Integrating Freight into NEPA Analysis

1. Public/Stakeholder Involvement

An effective public involvement process for any transportation project requires the identification of the appropriate stakeholders to engage with in developing a project. This identification should include the consideration of freight transportation interests from both the public and private sectors. Additional information on developing and conducting public involvement can be found in Appendix A.

Overview of Challenges

Outreach to freight transportation stakeholders can be challenging. It is often difficult to identify all of the relevant freight stakeholders. For those stakeholders that are identified, it is sometimes difficult to achieve a meaningful dialogue. The demands of operating a freight-related company do not easily lend themselves to participation in the transportation project development process. Additionally, freight stakeholders can be reluctant to disclose operational information that they deem to be proprietary and could benefit their competitors.

What To Look For

The degree of freight stakeholder inclusion specified in state DOT public involvement processes varies by state. Existing transportation planning process regulations require states (and MPOs) to consider freight in the development of Transportation Improvement Programs (TIP), Statewide Transportation Improvement Programs (STIP), and Long-Range Transportation Planning (LRTP) efforts. These involvement opportunities begun in planning should be folded into the NEPA process for a given project. A first step is to conduct a review of the planning studies to determine to what extent freight was considered. When evaluating information gathered through freight stakeholder involvement during the planning process, some key questions to ask are:

• Did the sponsoring agency reach out to freight stakeholders and are there other stakeholders that were not involved that should be?
• Did the outreach produce meaningful comments from freight stakeholders?
• Was there specific data collected from or verified by freight stakeholders?
• Were the freight stakeholder comments and data considered and included in the planning analysis and documents?
• How will you fold freight stakeholder outreach into the public involvement process during the NEPA analysis given what already has been done?

The information from the planning process will help frame the public involvement approach during the NEPA analysis for a specific project. Benefits will include but are not limited to identifying the freight stakeholders to engage with and how to engage with them.

Who To Talk To

There are several types of freight interests to consider. Table 1 provides a list of potential freight stakeholder types and recommended methods for engaging with each.

Table 1. Freight Stakeholder Outreach

Freight Stakeholder Type	Recommended Method of Outreach
Trucking Firms	State and regional trucking association, owner-operator trucking associations – dispatchers among others. Individual trucking firms. The state DOT truck permitting section may have useful information.
Railroads	For Class I railroads, contact public affairs department at HQ location. For short line railroads, contact directly or through state-level short line railroad association. The state DOT rail division will be a valuable resource for contacts and information.
Marine Ports	Major ports have transportation planners that are typically accessible through state and city DOTs or MPO planning organizations. American Association of Port Authorities. Intermodal Association of North America. In-person visits are recommended for marine ports. The state may have a port office that could be a valuable resource for contacts and information.
Port Terminal Operator	Contact through marine port.
Warehouse/Distribution Center Operator	In-person visit, some states and regions maintain freight facility databases which is a potential source of this information.
Truck Stop Operator	On-line trucking information web sites provide a list of truck stops around the country. Once identified, an in-person visit is recommended.
Major Shippers	Chamber of Commerce, local economic development agency, referral from other freight stakeholders (carriers and others). The state Department of Commerce (or equivalent) could be a valuable resource).
Air Cargo Companies	Contact through airport staff that manages air cargo operations. The state DOT may have an Aviation section/department that could be a valuable resource.
Pipelines	Work with state Department of Energy and U.S. DOT Pipeline and Hazardous Materials Safety Administration for specific contacts.
Federal Agencies (Federal Motor Carrier Safety Administration, Federal Railroad Administration, Federal Maritime Administration)	Contact state representatives for each relevant agency.

Note: For a detailed discussion on freight stakeholder participation refer to the FHWA workshop course “Engaging the Private Sector in Freight Planning.” Information on this course can be found at: https://ops.fhwa.dot.gov/freight/FPD/Docs/fpd_flyer0606.pdf.

A particular challenge for involving freight stakeholders is identifying a stakeholder whose facilities are located outside the defined project study area. For example, a trucking firm may be a frequent user of a rural interstate facility, even though their truck terminals are located in urban locations 50 miles or more from the study area. In these circumstances, statewide and regional associations will be important sources of information. This would include state trucking associations, state and local chambers of commerce, and state and local economic development agencies.

What To Ask

There are four types of input that should be received from freight stakeholders. First, what are their current uses of the facility being studied? These uses can be considered in terms of operations and trip characteristics of freight in the study area and include:

• The freight mode used;
• Origin-destination combinations served;
• Time of day of shipments;
• Number and types of trucks (or other vehicles) used;
• Vehicle routing; and
• The sensitivity of the shipments to the project alternatives being considered (time sensitivity of deliveries, ease of access to facilities, etc.).

Second, freight stakeholders should be provided with an opportunity to comment on the accuracy of freight forecasts used in the scoping process. Any assumed changes in the trip characteristics described above should be discussed with freight stakeholders. Third, freight stakeholders should be a source of input for identifying alternatives, particularly given their first-hand knowledge of the study area. Fourth, freight stakeholders should comment on the impact of project alternatives on their operations and trip characteristics. These types of input will be a recurring theme for each of the components of the NEPA process as discussed in the following sections.

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