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Tennessee Environmental Procedures Manual

Chapter 1: Environmental Regulations and The Environmental Evaluation Process

1.2 TDOT's Environmental Review Process

The intent of NEPA and associated regulations and guidelines that have been developed since NEPA's passage is to ensure that during project development and implementation, adequate and appropriate consideration is given to the potential impacts of the project on the natural and human environment. As a Department, TDOT must comply with NEPA and other federal and state regulations. Within TDOT, the Environmental Division has the job of ensuring that the requirements of NEPA and associated regulations are implemented throughout the Department's overall transportation project development process.

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1.2.1 TDOT Environmental Division

The Division is comprised of six (6) offices, as shown in Figure 1.1 and discussed below. Throughout the manual, references are made to the responsibilities of offices and sections of TDOT's Environmental Division.

The NEPA Documentation Office is responsible for the preparation of the environmental documents required for federal and state funded transportation projects. This office is responsible for collecting and compiling information on social, economic and environmental areas for all transportation projects, including purpose and need; the natural, cultural, social and economic environment; land use; farm land; energy; conservation; hazardous waste; visual concerns and construction impacts. The office is also involved in conducting public meetings and ensuring that the NEPA process is undertaken in accordance with the Department's Context Sensitive Solutions (CSS) approach to project development.

The Social and Cultural Resources Office is responsible for the protection of, historical and archaeological resources, analysis of air quality and noise impacts, and for the analysis and avoidance of hazardous materials sites associated with transportation projects. The professional staff performs scientific and technical analyses, writes reports and legal documents, coordinates technical issues with stakeholders, and oversees the avoidance, mitigation, minimization and remediation of impacts from early planning through construction. The Office also monitors mitigation during and after construction.

The Natural Resources Office is responsible for the preservation of ecological resources (streams, wetlands, and protected species) associated with transportation projects and, on a statewide basis, for assessing, preparing and acquiring all environmental permits for transportation projects. Environmental permits for impacts to wetlands, streams and rivers must be obtained from various federal and/or state regulatory agencies, including primarily the U.S. Army Corps of Engineers (USACE), the Tennessee Department of Environment and Conservation (TDEC) and the Tennessee Valley Authority (TVA). This office is also responsible for the statewide oversight and application for the National Pollutant Discharge Elimination System (NPDES) storm water permits from TDEC, for all transportation projects that will disturb more than one acre of land during construction. The professional staff performs scientific and technical analyses, writes reports, coordinates technical issues with stakeholders, and oversees the avoidance, mitigation, minimization and remediation of impacts from early planning through construction. The Office also monitors mitigation during and after construction.

The Beautification Office oversees the Scenic Highways Program and is responsible for the administration of statutory regulated services, such as Outdoor Advertising Control, Vegetation Control and Junkyard Control. In addition the Office is responsible for the administration of the Litter Grant Program throughout each of Tennessee's 95 counties as well as the Adopt-A-Highway Program and other public-involved volunteer services.

The Environmental Facilities Compliance Office has the responsibility of ensuring that the department's facilities comply with current environmental regulations. In addition, the office responds to the department's needs for investigating and, when necessary, remediation of past disposal and spill sites by providing technical expertise and oversight. It provides these services through the Resource Conservation and Recovery Act (RCRA), the Clean Water Act (CWA), the National Pollutant Discharge Elimination System (NPDES), the Emergency Planning Community Right-to-Know Act (EPCRA), the Toxic Substance Control Act (TSCA), the Comprehensive Environmental Recovery and Compensation Liability Act (CERCLA) and the Petroleum Underground Storage Tank Act.

The Comprehensive Inspections Office is responsible for oversight of environmental issues that may arise during TDOT's construction projects. The office is responsible for oversight of highway and bridge construction projects through implementation of the Quality Assurance/Quality Control Program. The office also works closely with the Tennessee Department of Environment and Conservation (TDEC) and other regulatory agencies involved with oversight of TDOT's construction and maintenance activities as related to National Pollutant Discharge Elimination System (NPDES) Construction Storm Water Permits, Aquatic Resource Alteration Permits (ARAP), U.S. Army Corps of Engineers (USACE) Section 404 Permits, and Tennessee Valley Authority (TVA) Section 26(a) Permits.

Figure 1.1 TDOT Environmental Division Organizational Chart

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1.2.2 TDOT's NEPA Process

For each of the three classes of action under NEPA, there is a general flow of activities that must occur during the environmental evaluation process. Figure 1.2, Figure 1.3, and Figure 1.4 illustrates the general steps that are followed for a Categorical Exclusion (CE), an Environmental Assessment (EA), and an Environmental Impact Statement (EIS), respectively.

Not all of these activities are conducted sequentially; some occur simultaneously, or may be repeated as necessary. The length of time and the number of steps required to conduct the environmental review process are dictated by the classification of action, the size or complexity of the project, the level of controversy, and the amount of coordination necessary. A Categorical Exclusion (CE) is usually prepared in a much shorter time frame than an EA or an EIS, and an EA can likely be prepared in a shorter time frame than an EIS, although there are examples of EISs being completed in less time than EAs.

The steps shown in Figures 1-2 through 1-4 are discussed in more detail in the remainder of this manual.

Figure 1.2 NEPA Flow Chart - Categorical Exclusions (CE)

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Figure 1.3 NEPA Flow Chart - Environmental Assessments (EA)

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Figure 1.4 NEPA Flow Chart - Environmental Impact Statements (EIS)

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1.2.3 TDOT's Program, Project and Resource Management (PPRM)

In March 2002, TDOT instituted the Program, Project and Resource Management tool, a computer-based, interactive database that allows TDOT to track all projects through the various phases of project development. The database includes project information, funding data, staff assigned and a schedule generator. The database is intended to serve as a tool for viewing project information, sorting information, assigning staff to project tasks, updating the status of tasks and producing reports and schedules. The PPRM database includes specific tasks for the environmental evaluation of projects. The activities for which the Environmental Division is responsible are incorporated into the database for each project. The PPRM tasks that are assigned to the Environmental Division are listed in Table 1-1. The PPRM flow chart, which depicts TDOT development activities, is shown in Figure 1.5a through 1.5d.

Table 1-1 PPRM Tasks Assigned to Environmental Division
Task Number Task Description
185 Complete Field Review with FHWA
190 Complete Environmental Scoping Process
195 Write Draft Environmental Document
200 Conduct Historical Study
205 Conduct Archaeological Study
210 Prepare Ecological Report
215 Conduct Air and Noise Study
220 Conduct Hazardous Materials Study
230 Complete Initial Technical Studies
245 Complete Draft Environmental Document
250 Obtain FHWA Approval of Draft Environmental Document
255 Prepare for Corridor Hearing
260 Hold Corridor Hearing
265 Select Alignment (Environmental)
270 Select Alignment (Project Management)
280 Finalize Technical Studies
285 Prepare Final Environmental Document
290 FHWA Review of Final Environmental Document
300 Obtain FHWA Approval of Final Environmental Document
305 Distribute Final Environmental Document
370 Provide Environmental Boundaries for Avoidance
480 Provide Noise Wall Locations
565* Develop Mitigation Plan
570* Prepare Mitigation Design
595 Confirm Environmental Technical Issues for ROW
640 Perform Hazardous Materials Remediation
645 Perform Archaeological Mitigation
670 Distribute Permit Requirements
675* Apply for Permits
680 Obtain Permits
730 Confirm Environmental Technical Issues for Construction

*Environmental Division with assistance from other TDOT Divisions

Figure 1.5 PPRM Flow Chart (a)

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Figure 1.5 PPRM Flow Chart (b)

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Figure 1.5 PPRM Flow Chart (c)

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Figure 1.5 PPRM Flow Chart (d)

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