For NEPA Nerds, TRB's discussion of NEPA 50% faster

So what’s going on with NEPA 50% faster initiative? Joe Shalkowski, Associate VP of Transportation Planning at PBS&J, attended the annual TRB meeting in January. Joe reported on what the TRB discussed to reduce the timeframe of the transportation project development process by 50% to the Austin subchapter of the Texas Association of Environmental Professionals. Both Joe and the TAEP were kind enough to allow Cubit to record the presentation and post it to YouTube (see below) as well as load the PowerPoint into Slideshare.

Here are a few points of interest that I took away from the presentation.

  • In Washington, a mandate was discussed that would require the affected environment section to appear before the development of alternatives section.
  • FHWA is in the process of taking all NOIs that are more than 10 years old off of the books.
  • The average time to complete the NEPA process nationwide is 6 years. This is for CEs, EAs and EISs. So it’s likely that the few huge EISs are skewing that average upwards.
  • The original size of an EA was supposed to be 15 pages.

Major causes of delay in the NEPA process

According to Joe’s presentation, the TRB concluded that the major causes of delay in the NEPA process are:

  • Low project priority,
  • Lack of funding,
  • Local controversy, and
  • Project complexity.

The NEPA 50% Faster Survey that came out of the Re:NEPA discussion agreed with the lack of funding issue and the local controversy issue as being major sources of delay and frustration. The survey results didn’t indicate that in the opinion of the more than 100 NEPA professionals who took the survey that low project priority and project complexity were major sources of delay.

Top 10 Ways to make NEPA more Efficient

There were 10 ways discussed at the TRB meeting to make NEPA more efficient and effective.

  1. Take advantage of the planning process as a catalyst for NEPA
  2. Initiative NEPA review only when the project is “ripe”
  3. Invest in focused scoping to determine the real issues
  4. Don’t avoid, but manage risk
  5. Establish a realistic schedule
  6. Prepare decision focused documents
  7. Avoid encyclopedic disclosure for the sake of full but unnecessary levels of costly bullet proofing
  8. Actively promote joint review opportunities
  9. Respect the Technical Support Data file and Administrative Record
  10. Quality, Innovation, and Training

Sounds good, right? My problem with this list is that it’s not a list of actionable items for me to improve my process when preparing a NEPA document. For example, when I start my work, I don’t say to myself, “Now I’m going to establish an unreasonable schedule.” Everyone tries to establish a reasonable schedule. Nor do I say “this project isn’t ripe yet; let’s begin working on it.” Instead of vague advice like 'establish a reasonable schedule' and 'work on ripe projects,' how about providing actionable changes?

Actionable Suggestions for Improving Efficiency of the NEPA Process

I caught up with Joe after his presentation to ask him this question- “Give me some actionable changes that I can implement today when preparing NEPA documents.” Below are 3 actionable suggestions from Joe.

  1. Check the STIP/TIP to make sure you have a matching project description BEFORE beginning your work on the project.
  2. Conduct a risk assessment. (I didn’t do a good job of asking Joe to explain to me the details of a risk assessment for a NEPA document. So if you’ve ever done a risk assessment and have found it to be a helpful tool, please leave me a comment with more information about how this works and what risk you assessed).
  3. EAs should only have 2 alternatives–a build and a no-build.

You can check out the YouTube videos of Joe’s presentation below. Please leave me your thoughts in the comments, especially if you are familiar with how a risk assessment can make the NEPA process more efficient.

Part 2 from the Presentation
Part 3 from the Presentation
Part 4 from the Presentation
Part 5 from the Presentation

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