Integrating Freight into NEPA Analysis

4. Alternatives Analysis

Freight considerations should be integrated into the Alternatives Analysis process for environmental studies. Additional information on Alternatives Analysis can be found in NHI Course 142005 NEPA and the Transportation Decision-Making Process, Lesson No. 7. A link to this course can be found in Appendix A.

CEQ NEPA regulations describe the importance of the alternatives analysis:

“This section is the heart of the environmental impact statement. Based on the information and analysis presented in the sections on the Affected Environment (Sec. 1502.15) and the Environmental Consequences (Sec. 1502.16), it should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decision-maker and the public.”

FHWA guidance recommends that the Alternatives Analysis section of environmental documents begin with a concise discussion of how and why the “reasonable alternatives” were developed for detailed study and explain why other alternatives were eliminated (FHWA Technical Advisory T 6640.8). The development and analysis of alternatives for freight-focused projects will differ somewhat from the process used for freight-related projects as described in the following sections. However, one subject that is relevant for both types of projects is freight diversion.

The two types of diversion to consider are modal diversion and route diversion. Typically, modal diversion occurs between the truck mode and the intermodal rail mode as the total logistics costs associated with shipping goods on one or both modes changes. However, truck-rail modal diversion is limited to only certain types of commodities of distances roughly 500 miles or more. Route diversion occurs most frequently by trucks using alternative highways. Route diversion also can occur between rail lines if significant operational changes are expected for the rail network.

It is important that the alternatives analysis examines whether the road network and freight origin-destination combinations are conducive to diversion for each of the alternatives. If freight diversion is possible for any of the alternatives, it is important that the analytical tools utilized for the study are capable of generating diversion estimates. A detailed discussion of estimating techniques for modal diversion can be found in the FHWA NHI Course Multimodal Freight Forecasting in Transportation Planning. A link to this course can be found in Appendix A.

Freight-Focused Projects

Identifying Alternatives. For freight-focused projects, all alternatives developed should focus on solving freight transportation problems. Reasonable alternatives should be developed in consultation with government agencies, the general public, private sector freight stakeholders, as well as any other organizations and interest groups that could have an interest. It is very important to keep track of all comments on alternatives whether developed during the planning or NEPA phases of a project so that responses can be folded into the modifications of alternatives to improve the overall project outcome. Private sector freight stakeholders often have the expertise to substantially affect the development of alternatives. Additional efforts may be needed during the NEPA process to reach out to freight stakeholders if their comments were not solicited or are not well documented from the planning phase.

Alternatives should be considered across three solution categories: 1) infrastructure solutions; 2) operations solutions; and 3) policy solutions. Examples of each of the types of solutions are shown in Table 4.

Table 4. Examples of Freight Solutions

Solution Category	Examples
Infrastructure	New alignments, adding lanes, improving roadway geometry, access to intermodal facilities, highway reconstruction, intersection design, truck climbing lanes, Interstate access, Truck parking, use of alternative routes, etc.
Operational	Improved traffic signalization, changing mixed-flow lanes to managed lanes, system integration, variable message signs, accident response management, systemwide management for truck parking, real-time traffic information, web-based port schedules (for pick up and delivery), weigh-in-motion, rationalizing cross-town movements (reducing number of truck trips), E‑ZPass, urban truck parking management, etc.
Policy	Defining the National Network, Regional Truck Size and Weight permitting, adopting weigh-in-motion (also Operations), routing for hazardous materials, city management of loading zones, overall land use and zoning approaches, facilitating diversion from one mode to another, etc.

Screening Alternatives. Robust freight data and analytical tools are keys to analyzing alternatives for freight-focused projects as well as the potential for environmental impacts. The most common analytical tool utilized for estimating truck traffic is the travel demand model. When utilizing a travel demand model for a freight-focused project, it is important to first understand the level of accuracy of the model relative to trucks in the study area. It is not uncommon for travel demand models to be validated on the basis of total vehicle volumes across regional screenlines. While this may be sufficient for regional or statewide planning purposes, it may not provide a sufficient level of accuracy for developing alternatives for a specific project and location during the NEPA and Preliminary Design phases. It may be particularly problematic when estimating truck volumes for specific projects. To verify the accuracy of the travel demand model, truck volumes need to be checked with model outputs at multiple locations in the study area. If the model and the volume data are substantially different, then either the model will need to be recalibrated or off-model techniques will be needed to estimate the impacts of alternatives. Forecasted truck volumes along a roadway also should be evaluated for reasonableness by checking growth rates with sources such as FHWA’s Freight Analysis Framework (FAF) forecasts, employment forecasts, and private sector freight stakeholders. When modeling/forecasting it is important to remember that trucks are not just big cars. They are on the road for different reasons and they behave differently (schedules, turning radii, etc.).

It is important to identify the potential environmental impacts of each alternative so that the nature and magnitude of the impacts are included as a factor in determining which alternatives (that meet the project purpose and need) should be advanced through the NEPA analysis and selection process. The emphasis on selecting reasonable alternatives to advance begins with: 1) consideration of alternatives that avoid impacts while meeting the purpose and need; 2) then the alternatives that minimize impacts; and 3) finally consideration of the potential mitigation of impacts of each alternative.

Identifying appropriate screening criteria for freight-focused projects also is an important step. A comprehensive stakeholder involvement process is likely to generate a number of alternatives that will need to be reduced to a set of reasonable alternatives for detailed analysis. A first level of evaluation can be conducted to eliminate alternatives that clearly do not meet the Purpose and Need of the project. Further screening may include: 1) the degree to which the alternative solves the problem; 2) whether or not the alternative is based on a proven technology; 3) compatibility with existing or planned transportation systems; 4) compatibility with local and/or community goals and objectives; and 5) an appropriate balance of environmental avoidance and/or impacts by alternative. A second level of screening can then be conducted with more detailed analysis of freight activity including performance metrics as shown in Table 5 and specific environmental impacts. These criteria should flow directly from the Purpose and Need Statement for the project as illustrated in Table 5.

Table 5. Performance Metrics Examples

Sample Problem Described in Purpose and Need Statement	Corresponding Performance Metric(s) Estimated in Alternatives Analysis
Congestion between a port terminal and nearby warehouse region.	Estimated travel-time savings between the port and the warehouse location, and reduction in the number of truck trips.
High truck accident location.	Estimated reduction in truck-involved accident rate and accidents and severity of accidents.
Trucks traveling through towns/urban areas causing travel-time delays, community disruption, property, and economic impacts.	Number of or percentage of trucks diverted from through town movement, travel-time differential.
Port access schedule resulting in long truck lines at specific times of the day contributing to poor air quality in nonattainment areas, congestion, and inefficient freight movement.	Number of trucks that shift port access to off-peak times, travel-time improvements for port access.

Freight-Related Projects

Identifying Alternatives. As discussed in the Public/Stakeholder Involvement Section identifying alternatives for freight-related projects will require consultation with: 1) relevant government agencies; 2) the general public; and 3) private sector freight stakeholders. It is just as important to ensure that outreach extends to the private sector freight stakeholders for freight-related projects as for freight-focused projects. The list of participating government agencies should be checked to confirm that appropriate freight-interested government agencies are consulted in developing alternatives (Army Corps of Engineers Port Division, state freight rail office, state economic development agency, etc.).

Alternatives should be considered across the same three categories as for freight-focused projects: 1) infrastructure; 2) operational; and 3) policy. The relationship between the project and freight which was established in the Purpose and Need Statement should be used to generate alternatives that address freight needs as well as the other identified transportation needs for the project. The same alternatives that would be considered for a freight-focused project also may be relevant for freight-related projects. The difference is that the development of alternatives will have to balance the degree to which they can satisfy all of the identified transportation problems not just freight issues.

Screening Alternatives. It is expected that some alternatives will improve freight movement while others may make freight movement more challenging. In many instances, the improvement of freight movements on a transportation project also will provide improvements for the movements of passenger vehicles. In screening freight-related projects, it is critical to have metrics that estimate both freight and other types of transportation improvements. Examples of metrics may include, but are not limited to: truck travel times, auto travel times, truck-involved accidents, auto-involved accidents, and percent truck and/or auto diversions. Developing alternatives to address multiple problems can be complicated and may require a balancing of benefits. Analytical tools that are capable of addressing diverse issues will need to be used and the applicability of travel demand models (or other analytical tools) to both passenger vehicle and freight vehicle traffic in the project’s study area will need to be examined carefully.

Conflicts in developing alternatives may occur so the screening of alternatives will need to incorporate a number of perspectives. For example: problems for a specific project may be defined as congestion and safety on an urban roadway and intersection affecting both truck and automobile movements. One solution might be to narrow the lane widths to add a lane so more cars and trucks can move through the intersection or to improve a turning movement. While benefiting autos this could increase the severity of the problem for the trucks traveling through the area as the lanes might not be wide enough for their safe passage causing further problems (property damage, traffic jams, crashes, etc.).

A number of approaches to screening alternatives may need to be considered that will be sensitive to the variety of problems identified in the Purpose and Need and the potential impacts of those alternatives on the natural and human environment. One concept that may be considered if used in concert with other approaches is to monetize performance metrics. This involves estimating a dollar value for performance metrics such as truck delay, auto delay, truck-involved accidents, auto-only accidents, fatalities, and emissions similar to what is done for benefit/cost analyses. This allows for an unbiased process (from one perspective) to be used to compare alternatives that benefit freight relative to alternatives that benefit passenger vehicles to alternatives that benefit both. The FHWA Highway Economic Requirements System (Highway Economic Requirement System for State Use, FHWA, 2008) is a good source for factors to convert travel time and accidents into dollar amounts for both passenger vehicles and trucks. This method would have to be balanced with other screening approaches to reach the best solution(s) which includes consideration of the No-Build alternative.

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