WRITING A BETTERPURPOSE AND NEED

A COMMON SENSE APPROACH

Kevin E. DavisEnvironmental Supervisor

ODOT-OES

What’s the Purpose?

What’s the Need?

Is there aPurpose and Need?

FHWA Definition

PurposeStates concisely and clearly why the

project is being proposed and articulates the positive outcomes that are intended

NeedDescribes the key transportation

problem(s) to be addressed and, to the extent possible, explains the underlying causes of those problems

CEQ Definition

40 CFR 1502.13 The statement shall briefly specify

the underlying purpose and need to which the agency is responding in proposing the alternatives including the proposed action

Importance of P&N

The P&N, in many ways, is the most important chapter of an environmental document

Explains to the public and decision-makers that the expenditure of funds is necessary and worthwhile, and that the priority the project is being given relative to other needed highway projects is warranted

Importance of P&N

Justifies why significant environmental impacts are acceptable based on the importance of the undertaking

Serves as the cornerstone for the Alternatives Analysis, but is not designed to discuss solutions to a transportation problem

Importance of P&N

Avoid developing an ill-conceived project

Defines transportation problems and objectives

Coordinate and communicate with stakeholders

Manage controversy

Importance of P&N

Justifies impacts

Guide development of and evaluate alternatives

Establish logical termini and independent utility

Ensure decisions are legally defensible

Transportation Needs

Transportation Needs

Transportation Needs

Transportation Needs

Transportation Needs

Transportation Needs

Economic Development How does it fit?

Most (if not all) communities have a vision for how they want their communities to evolve and prosper

A desired outcome of a majority transportation project is the facilitation of growth/economic development

However, transportation facilities are rarely the sole cause of economic development

Economic DevelopmentHow does it fit?

Transportation infrastructure and other public infrastructure collectively help determine the growth of a community

Provision of transportation infrastructure can facilitate the changing of land uses, which can lead to community growth/economic development

Economic DevelopmentHow does it fit?

When growth/economic development is part of the P&N, identify sources to support this information, such as:

MPO Long Range Transportation Plan or Comprehensive Transportation Plan

County and/or municipal land development plans or visioning documents

Economic DevelopmentHow does it fit?

When growth/economic development is desired, the Purpose Statement should not be written as:

“the purpose is to promote growth/economic development.”

Economic Development How does it fit?

The Purpose Statement should be grounded in transportation:

“The purpose is to provide transportation infrastructure to support community development as identified in [a plan].”

Economic DevelopmentHow does it fit?

Do not include in P&N if economic development can not be substantiated

Focus on the transportation problems

Avoid defining a purpose so broad that it requires consideration of a vast range of non-transportation alternatives in order to promote economic development

Putting it all together!

Basic Ingredients

Project History Status of the undertaking Background of previous studies Legislative mandates (i.e. earmarks) Long range plans, MPO studies, etc

Purpose Statement Clear and succinct Intended positive outcomes The “driver” behind the undertaking

Basic Ingredients

Need Elements Transportation problem(s) Existing, Future, and Desired

Conditions

Goals and Objectives Desired outcomes Important to consider

Summary

Basic Ingredients

Logical Termini Transportation problem begins/ends Rational end points

Independent Utility Interaction with intersecting

elements Does not rely on separate actions

“Just the Facts”

Eliminate FLUFF Opinions do not count Factual data

Words to avoid: May, maybe, likely, and could;

subjective Significant, segment, and hazardous;

Legal interpretations

What we’re looking for Categorical Exclusion projects One or two paragraphs per need element

EA or EIS projects Can be more detailed No more than three to five pages of text

Tangible, quantifiable data

Comprehensive, specific, and concise

End Result

Defines the transportation problem(s)

Needs establish logical termini and independent utility

Creates a baseline to evaluate, eliminate or advance alternatives

Does not restrict consideration of alternatives for other transportation improvements

THANKS FOR COMING!

Always contact respective ODOT District

You can always contact ODOT-OES Erica L. Schneider - AEA Policy Kevin E. Davis - Environmental Supervisor Libby Rushley - NEPA/Document ReviewODOT Districts 1, 2, 3, 7, 8, 12 Amber Hewitt - NEPA/Document ReviewODOT Districts 4, 5, 6, 9, 10, 11