestionnaireGuidance on Using Corridor and Subarea Planning to Inform NEPA
2012: MAP-21 adds new authority for carrying out PEL
2015: FAST Act amends authority for carrying out PELFAST Act added a new PEL approach to 23 U.S.C. 139
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
FHWA’s Project Development
Don’t forget these two “NEPA” federal requirements:
• Subsequent Project phase must be in the fiscally constrained TIP• EAs to be completed in 12 months; EISs in 24 months (effective 9/14/20)
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
Transportation System Condition:
Roads: Condition Rating Survey
Structures: National Bridge Inspection Standards Structure Information Mgmt. System Bridge Analysis & Mgmt. System Analysis
Drainage: Hydraulic Report
Safety: 5% Crash Location Reports
Operations: District Knowledge
Elected Officials and Public: Legislative InquiresMulti–Year Improvement ProgramMeetingsComplaints, etc.
Schedule: Varies
Planning & Pre-Phase 1
Project Level Phase 1 Project Level
Phase 2 Project level Phase 3
Studies:Engineering Studies &Environmental Surveys
Schedule:18 to 24 months
Results:Categorical Exclusion, or Finding of No Significant Impact, or Record of Decision; plus Engineering Report (35%)
Plans:Contract for 100% Detailed Engineering Plans
Schedule:18 to 24 months
Results: Job goes to Construction Letting
Construction:Contractor Selected
Schedule: 1 to 2 years
Results:Improved Transportation
Acquire Temporary & Permanent Right-of-Way from Railroads,
Utilities & others 6 to 24 months
Where Does PEL Fit Within IDOT?
OPERAT IONS
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
PlanningEnvironmental
Linkages
What did the FAST Act add to the PEL approach?
Efficient environmental reviews for project “decision-making”- 23 U.S.C. 139
Integration of planning & environmental review – 23 U.S.C. 168
“shall reduce duplication, to the maximum extent practicable, between the evaluation of alternatives under NEPA and... the metropolitan transportation planning process or a State environmental review process…” 23 U.S.C. 139 (f)(4)(E)
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
PEL and NEPA
• PEL is eligible for PL & Statewide Planning & Research (SPR) funds. • Once the NEPA process has begun, activities undertaken for a project are not
eligible for PL or SPR funds. • A project sponsor decides if a project is to be processed via PEL. • Under PEL, a goal is to secure a NEPA-ready purpose and need and determine the
alternatives that will be studied in detail during NEPA. • Preferred alternative is determined under NEPA, not PEL. • PEL can assist in determining how a project will be processed under NEPA
(CE, EA or EIS).
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
Why PEL?
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
• Transportation problem … Safety, Congestion, Reliability, etc.• Limited engineering & construction funds • Complete preliminary tasks that are NEPA compliant that carry into a future Phase I project.• Allow sufficient project development time: Can’t meet one-year timeframe to complete an EACan’t meet 2-year timeframe to complete an EIS
• Incorporate environmental and community values into transportation decisions, early in planning, and carry these considerations through project development and delivery.
• Enable resource and regulatory agencies to be active players early in the transportation decision-making process.
• Assist in gauging public support for a project.
PEL in Code and Regulation• 23 USC 168
• 23 CFR 450.212 & 318
FHWA PEL Questions and Answers• https://www.fhwa.dot.gov/hep/guidance/pel/pelfaq16nov.cfm#q7b
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
What Conditions Must be Met for PEL under 23 U.S.C. 168?
• Consulted with appropriate Federal and State resource agencies and Indian tribes. • Included broad multidisciplinary considerations of systems-level or corridor-wide
transportation needs and potential natural and human effects. • Public notice.• Has a rational basis, is based on reliable data and reasonable methodologies.• Documented in sufficient detail to support the decision or analysis results.• Appropriate for use in the environmental review process (meets NEPA requirements).• Approved within the 5-year period ending on the date on which the information is
adopted or incorporated by reference.• No significant new information or new circumstances
What Conditions Must be Met for a PEL Study under 23 CFR 450.212 & 318?
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
The study is conducted with -• Involvement of State, local, Tribal, & Federal Agencies• Public review• Reasonable opportunity to comment• Documentation of relevant decisions; and• The review of the FHWA
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
What are the conditions to eliminate an Alternative from Detailed Study under NEPA (23 U.S.C. 139)?
The Lead Agency may eliminate an alternative if: • The alternative was considered in MPO, State or local transportation
agency process• Lead agency provided guidance to MPO, etc. on NEPA requirements• Public review and comment• Rejected after considering public comments• Federal lead agency reviewed the alternative evaluation• Federal lead agency determined the alternative (in consultation with
Federal participating or cooperating agencies) not necessary for -• NEPA compliance• any permit or approval under any other Federal law
PEL Notes: • PEL is anticipated to be utilized for both state and local road projects.• PEL is optional. The project sponsor decides whether to use PEL or not.• PEL is anticipated to be used for many transportation projects that are ultimately processed via
NEPA, as either a complex Categorical Exclusion, Environmental Assessment, or Environmental Impact Statement.
• While in PEL, IDOT and FHWA will assist with evaluating how a project should ultimately be processed: either as a CE-Federally Approved, Environmental Assessment, or Environmental Impact Statement.
• PEL is per FHWA regulations.• Not all projects in PEL will ultimately go to Phase I. In other words, PEL projects could sit-on-
the-shelf for years/decades.... due to lack of funding, lack of need, etc.
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
14
I-80 OVER THE MISSISSIPPI RIVER PLANNING AND ENVIRONMENTAL LINKAGES (PEL) STUDY
IDOT Fall Planning Conference | Faith Duncan, P.E. | October 22, 2020
PEL OBJECTIVES
16
• Data Collection
• Define Purpose and Need Statement
• Explore Alternatives for Consideration
• Identify Stakeholders and Coordinate Public Outreach
• NEPA Merger Meeting
• PEL Report
STUDY AREA
17
WesternTerminus
EasternTerminus
• Western Terminus – East of I-80/Middle Road interchange.
• Eastern Terminus – I-80/I-88 interchange.
• I-80 Mississippi River Bridge – Four lanes with concrete barrier median. Multi-girder steel bridge approx. 3,500 feet long.
• I-80 Mainline – Four lanes with grass median.
• I-80 Interchanges at US 67 (partial cloverleaf), IL 84 (partial cloverleaf), Mississippi Rapids Rest Area (eastbound), and I-88 (full cloverleaf).
• I-88/Old IL 2 interchange (diamond).
• Truck weigh stations eastbound and westbound.
PUBLIC OUTREACH
24
• Virtual Public Meeting
• 500 Participants
• Video
• Presentation
• Live Question & Answer Session
• Post Survey
• Project Website
• www.i80mississippibridge.com
LESSONS LEARNED
30
• Logical Termini
• Purpose and Need
• Virtual Public Meeting
• Duration
• Data Collection
• Coordination
• Funding
• Project Team
• Programmers vs Designers : PEL vs Phase I
• PEER Exchange
PEL Lessons Learned
When to do a PEL –• Do you really have funding for project development/delivery?• Do you really know what class of action will the project be processed?• Do you really think you can complete an EA in one year, an EIS in two years? • Do you really have a project?• Do you really know what the project is yet?
What will your PEL look like?• Clarify scope of study and expectations• I-80 Lessons learned• Scale to funding amount/achievable outcome• Obtain FHWA Concurrence• Data Collection• Public/Agency Involvement
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages
PEL, What Next?
• PEL was adopted in the BDE Manual during June 2020 (see Chapter 11-7.04).
• See FHWA website about PEL: https://www.environment.fhwa.dot.gov/env_initiatives/pel.aspx
• Talk to your IDOT and MPO representative if your project should be processed as PEL.
IDOT Fall 2020 Planning Conference Planning and Environmental Linkages