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Tennessee Environmental Procedures Manual

Chapter 2: Project Identification and Development

2.3 Defining the Project

What constitutes a "project" that can advance from early planning through construction under the FHWA regulations? To be considered a project, a clear need for the project must be demonstrated. A clear need might be safety, rehabilitation, economic development, or capacity improvements. This need must be considered in the context of the social and economic environment, topography, future travel demand and other related infrastructure improvements. In addition, the project must be a "whole" or integrated project.

FHWA specifies that three general principles are used to frame (define) a highway project. Under 23 CFR 771.111(f), a proposed improvement shall:

  1. Connect logical termini and be of sufficient length to address environmental matters on a broad scope;
  2. Have independent utility or independent significance, i.e., be usable and be a reasonable expenditure even if no additional transportation improvements in the area are made; and
  3. Not restrict consideration of alternatives for other reasonably foreseeable transportation improvements.

The following subsections explain three critical items that must be addressed during the early phases of the project development process. These critical items are the purpose and need statement; logical termini and independent utility, and definition of the study area.

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2.3.1 Purpose and Need

The transportation planning process required by 23 U.S.C. 134 and 135 and 49 U.S.C. 5303-5306 sets the stage for the development of transportation projects. As part of the transportation planning process, states and local metropolitan planning organizations (MPOs) must develop long-range transportation plans to address projected transportation needs. In addition, they must create transportation improvement programs (STIPs or TIPs, respectively), which identify a list of priority projects to be carried out in the next three years to implement the long range plan. To receive Federal funding, transportation projects must come from an approved TIP or STIP. As a result, much of the data and decision-making undertaken by state and local officials during the planning process carry forward into the project development activities that follow the TIP or STIP. This means that the planning process and the environmental assessment should work in tandem, with the results of the transportation planning process feeding into the NEPA process. Ideally, the purpose and need for highway and transit projects should come out of the long-range transportation planning process. That is the point at which systemwide needs are analyzed and projects are moved forward for programming.

The purpose and need statement, at a minimum, is a statement of the transportation problem to be solved by the proposed project. It is often presented in two parts: broad goals and objectives, and a description of the transportation conditions (congestion, safety, etc.) underlying the problem. The long-range transportation plan also includes goals and objectives similar to "purpose and need" but on a broader scale, since it typically covers a wider area and spans at least twenty years. These goals and objectives are often identified through extensive public outreach.

The need for a project must be clearly demonstrated for it to proceed in project planning and to receive federal or state funding. The purpose and need statement is a written description of the transportation problems (the need) and the solution to the problem (purpose).

The purpose and need statement drives the alternatives development and analysis tasks, but it should not be so narrowly defined as to point to a single solution only. Without a well-defined and justified purpose and need statement, the identification of reasonable alternatives would be difficult. If the project purpose and need are rigorously defined, the number of solutions that will satisfy the need can be more readily identified. The purpose and need statement is the cornerstone of the alternatives analysis. It is not, however, the place where alternatives are defined or discussed.

The purpose and need should be defined in terms that are easily understandable to the general public. It should justify why the improvement should be implemented. The information presented should be as comprehensive and specific as possible to justify the need.

Regarding project need, the environmental document text should summarize the main problem or problems that point to the need for some action. This section should describe the existing conditions and the projected problems if no action is taken. For project purpose, the environmental document text should summarize the purpose that a proposed action should serve, i.e., describe how a potential solution should solve the identified problem or need.

Every effort should be made to develop a concise purpose and need statement that focuses on the main transportation problems to be addressed.

The elements of a purpose and need statement are outlined in the FHWA Technical Advisory T 6640.8A. (Appendix D [pdf 201 kb]). General direction on developing concise and discernible purpose and need statements is found in the CEQ/USDOT letter exchange found on-line, and in the FHWA/FTA Joint Guidance issued July 23, 2003. Additional guidance is available in Executive Order 13274, Purpose and Need Work Group Baseline Report (Revised draft, March 15, 2005).

All items listed below may not be applicable to every project, but those that are should be discussed, as appropriate, to help explain and justify the project's purpose and need.

  • Project Status: Provide a brief project history, including all actions taken, other state and federal agencies involved, and project schedule. Discuss the history of transportation planning in the area. Describe the actions taken and the governmental units or agencies involved. Discuss any existing transportation plans or other relevant studies.
  • System Linkage: Is the project a needed connecting link in a transportation system? How does the project fit into the system - existing and future? If the project is a needed link in a roadway network, describe the existing lack of connectivity. Explain how the proposed improvement would address the needs of the community and the roadway system. Even if system linkage is not a primary justification, it may still be beneficial to provide an overview of the overall roadway network and the function the subject road serves within the system.

    If applicable, discuss the relationship of the subject roadway to any other designated systems such as the National Highway System, Strategic Highway Network (STRAHNET), National Truck Network, and emergency evacuation roads (e.g., for roadways near nuclear facilities).
  • Existing and Future Conditions: Identify TDOT's roadway classification. What roadway capacity is needed, existing and future? What is the level of service for the existing and future facility? Give data for existing and future (projected) average daily traffic (ADT), peak hour characteristics and truck percentages and capacity and level of service (LOS). Include a brief explanation of LOS ratings, as described in the Highway Capacity Manual.
  • Transportation Demand: Discuss relationship to the state's transportation plan or plans adopted by the MPO; include traffic forecasts generated by the state or MPOs.
  • Legislation: Describe any federal, state or local government mandate for the action.
  • Social or Economic Conditions: Identify whether the subject facility may significantly impact any identified groups. Explain how the benefits and adverse impacts to these groups were considered during the planning process. Is the new or upgraded facility needed to serve a new school, a new factory, etc.? Is unemployment high in the area and is the road needed to promote economic development and provide jobs?
  • Land Use: If applicable, describe projected changes in land use that spur the need for improving the area's highway capacity. Reference the local area's land use plan and describe how it was considered in the transportation planning process. Explain how the project may impact major existing or planned development.
  • Modal Relationships: Describe relationships to other transportation modes such as airports, rail and port facilities and how the project may affect other transportation modes. Is the road needed or is an upgrade warranted to get traffic to an airport? To get trucks to a port or rail terminal?
  • Safety: Is the project needed to correct an existing safety hazard? For areas with high crash rates, provide data on the frequency, type, conditions, cause and increase or decrease over time in rate of crashes in comparison to the critical crash rates. Discuss any other type of safety hazard, such as substandard design or geometric deficiencies. Explain how the project might result in a lower crash rate.
  • Roadway Deficiencies: Are improvements necessary to correct existing roadway deficiencies, for example, substandard geometry or lane width? How will the project correct these deficiencies? Describe any design deficiencies, such as substandard cross section or horizontal or vertical alignment.

Although most transportation projects stem from a transportation-related need (e.g., congestion problems, lack of access, safety problems), transportation agencies recognize that economic development can be a primary or secondary purpose and need for some highway projects, particularly in rural areas. In these cases, the transportation needs are inextricably linking to the underlying need for economic development in economically depressed or underutilized areas

The Technical Advisory also encourages the use of exhibits, tables, maps and other graphics to illustrate or provide backup for points that are being made. It is important to include a project location map in the Purpose and Need Statement to establish the geographic context.

The purpose and need statement generally forms the first chapter of an EA or an EIS, and its preparation should be initiated during the earliest phases of project planning. It is important to note that the project purpose and need statement should be considered a "living document." It may be expanded as studies are undertaken along the corridor. Additional needs, beyond those originally identified, may be revealed as the project planning proceeds. The purpose and need statement should be re-examined and updated, as appropriate, throughout the project development process.

SAFETEA-LU Section 6002, Efficient Environmental Reviews for Project Decisionmaking, requires lead agencies to give the public and participating agencies the chance to be involved in the development of the project purpose and need statement in a timely and meaningful way. This opportunity can occur early during the transportation planning process before an EIS is initiated, if the project is sufficiently well defined at that time, or later during the scoping process. With a CSS approach, the opportunity for involvement will occur sooner in the process, rather than later.

The opportunity for input must be widely publicized and may occur in the form of public workshops or meetings, solicitations of verbal or written input, conference calls, postings on the Internet, distribution of printed materials or other involvement techniques. The opportunity must be provided prior to the FHWA's final decision regarding purpose and need. The Section 6002 provisions are required for EIS documents, and discretionary for EAs and CEs.

TDOT has entered in a cooperative agreement with FHWA and other federal, state, and local agencies to establish a coordinated planning and project development process for major transportation projects. This cooperative agreement, entitled "Tennessee Environmental Streamlining Agreement (TESA) for the Environmental and Regulatory Coordination of Major Transportation Projects, " is discussed in greater detail in Section 4.5 of Chapter 4 of this manual. In keeping with the requirements of SAFETEA-LU, TESA includes a set of key points at which TDOT is seeking to obtain the concurrence of cooperating and participating agencies in the transportation planning and NEPA process. The first concurrence point occurs during the development of the Preliminary Purpose and Need.

FHWA and FTA issued a joint guidance, Linking the Transportation Planning and NEPA Processes (February 2005), to describe how the transportation planning process can be linked with the NEPA decision-making process, especially for purpose and need statements and alternatives development. The transportation planning process can provide the basis or foundation for the purpose and need statement in a NEPA document. To the extent regional or systems-level analyses and choices in the transportation planning process help to form the purpose and need statement for a NEPA document, such planning products should be given great weight by FHWA and FTA, consistent with Congressional and Court direction to respect local sovereignty in planning. For more information, see the FHWA's website on Planning and Environment Linkages at

As part of the process to develop the SMART Delivery Management System (SDMS), in late 2009 TDOT initiated a series of workshops to look at opportunities to better link the Department's transportation planning and environmental process. As part of this effort, TDOT is developing a more formalized Needs Assessment process which will form the basis for the Transportation Planning Report and the later environmental document.

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2.3.2 Logical Termini and Independent Utility

In order to ensure meaningful evaluation of alternatives and to avoid commitments to transportation improvements before they are fully evaluated, the proposed action evaluated in an EA or EIS must meet the following criteria:

  • Connect logical termini and be of sufficient length to address environmental matters on a broad scope;
  • Have independent utility or independent significance (i.e., be usable and be a reasonable expenditure even if no additional transportation improvements in the area are made); and
  • Not restrict consideration of alternatives for other reasonably foreseeable transportation improvements. Development of Logical Termini

In FHWA's NEPA implementing regulations, 23 CFR 771.111(f)(1) states that an action evaluated in an EA or EIS shall" connect logical termini and be of sufficient length to address environmental matters on a broad scope."

FHWA issued a paper on November 15, 1993 entitled The Development of Logical Project Termini (

As defined by FHWA, logical termini are rational end points for a transportation improvement and rational end points for a review of the environmental impacts.

Some guidelines for selecting the project's logical termini are:

  • Begin/End project at points of major traffic generation, often intersecting highways. An example would be widening a two-lane roadway between two four-lane sections of highway;
  • The termini selected should encompass an entire project. Dividing the project up into small individual projects is called "segmentation" and is not allowable under NEPA. The project can be constructed in segments, but the project studies should encompass the entire project, so that the effects of the project can be fully identified; and
  • Geographic boundaries are generally not suitable as logical termini. For example, ending a project at a county line is not logical when the substandard roadway continues beyond the county line to an adjacent town or city.

For most projects, the choice of logical termini is likely to be obvious and non-controversial.

For a few major projects where other considerations are important, the termini must ensure the following:

  • Environmental issues can be treated on a sufficiently broad scope to ensure that the project will function properly without requiring additional improvements elsewhere; and
  • The project will not restrict consideration of alternatives for other reasonably foreseeable transportation improvements.

Establishment of logical termini is of major importance for EISs and EAs, but is not as critical for CEs. However, some CEs will have logical termini as a consideration. The decision of whether logical termini are needed for a CE is an FHWA decision that is made on a case-by-case basis. For example, logical termini would need to be established for widening an existing highway with no displacements and little or no right-of-way acquisition. On the other hand, logical termini would probably not have to be established for an intersection improvement or a bridge replacement.

The termini of the project should be determined during the earliest phases of the project; however, it may be necessary to refine the project termini as a result of agency coordination and public involvement. Demonstrating Independent Utility

23 CFR 771.111 (f)(2) also requires that a project must be able to function on its own, a term known as "independent utility." A project with independent utility or independent significance means that it is usable and is a reasonable expenditure of funding even if no other transportation improvements are made in the area. The project must meet a need without requiring the construction of adjoining projects. In addition, projects that have independent utility should be planned so as not to restrict the consideration of alternatives in adjoining segments.

Independent utility should be determined early in the project development process and should continue to be evaluated as project planning continues.

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2.3.3 Defining the Study Area

As the purpose and need statement is being developed, the limits of the study area should also be defined. The study area limits should be based on the logical termini and the purpose of the project. There are two general criteria for defining the study area:

  • It should be large enough to encompass a range of alternatives that meet the project purpose and need; and
  • The boundary should only be large enough to allow for flexibility in the development of alternatives.

The study area typically includes communities/areas/neighborhoods within the project corridor and immediately adjacent to it. "Community" boundaries can often be delineated by physical barriers, land-use patterns, political divisions, selected demographic characteristics, historical background, resident perceptions, subdivisions and historic neighborhoods. In addition, a project can have social and economic consequences for communities beyond the immediate geographic area. An example of this is the construction of a new segment of road that bypasses a small town. This could have negative impacts on the businesses in the small town. Thus the study area should include all or a portion of the town.

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