Integrating Road Safety into NEPA Analysis:
A Primer for Safety and Environmental Professionals
4.0 Public and Stakeholder Outreach
This section describes techniques for incorporating safety into public involvement activities related to NEPA. Public involvement requirements under NEPA are summarized in the text box below. In addition, SAFETEA-LU Section 6002 requires that lead agencies establish a plan for coordinating public and agency participation and comment during the environmental review process.
Public Involvement Requirements
Each state must have procedures approved by the FHWA to carry out a public involvement/public hearing program pursuant to 23 U.S.C. 128 and 40 CFR Parts 1500 through 1508. State public involvement/public hearing procedures must provide for:
- Coordination of public-involvement activities and public hearings with the entire NEPA process.
- Early and continuing opportunities during project development for the public to be involved in the identification of social, economic, and environmental impacts, as well as impacts associated with relocation of individuals, groups, or institutions.
- One or more public hearings or the opportunity for hearing(s) to be held by the state highway agency at a convenient time and place for any Federal-aid project which requires significant amounts of right-of-way, substantially changes the layout or functions of connecting roadways or of the facility being improved, has a substantial adverse impact on abutting property, otherwise has a significant social, economic, environmental or other effect, or for which the FHWA determines that a public hearing is in the public interest.
- Reasonable notice to the public of either a public hearing or the opportunity for a public hearing. Such notice will indicate the availability of explanatory information. The notice shall also provide information required to comply with public involvement requirements of other laws, Executive Orders, and regulations.
Source: FHWA Environmental Toolkit, Public Involvement Overview, http://www.environment.fhwa.dot.gov/projdev/tdmpubinv2.asp.
The extent to which public involvement activities focus on safety is partially a function of the main purpose of the project (safety-focused or nonsafety-focused) and the potential level of impact. Identify safety-focused projects through analysis, community input, safety plans, or more traditional planning processes. Introduce the topic of safety early in coordination, public involvement, and project development activities, such as advisory committees and stakeholder interviews.
The scope of an Environmental Impact Statement (EIS) refers to the range of actions, alternatives, and impacts to be considered. The scope is determined by the lead agency, preparers of the EIS, and the public, including other agencies. Scoping is the process of determining the scope of an EIS. It is a unique NEPA task that is required only for EISs. Part of the scoping process includes obtaining the public’s opinion on what important issues, including safety, should be addressed, and what project alternatives should be included in the EIS. While not required for CEs or EAs, the concept of scoping has merit for any NEPA class of action. Soliciting comments early in the project development process elevates stakeholder input and allows it to help shape the range of actions, alternatives, and impacts to be addressed. This focus on scoping-oriented outreach can also facilitate early and effective consideration of safety as well. The techniques described in the rest of this chapter apply to public involvement activities during scoping, as well as other stages of the NEPA process.
4.3 Who to Contact
Many individuals and groups can provide valuable input into the safety aspects of a project. Three important groups to consider include safety specialists, affected agencies and community groups, and facility users (discussed below).
Outreach to safety stakeholders does not eliminate the need for required outreach to other types of stakeholders, including low-income and minority populations protected by Title VI and related statutes.
Safety specialists possess unique knowledge of how to diagnose safety problems and address them using proven safety countermeasures. Drawing professionals from a range of backgrounds increases the likelihood that safety problem is diagnosed accurately, and a range of possible solutions is investigated. For example, the following describes types of input that could be provided by different types of safety specialists:
- Engineers with safety training can analyze crash data; determine which types of crashes are most prevalent; and identify changes to the roadway geometry, roadside features, signing, striping, or operations to address the identified issues. Engineers also may have knowledge of safety treatments to benefit specific users (e.g., pedestrians, bicyclists, and older road users); and knowledge of the Manual on Uniform Traffic Control Devices or MUTCD.
- Representatives of the Governor’s Highway Safety Office have knowledge of driver behavior issues.
- Maintenance crews have firsthand knowledge of the types of safety issues occurring on the facility (e.g., identifying locations where damaged roadside hardware may suggest a pattern of run-off-road-crashes).
- Local law enforcement officials may be aware of infrastructure and behavioral issues contributing to an identified crash problem (e.g., high incidence of late night crashes involving college students driving home after drinking).
- Emergency response personnel may be able to identify the degree to which poor response times are contributing to a high incidence of injuries and fatalities and suggest solutions. They also sometimes are the first to recognize a hot spot, or wet weather problem area because of multiple responses to the same location.
Incorporate the input of these professionals early in the project development process. Ideally, consult with them prior to initiation of the NEPA process (see Section 2.0) during safety planning processes. If this did not occur, consult with them during the early stages of developing the project purpose and need statement (see Section 5.0 for more detail). RSAs, also discussed in Section 5.0, are a tool for engaging safety professionals in diagnosing safety problems on an existing or planned facility.
In addition to contributing to problem diagnosis, safety professionals can contribute to or comment on the development of alternatives and the selection of mitigation strategies. For example, they may be able to suggest proven safety countermeasures to include in project alternatives, or to mitigate any expected safety impacts. Document all feedback so it can be used to meet NEPA outreach requirements. Documentation also is important to create a record of decisions (ROD) and commitments made during the NEPA process, so these can be communicated during project development and construction.
Affected Agencies and Community Groups
Public agencies affected by the project may have special concerns or knowledge regarding the project’s safety impact. Transit agencies may suggest improvements to pedestrian safety around transit stations. Officials from local public schools may be concerned about ensuring child safety to and from school.
Community groups and the general public will also likely have opinions or concerns regarding the safety of the facility. Local merchants may voice concerns regarding any roadway changes that affect access to their property. Community groups representing specific interests (bicycle and pedestrian advocacy groups, freight community, older drivers, disabled individuals, etc.) will advocate for consideration of all users.
Case Study: Safety and Public Outreach
A 40-mile stretch of U.S. 8 in western Wisconsin has been of interest to a coalition of county and local officials concerned with safety and congestion along the corridor. Input from the coalition has played a significant role in the selection of the preferred corridor for the eventual construction of a multilane facility. The coalition established a close working relationship with the Wisconsin Department of Transportation (DOT) to study corridor safety and congestion, participated in public forums, and held meetings. High fatalities on a particular segment prompted them to request a Road Safety Audit that will inform selection of the preferred alternative. Appendix B.5 provides more detail on this case study.
In considering outreach targets, first investigate the context and the specific type of safety problem at hand. Is the project near a school, a major bicycle route, a downtown area, or a freight corridor? Does the safety problem particularly affect bicyclists, pedestrians, or older residents? The context and the nature of the problem should inform the selection of stakeholders. Refer to Section 7.0, Defining the Affected Environment, for how context-specific factors may influence safety.
Outreach activities also provide an opportunity to gain insight from members of the general public who use the facility. Regular users of a transportation facility may be aware of problems missed by transportation engineers or other safety specialists. Reaching out to a range of users (vehicles, freight, pedestrians, bicyclists, etc.) will provide a more balanced perspective.
Facility users or members of the general public also may suggest solutions to identified safety problems. However, they may not be aware of the research regarding the likely safety benefits of their suggestions. It is, therefore, critical to use public outreach as an opportunity to educate the public and elected officials about the true safety impacts of certain types of project features. For example, if several crashes have occurred at a stop-controlled intersection, community members might advocate for installing a traffic signal to reduce crashes. However, research has shown that installing a traffic signal may actually increase the frequency of crashes (Transportation Research Board, 2003, NCHRP 500 Volume 5, A Guide for Addressing Unsignalized Intersection Collisions, http://onlinepubs.trb.org/onlinepubs/nchrp/nchrp_rpt_500v5.pdf). Use simple educational materials to communicate to the public the likely impacts of their requests and the safety benefits of alternatives.
Table 4.1 lists possible stakeholders organized by context. It does not list all possible stakeholders.
Table 4.1 Potentially Interested Stakeholders
||Safety problem diagnosis; knowledge of proven safety countermeasures and best practices.
||Personal experience and data reflecting safety issues on the facility. Awareness of areas that need safety improvement.
|Traffic operations center personnel
||Knowledge and data regarding incidents, crashes, and other issues on highway facilities. Familiarity with issues relating to incident response.
||Personal experience and data regarding safety issues on the facility. Awareness of behavioral safety issues (intoxication, speeding, etc.) affecting the facility.
|Incident response teams
||Knowledge of poor incident response times contributing to degraded trauma care outcomes; knowledge of hot spots on facility.
|Affected Agencies and Community Groups
||Child safety/school access
|Transit agency representatives
||Impact of safety features on transit operations/safe pedestrian access to transit stations.
||Impact of safety features on access to their business.
|Bicycle and pedestrian advocacy groups
||Bicycle and pedestrian safety concerns and solutions.
|Drivers, bicyclists, pedestrians, delivery trucks
Personal experience with safety and mobility issues on the facility.
4.4 Questions to Ask
Gather input on safety-related questions during each stage of the NEPA process, as required by Federal regulations (see box). The following sections list possible questions to ask during each major stage.
Topics to be Covered During Public Involvement – 23 CFR 771.111(h)(2)(v)
State public involvement/public hearing procedures must provide for explanation at the public hearing of the following information, as appropriate:
- The project’s purpose, need, and consistency with the goals and objectives of any local urban planning;
- The project’s alternatives and major design features;
- The social, economic, environmental, and other impacts of the project;
- The relocation assistance program and the right-of-way acquisition process; and
- The state highway agency’s procedures for receiving both oral and written statements from the public.
Purpose and Need Statement
Whether or not the project is safety focused, early dialogue about the project purpose and need statement should address safety. Sample questions for the public might include:
- What safety problems or issues have you experienced in this area/facility/corridor?
- What safety problem or issue do you think this project should address? What is your vision for improving safety in this corridor/area/project?
- Which types of road users (e.g., elderly, pedestrians, transit, and commercial vehicles) require special consideration?
- Are there special features of the proposed project and its surrounding envi-ronment that might have safety implications? If yes, what are the features and what are the safety implications?
Range of Alternatives
During development of project alternatives, stakeholders traditionally give input on how well each alternative meets the purpose and need of the project. To expand this discussion, provide stakeholders with meaningful information and analysis about the safety characteristics of each alternative so they can offer informed input on the alternatives. (See Section 6.0, Alternatives Analysis, for a discussion of how safety analysis tools can be used to provide quantitative information regarding the expected safety performance of different alternatives.) Sample questions for this stage of public involvement may include:
- Have any existing safety problems been addressed by the alternatives shown?
- Have the alternatives created any new safety concerns?
- Has safety been sufficiently integrated into all alternatives?
- Do you see any potential safety issues that should be addressed?
- Do you have any concerns regarding the safety of proposed alternatives?
As stated earlier, it is important to educate the public on which project features have proven safety benefits versus those that do not.
Social, Economic, and Environmental Impacts
Include safety topics in the discussion of project social, economic, and environment impacts. Questions may include:
- Have safety impacts been adequately addressed for all populations?
- Has the impact assessment missed anything or anyone?
- Are there any land uses or community features that create unforeseen safety implications?
- Have any potential safety concerns been avoided or mitigated in the pre-ferred alternative?
Chapter 7 of the Highway Safety Manual (discussed in Appendix A.4) provides information on analyzing the economic and social impacts of highway crashes. The Highway Safety Manual (HSM) is a definitive, science-based manual that takes the guess work out of safety evaluations. It provides tools to conduct quantitative safety analyses, allowing for safety to be quantitatively evaluated alongside other transportation performance measures, such as traffic operations, environmental impacts, mobility measures, or construction costs. The Highway Safety Improvement Program manual is another relevant reference document. Both of these resources can assist in generating additional questions to engage the public.
Document all feedback to ensure NEPA public outreach requirements are met and decisions are recorded for future reference.
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