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Proposal to delegate approval of programmatic categorical exclusions to districts based on a system of standards of submission for deliverables and a QA/QC program for monitoring program performance.
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Standards of Submission, Environmental QA/QC/CI,
PCE Determinations
A Proposal to Decentralize Environmental Review
(View in Notes Page mode to view script)
Baseline Perceptions
District Perceptions Districts should have more authority ENV standards too high
ENV Perceptions Districts not reviewing NEPA documents,
reports, and studies Districts reluctant to disclose impacts Consultants repeating same errors
Shared Perceptions Too much back and forth We’re here to build roads
TxDOT’s Goal To more efficiently build Transportation
Improvements that are environmentally sensitive and supported by the public
Proposal for Change Initiate use of Standards of Submission Develop and implement QA/QC process for
TxDOT CI/training to reduce error, replicate
success Cooperate to prevent error on critical
projects Move PCE determination to Districts Audit performance to identify training and
guidance needs
PCE Agreement What it is
Not Delegation Establishes thresholds for PCEs ENV ensures/verifies thresholds are met If thresholds are exceeded, CE is
forwarded to FHWA If not exceeded, PCE is assumed approved
by FHWA, processed by ENV
Persuading FHWA
FHWA not opposed to delegation SAFETEA-LU 6005 provides model
Transfers FHWA accountability to State DOT’s Reduces FHWA oversight to program audit Links continuation of delegation to audit results
Bottom line: 6005 delegation requires assurances and accountability for FHWA
Use 6005 model for PCE determination at District level
Persuading FHWA ENV developed a 6005 program FHWA already likes TxDOT’s 6005 model:
Regarded TxDOT’s QA/QC/audit system as model for other states;
Wanted others to adopt TxDOT District/ENV structure;
Know TxDOT can monitor itself reliably; FHWA and ENV recognize CI value.
Mr. Saenz wanted our 6005 system regardless of 6005 results
Adapting the 6005 Model Moving PCEs to Districts still leaves FHWA
responsible—unlike 6005 Keys to FHWA acceptance:
Maintaining District/ENV firewall Balancing project- vs. program-level
QA/QC/audit Balancing program standards vs. project-
specific exceptions Maintaining accountability:
between TxDOT, FHWA, and stakeholders within Districts and ENV individually
Implementation Sequence of events
Centerpiece: Finalize, roll out standards of submission (SOSs)
Finalize, roll out, test-drive QA/QC/audit system Perform demonstration audits/CI reviews Request FHWA approval to move verification
authority to districts Repeat as necessary
Standards of Submission Created to increase CZ control over review
time/outcome for SH 130 SOSs:
Define minimum acceptable performance Reduce ambiguity to minimum levels Are Statements of Work for producers,
reference for reviewers Maximizes first-time acceptance by ENV,
agencies and FHWA In place for SH 130
Effectively a pilot program
Standards of Submission What they can do:
Get producers, reviewers on same page Front-load project for successful outcome Reduce preventable re-dos Increase consultant, District, ENV accountability Provide baseline for consistent QA/QC/audit
If producers meet an explicit standard, basic quality happens automatically If there is good reason for more, standard is
place to start
Standards of Submission What they are:
Criteria for acceptance – Maximizes likelihood of acceptance of reports, documents, etc
Baseline for legal adequacy Point of departure for innovation, risk
management What they aren’t:
The only acceptable way to do things Permanently unchanging
Standards of Submission Agency/FHWA approval useful, but not
necessary Even without approval
Can be adapted to Agency/FHWA expectations Point of departure for project-specific
exceptions negotiated by District, FHWA, ENV If exceptions become common, adapt
SOSs to changed Agency/FHWA expectations
Excerpt from Sample SOS
REVIEW STANDARDS FOR DRAFT AND FINAL REPORTS FOR ARCHEOLOGICAL SURVEYS—INDIVIDUAL ANTIQUITIES PERMITS
# Criterion Meets criterion?Yes / No / N/A
1 Report cover and title page include Hwy/limits, Counties, CSJ(s), District(s), Antiquities Permit #, Principal Investigator’s name, and investigative firm’s name. (Abstract form and curation form must accompany final report.)
2 Report includes a map of the area surveyed on a USGS 7.5’ Quadrangle or equivalent if 7.5’ Quad unavailable. (In final report, the map of the area surveyed cannot include site location. Map with site locations must be included as separate enclosure.)
3 Report includes Project Type/Description/Impacts and acreage of area surveyed.
4 Report defines the Area of Potential Effects (APE) in three dimensions, referring to project plans or to typical impacts for this class of project.
5 Report includes discussion of previous work/sites within one kilometer of the area surveyed with explicit reference to review of TARL files, THC or Historic Sites Atlas maps, and explicitly indicates trinomials of sites or absence of sites within one kilometer.
6 Report includes description of topography, soils, and geology. Report references soil survey maps and geological maps for the entire area surveyed or indicates that none are published for the area surveyed.
7 Report includes estimate of surface visibility, description of land use, and general description of vegetation in and adjacent to the area surveyed.
SOSs and QA/QC Legal, guidance, policy foundations of
SOSs define: Performance standards for various
environmental tasks Standards for documentation/disclosure
Therefore, SOSs define: Minimum standards for tech reports,
documents, studies, etc QA/QC/audit criteria that apply to both ENV
and Districts
District QA/QC Check reports, studies, and documents
against SOSs For consultants, Districts, local governments
District performs QA/QC review Preparer and District certify:
Report, study, document, meets SOSs, or Report, study, document deviates from SOSs, but
meets: Other criteria pre-approved by FHWA and ENV/other
agencies (i.e., project-specific SOS) Legal requirements covered by SOSs
Under PCE determination by districts, SOSs become standards for District review and approval
Excerpt from Draft Certification
COMPLETED ENVIRONMENTAL DOCUMENT CERTIFICATION CSJ: __________ Highway: ____________ County: _______ District: ______
Project Scope:__________________________________________________
Description Yes No NA
Does the N&P discussion follow current guidance? ___ ___ ___
Has the district actively developed the project with planners, designers, & MPO? ___ ___ ___ Are the project limits and logical termini identified/ consistent? ___ ___ ___
Do the typical cross sections match the text describing the proposed improvements? ___ ___ ___
Has the appropriate level of public involvement been completed? ___ ___ ___
Is project in current MTP/STIP/TIP? ___ ___ ___
Is the document properly classified per 23 CFR 771 and 43 TAC 2.1-2.20 (BCE, SCE, PCE, CE, EA, EIS)? ___ ___ ___
Has the district completed the two-tier level QA/QC process? ___ ___ ___
[…]
This document is fully compliant with the NEPA process and with all the rules, regulations, permits, and environmental procedures.
_________________________________ _________________________________
Authorized Preparer Representative/Date Authorized District Representative/Date
ENV QA/QC/Audit Check certain % of reports, studies and
documents for conformance with: SOSs, or Pre-approved deviations, or Legal requirements covered by SOSs
Check environmental tasks for conformance with SOSs or legal requirements
Maintain data base of review results Periodic audits to evaluate performance Periodic meetings w/ Agencies/FHWA to gauge
their perspective of program issues
Audit 6005 model relies on program-level audit
Determine success of delegation Identify opportunities for mid-course change Monitor effectiveness of mid-course change
Approach consistent with: FHWA approach in LGPOTF TxDOT use of Independent Engineers in CDAs TxDOT’s general internal audit program
Base PCE move to districts audit on 6005 model
Audit: Proposed Model Identify possible systemic error, success
Use QA/QC data base Look for correlations involving specific districts,
issues, reviewers, project types, etc. Examine project files
Is correlation actual vs apparent? Can a cause be identified? Is there problematic or innovative deviation from
SOSs, legal requirements of SOSs, or pre-approved deviations?
SOSs become audit standards
Audit & Continuous Improvement Program-level audit to identify
opportunities for program improvement Program-level QA/QC audit directed
toward identifying: Systemic causes of error Replicable innovations Proposed changes
Proposed changes function as CI recommendations Training, guidance, technical assistance likely
to be major CI items
Maintaining PCE move to Districts Principal key: Maintain quality
Meet FHWA comfort levels Maintain accountability Maintain relationships with resource agencies Document legal defensibility of program
Prevent QA/QC problems Respond to CI recommendations Foreclose review problems through
Pre-approved deviations from SOSs ENV technical assistance for difficult tasks
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