Integrating Freight into NEPA Analysis

3. Purpose and Need

Freight transportation issues should be considered in the development of Purpose and Need Statements for any project. Additional information on developing Purpose and Need Statements can be found in NHI Course 142005 NEPA and the Transportation Decision-Making Process, Lesson No. 4. A link to this course can be found in Appendix A.

CEQ NEPA regulations are brief in the description of Purpose and Need: “The statement shall briefly specify the underlying Purpose and Need to which the agency is responding in proposing the alternatives, including the proposed action.” (40 CFR 1502.13). FHWA technical guidance states that the Purpose and Need statement will:

“Identify and describe the proposed action and the transportation problem(s) or other needs which it is intended to address (40 CFR 1502.13). This section should clearly demonstrate that a ‘need’ exists and should define the ‘need’ in terms understandable to the general public. This discussion should clearly describe the problems which the proposed action is to correct. It will form the basis for the ‘no action’ discussion in the ‘Alternatives’ section, and assist with the identification of reasonable alternatives and the selection of the preferred alternative (FHWA Technical Advisory T 6640.8A).”

Freight-Focused Projects

For freight-focused projects, the Purpose and Need should articulate the freight transportation problems to be resolved and the nature of freight activity in the study area. The problem(s) to be resolved should be defined in detail. Ideally, much of the information related to the Purpose and Need for freight-focused projects should be found in previous planning documents of the project. The types of information that should be included in the Purpose and Need Statement are found in Table 2.

Table 2. Description of Freight Data

Freight Element	Types of Information to Consider for Inclusion
Freight Facility Information	Map indicating the location and type of freight facilities in the study area. For projects involving freight rail, a map showing rail facilities, rail lines, and at-grade rail crossings in the study area is needed. Square footage of each facility in the study area. Number of employees at each facility in the study area. Number of vehicles (trucks, trains, ships, planes) per day or year in and out of each facility in the study area. Types and amount of commodities in and out of each facility.
Volume Data	Hourly classification counts to separately identify truck volume peaks and auto volume peaks. On- and off-ramp classification counts to better understand specific destinations of trucks on corridors.
Level of Service Data (LOS)	Separate LOS estimates for morning, midday, and afternoon periods for highway corridors. Identification of congested freight rail lines, where relevant.
Freight Forecasts	Growth of freight traffic should be developed from freight-specific sources. See section on sources of freight data for more information.
Safety Data	For highway corridors, report accident rates separately for truck-only accidents, truck-auto accidents, and auto-only accidents. Also report fatality rates separately by vehicle class, where relevant. For rail corridors, report accidents separately for passenger transit and freight rail. When relevant, report accidents at at-grade highway-rail crossings.
Road Geometry	Identify locations of steep grades, sharp curves, short weaves, and reduced vertical clearances that impact truck operations.
Pavement Condition	Describe pavement condition using information from state DOT road network database, FHWA HPMS data, stakeholder input, and/or field observation.
Origin-Destination Data	Identify split between through traffic versus traffic destined into and out of the study area. Identify routing information and determine potential for diversion to other routes and modes.
Economy	Describe the freight component of the study area’s economy, including the number of employees and output by dollar or tonnage for specific industries.
Land Use	Land use data, including the existing and future location of facilities that generate or attract freight shipments should be collected to provide as much industry detail as possible because truck, rail, and port trip generation characteristics vary substantially by industry.

Freight-Related Projects

The Purpose and Need for freight-related projects should include a definition of the freight transportation problem(s) to be resolved (as with the freight-focused project) along with any other transportation issues. The problem(s) should be clearly defined. Information that can be of use in defining the freight problem(s) could include but is not limited to:

1. Truck volume percentages may be high on one segment of a corridor and low on other segments indicating that freight analysis should be focused in one area.
2. A specific interchange or intersection could have a high level of truck-involved accidents indicating that truck-focused safety improvements should be targeted at that location.
3. Traffic has a high percentage of trucks (e.g., 20 percent or more). In this case, it will be important to describe the nature of those truck flows (commodity distribution, origin-destination pairs, truck types, etc.) to determine if there are problems related to these volumes and to focus where solutions will need to be considered.
4. Traffic volumes through a small town may have reached a level that is a problem for the town. Forecasts may show this traffic (including trucks) increasing in the future. The truck portion of this problem needs to be accurately defined (origin and destination, volumes, etc.) so that the appropriate solutions that are balanced between vehicle types can be developed. For example, solutions appropriate for increasing car volumes may be possible within the confines of the town on existing roadways but could result in substantial displacements (residents and businesses) if designed to accommodate truck volumes and movements.

After the nature of the problem(s) has been established, Table 2 should be reviewed to determine which of the freight elements are relevant for the Purpose and Need. The problem definition will drive the rest of the environmental and alternatives analysis.

Data Sources

A key component of the Purpose and Need is the presentation of available data for freight elements in the study area (Table 2). Some freight data should be available from preceding planning studies, but it may need to be supplemented or updated to complete the environmental analysis. A list of key freight data types and potential sources of related data is shown in Table 3. The NHI Courses listed in Appendix A also include several specific freight data sources.

Table 3. Freight Data Sources

Type of Freight Data	Potential Sources of Data
Truck Counts	State DOTs, MPOs, special counts collected as part of previous planning studies. May need to update truck counts for a specific project.
Truck Volume Estimates	Truck components of travel demand models, estimated truck percentages applied to total volume data.
Origin-Destination Data	Roadside truck surveys, state-level O‑D data from freight flow databases (e.g., FAF), input from freight stakeholders.
Freight Flow Data	FHWA Freight Analysis Framework database, Bureau of Transportation Statistics Commodity Flow Survey Data, proprietary commodity flow databases (e.g., TRANSEARCH).
Freight Forecasts	Extrapolation from historical truck counts and rail volumes, FHWA FAF data, extrapolations of employment forecasts, interviews of freight stakeholders, and proprietary TRANSEARCH database.
Freight Shipment Characteristics	Roadside truck surveys, input from freight stakeholders.
Freight Facility Databases	Land use databases, previous planning studies, visual observation of study area.
Freight Safety Data	State accident databases for highway safety data, FRA for rail safety data.
Economic Data	The U.S. Economic Census contains county-level economic data (some data is suppressed due to confidentiality concerns), state Departments of Labor maintain county-level industry-specific employment databases and often can provide 10- to 15-year forecasts, Proprietary sources such as Dun & Bradstreet provide zip code-level employment information by industry, socioeconomic data also can be found in state and regional travel demand model databases.

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