FHWA in conjunction with the American Association of State Highway and Transportation Officials (AASHTO) have issued a report on an initiative to improve the quality of EISs and EAs written to comply with NEPA. The report can be found at http://www.environment.transportation.org/pdf/IQED-1_for_CEE.pdf.
The report identifies the core principals of quality NEPA documents:
Principal 1 - Tell the story of the project so that the reader can easily understand the purpose and need of the project; how each alternative would meet the project goals, and the strengths and weaknesses associated with each alternative.
Principal 2 - Keep the document as brief as possible, using clear concise writing; an easy-to-use format; effective graphics and visual elements; and discussion of issues and impacts in proportion to their significance.
Principal 3 - Ensure that the document meets all legal requirements in a way that is easy to follow for regulators and technical reviewers.
The recommendations stress the use of plain language with effective visual elements (pictures, simulations, graphs, figures, tables, etc.).
The report also offers an alternative organization for headings in an EA or EIS, with the use of question and answer headings to help direct readers to the information they are most interested in. Figure 6-1 provides an example of how the traditional EIS format might be transformed into a question and answer format.
The report does not provide a template, but does endorse a basic blueprint as an effective organization for most EIS documents. The blueprint sets forth the following components for NEPA documents, each of which should focus on telling the project decision-making story clearly, while still meeting legal sufficiency needs:
The blueprint differs from traditional NEPA documents in two key areas. It combines the Affected Environment and Environmental Consequences discussions into one chapter. The intent of combining these discussions is to provide readers with a full understanding of which environmental issues are significant in the project area and how each alternative affects them.
In addition, the blueprint divides the Alternatives chapters into two separate chapters. One chapter identifies preliminary alternatives, explains the screening process, and discusses how alternatives were developed. A separate chapter provides a comparison of the reasonable alternatives that were carried forward for detailed study, and describes the preferred alternative once it is identified or selected.
|Question-and-Answer EIS/EA Headings|
|Traditional EIS||Reader-Friendly EIS|
|Purpose and Need||Why do we need the project?|
|Project termini and why are they logical||Where is the project located and why were these boundaries selected?|
What is the alternative?
How would it be built?
How would it change access?
How would it affect travel times and traffic flow?
How would pedestrians and bicycles be affected?
Impacts and Mitigation
How would it change the characters and land use in the project area?
How would noise levels change?
How would the alternative affect neighborhoods and the people who live there?
Source: Improving the Quality of Environmental Documents, May 2006.
Figure 6-2 provides a comparison of the organization of the traditional NEPA document and the suggested blueprint.
Regardless of the format used, a quality document requires careful management of the entire document creation process, starting early in the process.
Source: Improving the Quality of Environmental Documents, May 2006.
In order to improve the overall quality of documents provided to FHWA and other resource agencies for their review and concurrence, TDOT has established an Environmental Document Quality Process. This process is designed to ensure the overall quality of the document and to minimize correctable errors,
Quality Assurance (QA) as jointly defined by various national agencies means "All those planned and systematic actions necessary to provide confidence that a product or facility will perform satisfactorily in service." More simply stated, quality assurance can be defined as "making sure the quality of a product is what it should be."
Quality Assurance is an all-encompassing term that includes Quality Control (QC) by the NEPA Planner (internal or consultant) and acceptance by TDOT, and the use of qualified personnel and industry accepted engineering and planning practices by both parties. Additionally, quality assurance requires joint agency/industry support and the implementation of quality assurance specifications.
The term "quality control/quality assurance" or "QC/QA" has often been used in the past synonymously with quality assurance. The term QC/QA has been applied historically by some transportation agencies wherein quality control was viewed as the consultant or contractor's responsibility and quality assurance was seen as the agency's responsibility. However, consistent with the accepted definition of quality assurance, quality control is not a separate function but rather is one of the core elements of quality assurance. Accordingly, "quality assurance" or simply "QA" is considered to be the proper term.
The TDOT Environmental Document Quality Assurance Process will apply to all documents being sent to external agencies as part of the TESA concurrence process and to the submission of draft environmental documents and final environmental documents to FHWA for review and approval. The process also applies to the preparation of environmental documents for state funded projects (TEER).
The Environmental Document Quality Assurance Process can be initiated in one of two ways depending on whether the document has been developed internally by TDOT staff or by a consultant as illustrated in Figure 6-3 and discussed below. Yellow boxes denote activities performed by consultants, green boxes denote TDOT tasks, and orange boxes reflect FHWA actions.
In cases where TDOT staff is preparing a document, TDOT will assign the document to a NEPA planner and technical studies are conducted, completed, and approved. TDOT staff then prepares the environmental document based on the technical studies conducted. Upon completion, the document goes to TDOT for internal review prior to submission to FHWA.
TDOT will perform a quality assurance check on the document. This quality assurance review will be conducted by the TDOT Point of Accountability, the appropriate TDOT Environmental Division Regional Manager and the TDOT Environmental Division Quality Coordinator. If the document is determined to not meet quality standards and/or has other content specific or technical issues, the document is sent (with comments) back to the TDOT staff member who prepared the document. Required edits are made and it is resubmitted for TDOT quality assurance review until it is approved. Figure 6-4 shows the coversheet that must be completed and signed by the Project Manager to confirm that internal quality reviews have been conducted. (Note: TEER documents are not reviewed by FHWA.)
If a consultant is being utilized to develop an environmental document, the first step in the document quality process is for TDOT to issue a work order to authorize that consultant to prepare the environmental document. As part of the work order process, the consultant is required to provide documentation of its internal quality assurance process. This documentation is provided in the form of a quality assurance plan for the project.
The consultant's quality assurance plan should specify the steps and procedures the consultant will utilize to ensure both the technical completeness and integrity and the editorial quality of the document. This plan should also define how the quality of work being performed by any sub-consultants is being assured, both in terms of prime consultant review and the subcontractor's own internal processes. This quality assurance plan must be approved by the TDOT Point of Accountability for a given project, the Lead TDOT NEPA Planner for the project, the TDOT Environmental Division Regional Manager and the TDOT Environmental Division Quality Coordinator prior to the authorization being given to the consultant to start work.
After work has been authorized, required technical studies are conducted, completed, and approved. The TDOT consultant then uses the technical studies to prepare the environmental document according to the findings in the studies.
Once the document has been written, the consultant has the responsibility to execute its own internal quality assurance process on the document following the approved quality assurance plan. If the document does not meet the firm's internal quality standards, the document should stay within the firm until such time as the appropriate personnel can verify that the document meets the required standards of accuracy and completeness. When the document passes the consulting firm's internal quality assurance check, the consultant then submits the document and the quality checklists and the QA coversheet to TDOT indicating that the document has been checked and includes sign-offs from the appropriate personnel in the firm verifying that a quality assurance review has been conducted consistent with the approved quality assurance plan for the project. The QA Coversheet to be submitted by the consultant is shown in Figure 6-5.
TDOT then reviews the document prior to submission to FHWA and/or other resource agencies and conducts its own quality assurance review on it. This quality assurance review will be conducted by the TDOT Point of Accountability, the Lead NEPA Planner, the appropriate TDOT Environmental Division Regional Manager and the TDOT Environmental Division Quality Coordinator.
Each of these individuals must sign-off on the accuracy and completeness of a document prior to the document being submitted to FHWA and/or other resource agencies. If the document is determined to not meet quality standards and/or has other content specific or technical issues, TDOT returns the document with comments back to the consultant and the process begins over again within the consulting firm. Figure 6-6 contains the master coversheet that TDOT must execute to certify that the consultant's work has been reviewed.
Regardless of whether a TDOT NEPA planner or a consultant creates the environmental document, once it passes the TDOT quality assurance check, the document is then transmitted to FHWA. FHWA independently reviews the document for accuracy and completeness. If the document fails FHWA's review, it is returned with comments to TDOT, who passes along the comments to the originating consultant or TDOT NEPA planner for adjustments to the document. Once edits have been made to the document TDOT will once again execute its quality assurance process to ensure that FHWA's comments have been addressed and no new correctable errors are found. Once the document has passed TDOT's quality assurance review, the document is resubmitted to FHWA for another review. This process will continue until FHWA approval is obtained.