NEPA Implementation
The Development of Logical Project Termini
November 5, 1993
I. Introduction
In developing a project concept which can be advanced through the stages of planning, environment,
design, and construction, the project sponsor needs to consider a "whole"
or integrated project. This project should satisfy an identified need,
such as safety, rehabilitation, economic development, or capacity improvements,
and should be considered in the context of the local area socioeconomics
and topography, the future travel demand, and other infrastructure improvements
in the area. Without framing a project in this way, proposed improvements
may miss the mark by only peripherally satisfying the need or by causing
unexpected side effects which require additional corrective action. A
problem of "segmentation" may also occur where a transportation
need extends throughout an entire corridor but environmental issues and
transportation need are inappropriately discussed for only a segment of
the corridor.
The Federal Highway
Administration (FHWA) regulations outline three general principles at
23 CFR 771.111(f) that are to be used to frame a highway project:
In order to ensure
meaningful evaluation of alternatives and to avoid commitments to transportation
improvements before they are fully evaluated, the action evaluated in
each environmental impact statement (EIS) or finding of no significant
impact (FONSI) shall:
- Connect logical termini and be of sufficient length to address environmental
matters on a broad scope;
- Have independent utility or independent significance, i.e., be usable
and be a reasonable expenditure even if no additional transportation
improvements in the area are made; and
- Not restrict consideration of alternatives for other reasonably foreseeable
transportation improvements.
The aim of this paper
is to discuss criteria that can be used to select logical termini (project
limits) for development of a project. The primary discussion will be on
the first of the three factors mentioned above. However, all three are
interrelated and necessary to the development of an integrated project.
The remainder of this
paper is divided into three sections. Section II will further define logical
termini. Section III will discuss several case studies covering factors
that can come into play in choosing termini, and Section IV will offer
some conclusions.
II. A Definition of Logical Termini
Logical termini for
project development are defined as (1) rational end points for a transportation
improvement, and (2) rational end points for a review of the environmental
impacts. The environmental impact review frequently covers a broader geographic
area than the strict limits of the transportation improvements. In the
past, the most common termini have been points of major traffic generation,
especially intersecting roadways. This is due to the fact that in most
cases traffic generators determine the size and type of facility being
proposed. However, there are also cases where the project improvement
is not primarily related to congestion due to traffic generators, and
the choice of termini based on these generators may not be appropriate.
The next section will show some examples where this is the case.
Choosing a corridor
of sufficient length to look at all impacts need not preclude staged construction.
Therefore, related improvements within a transportation facility should
be evaluated as one project, rather than selecting termini based on what
is programmed as short range improvements. Construction may then be "staged,"
or programmed for shorter sections or discrete construction elements as
funding permits.
III.
Sample Project Concepts and Discussion
A. Case #1
US 22 is a rural two
lane facility without access control. A number of high accident locations
have been identified, and the need for the project is to correct site
specific geometric deficiencies between point A (Route 602) and point
B (no intersecting roadway).
Discussion: In this
case, the selection of A and B as termini is reasonable, given the scope
of the project. In fact, for projects involving safety improvements, almost
any termini (e.g., political jurisdictions, geographical features) can
be chosen to correspond to those sections where safety improvements are
most needed. The first criterion, that the project connect logical termini
and be of sufficient length to address matters on a broad scope, is largely
irrelevant due to the limited scope of most safety improvements. Furthermore,
even if other safety improvements are needed beyond those in segment A-B,
the project termini need not be expanded to include these other improvements.
The other two criteria still need to be met to choose A and B as termini:
the safety improvements have independent utility (i.e., they can function
as stand-alone improvements without forcing other improvements which may
have impacts), and these improvements do not restrict consideration of
other reasonably foreseeable transportation improvements (such as major
safety improvements in an adjoining section, e.g., point B to Route 604,
which could involve changes in alignment of the segment currently under
review). Also, all environmental requirements must still be met. For instance,
straightening of a curve through parkland cannot take place without completing
the necessary section 4(f) analysis.
B. Case #2
US 26 is on the eastern
fringe of a rapidly growing urban area. Over the next 20 years, traffic
growth and congestion are predicted for the section of roadway closest
to the urban area, between Route 100 and Route 200. Since US 26 also serves
as a through facility to points east, congestion will increase on the
other sections also. It is proposed to deal with the worst of the congestion
problems by widening the road to four lanes between point A (Route 100)
and point B (Route 200).
Discussion: Widening
between point A and point B could be implemented as a reasonable project
with logical termini, but several conditions would have to be met:
- The project serves
an identified need to upgrade US 26 in the suburban area, and stands on
its own from point A to point B.
- The improvement
will not force immediate transportation improvements on the remainder
of the facility (i.e., the project will not substantially increase congestion
or safety problems on the mountainous section of US 26 beyond the problems
under the no-build case). If improvements are forced, there could be project
impacts severe enough (e.g., 4(f), endangered species) to complicate completion
of US 26 in the mountainous section, and this should be investigated now.
This would be to see whether alternatives for other foreseeable transportation
improvements have been restricted to the point where environmental requirements
will be difficult or impossible to satisfy.
- If there is a demonstrated
need for improvements in the entire corridor from point A to point C,
there may still be no funding available and no likelihood of improving
the entire corridor in the near future. In this case, the project from
point A to point B could still be implemented providing the above conditions
were met.
- If there is potential
for improvements to the whole US 26 corridor in the near future, and if
there may be alternate alignments to satisfy the project need that will
change the alignment in the AB section, it would be prudent to evaluate
the entire corridor from A to C. Assuming limited funds, the suburban
section could be programmed for staged construction first, and subsequent
sections could be reevaluated at the appropriate time. However, as long
as the AB segment represents a stand-alone project (i.e., all three of
the criteria in 23 CFR 771.111(f) are met), there is no environmental
requirement to consider the entire corridor in one document. The only
issue that needs to be treated with care is to leave enough flexibility
in alternative selection in future upgrading of the entire corridor so
that environmental requirements can be satisfied (e.g., don't build the
AB segment in a way that it would be a "loaded gun" forcing
the upgrading to point C to take 4(f) property, which otherwise would
have been avoided).
C. Case #3
The proposed project
is a new interchange with I-28 at the north edge of a growing urban area
with options to upgrade an existing north-south feeder/collector route,
Kellogg Rd., on a new location. The next interchange south is at capacity
now due to 1) new housing in the north end of town, and 2) a rapidly expanding
commercial area at the existing interchange. The identified purposes of
this project are to reduce circuitous travel for north end residents and
to reduce congestion at the next interchange south.
Discussion: At first
glance, the logical termini for analysis are the points where the new
interchange ties in with existing facilities (Kellogg Rd. and Drury Rd.).
Would this action force other project improvements? In this example, Kellogg
Rd. and Drury Rd. may be overloaded by interchange traffic. If this is
considered now, there may be design options to address this without substantial
change or disruption. If this is dealt with later, the options may be
more limited. If the only remaining option in the future is to widen Kellogg
Rd. and Drury Rd., there may be considerable disruption, relocations,
etc., which could possibly have been avoided. For this particular project,
the eastern project terminus was the intersection of Coleman St. and Drury
Rd., since there was adequate capacity on Drury Rd. to absorb the traffic
and no additional improvements would be forced. The western project terminus
was further away from the intersection, since Kellogg Rd. did not have
enough capacity to handle the traffic from the interchange. The terminus
in this case was where Kellogg Rd. intersected with Chris Rd. It was demonstrated
that Chris Rd. had the capacity to handle the additional traffic and that
no additional improvements would be forced. Options for upgrading Kellogg
Rd. included widening of the existing Kellogg Rd. or a north-south feeder
road on new alignment. Even if the project sponsor had decided not to
upgrade Kellogg Rd., the environmental document should have covered the
environmental impacts resulting from the congestion of this route (e.g.,
community disruption, possible air quality violations).
D. Case #4
This
proposed facility is on new alignment, connecting Route 91 with I-17.
Alternative 1 is shorter, connecting to I-17 at point A, and alternative
2 would tie in further east, at point B. The primary travel on this new
facility is to and from points east on I-17. I-17 is four lanes west of
point B and six lanes east of point B. Alternative 2 has been designated
as the preferred by the project sponsor. Alternative 1 was proposed by
a citizen's group to reduce the number of relocations and community disruption.
Cost estimates are $50 million for alternative 1 (to tie in at point A)
and $63 million for alternative 2 (to tie in at point B).
Discussion: It is
likely that an incomplete picture of the costs and impacts of alternative
1 is being provided by only carrying the analysis as far as point A. For
both alternatives, consideration of impacts should continue to point B,
or east of B if there are likely to be any weaving or merging problems
which will force changes in the facility beyond B. In this example, the
four lane section between A and B, if overloaded by alternative 1, would
force further improvements on I-17 which would likely have additional
impacts. Failure to take this into account would underestimate the cost
and overall impacts of alternative 1 and skew decisionmaking. As a result
of these factors, if Alternative 1 is considered a reasonable alternative,
the discussion of impacts should extend to impacts occurring at point
B. If I-17 will be able to handle the increased traffic from alternative
1 without widening, then the discussion could simply be a demonstration
of that fact.
IV. Conclusions
The aim of this paper
has not been to present all possible ways of determining logical project
termini, but rather to present a thought process that can be used to make
these determinations on a case by case basis. For the vast majority of
highway projects, the choice of logical termini will be obvious and non-controversial.
For those few major projects where other considerations are important,
the termini chosen must be such that:
- environmental issues
can be treated on a sufficiently broad scope to ensure that the project
will function properly without requiring additional improvements elsewhere,
and
- the project will
not restrict consideration of alternatives for other reasonably foreseeable
transportation improvements.
By following this
guidance, proposed highway projects will be more defensible against litigation
claims of project segmentation, and decision makers and the public will
have a clearer picture of the transportation requirements in the project
area and a better understanding of the project purpose and need.