Integrated Planning Work Group
Two-Year Work Plan
June 2007

Introduction

President Bush signed Executive Order (EO) 13274, Environmental Stewardship and Transportation Infrastructure Project Review, on September 18, 2002. This EO established an Interagency Task Force to cooperate on the promotion of environmental stewardship in transportation programs and to ensure coordination and process improvement for transportation projects during the environmental review process. In addition to working on a number of priority transportation projects, the Task Force identified three areas where Federal coordination and decisionmaking should be improved. The three areas identified were: integrated transportation planning challenges and opportunities; indirect and cumulative effects; and purpose and need. A work group was formed for each one of these areas consisting of representatives from each of the Task Force agencies.

Since its formation, the field of integrated planning has been advanced by this work group and other bodies. This work plan represents a summation of that advancement and the priorities of this work group moving forward. The work plan outlines the following:

1. Background of the Issue
2. Definition of Key Terms
3. Identification of Key Issues
4. Integrated Planning: Status of Activities
5. Priorities for the Next Two Years

The work group wishes to acknowledge the authority of state and local governments with respect to planning decisions. The discussion and recommendations of this work plan are intended to provide insight, opportunities, and best practices to transportation planners, resource planners, and resource agencies to enable them to better integrate a wide range of factors into planning decisions, should they desire to do so.

I. Background

The Task Force recognized the continuing need to more effectively “link” transportation planning and corridor level planning studies performed by State and local governments and Metropolitan Planning Organizations (MPOs) with the subsequent project-specific environmental reviews, approvals, and permitting processes. There has been a realization over the years that these two processes, which operate in separate areas of authority and jurisdiction, lack adequate early coordination resulting in lost opportunities for maximizing protection of environmental resources, creating conditions for costly delays later in the NEPA process. Local, metropolitan, and statewide aviation and surface transportation planning processes result in transportation plans developed by local and State governments and airport sponsors. These plans may identify State, regional, and local needs and must take into account a range of planning factors, including the overall economic, social, and environmental effects of transportation systems. However, the linkage between the local transportation planning process and the federal environmental review process is not always clearly defined. For surface transportation projects, long-range planning studies typically do not provide the types of information necessary to support project-level environmental decisionmaking and often fail to attract the participation of Federal resource agencies to ensure that environmental issues are considered.

Planning for aviation projects differs from surface transportation planning. In aviation, state agencies and MPOs, which plan for a system of airports within their jurisdiction, generally limit their planning to broad recommendations on airport role and development. Project development normally flows from the master planning done by airport sponsors for specific airports. It is important to link airport master planning with project specific environmental reviews, approvals, and permitting processes. This is particularly important for large and complex airport development projects. Although the discussion in the sections below may not accurately describe how airport development projects are planned, the concepts presented for integrating transportation planning and environmental processes should be incorporated into the formulation of airport development projects.

Federal agencies typically use the NEPA process as the mechanism to concurrently meet their environmental review, approval, and permitting responsibilities for specific projects. Linking long term State, local and MPO transportation planning with project planning and NEPA promotes stewardship when it takes environmental issues into account up front and early in the process, resulting in a project design that moves through the approval process in a predictable and timely way and addresses environmental mitigation and enhancement throughout the project’s phases. Integrated planning also offers the opportunity to examine multiple projects planned for a given area in a comprehensive way, saving time and effort and improving the cumulative impacts analysis. Effectively linking the planning and environmental processes can result in shorter environmental review times for projects by bringing together the necessary agencies and stakeholders well ahead of project development. Such integrated planning maximizes use of scarce resources by encouraging agencies to work in a concurrent, rather than a sequential fashion, on decisions and approvals for projects. Therefore, this integrated process promotes the analysis and selection of alternatives that can be a win-win for meeting transportation and environmental protection needs. By fully exploring options and alternatives to meet transportation needs and address environmental concerns, integrated planning identifies cost-effective and environmentally sensitive solutions, improves public relations, and lessens the likelihood of legal obstacles by soliciting and addressing stakeholder concerns and interests early in the project development process.

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II. Definitions of Key Terms

Airport Planning - Airport planning is the process of identifying the aeronautical needs of a community, region, state, or nation and recommending a plan of airport development to meet those needs. Through such planning, the condition and performance of individual airports or the system of airports is determined and a concept of development is presented. Airport planning is conducted for both individual airports (master plan) and for a system of airports (system plan). The planning period has short term (0 to 5 years), intermediate term (5 to 10 years), and long-term (10 to 20 years) components.

Airport Development - Airport development is the undertaking by an airport sponsor of facility construction, reconstruction and improvement; equipment acquisition and installation; land acquisition; engineering and design services; mitigation of aeronautical hazards; and other similar activities needed to improve a public use airport.

Airport Master Plan - An airport master plan is the product of a thoughtful process to identify the needs of an individual airport and a plan of action to address these needs. It represents an airport sponsor’s approved actions to be accomplished for the phased development of an airport. The master plan is displayed in both graphic form (Airport Layout Plan) and text form (Master Plan Report).

Consultation - State Departments of Transportation and Metropolitan Planning Organizations are required to consult with stakeholders early and continuously throughout the transportation planning processes, both for the long-range plan (20-year time frame) and for the Transportation Improvement Program (4-year time frame). ¹ Of specific interest for resource agencies, when developing long range transportation plans, State DOTs and MPOs must consult, as appropriate, with "State and local agencies responsible for land use management, natural resources, environmental protection, conservation, and historic preservation." In addition, State DOTs must consult with State Historic Preservation Officers and Indian tribes. At a minimum, such consultations are to consist of 1) a comparison of transportation plans with State conservation plans or maps, if available; and 2) a comparison of transportation plans to inventories of natural or historic resources, if available. ²

Corridor Planning - Corridor planning is a targeted analytical effort that addresses specific surface transportation problems identified in a corridor or subarea of a region. Corridor planning includes the development of goals, objectives, and evaluation measures for the corridor; alternative strategies to address identified problems; an analysis of forecasted impacts of these alternative strategies in terms of environmental, transportation, and financial impacts; and an evaluation of how each alternative strategy addresses the specified problems of, and goals and objectives for, the corridor. Corridor planning can occur as part of, or prior to, the formal NEPA process.

Environmental Stewardship - Environmental stewardship involves the careful management of environmental resources and values through partnerships among public and private agencies. The goal is not to simply comply with regulations, but also to improve environmental conditions and the quality of life when possible. (AASHTO definition)

Integrated Planning - Integrated planning is a process or method for considering and documenting the consideration of environmental concerns early in the planning process and involving resource agencies and the public in identifying and refining concerns and broad strategies to maximize environmental protection and transportation benefits. The coordination of watershed plans and transportation plans at the broad system level is an example of integrated planning.

Landscape Level Mitigation - For surface transportation projects, landscape level mitigation considers the impacts to resources beyond the individual project level, by grouping proposed projects and impacts with solutions which will mitigate these impacts based on a watershed, air basin, wildlife corridor, habitat, or similar, resulting in greater protection to ecosystem processes. A 2006 report, Eco-Logical, gave an overview of this type of ecosystem planning. ³

Linking Planning and NEPA - Linking planning and NEPA creates a continuum between transportation planning at the conceptual level and the project-level NEPA process. Assessments of corridor issues done at the ecosystem level, for example, could be linked to the NEPA assessment of a project alignment through tiering, sub-area, or corridor studies. This process can help to validate early consideration of environmental concerns in the planning process, before project alignments are specified.

Long-Range Planning - In surface transportation planning, this refers to a transportation plan that meets future needs for 20 years or more. The long-range transportation plan for metropolitan areas and for States includes projections for land use, population, employment, and future transportation needs for the 20-year period. In other agencies, long-range planning may represent a different planning horizon. For example, the Forest Service uses a 15-year horizon for long-range plans.

Metropolitan Planning Organization (MPO) - MPOs serve as a forum for cooperative and collaborative surface transportation decision-making for Census-defined Urbanized Areas with population of 50,000 and greater. MPOs provide short and long-term solutions to transportation and transportation related concerns. Under aviation systems planning, MPOs provide recommendations on the role and development of airports within their jurisdiction.

Planning-Level Mitigation - This concept has been developed to maximize the opportunities for ecosystem mitigation measures. A discussion of potential environmental mitigation activities is now required for each statewide and metropolitan long-range plan. This discussion is to be developed in consultation with Federal, State, and Tribal wildlife, land management, and regulatory agencies. ⁴

Project Development - For surface transportation activities, project development relates to activities that are undertaken to refine the concepts and needs identified in the long-range planning process and result in project decisions that progress to final design and construction. The NEPA process and the preliminary design are the primary components of project development. For aviation projects, project need and alternatives analyses are developed under airport master plans.

Resource Agency - This term is defined to include not only traditional resource/regulatory agencies, such as the United States Fish and Wildlife Service (USFWS), National Oceanic Atmospheric Administration Fisheries (NOAA), and the Advisory Council on Historic Preservation (ACHP), but also other regulatory agencies such as the United States Army Corps of Engineers (USACE), land management agencies such as the United States Forest Service (USFS), and agencies with both resource and regulatory responsibilities such as the Environmental Protection Agency (EPA), as well as State and local agencies with review and approval responsibilities, such as the State Historic Preservation Officer.

State Departments of Transportation (State DOTs) - Each State, Puerto Rico and the District of Columbia has a State-level department that is responsible for implementing the Federal transportation program within that State. Implementation includes planning, engineering, constructing, operating and maintaining transportation facilities within the State. Also, most State DOTs have a separate aeronautical office to assist FAA field offices in funding and technical support of airport development projects.

Tiering of Environmental Analyses and Documents - Tiering is the process of addressing general broad matters such as general location, mode choice, and regional air quality or land use implications in a broad scope Environmental Impact Statement (EIS) or Environmental Assessment (EA), and then analyzing a narrower site-specific proposal or proposal for a specific alignment in a subsequent, Tier 2 environmental document. The Tier 2 analysis and documentation focuses primarily on the issues relevant to the site-specific proposal or proposal for a specific alignment, and does not duplicate material found in the Tier 1 document.

Transportation Planning - Metropolitan Planning Organizations (MPOs) and State Departments of Transportation (State DOTs) plan for transportation in a continuing, comprehensive and cooperative process. Both MPOs and State DOTs regularly renew their long-range transportation plans, covering 20 years, and a shorter term plan called the (State) Transportation Improvement Program (TIP or STIP). The metropolitan long range plan, the TIP and the STIP are fiscally constrained. The transportation planning process takes into account demographic and travel characteristics for a given area, how they will change over a given period of time, and evaluates alternatives for the transportation system of the area.

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III. Identification of Key Issues

The work group identified three broad issue areas:

1. Integrating Environmental Considerations Early into the Planning Process

• The regulatory landscape for transportation planning has changed since this work group was formed. SAFETEA-LU section 6001 requires consultation and mitigation in the transportation planning process, both for MPOs and State DOTs. Improving the interface between all transportation planning staffs, project development staffs, and resource agency staffs will help transportation planners further the goals of SAFETEA-LU. There is significant flexibility given to MPOs and State DOTs regarding how environmental factors are considered in the development of Statewide and metropolitan long-range plans, pre-NEPA corridor-level studies, and the shorter-range transportation improvement programs. Delays can occur if environmental requirements are not factored into project development adequately, and it can be difficult to reach consensus at the project level when planning-level decisions about environmental enhancement and preservation are not robust and well documented.
• Beyond basic compliance with SAFETEA-LU and regulatory requirements, there has been increased interest in having resource agencies contribute their expertise to the long-range and project planning processes. To efficiently utilize this expertise it is important to develop methods to provide adequate and timely notice to these agencies of how and when to comment, and to the local planners as to how and why it would be beneficial to consider this input in development of plans, programs and projects. It is also important to help planning agencies learn to communicate transportation options and outcomes in ways that can be understood by other agencies and the public. Building relationships between the many entities involved in integrated planning is an important part of making this collaboration possible.
• Linking the state and local transportation planning process with the NEPA process has been a topic of interest for policy makers and researchers for several years. Revisiting planning decisions in the NEPA review phase often leads to backtracking and other inefficiencies. The regulations in effect regarding Statewide and metropolitan planning contain provisions that do not require, but that do allow, agencies to link the transportation planning and NEPA processes. Additional training, outreach, and pilot projects will be needed to establish these linkages as standard practice. Without these linkages, neglecting environmental review issues in the early stages of planning often leads to revisiting long-range planning decisions, resulting in the delay of transportation improvements and increased costs.
• Integrated planning ensures that each agency or entity (Tribal, Federal, State or local) respects the other agencies’ jurisdiction, roles, and responsibilities. Furthermore, each party involved needs the training and education that will allow them to participate fully in an integrated process. Effective communication is essential throughout this process and enables the understanding of issues and concerns of all parties involved.

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2. Tiering, Corridor and Sub-area Studies as Planning/NEPA Integration Tools

• Tiering, corridor and sub-area studies are encouraged by various regulations governing transportation planning and NEPA review of projects. CEQ regulations state that it is “appropriate” to tier the NEPA process when a broad scope analysis is used to address issues that are “ripe for decision” at that time. ⁵ The FHWA/FTA planning regulations promulgated in February 2007 encourage the use of corridor and sub-area studies to a similar level with tiering. The Environmental Impact Statement or Environmental Assessment conducted for a specific project can avoid duplication of information and analyses through incorporation by reference of corridor and wider area studies and tiered analyses. FHWA/FTA regulations recommend a tiered approach to look at “broad issues”, such as general location, mode choice and regional air quality or land use implications. ⁶ Section 4(f) regulations recognize tiering as a mechanism that complies with the USDOT Act of 1966 while using a lesser degree of detail to perform a “preliminary evaluation” of 4(f) use. ⁷
• The concepts of tiering, corridor, and sub-area studies are currently being employed by FHWA/FTA in efforts to integrate transportation planning with the NEPA environmental analysis. For surface transportation projects, tiering the NEPA project decisionmaking process and corridor studies allow for environmental input and “shaping” of early transportation planning-type decisions by all involved agencies and the public. This can provide a level of predictability for surface transportation and land use planners that certain decisions will not be questioned later in the process.
• The planning regulations promulgated in February 2007 provide additional guidance (in the form of an appendix to the rule) on the relationship of state and local transportation planning process to the NEPA process. 8 The appendix addresses the applicability of the results from "multimodal, systems-level corridor or sub-area planning" to the NEPA review. If planners do the appropriate analysis, consultation, public involvement, and documentation, the results of such activities can be used in the NEPA process for the following:
  1. Purpose and need or goals and objective statement(s);
  2. General travel corridor and/or general mode(s) definition (e.g., highway, transit, or a highway/transit combination);
  3. Preliminary development and screening of alternatives and elimination of unreasonable alternatives;
  4. Basic description of the environmental setting; and/or
  5. Preliminary identification of environmental impacts and environmental mitigation. ⁹

These regulations provide a strong incentive for integrated planning and linking planning and NEPA.

• For surface transportation projects, the failure to effectively merge NEPA and Clean Water Act (CWA) Section 404 permitting requirements has created difficulties when tiering, especially in the context of purpose and need, alternatives analyses, and determining the appropriate level of detail for the analysis. To be effective, all involved parties must be clear on what decisions are being made at each tier. This is especially important in the framing of the purpose and need statement that will affect the range of alternatives and the level of acceptable NEPA and 404 analyses. These issues have also been problematic in integrating review under Section 106 of the National Historic Preservation Act with tiered NEPA studies.
• Data needs and appropriate levels of analyses in tiering, corridor, and sub-area documents are appropriate areas for investigation by the work group. If the broader level of analysis available at the planning level does not allow project-level efforts to move forward without revisiting issues decided at the state and local planning stage, the concept of tiering as an effective way to integrate planning and environment may be seriously undermined.

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3. Interagency Challenges and Opportunities

• Different legislation, missions, and resource challenges guide FTA, FHWA, FAA, and Federal resource agencies. FTA, FHWA, and FAA have instituted varying planning and project development procedures to satisfy their individual requirements that are not always easily integrated with other agencies’ planning, permitting and approval processes.
• Additional responsibilities and requirements under SAFETEA-LU may increase the demands for resource agencies to participate in transportation planning activities, and may create staffing, funding, and prioritization challenges for those agencies. Early consultation is critical, but staffing constraints may limit resource agency participation in multi-year planning limited. Tiered documents, larger surface transportation corridor and sub-area studies, and landscape level mitigation, which may support numerous surface transportation projects while advancing environmental goals, may also be constrained by limited budgets.
• Transportation and resource agencies typically have not met at the outset of long range plan development or specific project development to share major issues that should be considered and to discuss compliance with environmental laws. Likewise, the development of project specific mitigation documents rarely include participation by affected resource agencies and State and local officials to facilitate development of an integrated mitigation plan. In addition, geographic information systems (GIS) and data-sharing can provide a forum for cross-agency communication and coordination.
• Resource and planning agencies are challenged by inadequate numbers of staff that have been trained to effectively participate in all long-range, project planning, and NEPA processes.
• There is great and as yet underutilized potential for increased use of GIS mapping and sharing of information with other agencies and planning organizations. For instance, a GIS analysis overlapping the mosaic of critical habitat and habitat critical for recovery of threatened or endangered species with each transportation planning area would provide information to planners about transportation planning and possible species interaction. Similarly, the use of GIS mapping for cultural resources has enhanced the ability of transportation agencies and planning organizations to identify potential conflicts during planning; however, concerns about the protection of information on archaeological site locations and Native American sacred sites has created challenges to using this technology.
• Programmatic and merger agreements, including Section 106 programmatic agreements, provide the means to deal with recurring requirements, usually at the project level. There is currently little guidance to assist agencies in determining when concurrence should be sought, the method in which concurrence is to be documented, and how to enforce concurrence points.

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IV. Integrated Planning: Status of Activities

Since this work group was created, the landscape for integrated planning has changed significantly. Some of those changes are highlighted below, especially those that resulted from this work group.

Eco-Logical. After considerable dedication of the steering team, eight resource agencies and the Federal Highway Administration signed off on Eco-Logical in April 2006. This publication addresses one of the core concepts of integrated planning: approaching transportation development from an ecosystem level. By working from the concept of the ecosystem, planners can mitigate the negative effects of transportation infrastructure in a holistic manner, rather than piecemeal.¹⁰

Integrated Planning Baseline Report. This work group oversaw a report on integrated planning that summarized the existing knowledge base in the area.¹¹ This report made recommendations at three levels:

1. Recommendations on the components of an integrated planning framework and the associated objectives and outcomes that should be pursued and that should ensue;
2. Recommendations on the types of strategies that can be implemented to resolve challenges and make progress toward integrated decision-making; and
3. Recommendations on specific Federal government activities to advance the state of planning practice and begin forging an integrated planning approach.

Purpose and Need, and Indirect and Cumulative Effects Baseline Reports. These work groups also created baseline reports. Some observations and recommendations in these reports are relevant for discussion here, namely:

1. The purpose and need report suggests that a link to the transportation planning process is essential in developing a sound purpose and need statement. While this relationship is the most direct in terms of linking planning and NEPA, there are challenges in successfully making the link. ¹²
2. The Indirect and Cumulative report recommends that approaches for integrating indirect and cumulative impacts analysis into the planning process need to be developed. ¹³

Information Resource. The work group is currently overseeing an in-depth Information Resource about best practices in integrated planning efforts. This document will be web-based and print-ready, highlighting practical details of some of the most successful integrated planning work being done currently in the U.S. transportation and resource agencies across the country will be able to use the Information Resource to shape their own programs and projects.

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V. Recommendations for Work Plan Priorities

The following priorities are based on several sources: the past work plan for this group, the 2005 “Integrated Planning Work Group Baseline Report and Preliminary Gap Analysis,” and input from the work group at a meeting in March 2007. For each of the items of highest priority, the work group will establish project working teams, and develop specific project proposals based on the descriptions below. These future action proposals will be much more detailed. The list below focuses on the projected goals and outcomes for each action item.

Note that no conclusions have been predetermined regarding source and type of resources to carry out the activities, or the composition of the projects teams. It should also be noted that this Work Plan, and the subsequent more detailed project activities that will result from the efforts of the project teams, will be pursued in full appreciation of the limited staff resources at many of the agencies involved in the work group.

Highest Priority

1. New Transportation Planning Regulations: Outreach and Training
   Develop and conduct outreach and training on new transportation planning regulations for transportation planners and resource agencies. This training would encourage cross-training and relationship-building. The outreach and training may use multiple modes, including but not limited to webinars, regional workshops, independent use modules, and seminars at conferences.
2. Eco-Logical Concepts: Outreach and Training
   Support implementation by making a cooperative effort to spread the ideas of Eco-Logical throughout each agency, including both resource and transportation planning agencies. The result of this work effort would be a more informed staff at each Eco-Logical signatory agency (and others), with a special focus on field staff education.
3. Tiering, Corridor, and Sub-area Studies: Synthesize the State of the Practice in Connecting Planning and NEPA
   Spread knowledge of the state of the practice in linking planning and NEPA by conducting a survey of tiering, corridor and sub-area studies. The synthesis would focus on practice in several areas, including but not limited to:

   i. Indirect and cumulative effects,
   ii. Modal analysis,
   iii. Programmatic agreements,
   iv. Purpose and need, and
   v. Alternative development and screening.

   This synthesis of practice would result in a report that would highlight success stories and methodology. Since this activity area relates to recommendations for activities under the purpose and need, and indirect and cumulative work groups created through EO 13274 (see section IV: “Integrated Planning: Status of Activities”, above), this activity would be conducted in collaboration with those work groups.
4. Integrated Planning: Seed Pilot Projects around U.S.
   Put integrated planning concepts into practice more frequently by supporting pilot projects throughout the U.S. The U.S. Department of Transportation requested proposals from agencies under integrated planning in April 2007, and this work group can play a key role in tracking, following, and informing those projects. The results of these studies should be publicized and utilized by the work group for recommendations to transportation planning agencies and resource agencies in the future. The work group will also continue to explore opportunities to initiate, participate in, and share the results of other pilot projects around the country, as applicable.

Secondary Priority

1. Eco-Logical Concepts: Implementation Support
   Promote the concepts in Eco-Logical by assessing barriers to Eco-Logical implementation, and find ways to overcome those barriers. This process would result in a gap assessment addressing what is needed to implement the Eco-Logical framework at an operational level. The assessment would especially address staffing and institutional needs for each agency, and could be followed by technical assistance for agency field staff.

Priorities Being Addressed by Others

1. Resource and Institutional Issues for Integrated Planning: Assess and Make Recommendations to Improve
   Assess resource agency needs regarding staffing and funding that would enable them to participate appropriately and effectively in the transportation planning process. This activity would involve a review of the current use of liaison positions and other innovative techniques for providing resource agencies additional funding and staffing. These techniques would be profiled using best practice case studies, culminating in recommendations for improvements to practices in the field with liaison positions and other methods.
   This issue is currently being studied and evaluated under a current National Cooperative Highway Research Program (NCHRP) project, and so this action item has been lowered in priority. However, because staffing and other resources are critical to implementation of integrated planning, the work group will track this study closely.
2. Interagency Coordination: Evaluate Possibility of Issuing Guidelines
   Identify ways to better inform resource agencies of State DOT and MPO transportation plan and project priorities and changes thereto so that agencies can allocate available resources more efficiently. In order to assess areas for improvements, this action item would first assess policy gaps for interagency cooperation, and then create a set of guidelines for interagency cooperation. This issue is currently being studied as part of an ongoing Strategic Highway Research Program II (SHRP II) project, entitled “A Framework for Collaborative Decision Making on Additions to Highway Capacity.” SHRP II staff will provide periodic updates on the progress of the project.

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Sources
¹ See 23 CFR 450, sections 210 and 316.
² See 23 CFR 450 sections 214(i) and 322(g).
³ Eco-Logical: An Ecosystem Approach to Developing Infrastructure Projects. Accessible at:
https://www.environment.fhwa.dot.gov/env_initiatives/eco-logical/report/eco_index.aspx.
⁴ See 23 CFR 450.214(j) and 450.322(f)(7).
⁵ See 40 CFR 1508.28.
⁶ See 23 CFR 771.111.
⁷ 23 CFR 771.135(o).
⁸ See 23 CFR 450, Appendix A.
⁹ See 23 CFR 450, sections 212, 318, and Appendix A.
¹⁰ Eco-Logical: An Ecosystem Approach to Developing Infrastructure Projects. Accessible at:
https://www.environment.fhwa.dot.gov/env_initiatives/eco-logical/report/eco_index.aspx.
¹¹ Executive Order 13274 Integrated Planning Group: Baseline Report and Preliminary Gap Analysis. Accessible at:
https://www.govinfo.gov/content/pkg/FR-2002-09-23/html/02-24252.htm
¹² Executive Order 13274 Purpose and Need Work Group: Baseline Report, Revised Draft. Accessible at:
https://www.govinfo.gov/content/pkg/FR-2002-09-23/html/02-24252.htm.
¹³ Executive Order 13274 Indirect and Cumulative Impacts Work Group: Draft Baseline Report. Accessible at:
https://www.govinfo.gov/content/pkg/FR-2002-09-23/html/02-24252.htm.