Pilot Testing of the TCAPP Decision Guide and Related Capacity Products: Hoopstick Creek, South Carolina (2014)

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CHAPTER 2 Description of the Project and Summary of Outcomes The Hoopstick Creek Bridge Replacement project was selected for this pilot project to test and provide useful feedback on the operation and utility of the web-based TCAPP resource. The focus was on assessing the tool’s value in providing guidance to help project partners work collaboratively toward an environmental permitting decision. The final environmental permitting process would be deemed a success if the agency partners agreed on a least environmentally damaging practicable alternative (LEDPA). The pilot project focused on the implementation of six “decision point files” of the TCAPP decision tool, entirely from the ENV section. These steps were selected for this test because they were deemed the most relevant and critical to the SCDOT’s permitting process. Each of the tasks included in the pilot test, along with their relationship to the relevant TCAPP decision point, are described below. In addition, a key outcome is included that indicates the specific result from applying TCAPP. Task 1: Training The SCDOT participated in a TCAPP training session hosted by AASHTO in Atlanta, Georgia, on April 29 and 30, 2013. On May 6, 2013, the SCDOT personnel who attended the training session presented an overview for the remainder of the team. Key outcome: After the training, SCDOT personnel felt the tool provided valuable resource information, but the breadth and depth of the website were overwhelming. It was expressed that the TCAPP tool would be best suited for transportation practitioners new to the planning field. SCDOT personnel with extensive project and planning experience did not anticipate using the tool but felt TCAPP could be used as a resource, potentially for training new staff. The tool was also perceived to have been developed with little state or local transportation agency input. Task 2: Agency Workshop An agency workshop was held on August 29, 2013, at the SCDOT offices in Columbia, South Carolina. All external agency decision makers were invited. During the agency workshop, the SCDOT and Tidewater provided an overview of the C39A1 project and the proposed pilot project on Hoopstick Creek on Johns Island, South Carolina. The TCAPP website was projected on a large screen; SCDOT and Tidewater personnel reviewed components of the TCAPP Decision Guide, partner and stakeholder definitions, and where the roles of partners were defined in each key decision point. A foam board with each ENV decision point was used to show the role, as defined by TCAPP, of the agency partners for the Hoopstick Creek Bridge Replacement. A color-coded system was used to show which agencies were decision makers, advisors, or observers at each decision point. The goal of the foam board was to emphasize that partner roles 15

change through the key decision points. The board also created a source of discussion among the SCDOT and agency partners about whether their roles followed the TCAPP guidance or would be different for this pilot project. Evaluation of Existing SCDOT Environmental Permitting/NEPA Process To initiate the use of the TCAPP Decision Guide, the SCDOT led a discussion of the existing SCDOT project delivery process. The goal of this exercise was to inform agency partners of the SCDOT’s perspective of where and when they fit into project delivery and how their decisions affect project delivery. This task gave all participants insight and context for subsequent tasks and goals. The SCDOT presented a flow chart (Figure 2.1) of how projects currently move through the permitting process, beginning with the approval of a Program Action Request (PAR). During the presentation, the SCDOT stated its view of where in the process agencies should be brought in for commenting and opinions. This led to a discussion which resulted in several different opinions being voiced by various agencies on SCDOT’s perspective and where they believed they best fit into the process. This proved to be an opportunity for all participants to share their views openly. Several topics were brought up during the discussion. For example, agencies indicated that documentation was sent to them at different times, resulting in confusion about the project. One agency noted that a permit application was sent before the Environmental Assessment (EA), that sometimes the EA does not arrive in a timely manner, and that sometimes the permit application and EA are sent to different project managers—all of which create a delay. The USACE indicated that permit applications are often received before the public meeting which may result in changes to the project. If project changes result from the public meetings, then the permit application submitted is no longer valid and needs to be modified. The USACE questioned the practice of submitting permit applications ahead of known public meetings. One important statement was supported by all agencies: formal comments cannot be given on the permit application until the public notice is complete. To capture the perspectives of the agencies, the agencies used sticky-notes to indicate on the flow chart where they wanted to participate and have involvement in the permitting and NEPA processes. All agency partners agreed that each project is different and requires varying levels of involvement at each stage. The SCDOT and Tidewater made revisions to the flow chart based on the comments received during this portion of the workshop and provided revised copies to all agency partners (Figure 2.2). Key outcome: This portion of the workshop resulted in several important outcomes. The first is that all SCDOT documentation needs to be completed and submitted concurrently to the agencies after all known public information or hearings have been completed. If there are changes to the NEPA documents, design, and/or scope, then the agencies must be notified as soon as practical. The second outcome is that the agencies are unable to provide official comments on projects before receiving a formal or official application or request. They can 16

provide guidance and minimal feedback on information presented, but they cannot offer absolute or conclusive opinions on informal requests. The last, and possibly most important, outcome of the agency workshop was that the agencies were able to express the precise times when they felt their notification and involvement in the permitting process would be the most beneficial and appropriate. The SCDOT indicated that due to the discussion, it should better be able to involve all parties at the times indicated and better improve the process and communication among agencies. The SCDOT should also notify agencies of any changes to the project during public involvement and design stages. TCAPP facilitated the evaluation of existing SCDOT environmental permitting and NEPA processes. During preparations for the agency workshop, the project team considered the questions TCAPP recommends before using the Partner Collaboration Assessment—who would be a partner, what were their roles in the process—and whether to evaluate the existing process or situation. The project team decided it was necessary to evaluate existing processes and procedures before using the Partner Collaboration Assessment or proceeding with the steps of the Decision Guide. While the SCDOT regularly evaluates its ESO processes and procedures, TCAPP provided a forum to consider the existing situation that involved all of the agency partners. Typically, the SCDOT works with the individual agencies to refine the ESO processes; TCAPP and the pilot project provided an opportunity to evaluate the ESO processes collectively with all the agency partners. As a result of TCAPP, the SCDOT ESO is aware of procedural issues and is disseminating information to ESO personnel to improve permitting and NEPA correspondence. 17

Figure 2.1. ESO environmental process before TCAPP pilot project. EMO = environmental management office; PPR = local public agency project planning report; PM = project manager; PPMS = Oracle Project Portfolio Management Software; CE- A = Type A categorical exclusion; CE-B = Type B categorical exclusion; CE-C = Type C categorical exclusion; GPS = global positioning system; PD = proposed design; LOI = letter of intent; FONSI = finding of no significant impact; PDCA = plan, do, check, act. 18

Figure 2.2. Improved ESO environmental process. EFH = essential fish habitat. 19

ENV-3: Approve Purpose and Need, Reach Consensus on Project Purpose The ENV-3 key decision was used to substantiate and identify any missing aspects of the project purpose and need. The SCDOT provided an overview of the existing bridge and roadway conditions. The National Bridge Inventory, Structure Inventory and Appraisal Report determined the Hoopstick Creek Bridge to be structurally deficient and functionally obsolete. The substructure was reported to be poor, with “intolerable” deck geometry that prioritizes corrective action. Scour around the bridge footings was determined to be “somewhat better than the minimum adequacy to tolerate being left in place as is.” The SCDOT provided the following project purpose to initiate discussion with agency partners: The purpose of the project is to correct structural deficiencies of the S-20 over Hoopstick Creek Bridge and to bring the existing bridge and its approach roads up to current design and safety standards. Key outcome: The tool was used to identify partner roles in approval of the purpose and need. Several partner agencies disagreed with their identified role in this step of the TCAPP Decision Guide. For example, the USACE stated it could not “approve” a purpose and need. Resources agencies, such as SCDHEC-OCRM and SHPO, felt their role as advisors was not needed so early in the permitting process for a project of this scale. The Questions to Gather Stakeholder Interests, provided by TCAPP for each step of the Decision Guide, were also used to facilitate discussions about any additional needs or purposes that should be included. Minimal input was received from the agency partners, likely a result of inexperience with functional and deficiency ratings. The uncontroversial nature of a bridge replacement project may have also limited agency feedback. One agency partner felt limited to provide input because of the technical specifications supporting the project. ENV-4: Reach Consensus on Study Area The purpose of this step was to reach consensus on an initial geographic area of study (the area within which any alternatives will fall). Key outcome: The Questions to Gather Stakeholder Interests were also used to facilitate discussions about the study area. The SCDOT selected the large study area because of the potential impacts associated with closing the road and detouring traffic to other secondary roads on Johns Island. The USACE and FHWA recommended creating a more refined study area where most of the field studies would occur. As a result of this discussion, the SCDOT narrowed the study area to the roads and resources immediately surrounding the bridge and its approaches (Figure 2.3). When asked about the resources within the study area that each agency partner valued, most of the agencies responded with the resources within their regulatory jurisdiction. For example, the SHPO valued archeological and architectural resources that may be within the study area, while SCDHEC-OCRM was concerned with impacts to the salt marsh critical area. 20