Integrating Freight into NEPA Analysis
2. Scoping
Freight considerations should be integrated into the scoping process for environmental studies. Additional information on the scoping process can be found in NHI Course 142005 NEPA and the Transportation Decision-Making Process, Lesson No. 6. A link to this course can be found in the Appendix A.
As provided in the CEQ NEPA regulations at 40 CFR 1501.7, scoping is “an early and open process” designed to “identify the significant issues related to a proposed action.” FHWA’s technical guidance provides detailed information on the preparation of the Notice of Intent (NOI) to prepare an EIS and includes reference to conducting public scoping meetings.
“Freight-Focused Problem”
Freight-focused projects will have problems that are specific to freight which need to be addressed. This can include: road access to an intermodal facility, high numbers of truck-involved crashes, or delay on a key freight route (e.g., between port and nearby urban area).
Consideration of freight transportation in the scoping step begins with understanding the nature of the freight issue or issues to be considered. Is there a freight transportation problem to be solved and/or are their freight facilities and features in a study area that could be affected by a project? These perspectives are described as follows:
- “Freight-focused” projects are projects that address a specific freight transportation problem or need. Examples include: construction of truck-only lanes, highway capacity improvements due to increased truck volumes, highway reconstruction/paving due to increased volumes of trucks, interchange construction/reconstruction to provide or improve truck access, rail relocation, and developing an access road to a container port, rail yard, or pipeline/truck depot.
- “Freight-related” projects are projects in which freight is one of a number of transportation problems which are being addressed. Other problems or needs may include, but are not limited to: safety, capacity for all vehicles, access, and design to name a few.
- “Freight impact analysis” is the analysis of the impacts to freight activities, and facilities (distribution centers, loading docks, intermodal facilities, industry access, and access in and out of ports, truck access and flows on roadways (for example) of any project alternatives.
Freight-Focused
For freight-focused projects, a thorough examination and understanding of freight transportation problems in an area will be required to develop alternatives and assess the impacts of these alternatives on the full spectrum of environmental resources. This analysis will eventually focus on the specific issues that are relevant. This understanding also will be important to developing mitigation measures if needed.
Freight-Related
For freight-related projects, the scoping phase is critical to defining the freight problems to be resolved in concert with other problems and setting the study boundaries. For example, a major freight facility such as an intermodal rail yard or big box retail distribution center may need to be identified within the study area boundary, a multimodal corridor under study could have trucks as 30 percent of the total vehicular traffic contributing to the defined problems, and/or truck-related accidents could be one of a number of issues that need to be addressed. This will ensure that freight transportation problems are addressed as appropriate while avoiding a comprehensive freight review which is needed for a freight-focused project.
Freight Impact Analysis
The freight impact analysis will include, but may not be limited to the potential impacts that project alternatives have on freight operations (movement) and freight facilities. The analysis of impacts to freight facilities and freight operations could be folded in with the “social and economic” impact analysis for a given project or considered separately. Information on freight impact analysis will be folded into the Affected Environment section as well as the Environmental Consequences and Mitigation sections.
If there are conflicts between freight and the local community regarding the proposed project, conflict resolution opportunities should be identified as part of the project study (early in the process). The project sponsor must strive to be an honest broker of the facts and not aligned with either conflicting interest.
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