DEVELOPING A GOOD PURPOSE AND NEED. Patrick Lee TxDOT Environmental Affairs Division

Transcription

1 DEVELOPING A GOOD PURPOSE AND NEED Patrick Lee TxDOT Environmental Affairs Division

2 Efforts and courage are not enough without purpose and direction. JFK 2

3 TxDOT ENV Guidance Preparing a Purpose and Need Statement TxDOT.gov Inside TxDOT Divisions Environmental Affairs Environmental Compliance Toolkits NEPA and Project Development 3

4 Why is a Purpose and Need Statement Important? Provides basis for development and evaluation of project alternatives Each alternative must be analyzed in terms of the extent to which it will or will not satisfy the purpose and need 4

5 Where does the Purpose and Need Statement go? Has its own heading within EA or EIS Near the beginning of the document, before discussion of alternatives In TxDOT s EA Outline, the Purpose and Need Statement is Section 3.0 Generally no longer than one or two paragraphs (more on that later) 5

6 Three parts to a Purpose and Need Statement 1. Need (single sentence) 2. Supporting Facts and/or Data 3. Purpose (single sentence) 6

7 Part 1 The need sentence Identifies the transportation-related problems or unsatisfactory conditions the project is needed to address Can be a single transportation-related problem or unsatisfactory condition no need to bolster with further justifications 7

8 Example of a need sentence The project is needed because FM 1234 between the intersections with Elm St. and Maple St. is: (a) (b) inadequate to meet current and future traffic volumes, resulting in congestion, reduced mobility, and a Level of Service of F on this stretch of highway; and does not meet current design standards as the travel lanes are too narrow and there are no shoulders. 8

9 Part 2 Supporting Facts and/or Data The need sentence cannot be conclusory must be supported by facts or data 9

10 Examples of types of supporting facts and/or data Safety Describe the crash history, relating the history to similar roadways, as appropriate Identify design or operational issues leading to safety problems, such as vehicles have to make unprotected left turns 10

11 Examples of types of supporting facts and/or data Congestion and/or mobility Discuss the capacity of the existing facility and its ability to meet current and future traffic volumes Provide historical, present, and protected traffic volumes and levels of service Describe any trends in land use and population leading to congestion 11

12 Examples of types of supporting facts and/or data Failure to meet current design standards Explain how the existing roadway does not meet current design standards, such as load limit, geometrics, or lack of turning lanes 12

13 Examples of types of supporting facts and/or data System connectivity Explain how the existing transportation system within the project area interfaces and connects with other facilities, and identify any connectivity problems 13

14 Do I need to do a separate Purpose and Need Technical Report? In most cases, no -- the entire purpose and need statement can be included in the body of the EA or EIS However, in rare cases where there is a substantial amount of supporting facts and/or data that needs technical explanation, it may be appropriate to do a separate Purpose and Need Technical Report Talk to your ENV core team member before doing this 14

15 Part 3 The purpose sentence Again, just a single sentence The need sentence describes a problem, the purpose sentence states the intention to solve that problem Must be 100% consistent with the need sentence 15

16 Need: Example of a purpose sentence: This project is needed because the capacity of FM 1234 between the intersection with Elm St. and Maple St. is inadequate to meet current and future traffic volumes, resulting in congestion and reduced mobility on this stretch of highway. Purpose The purpose of the project is to reduce congestion and improve mobility on FM 1234 between the intersections with Elm St. and Maple St. 16

17 Bad purpose sentences Do not identify or describe the preferred alternative, or be so narrowly written as to unreasonably limit the consideration of alternatives to address the need, or leave construction of the preferred alternative as the only alternative that could possibly fulfill the purpose. The purpose of the project is to widen the two-lane road to four lanes to relieve congestion. No! 17

18 Bad purpose sentences Likewise, the purpose sentence must not be overly broad, such that it invites the consideration of a near infinite number of alternatives. The purpose of the project is to improve traffic mobility in Austin. No! 18

19 More tips In writing the need statement, limit it to problems or unsatisfactory conditions for which a solution is truly needed the more concise and focused the need statement, the easier it will be to later compare and evaluate alternatives 19

20 More tips Do not include non-transportation-related issues or outcomes and goals that are merely desirable, but not essential For example, do not include minimization of environmental impacts, as this is not a transportationrelated problem or unsatisfactory condition. We can still take into consideration without it being a project need. 20

21 More tips Do not break the purpose and need statement into primary, secondary, and tertiary needs and purposes too complicated 21

22 More tips Do not rely exclusively on planning or programming documents, like the STIP, to justify the project. It s not sufficient to just say, this project is called-for by the STIP, as this does not convey the true, underlying need and purpose of the project 22

23 More tips Do not discuss alternatives in the purpose and need statement Alternatives are discussed and evaluated in the Alternatives Section of the EA or EIS (Section 4.0 in ENV s EA outline) 23

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