Section 4.0 Conclusions and Recommendations
The information included in this report comes from eight case studies. The data is restricted to what could be obtained through interviews with a variety of participants on the different projects. The total number of intermodal freight transportation projects currently underway in the United States is unknown, and thus, this is not a statistical sample of all port, rail, highway, and airport facilities. The information represents a first look at environmental issues affecting development of intermodal freight transportation facilities. Enough information has been collected to make it clear that there are a variety of environmental concerns on intermodal freight transportation projects and they are not restricted to issues of air quality, noise, and community impacts.
Conclusions
Initial conclusions that can be drawn from the information reviewed include, but are not limited to the following:
- Intermodal freight transportation projects, depending on federal funds or permits, frequently involve a variety of federal agencies as reviewers or that could be directly affected (port improvements and landside access issues).
- Clear communications and early involvement of federal and state agencies are critical to the successful completion of environmental analysis for projects (time, money spent, design of project, etc.)
- Conflicts between state and federal environmental requirements can cause delays on projects but can be overcome with early recognition of issues and agreements among agencies on how to proceed.
- The variety of environmental issues that can become a concern on a given project depend on the nature of the project and the location of the project. They are not uniform for every project.
- Consideration of environmental resources (including avoidance and minimization of impacts through site selection and design) early in the planning and project design phases can result in simplified environmental review and avoidance of costly delays in project schedules.
- Early coordination with public interests on intermodal freight projects can lead to resolving concerns before they become a problem.
- NEPA streamlining through improved agency consultation may be difficult to achieve on many projects if the regulatory agencies do not have adequate resources to engage in early consultation.
- When questions or disagreements arise over the assumptions behind a project's purpose and need, and alternatives, regulatory agencies do not always have the resources to independently verify cargo projections, market analyses, and facility land use needs. They have to rely on the lead agency to comply with the NEPA requirement for independent verification of the information and analyses submitted by a permit or funding applicant.
- Port dredging, land side development, and land side access projects are sometimes covered by separate NEPA documents because funding is not always available to cover all three types of activity simultaneously and because different agencies take the lead on these projects. On a related note, there does not appear to be any regional or national guidance or policies for project sponsor agencies and regulatory agencies to follow when considering the funding, permitting, and environmental review of projects in separate political or planning jurisdictions that compete in the same freight markets.
Recommendations
Additional efforts in this area of environmental review might include the following next steps:
- Further research to confirm the preliminary conclusions discussed above. This might include researching FHWA EAs and EISs for intermodal facilities; reviewing past funding of intermodal projects; and interviewing additional FHWA Division Office staff.
- Further research into how FHWA Division staff considers a project's purpose and need, and alternatives when it is a cooperating or review agency.
- Further research into how other reviewing agencies (e.g., EPA, FWS, NMFS, and SHPOs) consider a project's purpose and need and develop alternatives. This research could include whether those agencies have the resources to independently verify a lead agency's or applicant's freight projections and market analysis, if they have reason to suspect them.
- Follow-up calls to determine whether some of the projects excluded from this report might be worth further review. In addition, projects that were only in the early stages of review during the preparation of this report might be appropriate for review in a subsequent effort.
