Integrating Freight into NEPA Analysis

6. Environmental Consequences

The environmental consequences step represents the core of the environmental impact analysis for a project. This section includes information on how freight-focused and freight-related projects should be evaluated with respect to their environmental impacts and folds in the analysis of any transportation project on freight features and facilities. Additional information on Environmental Consequences 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 Appendix A.

The CEQ regulations at 40 CFR 1508.8 define “effects” as follows:

Effects includes ecological (such as the effects on natural resources and on the components, structures, and functioning of affected ecosystems), aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or cumulative. Effects also may include those resulting from actions which may have both beneficial and detrimental effects, even if on balance the agency believes that the effect will be beneficial.

FHWA technical guidance regarding environmental consequences recommends that this section includes the probable beneficial and adverse social, economic, and environmental effects of alternatives under consideration and describes the measures proposed to mitigate adverse impacts. The information should have sufficient scientific and analytical substance to provide a basis for evaluating the comparative merits of the alternatives (FHWA Technical Advisory T 6640.8A).

Freight-Focused and Freight-Related Projects

For both freight-focused and freight-related projects, there could be direct, indirect, and cumulative environmental impacts. Direct impacts may include but are not limited to the impacts related to freight-focused or freight-related projects that may introduce more freight transportation (trucks, trains, etc.) into a project study area, and the impacts of building a freight-focused or freight-related transportation facility on all environmental resources and features. These impacts may in turn create additional indirect impacts that need to be considered.

Table 6 provides examples of types of impacts to the various environmental resources and features that could occur with the development and construction of freight-focused and freight-related projects.

Ultimately, freight-focused and freight-related projects are no different than any other transportation projects with respect to their potential to have impacts on a variety of environmental resources and features. Each project will need to have a carefully crafted Purpose and Need Statement and be scoped to define the areas of focus that will be needed in the environmental analysis. Creating a comprehensive definition of the affected environment, including mapping and quantitative as well as qualitative data, will be just as important for these types of projects as for any transportation project and should be done early in the process to support the development of alternatives as well as the impact analysis.

The following sections provide examples for consideration in developing the impact analysis for freight-focused and freight-related projects.

Table 6. Impacts of Freight-Focused and Freight-Related Projects on Environmental Resources and Features

Resource or Features	Description of Potential Impacts and Effects
Economic	There could be an increase in employment and output as freight activity increases. Increased freight traffic may be detrimental for nonfreight-focused industries (e.g., tourism, recreation). Improvements of freight access could result in desired economic development. Add to the tax base.
Energy	Fuel efficiency for trains is better on a ton-per-mile basis relative to trucks. Fuel efficiency for trucks is better on a miles-per-gallon basis relative to autos. Reliable travel speeds improves efficiency for all modes.
Social/Environmental Justice	Industrial areas that require truck and other modal access are often surrounded by residential neighborhoods that can be low-income and minority in composition. Improving freight access into and out of a community may benefit to businesses as well as residents. Freight projects may generate jobs to improve economically disadvantaged regions. Alternatives may cause severing of community and neighborhood ties.
Air Quality	Freight vehicles are typically powered by diesel engines which have particular emissions characteristics. Increasing the volume of these vehicles into an area can result in impacts that will need to be mitigated and innovative approaches may need to be used. Decreasing freight congestion improving travel time may decrease the amount of total pollutants emitted. Idling may be decreased at intersections or at an intermodal facility gate also providing AQ benefits. Greenhouse gas analysis is also included here.
Noise	One truck is the equivalent of 32 cars in terms of noise generated. Freight trains are even louder.
Visual	Trucks, trains, and cargo ships are typically considered to be eyesores by local residents and tourists alike.
Bicycle and Pedestrian	Bicycle and pedestrian paths can be negatively impacted by alternatives that introduce more freight traffic or that are located in the vicinity of pedestrian/bicycle path.
Land Use	Freight projects may generate a variety of freight-related land uses that may or may not be compatible with an area’s established planning and zoning policies. Expanding a port facility may create conflicts within a municipality that would like to develop high-end residential properties instead.
Farmland/Rural Character	Freight projects may preserve or increase viability of prime, unique, or important farmland by providing additional access to markets for these goods.
Significant Historic Properties (Archaeology, Buildings, Landscapes, etc.)	A Freight facility that is being modified (improve capacity and/or function) may be a significant historic property. Expansion of existing facilities or building new facilities may impact one or more types of historic properties directly, indirectly, and/or cumulatively.
Wetlands	As with all transportation projects freight-focused and freight-related projects can impact wetlands in a variety of ways that will need to be evaluated carefully.
Section 4(f) Properties and Resources (Public Parks, Historic Properties, Wildlife Refuges, etc.)	A freight facility may be identified as a Section 4(f) resource (significant historic property) or may be in or near a Section 4(f) resource, with the potential to impact that resource. Alternatives such as a highway on new location benefiting freight transportation could result in a “taking” from a Section 4(f) property (park, recreation, area, historic property).
Coastal Zone, Water Quality, T&E Species, Floodplain	Freight-focused and freight-related projects may have direct, indirect, and/or cumulative impacts on these resources.

Energy, Air Quality, and Noise

Trucks and trains have vastly different operating characteristics relative to autos. Therefore, changes in freight movement also could have notable impacts on energy consumption, air quality, and noise. These changes must be explored for both freight-focused and freight-related projects. These can be described as performance metrics in the Alternatives Analysis to enable comparisons between alternatives with vastly different performance characteristics. More information on these environmental impacts can be found in the FHWA NHI Course Integrating Freight into the Transportation Planning Process Session on Freight Impacts. This course also includes reference material that can be used to estimate energy, air quality and noise impacts from changes in freight activity.

Social, Economic, and Environmental Justice

In terms of social impacts, FHWA recommends that freight be incorporated into the consideration of changes in an area that can affect populations in various ways, including, but not limited to, neighborhoods and communities. These changes may be beneficial or adverse, and may include, but are not limited to: splitting neighborhoods, improving access to goods and services, introducing more job opportunities, affecting the cost of goods, isolating a portion of a neighborhood or an ethnic group, generating new development, affecting property values, or separating residents from community facilities, and improving safety. Other aspects to consider include changes in travel patterns and accessibility (e.g., vehicular, commuter, bicycle, or pedestrian) along with impacts on school districts, recreation areas, churches, businesses, tax base, police, and fire protection. This should include both the direct impacts and the indirect impacts to a population. Analysis of the social impacts of freight-focused and freight-related projects is both qualitative and quantitative, and it does require having good data on the traffic impacts of various alternatives.

Freight-focused and freight-related projects may be located in areas that are populated by low-income and minority people. As stated in Executive Order 12898:

“[E]ach Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations…”

Historically, residential housing in the vicinity of heavy or light industry historically housed the people that worked at those facilities (factories, docks, and rail yards). This housing tends to be less expensive then other areas and may be home to minority and/or low-income populations that may or may not work at these facilities. Therefore, issues of Environment Justice (EJ) will need to be addressed as would be the case with expanding major arterial, highways, and Interstates. In addition a project may affect access to jobs for low-income and minority populations and this impact should also be taken into consideration. FHWA conducts an EJ analysis as part of the NEPA analysis of impacts on all communities affected by a project.

The quantitative aspect of this analysis involves overlaying changes in freight activity with socioeconomic data. Where travel demand model outputs are available, a map should be generated that shows changes in the volumes of trucks and trains and how that overlaps with various neighborhoods, income groups, ethnic groups, as well as businesses. Off-model estimation techniques can be utilized for circumstances where travel demand models are not available. In addition the population and business travel patterns and transportation needs can be quantified and mapped.

The qualitative aspect of this analysis involves stakeholder involvement. The outreach must involve the freight community to determine how alternatives could impact their operations. The outreach also must include, but is not limited to, the general public, neighborhood and community groups, businesses, schools, and community facilities to determine the impacts of alternatives on an area.

Indirect and Cumulative Impacts

Indirect effects are effects that are caused by a proposed action, but are later in time (although reasonably foreseeable) or farther removed geographically. Indirect effects may include growth-inducing effects and other effects related to induced changes in the pattern of land use, location of freight facilities, and related effects on air and water and other natural resources. For example, a road project may shift existing and anticipated industrial growth to a different area of a region and this will in turn change the pattern of freight movement in the region. The growth already may have been happening, but the road project “indirectly” influenced where it took place. Another example of indirect affects could be that a road project on new location may influence the location of freight distribution centers in the future resulting in development and changes in traffic and specifically truck access into and out of an area. Indirect effects, while difficult to quantify and assess, must be linked to a discernable direct effect due to the project.

Cumulative effects are defined (Per the Council on Environmental Quality’s (CEQ) regulations implementing the procedural provisions of the National Environmental Policy Act (NEPA)) as:

“The impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such other actions (40 CFR 1508.7).”

Analyzing cumulative effects differs from the traditional environmental impact assessment because the analysis must consider expanding the geographic area of study beyond that of the proposed project and expanding the temporal limits to consider past, present, and future actions that may affect the resource elements of concern. For freight-focused and freight-related projects, this means that the entire supply chain of goods movement must be considered in the overall analysis, including those elements of the supply chain that occur outside of the study area boundaries. Cumulative effects can be positive as well as negative depending on the resource element being evaluated.

Freight Impact Analysis

This section addresses the analysis of the impact of any transportation project on freight activities, facilities, features, and operations in a project study area. This will ensure that as alternatives are developed for transportation projects, freight is taken into consideration when determining the impacts and the balancing of those impacts with other environmental (human and natural) resources and features. From this perspective freight transportation may be considered an element or subset within the context of social and economic resources or features. A project alternative that has a negative impact on access to an intermodal freight facility, warehousing, expansion of a port facility, access to industrial sites, or precludes the efficient development of these types of facilities may have a detrimental impact on the economy in the area, including, but not limited to jobs, community viability, and the tax base. While general (people and transit) access to a community may be the objective of a particular project access by freight carriers also may need to be considered. Viability of that community could be negatively affected if freight access into and within the community is impeded (access to: hospitals to deliver life saving product, delivery to stores of food, and to gas stations to deliver fuel for example). Some examples of impacts to freight facilities and operations that may need to be considered include but are not limited to:

1. Changing access to warehousing areas: can create safety and access problems for trucks; the possibility of increasing truck traffic through communities creating safety, air quality, and noise issues for residents; and increases in costs to transport freight resulting in increased costs of products to consumers, etc.).
2. Changing design of highways to narrow lane widths to increase the number of lanes on a highway in a highvolume truck corridor can result in unsafe conditions for trucks and autos due to the size of trucks (width and length).
3. Application of tolling to an existing or new limited access freeway can cause trucks to leave the freeway to avoid tolls thus increasing trucks on parallel roads that are not necessarily designed to handle high volumes of truck traffic. This could result in safety problems (increased crashes), as well as accelerating the deterioration of pavements and bridges due to truck weights and loading factors and an increase of trucks through towns and cities negatively affecting traffic flow and safety of autos, pedestrians, and bicycles.
4. The design and placement of roundabouts to deal with traffic congestion and flow could result in trucks not being able to maneuver through intersections resulting in safety problems and increased congestion.
5. Poor signal timing that restricts the number of trucks that can pass through an intersection in areas with large volumes of trucks can exacerbate congestion and increase the potential for crashes.

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