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99 forward a project, changes in political administration, and organization. Although each of the case studies presented lack of coordination between DOT units as a project pro- different aspects of incorporating environmental factors into ceeds from one step to another have all been identified as organizational procedures or agency culture, the strategies important sources of delay. Changes to the organization, usually had many common characteristics. These character- management oversight, and improved project information istics included systems are being viewed as the most appropriate ways of dealing with this issue. Top Management Support--In many cases, require- Other types of strategies are being considered by imple- ments of state law provided an incentive for state trans- menting agencies to reduce the amount of time that projects portation officials to consider environmental factors spend in project development because of environmental during systems planning. However, even in such cases, reviews. These include: listing certain categories of projects the level of commitment to this concept very much in a programmatic permit approval, parallel processing of depended on the extent to which the secretary, commis- NEPA and engineering design, funding environmental sioner, or chief engineer held a strong positive position resource staff to work on transportation projects, and estab- on the policy. This continuing top management interest lishing interagency agreements that define the respective and support provided the motivation to continue facing roles of the agencies participating in project development. the organizational barriers that often accompanied such A context-sensitive solutions (CSS) approach to project efforts. In California, Florida, New York, and Pennsyl- development is viewed by DOTs and MPOs as a mutually vania, for example, the secretary of transportation was beneficial situation. Although not the same as considering personally interested in seeing that the agency's envi- environmental factors early in systems planning, the concept ronmental or CSS efforts were successful. The concept of CSS as an approach to project development was a notice- of an internal champion to "push" new planning con- able policy directive in all of the DOTs visited, and was cepts was found in Mn/DOT where full-time staff were being encouraged by MPO officials as well. In some ways, reassigned to develop the environmental streamlining CSS is being viewed in similar terms as incorporating envi- strategy for the agency. ronmental considerations early in systems planning. This Some the case studies also showed the importance of approach to project development calls for early and contin- a political champion or leader in fostering more atten- ual involvement of community stakeholders, a mutual tion to environmental issues in systems planning. For definition of problems, and a collaborative development of example, the governors of Pennsylvania and Maryland solutions. If applied to systems planning, this is, in essence, may be appropriately viewed as having been the cham- the concept that was being explored in this research project. pions of environmentally sensitive development in their The response to CSS has been very positive. The projects states through their leadership and endorsement of envi- that have been completed in the states visited were noted ronmental and growth management laws. The consen- with pride by all involved as showing what can be accom- sus building and general public awareness that occurs plished when everyone works together. The image of the during the passage of laws and the adoption of policies DOT was enhanced, community support for projects was at may begin to create a more supportive environment as a much higher levels than for previous comparable projects, backdrop for planning activities in a state. It is not nec- and engineers developed confidence in their abilities to meet essarily the case that this policy approach would readily the mobility needs of the community while providing a cre- carry over into agencies that are tasked with implemen- ative design that received community accolades. tation. They may not be prepared to take up the tasks The concept of CSS as an approach to project develop- associated with new laws, policies, and their associated ment can be linked closely with the early consideration of regulations, or they may disagree with the intent. In environmental factors in system planning. Not only can sys- Wisconsin, for example, the actual requirements of tem planning identify areas where CSS might be very appro- TRANS 400 were debated and legally challenged for priate (e.g., sensitive or historic areas), but system planning over 10 years before the DOT finally agreed to the pres- can also identify key participants who could play important ent form of implementation. However, where laws are roles as the project moves closer to reality. passed and resources provided for their implementation, the legislative foundation serves as an enabler for INSTITUTIONAL STRATEGIES accomplishing environmental goals. TO IMPLEMENT CHANGE Organizational Assessment--For those agencies that targeted the entire organization and its procedures for Throughout this research, each of the successful efforts to change, an organizational assessment was conducted to incorporate environmental factors into the policy, planning, understand what functions provided opportunities for or project development activities of a transportation agency incorporating environmental factors into agency activi- was implemented with strategic deliberation and considera- ties. This often meant forming task forces or committees tion of how such a change could best be carried out in the with a mandate to recommend changes. Table 18, for

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100 TABLE 18 Work groups formed by FDOT for the ETDM process Task Work Group Objective 1. Develop a process to obtain construction permits simultaneously with the NEPA Record of Decision 2. Achieve concurrent and simplified notices where feasible Environmental Permits 3. Develop criteria for categorically excluding certain projects from permitting 1. Evaluate the feasibility of implementing a two-year STIP and a two- Two-Year State year TIP development cycle Transportation Improvement Program 2. Determine the steps required to implement this two-year planning cycle with FDOT Programming NEPA 1. Develop a method for proceeding with environmental studies earlier in Projects the FDOT Five-Year Work Program 1. Determine how project development will be accomplished in the ETDM process and create a linkage to project development NEPA Decision-Making Process 2. Describe the timing during the planning process, the content, and the audience for the documents 1. Create a framework in the ETDM process for conducting secondary and cumulative assessment that incorporates needed data from land Secondary and Cumulative use, transportation, and resource protection plans Impacts 1. Investigate and document how the FDOT Bridge Program enters the Bridge Program Five-Year Work Program 2. Recommend a method for interfacing the Bridge Program with the ETDM process 1. Investigate and document how to complete archaeological and historical assessments for transportation projects more efficiently and earlier in the project development process Cultural Resources 2. Ensure how appropriate identification, avoidance, minimization, and mitigation of Native American issues are considered and documented Community Impact 1. Document how CIA and public involvement are accomplished in the Assessment (CIA) ETDM process Source: Florida Department of Transportation, 2002 (77). example, shows the different working groups estab- state transportation agencies would have important lished in FDOT to assess where changes in internal implementation responsibilities) are targeted for special procedures were appropriate. In many cases, represen- responsibilities. tatives of environmental resource agencies, regional Institutional Change in Standard Procedures--Many planning organizations, and other concerned stakehold- state transportation agencies rely on standard operating ers were part of this process. procedures to guide agency staff in their approach to Internal Implementation Strategies--Some of the more standardized situations. Thus, many procedures relating comprehensive programs examined in this research to project design follow accepted practices that are pre- included efforts to consider environmental factors in scribed in design manuals. Incorporating environmental many aspects of an agency's activities, thus influencing factors into this prescribed practice is a good way of insti- many different units within the organization. Successful tutionalizing such a process in the daily operations of the implementation of these programs entailed a broad per- organization. This was certainly an important part of the spective on the types of actions that different units strategy in the NYSDOT for institutionalizing its Envi- would take to implement the program. Table 19, for ronmental Initiative in all parts of the organization. example, shows Caltrans' plan to implement CSS in the Resources--The most important obstacle cited by DOT organization. Note that responsibilities for actions range and MPO officials as hindering the incorporation of from the director to public relations staff. Key units in environmental factors into transportation planning was the organization, such as district offices (which in most "competing objectives that detract from environmental

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101 TABLE 19 Caltrans implementation strategy for CSS Focus Strategy Technique Responsibility Schedule Academies/train- Provide focused Develop CSS guidelines Districts and divisions will ing/tools training for staff Include CSS modules in existing organize CSS training and guides regarding CSS functional academies districtwide and departmentwide concepts and Districts will contribute CSS case Share technical case Now applications studies and lessons learned studies/lessons learned Provide specific tools HQ divisions will lead tools and Develop and distribute tools and and applications for application development with applications implementation districts District system Use DSMP as Caltrans Include CSS considerations in Districts will include CSS management policy-level system DSMPs, particularly under the concepts in DSMP Now plan (DSMP) planning document to stated policies and strategies DOTP will incorporate CSS communicate CSS as support and info in DSMP department policy guidelines Transportation Long-range Caltrans Include CSS considerations in TCRs District planning will include CSS corridor report concepts for state TCR should include a route/corridor strategies in TCRs (TCR) highways must address context for use in project documents DOTP will revise system planning Now CSS guidelines to include CSS Transportation TSDP, as project Include CSS element in TSDPs Districts will include CSS system information element in elements in each TSDP Now development Systems Planning DOTP will include CSS in program process, must address guidelines (TSDP) CSS Transportation Use DOTP Incorporate CSS support in grant DOTP will include CSS support in planning grants discretionary planning guidelines grant guidelines Now grants as stimulus for Include information in grant criteria Districts will facilitate CSS considerations by to encourage CSS consideration of CSS strategies in planning and local all grant applications agencies Project initiation CSS as part of project Include CSS strategies in PID Districts will include CSS documents initiation becomes an guidelines strategies in PIDs (PIDs) integral part of all Include CSS consideration in all Districts will facilitate the projects PIDs involvement of CSS stakeholders Now Include "Statement of Context" in all in the development of PIDs project reviews HQ Design will enhance CSS concepts in PDPM Project reports Projects final scope of Include strategies in project review Districts will include CSS Now work; cost estimates guidelines strategies in project reports and time-lines should Include CSS consideration in project Districts will facilitate the consider and, if reports involvement of CSS stakeholders appropriate, in the development of project incorporate CSS Include "Statement of Context" in all project reports reports HQ Design will enhance CSS concepts in design manual Intergovernmental Use reviews as Include CSS review and, if District planning functions will Now review opportunities to appropriate, recommendations in include CSS strategies in advocate CSS Caltrans intergovernmental review intergovernmental review regarding local process program development proposals California Reflect department's Include CSS description and DOTP Now transportation commitment to CSS in support strategies in Plan Districts will recommend CSS plan/interregion- Plan Include CSS strategies in state plan strategies during the development al transportation development guidelines and review of regional strategic transportation plans plan/regional Include CSS strategies in regional plans plan development guidelines HQ Programming to provide CSS criteria in program themes (continued )

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102 TABLE 19 (Continued) Caltrans implementation strategy for CSS Focus Strategy Technique Responsibility Schedule Promulgate CSS Include strategies in OWP Districts will work with regional Now Regional overall through regional guidelines agency OWP staff work programs planning efforts Recommend CSS-related activities (OWPs) in OWP Highlight CSS Include CSS in all environmental Environmental Programs to Now Environmental considerations in documentation, including initial highlight CSS considerations in assessments Caltrans environmental studies and full impact reports documents and meetings program Integrate CSS in Review routine maintenance and Each program area Now Maintenance maintenance and operations activities to identify and operations operations opportunities for minimizing impacts to communities and the environment Source: California Department of Transportation (Caltrans), 2002 (99). considerations." In one sense, this could be interpreted An example of such an agreement can be found in as a resource allocation problem (i.e., a lack of sufficient California. California's state transportation agencies have resources to consider environmental factors in plan- been national leaders in establishing formal partnership ning). If a state perceives that an environmental problem relationships with environmental resource agencies. is serious or important enough--such as the deteriora- California's Business, Transportation, and Housing tion of the Chesapeake Bay in the case of Maryland--it Agency has recently entered into a partnership agreement will pass the laws necessary to address the problem. with the California Environmental Protection Agency Enabling legislation for environmental analysis is prob- and the Resources Agency to identify program areas in ably the most important motivator for transportation which additional cooperation will result in a more suc- agencies in considering environmental factors in trans- cessful integration of statewide mobility goals with envi- portation planning. ronmental protection. This Tri-Agency Partnership, Many of the case studies in this research indicate that which realigns institutional relationships to improve the the early consideration of environmental factors can scope and pace at which environmental considerations consume a great deal of time and resources. Transporta- are incorporated into transportation planning, identifies tion agency staff must often spend considerable time with two purposes for the partnership. First, the partnership is environmental resource agencies explaining the rationale designed to foster cooperative interactions among the for a particular project and the actions to be taken by three agencies. Second, the result of this cooperation is the DOT in environmental mitigation. The expectation is the timely planning and implementation of transportation that the extra time spent early in the process will result in projects that protect or restore environmental resources. greater progress in moving the project through project The specific goals of this partnership included development when it reaches that stage. Identifying and sharing information on transporta- The case studies illustrated the level of support that was tion and environmental priorities; deemed necessary to assure success. In New York, the Developing transportation and environmental per- DOT hired environmental managers for every district in formance criteria to evaluate transportation proj- the state to act as catalysts for the Environmental Initia- ects and to improve their selection and design; tive. In Minnesota, the DOT dedicated full-time staff in Ensuring the timely development of environmentally the effort to change the internal procedures of the organi- beneficial transportation plans and projects that rec- zation. In Florida, millions of dollars have been spent on ognize the priorities of livable communities, the prin- the environmental screening tool that serves as the foun- ciples of environmental justice, regional planning, dation of the ETDM process. All of these efforts were crit- cultural and natural resource conservation, and envi- ical to the success of the initiatives in each agency. ronmental protection; External Implementation Strategies--Much of the suc- Ensuring compliance with all applicable environ- cess in considering environmental factors in systems mental laws, rules and regulations, permits and planning relies on establishing agreements with envi- policies while reducing the time required to ronmental resource agencies that articulate the respec- develop and implement transportation policies; tive roles of each actor in planning and project develop- Encouraging early and continuous participation of ment. The usual means of doing this is through effected state, federal, and local agencies, public memoranda of understanding, or in the case of FDOT's interest groups, and the public throughout the local ETDM process, agency operating agreements. land-use planning, resource conservation planning,