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U.S. Department of Transportation

Advancing Metropolitan Planning for Operations: An Objectives-Driven, Performance-Based Approach – A Guidebook

Appendix C. Applications of the Approach

1.0 Linking Planning and NEPA

SAFETEA-LU illustrates the close links between the metropolitan transportation planning process as practiced by metropolitan planning organizations (MPOs) and the environmental analysis undertaken by project sponsors. Legal guidance previously distributed to planning agencies35 notes that:

...much of the data and decision-making undertaken by State and local officials during the planning process carry forward into the project development activities that follow the TIP or STIP. This means that the planning process and the environmental assessment required during project development by NEPA (42 U.S.C. 4231 et seq.) should work in tandem, with the results of the transportation planning process feeding into the NEPA process.36

The memorandum points out that this close linkage is not always observed in the course of project development. As stated by the authors of the memo:

In practice, the environmental analyses produced during the NEPA process are sometimes disconnected from the analyses used to prepare transportation plans, transportation improvement programs, and supporting corridor or subarea studies. Analyses and decisions occurring during transportation planning can be ignored or redone in the NEPA process, resulting in a duplication of work and delays in implementation of transportation projects. The sharp separation between the work done during the transportation planning process and the NEPA analysis and documentation process is not necessary.37

As stated, planning information can and should be incorporated into the environmental review process, rather than starting with a blank page for every project.

As further discussed in the memo, "NEPA and the government-wide regulations that carry out NEPA (40 CFR Parts 1500 et seq.) clearly contemplate the integration of the NEPA process with planning processes. In 40 CFR 1501.2, Federal agencies are required to "integrate the NEPA process with other planning at the earliest possible time to ensure that planning and (agency) decisions reflect environmental values..."38

Sections of the Final Rule referring to transportation planning studies and project development (450.318, p. 7274) discuss the high standards that must be met for incorporation of planning studies into the NEPA process. The Rule notes that:

Publicly available documents or other source material produced by, or in support of, the transportation planning process described in this subpart may be incorporated directly or by reference into subsequent NEPA documents, in accordance with 40 CFR 1502.21, if:

1. The NEPA lead agencies agree that such incorporation will aid in establishing or evaluating the purpose and need for the Federal action, reasonable alternatives, cumulative or other impacts on the human and natural environment, or mitigation of these impacts; and

2. The systems-level, corridor, or subarea planning study is conducted with:

i. Involvement of interested State, local, Tribal, and Federal agencies;

ii. Public review;

iii. Reasonable opportunity to comment during the metropolitan transportation planning process and development of the corridor or subarea planning study;

iv. Documentation of relevant decisions in a form that is identifiable and available for review during the NEPA scoping process and can be appended to or referenced in the NEPA document; and

v. The review of the FHWA and the FTA, as appropriate.39

Appendix A to 23 CFR 450, while addressing the level of detail appropriate for incorporating planning analysis in project development studies, notes that, for purposes of transportation planning alone, a planning-level analysis does not need to rise to the level of detail required in the NEPA process. Rather, the planning-level analysis needs to be accurate, up to date, and should adequately support recommended improvements in the statewide or metropolitan long-range transportation plan.

SAFETEA-LU requires transportation planning processes to focus on setting a context and following acceptable procedures. For example, SAFETEALU requires "a discussion of the types of potential environmental mitigation activities" and potential areas for their implementation, rather than details on specific strategies. SAFETEA-LU also emphasizes consultation with Federal, State, Tribal land management, wildlife, and regulatory agencies.

However, the environmental assessment (EA) or environmental impact statement (EIS) ultimately will be judged by the standards applicable under the NEPA regulations and guidance from the Council on Environmental Quality (CEQ). To the extent the information incorporated from the transportation planning process, standing alone, does not contain all of the information or analysis required by NEPA, it will need to be supplemented by other information contained in the EIS or EA that would, in conjunction with the information from the plan, collectively meet the requirements of NEPA.

In this context, the congestion management process, if appropriately developed, can provide at a minimum a valuable starting point for the NEPA process, and, ideally, could give the agency a "running start" on critical components of the NEPA process such as purpose, need, and alternatives screening, among others.

The congestion management process is one of many elements feeding into the metropolitan transportation planning process. Along with requirements for coordination with State and local officials, consultation with Federal and tribal agencies, and consistency with the regional or statewide ITS Architecture, the CMP provides a mechanism for addressing regional, corridor-wide, and spot congestion issues in a comprehensive fashion. At the same time, the CMP works with the eight planning factors that should be considered in preparing long-range plans, and especially with promoting efficient and effective transportation system M&O.

The CMP is not intended to replace any of the existing elements of the planning process, but instead to complement and efficiently organize existing methods and techniques. The CMP also is focusing on management and operations strategies as potential means for mitigating or offsetting existing and future congestion. By emphasizing system performance measures and the data needs derived from such measures, the CMP helps system planners to identify ways to maximize the use of existing capacity, and to extend the usefulness of proposed improvements by enhancing operational efficiency and effectiveness.

Current Practice:

Linking NEPA studies with the Congestion Management System (CMS) Toolbox was a logical approach given that alternatives defined with congestion relief potential would be developed, screened, and evaluated for any NEPA study underway in the region.

The Mid-America Regional Council (MARC) serves eight counties and 116 cities in the greater Kansas City bi-State (Missouri and Kansas) region. In 2001, MARC developed an enhanced congestion management system (CMS) designed to integrate with the regional transportation plan (RTP), transportation improvement program (TIP), and corridor evaluations, including the major investment study (MIS) planning processes. In developing its CMS, MARC identified a "CMS Toolbox" that incorporated a broad catalog of potential strategies under the following headings:

  1. Highway projects.
  2. Transit projects.
  3. Bicycle and pedestrian projects.
  4. Transportation demand management strategies.
  5. Intelligent transportation systems and transportation systems management strategies.
  6. Access management strategies.
  7. Land development strategies.
  8. Parking management strategies.

MARC adopted a policy that its CMS Toolbox of strategies would be considered when the purpose and need for an environmental study includes congestion management. The agency wanted to demonstrate how any suggested capacity improvements had been evaluated using the congestion management process.

At the time MARC was developing its CMP, the agency had established a network of facilities on which it collected data, including travel time studies and traffic counts, but was only using CMS methods to support the regional planning process by providing data to potential project sponsors for the RTP and TIP. Because the system is less congested than most other metropolitan regions of comparable size, the CMS has been less of a planning focus than in other locations.

MARC wanted to develop a transparent process to show how a capacity improvement had gone through the congestion management process. Linking NEPA studies with the CMS Toolbox was a logical approach given that alternatives defined with congestion relief potential would be developed, screened, and evaluated for any NEPA study underway in the region. The MARC Congestion Management System Policy adopted the following language on the integration of major investment studies to the metropolitan planning process:

The CMS Toolbox provides alternative congestion management strategies for consideration in MIS [Major Investment Studies] and Corridor Studies. When traffic congestion is referenced in the Purpose and Need Statement for an MIS, the MIS shall consider the congestion management strategies included in the MARC CMS Toolbox as a starting point for the development of alternative strategies. This does not preclude the MIS from considering other strategies that may not be in the CMS Toolbox, nor does it require that the MIS select a strategy from the CMS Toolbox be the preferred alternative, however, the MIS document must include a discussion of how the CMS Toolbox strategies were addressed.40

Currently, there is no NEPA requirement that the CMS be incorporated into the NEPA process. MARC's policy that NEPA studies incorporate the CMS Toolbox is not codified in any agreements with implementing agencies, but instead is implemented on a voluntary and cooperative basis. However, MARC and the Missouri Department of Transportation (MoDOT) have worked closely in a number of instances to incorporate CMS Toolbox strategies into relevant projects.

A major benefit is that by coordinating planning and NEPA through the CMP, duplication or redoing the planning work in the NEPA process is avoided. This helps to "streamline" the NEPA process. Since adoption of the Policy, MARC has not been challenged about any projects in the TIP. MARC feels the region is accomplishing the goals that Congress had set for CMS when it was established, since transportation is being approached from a multimodal perspective. Overall, MARC feels that the partnerships among State, Federal, and regional government agencies are working well, with MARC staff continually involved in a significant number of projects.


2.0 Freight Planning

Most metropolitan areas face challenges in transportation planning for freight mobility. Dramatically increasing freight flows in the metropolitan areas have contributed to increased congestion in the transportation system, imposing costs on shippers, consumers, and the environment. Using CMP tools, processes, and data assists in freight planning.

The U.S. DOT has developed a "Framework for a National Freight Policy."41 This framework contains a vision of freight transportation systems that will ensure the efficient, reliable, safe, and secure movement of goods and support the Nation's economic growth while improving environmental quality. The framework offers potential strategies that can be considered when assessing goods movement through the congestion management process.

The CMP can assist in addressing freight-specific congestion, and congestion impacting freight movement, by incorporating specific freight-related strategies in the development of an objectives-driven, performance-based approach to resolving congestion issues. Freight-specific strategies might include truck-only lanes, infrastructure improvements to remove freight bottlenecks, and designated truck routes.

3.0 Safety Planning

Incorporating safety as a regional priority and establishing specific safety-related performance objectives is an important first step toward having safety considerations included in the metropolitan transportation planning process. When safety objectives are included in the MTP, this drives the development of safety-related performance measures in the CMP. An emphasis on safety becomes integral to the collection of crash and injury data, which further supports the analysis of safety during the planning process. As local jurisdictions develop and maintain crash information databases and conduct independent safety analyses, such data can further support the identification of locations and types of safety improvements that are needed.

Involving local public safety officials as CMP stakeholders is key to identifying safety concerns and can provide useful input on key transportation safety issues. Planners can work with traffic, engineering, and public works staff to develop safety-related objectives in the CMP. These measures allow safety countermeasures to be incorporated into highway rehabilitation or improvement projects. Stand-alone projects to address critical safety issues also can be incorporated into the planning process.

4.0 Land Use Integration

The planning and management of urban land use greatly impacts transportation demand on the surface transportation system. Since land use decisions are generally made at the local level, considerations with respect to jurisdictional control should be considered when advancing land use strategies.

Including operational objectives dealing with land use in the MTP highlights the importance of transportation investment for land development, regional demographic growth, and economic development. Land development strategies have been used in some areas to manage demand on the transportation system, and to help agencies meet air quality conformity standards. Land use strategies can include limits on the amount and location of development until certain service standards are met, or policies that encourage development patterns better served by public transportation and non-motorized modes. Examples of land use strategies include transit-oriented development, densification and infill strategies, and encouragement of mixed-use development.

For more information:

To learn more about applications for the elements of the objectives-driven, performance-based approach to plan for operations, read six case studies from across the country:

35 Memorandum: Integration of Planning and NEPA Processes, February 22, 2005; D.J. Gribbin, Chief Counsel, FHWA and Judith S. Kaleta, Acting Chief Counsel, FTA, to Cindy Burbank, Associate Administrator, Office of Planning, Environment and Realty, FHWA, and David A Vozzolo, Deputy Associate Administrator, Office of Planning and Environment, FTA.

36 Ibid.

37 Ibid.

38 Ibid.

39 Federal Register: February 14, 2007 (Volume 72, Number 30), Statewide Transportation Planning; Metropolitan Transportation Planning; Final Rule, Discussion of Comments, p. 7274. Available at:, last accessed December 6, 2009.

40 Mid-America Regional Council, "MARC Congestion Management System Policy," December 18, 2001. Available at:, last accessed February 9, 2010.

41 U.S. Department of Transportation, FHWA, Freight Transportation, "Framework for a National Freight Policy," Available at:, last accessed December 6, 2009.

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