Tennessee Environmental Procedures Manual
TDOT initiates coordination with agencies and the public for a project as one of the earliest tasks in the NEPA process for EA and EIS projects. A key element in early coordination is the preparation of a package of information describing the project. This package, containing a transmittal letter, a project description and a map of the project area, is prepared by the planner for distribution to various agencies, organizations and individuals that are expected to have an interest in the project.
The information obtained through the early coordination process is used to help determine the alternatives and the issues that will be examined in the EA or the EIS. While there is an initial effort to include all potentially interested agencies early in the project process, if other agencies are identified as the project progresses, coordination packages should be modified with current information and sent to those additional agencies as soon as possible.
The components of the early coordination packages are:
The Project Data Summary Sheet is prepared to provide agencies and the public with information on the proposed project. At this stage, detailed information on project impacts is generally not known; thus the summary sheet should only state what types of impacts might be anticipated.
The Project Data Summary is brief, typically two to five pages in length. It may be accompanied by a summary table. A sample Project Data Summary can be viewed in Appendix F [pdf 627 kb].
The following items are typically presented in the Project Data Summary Sheet:
Two exhibits usually accompany the Project Data Summary Sheet: a Vicinity Map and a Project Location Map. However, map insets can be used to show the project in its area context, eliminating the need for a separate vicinity map. An example of an initial coordination project map, with an inset map, is in Appendix F [pdf 627 kb].
The Vicinity Map can be prepared on a TDOT county map base with the study area highlighted. The Vicinity Map should have a title, indicating the project name and the county in which the project is located, a scale and a north arrow.
The Project Location Map is generally developed using a USGS map or other mapping in an urban area, and should show the project's termini, the location of the existing facility and the location of the build alternatives. The Project Location Map should clearly identify existing route names and numbers, the county name, and should include a title, a scale and a north arrow.
Accompanying the Project Data Summary Sheet and exhibits is a transmittal letter. This letter is addressed to representatives of agencies and organizations and to individuals. The transmittal list is discussed in Section 4.3.5.
The letter should include the following types of information:
These letters are also used to request agencies to serve as cooperating and/or participating agencies and to request review of the project's Coordination Plan.
For assistance in compliance with Title VI of the Civil Rights Act, the transmittal letter to local officials also includes a request to contact any local interest group that may be affected.
The letters are prepared on Environmental Division letterhead and are generally signed by a Manager II in the Environmental Division NEPA Documentation Office. 1 The individual letters should be personalized using an electronic mail merge process.
Samples of the coordination transmittal letters are provided in Appendix F [pdf 627 kb].
Three other types of required initial coordination letters are described below:
The farmland impact assessment is undertaken by the planner or consultant and is coordinated with the state office of the Natural Resource Conservation Service (NRCS) at the initial coordination stage. Guidance on coordination with NRCS is available in FHWA's Environmental Guidebook on the FHWA website: http://environment.fhwa.dot.gov/guidebook/chapters/v1ch5.asp
The planner or consultant must complete Parts I and III of the Farmland Conversion Impact Rating form (Form AD-1006) for this submission. This form and the instructions for completing it can be found at: http://www.nrcs.usda.gov/programs/fppa/AD1006.PDF
Available plans (functional or other) are used to calculate the amount of right-of-way that may be needed for the project from non-developed lands pursuant to the NRCS instructions.
In the mailing to NRCS, TDOT will include a cover letter requesting completion of the AD-1006 form by the NRCS, a copy of the AD-1006 form with Sections I and III completed, and a map(s) indicating locations of project alternatives. The mailing is sent to the NRCS office (their address is on the Environmental Division's initial coordination list). Mapping can be USGS quadrangle maps with the alignment shown or TDOT's functional plans. If functional plans are utilized, a map should also be included that shows the project in the context of the county. The additional steps involved in the farmland coordination process are described in Chapter 5, Section 126.96.36.199. A sample initial coordination letter to NRCS and a copy of the AD-1006 form are in Appendix F [pdf 627 kb], respectively.
The National Historic Preservation Act requires the FHWA or its designee (in this case TDOT) to identify the appropriate parties that need to be involved in the process of identifying effects of a proposed project to historic resources and working through the process with such parties. This "involvement" is referred to as "consultation."
Generally, the first outreach effort to the State Historic Preservation Office (SHPO), Native American tribes that are recognized within the state, local government, and known parties with historic preservation interests occurs in the NEPA early coordination stage. 2 At that time, the Environmental Division cultural resource staff will prepare or will assist the planner or consultant in preparing a special Section 106 initial coordination mail-out. A list of parties with historic preservation interests is sorted by county and is available from the TDOT Historic Preservation Program Manager. The letter to Native American tribes will be sent out by the TDOT Archaeology Program Manager.
The mail-out package includes a cover letter requesting the recipient to provide comments on the project and its potential impacts to architectural/historical and archaeological resources, the Project Data Summary Sheet (discussed in Section 4.3.1) and Project Location Maps.
The Section 106 outreach and coordination that occur after the early coordination efforts are discussed in Chapter 5, Section 188.8.131.52. Examples of Section 106 Initial Coordination letters are in Appendix F [pdf 627 kb].
Typically at the early coordination stage, TDOT knows which agency or agencies should participate in the project planning process as a NEPA cooperating agency. As described in Section 4.4.2 below, "cooperating agencies" are those governmental agencies specifically requested by the lead agency to participate during the environmental evaluation process.
If the project will likely have permitting or other involvement with federal agencies, such as the U.S. Army Corps of Engineers, the Tennessee Valley Authority, the U.S. Coast Guard or the National Forest or Park Service, the agency should be requested during early coordination to participate in project planning as a NEPA cooperating and participating agency. A sample letter is in Appendix F [pdf 627 kb]. The mail-out should include the Project Data Summary Sheet (discussed in Section 4.3.1) and Project Location Maps.
Federal agencies that decline to be a cooperating agency must do so in writing.
Also during the initial coordination stage, TDOT works with FHWA to identify those federal, state, tribal, regional and local government agencies that have special interest or expertise related to the project (see Section 4.4.3). A participating agency letter is sent to those agencies, requesting that they respond in writing with an acceptance or denial of the invitation within 45 days. If a federal agency chooses not to be a participating agency for the project, the agency must state the reason for declining the invitation. Tribal, state, regional and local agencies must respond in the affirmative to the invitation to be a participating agency; if the non-federal agency fails to respond by the stated deadline, the agency should not be considered a participating agency. A sample letter is in Appendix F [pdf 627 kb].
The Environmental Division maintains a coordination list. This list includes the names of federal, state and other agencies (such as regional planning agencies) and local governments that TDOT will coordinate with for this project. The list also includes private organizations and individuals who have requested to be included in initial coordination. Persons and agencies on the list will receive the initial coordination package, and later may receive the approved EA or DEIS for review and comment. As appropriate, persons and agencies on this list will also receive other correspondence related to the project.
Over the years, TDOT has compiled a broad list of federal, state, local and other agencies, private organizations and individuals from which the project-specific coordination list is prepared by the planner or consultant. This broad list is continually updated as new officials are elected, as agency representatives and addresses change, and as new organizations request to be added to the list. The following federal agencies and offices are generally included. Many of these would likely serve as participating agencies:
The following Tennessee State agencies are generally included:
Local and regional agencies would include county mayors, city mayors and/or city managers, town administrators, local planning agencies, Metropolitan Planning Organizations (MPOs), Rural Planning Organizations (RPOs), and Development Districts.
Private organizations that have expressed an interest in being included in the initial coordination list include:
In addition, various private individuals have expressed an interest in knowing about proposed projects.
The Environmental Division maintains and updates the overall coordination list of agencies, organizations and individuals, and that latest list should be consulted as the project specific coordination list is being compiled. At the coordination package stage of project development, the planner or consultant leading the NEPA document preparation develops the project-specific list by selecting those agencies, organizations and persons that are likely to be interested in the project and/or are located in the geographic area of the project. The project-specific list is likely to be amended as the project proceeds, with the addition of other individuals, groups and/or agencies.
The Environmental Division also sends copies of the package to other offices and divisions within TDOT, such as the Civil Rights Office, Aeronautics Division, and the Multimodal Transportation Resources Division.
The planner must prepare a package of information for the early coordination efforts and submit it to the FHWA Division Office. The package will state that the coordination package has been sent out and the date that it was sent. The package should include a sample letter, the mailing list and a copy of the Project Data Summary Sheet and exhibits.
1. If the project is being conducted by a local government, the planner or consultant should clarify with the local government official and the TDOT Environmental Division regarding which agency should send the early coordination letters.
2. It may be desirable to conduct coordination with the SHPO earlier than NEPA early coordination, in either the Transportation Planning Report (TPR) process or Context Sensitive Solutions (CSS) process, for example, for projects that have not progressed into the NEPA process.
3. ARC counties in Tennessee are Anderson, Bledsoe, Blount, Bradley, Campbell, Cannon, Carter, Claiborne, Clay, Cocke, Coffee, Cumberland, De Kalb, Fentress, Franklin, Grainger, Greene, Grundy, Hamblen, Hamilton, Hancock, Hawkins, Jackson, Jefferson, Johnson, Knox, Lawrence, Lewis, Loudon, McMinn, Macon, Marion, Meigs, Monroe, Morgan, Overton, Pickett, Polk, Putnam, Rhea, Roane, Scott, Sequatchie, Sevier, Smith, Sullivan, Unicoi, Union, Van Buren, Warren, Washington, and White.