Project Report on Effective Organizational Structures and Management Practices

Description
This report describes organizational structures and management practices that contribute to achieving environmental stewardship and streamlining in state DOTs.

NCHRP 25-25, Task 37 COPY NO. ___
Effective Organizational Structures and
Management Practices for Achieving
Environmental Stewardship and Streamlining
in Transportation Agencies
Requested by:
American Association of State Highway and Transportation Officials (AASHTO)
Standing Committee on the Environment
Prepared by:
PB Americas, Inc.
Washington, D.C.
J une 2009
The information contained in this report was prepared as part of NCHRP 25-25, Task 37,
National Cooperative Highway Research Program, Transportation Research Board.
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NCHRP 25-25, Task 37 Organizational Structures And Management Practices For Achieving
Environmental Stewardship And Streamlining
Page i
Acknowledgement
This study was requested by the American Association of State Highway and
Transportation Officials (AASHTO), and conducted as part of National Cooperative
Highway Research Program (NCHRP) Project 25-25. The NCHRP is supported by annual
voluntary contributions from the state Departments of Transportation. Project 25-25 is
intended to fund quick response studies on behalf of the AASHTO Standing Committee
on Environment. The report was prepared by Cynthia J . Burbank, Hal Kassoff, Amy
Zwas, and Alan Lubliner of Parsons Brinckerhoff Americas. The work was guided by a
task group, which included Tim Hill of the Ohio Department of Transportation, Kelly
Dunlop of CALTRANS, Mary Ivey of the New York Department of Transportation, Mark S.
Kross, Chair of the TRB Committee on Environmental Analysis in Transportation
(ADC10), Nancy Lee of U.S. Fish and Wildlife Service, J ennifer Moyer of U.S. Army
Corps of Engineers, Denise M. Rigney of the U.S. Environmental Protection Agency, Kim
Thurman of the Mississippi Department of Transportation, and Shari Schaftlein of the
Federal Highway Administration. The project was managed by Nanda Srinivasan, NCHRP
Senior Program Officer.
Disclaimer
The opinions and conclusions expressed or implied are those of the research agency
that performed the research and are not necessarily those of the Transportation
Research Board or its sponsoring agencies. This report has not been reviewed or
accepted by the Transportation Research Board Executive Committee or the Governing
Board of the National Research Council.
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
Achieving Environmental Stewardship and Streamlining
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CONTENTS
ACKNOWLEDGEMENTS................................................................................... i
LIST OF FIGURES AND TABLES ....................................................... ............ iii
ABSTRACT..................................................................................................... iv
EXECUTI VE SUMMARY................................................................................... 1
CHAPTER 1 Background................................................................................. 6
CHAPTER 2 Research Approach..................................................................... 7
CHAPTER 3 Findings and Applications.......................................................... 9
3.1 Broad Themes Common to Most or All 11 State DOTs............... 9
3.2 Additional Specific Advice from One or More State DOTs ....... 17
3.3 Relationship of Literature Review to the Twelve Themes....... 18
3.4 I ndividual Summaries of the First Phase of I nterviews .......... 27
Interview with Florida DOT............................................. 28
I nterview with Maryland State Highway
Administration................................................................... 32
Interview with New York State DOT................................ 35
Interview with Oregon DOT.............................................. 40
Interview with Tennessee DOT........................................ 46
Interview with Vermont Agency of Transportation......... 50
3.5 Individual Summaries of the Second (“Beta”) Phase .......... 56
Interview with Arkansas State Highway and
Transportation Department.............................................. 56
Interview with Illinois DOT............................................. 60
Interview with Minnesota DOT......................................... 63
Interview with Montana DOT........................................... 66
Interview with New Mexico DOT...................................... 70
CHAPTER 4 Conclusions and Suggested Research..................................... 74
REFERENCES................................................................................................ 79
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
Achieving Environmental Stewardship and Streamlining
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List of Figures and Tables
Figure 1: The 11 State DOTs Interviewed for NCHRP 25-25 (37)……………………………… 8
Table 1: 12 Themes Identified in the 11 State DOT Interviews…………………………………9
Table 2: Comparison of the 12 Themes to Literature Review………………………………….25
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NCHRP 25-25, Task 37 Organizational Structures And Management Practices For Achieving
Environmental Stewardship And Streamlining
iPage iv
Abstract
This report describes organizational structures and management practices that
contribute to achieving environmental stewardship and streamlining in state DOTs. It is
based primarily on a two-phase set of interviews of state DOTs – six states in Phase 1
(Florida, Maryland, New York, Oregon, Tennessee, and Vermont) and five states in
Phase 2 (Arkansas, Illinois, Minnesota, Montana, and New Mexico). From the interviews
of this diverse group of state DOTs, twelve main themes emerged as important to
success in environmental stewardship and streamlining:
1. Provide two levels of leadership.
2. Organize for environmental awareness and accountability throughout the DOT
and assure effective communications.
3. Provide expert staffing.
4. Build an environmental culture.
5. Support improved land use.
6. Invest in environment.
7. Nurture relationships with resource agencies.
8. Invest in GIS.
9. Develop programmatic agreements.
10. Shift from projects to ecosystems.
11. Be judicious with environmental management systems (EMS) and environmental
performance measures (EPMs).
12. Continually streamline environmental processes.
In addition, a literature review was conducted, yielding 27 reports that contain findings,
recommendations and tools that could help state DOT efforts to advance environmental
stewardship and streamlining.
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NCHRP 25-25, Task 37 Organizational Structures And Management Practices For Achieving
Environmental Stewardship And Streamlining
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Executive Summary
One of the top challenges facing state Departments of Transportation (DOTs) is
environmental performance. They are challenged to comply with a lengthy list of
environmental laws, meet public expectations for environmental protection and
enhancement, and also expedite environmental reviews in order to deliver high quality
transportation improvements that meet transportation needs.
To help state DOTs meet this challenge, this NCHRP study focused on identifying and
describing effective organization structures and management practices to achieve a high
level of environmental stewardship and environmental streamlining.
The study relied primarily on two phases of interviews of state DOTs, and secondarily on
a literature review. First, the research team interviewed six state DOTs which had
strong track records of environmental performance, based on environmental awards
received, accomplishments in both stewardship and streamlining, and overall
environmental credibility. State DOTs were also selected to ensure diversity in their
geography and size of their programs. The six states interviewed in Phase 1 were
Florida, Maryland, New York, Oregon, Tennessee, and Vermont. All interviews were
conducted between December 2007 and April 2008.
The results of these six interviews were summarized for each state, and twelve
dominant themes from these interviews were synthesized. The twelve dominant themes
were:
1. Provide Two Levels of Leadership: Two forms of leadership are essential:
(a) CEOs and other DOT executives, and (b) career environmental managers.
CEOs, their Deputies, and Chief Engineers need to provide personal, highly
visible leadership on environmental issues both within their organizations and
with resource agencies. DOT executives who are personally engaged in
addressing high-profile environmental issues not only lend their insights and
authority, but their participation conveys a message to all parties, both within the
DOT and beyond, about priorities and values. Engaged executives must be
matched by capable leadership of career environmental managers within a state
DOT. These career leaders must reflect the philosophy and policy direction of
agency leaders. Career environmental managers need to be strong leaders in
their own right, with an ability to interact effectively at all levels, including with
their own executives. In the face of CEO changes every few years, career
environmental managers provide needed continuity and day-to-day, year-to-year
direction and decision-making.
2. Organize for Environmental Awareness and Accountability and Assure
Effective Communications throughout the DOT: State DOTs need both:
(a) a strong core environmental staff in headquarters, and (b) environmental
staff and responsibilities appropriately dispersed in other parts of the
organization. For maximum effectiveness, environmental responsibilities and
environmental staff should reside in virtually all functions, as well as in the field,
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
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in DOT regions and districts. The decentralized structure of large state DOTs is a
major challenge, requiring greater time and effort in coordinating and
maintaining consistency on environmental policies and procedures. Placement of
environmental units within the state DOT hierarchy is also important. A decade
or more ago, environmental units were often placed on a lower organizational
tier, in engineering units where environmental scientists and experts were often
given relatively little credence. In recent years, many state DOTs have moved
environmental units up to a higher level within the state DOT, to the first or
second tier below the CEO or chief engineer.
3. Provide Expert Staffing: As environmental issues have grown more important
and complex, state DOTs need to make a significant investment in building
strong environmental expertise among their staff. In doing so, state DOTs gain
credibility with resource agencies, which is essential to resolving the wide range
of issues regarding wetlands, water quality, air quality, wildlife, and other issues
that can block important transportation improvements. Over time, a state’s
expertise on specific environmental issues can build trust and lead to break-
through agreements. The use of expert environmental consultants is widespread
and understandable to address peak workloads and technical specialties.
However, each state DOT needs to maintain core environmental competency and
a base of institutional knowledge to direct in-house work, to relate to resource
agencies, to guide and manage outsourced activities effectively, and to perform
quality assurance on those activities.
4. Build an Environmental Culture: To be successful in the 21
st
century, state
DOTs need to have a strong environmental ethic shared throughout the DOT
workforce, from transportation planners, to construction engineers, to
maintenance staff. Creating a pervasive environmental culture doesn’t happen
overnight; it takes time to build and it takes constant communication with the
workforce. The more the workforce sees and hears from DOT CEOs, their
Deputies, and Chief Engineers about environmental values, the better.
Environmental recognition and awards programs can be extremely helpful in
building a strong environmental ethic. Environmental training programs are also
important, to explain environmental policies and provide employees with the
environmental skills and knowledge to be successful.
5. Support I mproved Land Use: Virtually all the interviewed state DOTs saw
land use as a critical issue for state DOTs. All of the state DOTs had limited or no
land use authority, even those states with strong state-level land use planning.
Despite their lack of authority, however, the state DOTs recognized they could
and should help influence land use in ways that are good for the environment
and good for transportation. For example, several state DOTs are providing
technical assistance to local governments on land use planning.
6. Invest in Environment: Every state is faced with tight budget constraints,
forcing difficult choices to be made. None of the interviewed states saw an
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“either-or” choice between funding environmental protection/enhancements and
transportation improvements. Instead, they emphasized that environmental
features are essential elements of transportation projects, just as safety features
are essential in the design of transportation projects. All of the interviewed
states had a track record of investing in environmental staff, environmental
mitigation, environmental enhancement, and environmental process
improvement.
7. Nurture Relationships with Resource Agencies: All the interviewed state
DOTs emphasized the importance of building and maintaining effective
relationships with resource agencies, both on the state and federal levels.
Despite these efforts, results can be slow and mixed. While some states
emphasized their efforts have paid off with strong, effective relationships, other
states cited ongoing issues, such as a regulatory mindset, a tendency for issues
to be raised late in the environmental process, having to “prove a negative,” staff
turnover among resource agencies, inconsistencies among and within resource
agencies, and reluctance to invest in early coordination. There were no silver
bullets to address these difficulties, other than a persistent, step-by-step process
of establishing relationships and building trust.
8. Invest in GIS: A comprehensive Geographic Information System (GIS)
database was cited repeatedly as an invaluable tool for both environmental
stewardship and streamlining. DOTs in most of the interviewed states have
invested and continue to invest in a high quality GIS database and expert GIS
staff to make full use of the database. This earns credibility and respect from
resource agencies, facilitates early coordination with resource agencies, and
enables states to do better, more efficient, and more effective transportation
planning and environmental mitigation planning.
9. Develop Programmatic Agreements: The interviewed states cited a variety
of Programmatic Agreements (PAs) that have been invaluable in improving the
environmental process, both through improved stewardship and timelier project
development. These successful PAs are described in the report, and AASHTO’s
Center for Environmental Excellence provides a library of PAs, together with a
detailed step-by-step “how to” guide to develop successful PAs.
10. Shift from Projects to Ecosystems: All the interviewed state DOTs saw the
need to move away from project-by-project environmental planning and
mitigation, to ecosystem planning and mitigation. A valuable tool for ecosystem
planning and mitigation is the handbook “Eco-Logical: An Ecosystem Approach to
Developing Infrastructure Projects,” which was issued by FHWA and seven
Federal resource agencies (Fish and Wildlife Service, Forest Service,
Environmental Protection Agency, Bureau of Land Management, Army Corps of
Engineers, National Park Service, and the National Marine Fisheries Service) in
2006. In 2007-08, FHWA supported the “eco-logical” approach through the
award of 15 cooperative awarded 15 15 cooperative agreements
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totaling approxi matel y $1.4 mi llion in response to the 2007
" Integrating Transportati on and Resource Planning to Develop
Ecosystem Based Infrastructure Projects" grant solicitation.
The recipients represent State and local Departments of
Transportation, State resource agencies, Metropolitan Planning
Organizations, local governments, non governmental organizations,
and one university
11. Be J udicious with Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs): Most of the interviewed
state DOTs saw value in Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs) and were implementing them to
some degree. For the most part, these states’ use of EMS and EPMs is a work in
progress – only partially implemented -- although most of the states intend to
develop them further.
12. Continually Streamline Environmental Processes: Environmental
streamlining is a work in progress in all the interviewed states, with differing
levels of emphasis and differing levels of success. As one might expect,
streamlining is a higher priority in high-growth states which have more major
capacity expansion projects than in states with established transportation
systems and relatively few capacity expansion projects. Guidelines for states
seeking to streamline project delivery vary based on the variety of experiences
among the interviewed states; these guidelines are described in the report. In
addition, the AASHTO Center on Environmental Excellence website provides
valuable case studies on environmental streamlining.
After the first round of interviews, the research team conducted a second set of
interviews with an additional five state DOTs. The additional five state DOTs were
selected to provide geographic and programmatic diversity. They were Arkansas,
Illinois, Minnesota, Montana, and New Mexico. Several of these states also had high-
level environmental track records, achievements, and credibility. In the second set of
interviews, these five states were asked about the twelve themes that emerged from the
first set of interviews, as well as for any additional experience and insights they could
offer to achieve a high level of environmental stewardship and streamlining.
Uniformly, the five states affirmed the 12 dominant themes from the first set of
interviews, augmenting the themes with additional information, insights, and examples.
Surprisingly, no new themes emerged from the five states that approached the level of
emphasis of the 12 themes that emerged from the first set of interviews.
Both sets of interviews were designed and conducted to serve several purposes:
To elicit valuable information that could be summarized in this NCHRP report.
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
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To include senior executives (e.g., Chief Executive Officers (CEOs), Deputy CEOs,
and Chief Engineers) from as many of the state DOTs as possible, together with
the state DOT environmental managers.
To provide a forum where both senior DOT executives and environmental
managers could jointly reflect on their environmental performance and how their
management practices and organizational structures contributed to (or perhaps
limited) their environmental performance.
To provide “cross fertilization,” by allowing the research team to share
information from other states and the Literature Review that might be relevant
to each state DOT. (This was particularly relevant for the second phase of
interviews, which received the benefit of the dominant themes and information
gained from the first phase of interviews.)
In short, the project was designed to be more than a written report, so that it could also
serve as an active learning process through the way the interviews were designed and
conducted.
In addition, a literature review was performed, to serve as a secondary and
supplementary source of information. 27 reports were identified with useful information
about management practices and organizational structures for environmental
stewardship and streamlining. These reports included studies of private sector
experience in elevating their environmental performance, as well as experience in the
public sector and among state DOTs in particular.
One report was particularly valuable, “Promoting Environmental Sensitivity: Business
Organization and Operations – Volume 1: Private Sector Companies.” The report was
prepared for the Federal Highway Administration in the early 1990s, but has never been
published and is not available on the internet. Although over 15 years old, many of its
conclusions and recommendations mirrored the insights and recommendations from the
11 state DOT interviews. These parallels include a list of 50 recommended organization
actions/activities for private sector management to achieve a high level of environmental
performance. The 50 recommendations are reproduced in this NCHRP report in Section
3.3.
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1.0 CHAPTER 1
BACKGROUND
Over the past 20 years, transportation agencies have faced increased expectations for
environmental stewardship and have responded with significantly increased
environmental stewardship. Their stewardship is reflected in environmental excellence
awards; progressive approaches to wetlands, habitat, and wildlife crossings; the NCHRP
Compendium of Environmental Stewardship Practices in Construction and Maintenance;
commitment to Context Sensitive Solutions; and intensive partnering of state DOTs with
resource agencies. While environmental stewardship has increased in all states, some
states have gone farther than others and are on the cutting edge of environmental
initiatives.
Transportation agencies also strive to successfully streamline environmental reviews and
procedures, so they can implement timely transportation improvements that provide
safe, effective, sound transportation for a growing population. Many states have worked
hard to streamline the project development process, including pioneering efforts in
process re-engineering (Florida’s Efficient Transportation Decision Making, Oregon’s
Collaborative Environmental and Transportation Agreement on Streamlining, and North
Carolina’s Ecosystem Enhancement Program), and exemplary programmatic agreements
(PAs), like the Oregon Bridges PA and the Ohio PA for Indiana bats. Unfortunately,
however, the median time for highway project development continues to be long - over
five years for Environmental Impact Statements (EISs).
Environmental stewardship and streamlining both present challenges. The bar seems to
be constantly moving upward, as more and more stewardship is expected by resource
agencies and environmental advocates. Some expectations of environmental advocates
and resource agencies are difficult, if not impossible, for state DOTs to meet, such as
significantly changing land use or reducing vehicle miles traveled (VMT). (While state
DOT decisions influence land use and VMT, other actions and policies have much greater
effect on land use and VMT – local land use decisions, broad economic conditions, and
tax policies.)
Funding environmental stewardship can also be a challenge, because most state DOTs
face a tightly constrained budget and a backlog of transportation needs – a situation
that worsened in 2007-2009 and may be even more problematic in coming years.
The challenges to environmental streamlining are often even steeper. Despite at least
six years of concentrated effort by FHWA and state DOTs, the median time for EISs
remains above five years. The difficulty in achieving streamlining is manifold: over 40
Federal environmental laws, lack of resource agency staff, often-changing environmental
policies and interpretations, litigation, varying court decisions, and more.
To help state DOTs meet these challenges, this NCHRP report summarizes the
organizational and management approaches that are helpful in achieving environmental
stewardship and streamlining.
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2.0 CHAPTER 2
RESEARCH APPROACH
The research for this project was carried out in four stages:
(a) Literature Review: The research team scanned the literature for reports that
identified successful organizational and managerial approaches to environmental
stewardship and streamlining. This included literature within the transportation sector, as
well as literature on business experience in achieving success in environmental stewardship
and environmental process improvement. Because the research team placed the highest
emphasis on interviews of state DOTs, the literature review was not exhaustive, but
concentrated on identifying and reviewing the most relevant and important literature on
organizational and management strategies for environmental success.
(b) Phase 1 Interviews of Six State DOTs: For the first phase of the study, the
research team identified six state DOTs with strong track records in environmental
stewardship and/or environmental streamlining, which represented a range of different
DOTs in terms of size, environmental characteristics, and geographic locales. The
selected states were:
Florida Department of Transportation (FDOT)
Maryland Department of Transportation - State Highway Administration (SHA)
New York State Department of Transportation (NYSDOT)
Oregon Department of Transportation (ODOT)
Tennessee Department of Transportation (TDOT)
Vermont Agency of Transportation (AOT)
These six states were selected in consultation with the Chair and Vice Chair of the
American Association of State Highway and Transportation Officials (AASHTO) Standing
Committee on Environment (SCOE) and the NCHRP Panel for Task 37. The research
team then interviewed representatives of these six state DOTs, including state DOT
Chief Executive Officers (CEOs) and Chief Engineers as well as environmental managers.
(c) Summary of Major Themes from Phase 1 Interviews: The research team
summarized the main themes that emerged from the Phase 1 interviews, obtained
feedback on these themes from the NCHRP Panel, and used the themes as a starting
point for a second round of interviews.
(d) Phase 2 (“beta”) I nterviews of Five State DOTs: After consulting with the
NCHRP Panel, the research team identified and enlisted five additional state DOTs for
interviews. (Three other states recommended for interview in Phase 2 did not respond
to invitations to participate in the project, despite repeated efforts by the NCHRP
research team. This lack of response may be cause for concern, as an indicator of work
overload and lack of time to participate, or lack of interest.) As in Phase 1, the five
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states interviewed in Phase 2 represented a variety of sizes, environmental
characteristics, and geographic locales:
Arkansas State Highway and Transportation Department (AHTD)
Illinois Department of Transportation (IDOT)
Minnesota Department of Transportation (MNDOT)
Montana Department of Transportation (MDOT)
New Mexico Department of Transportation (NMDOT)
The research team provided the Phase 2 states with a summary of 12 main themes
identified in the Phase 1 interviews, and asked for feedback on these themes, based on
these questions:
Do the 12 themes ring true to you? Which of the 12 themes would you place the
highest weight on?
Have you had success or failure in implementing any of these themes?
For each of the themes, do you have additional insights or observations?
Which of these themes do you consider most challenging to implement?
Are there any major themes or points you believe should be added?
Figure 1: The 11 State DOTs Interviewed for NCHRP 25-25 (37)
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3.0 CHAPTER 3
FINDINGS AND APPLICATIONS
3.1 Broad Themes Common to Most or All 11 DOTs I nterviewed
Based on the interviews with 11 state DOTs in Phase 1 and Phase 2, there were
12 broad themes that were emphasized by most or all the DOTs. Below is a table that
identifies the 12 themes:
Table 1: 12 Themes Identified in the 11 State DOT I nterviews
1. Provide Two Levels of Leadership
2. Organize for Environmental Awareness and Accountability Throughout
the DOT and Assure Effective Communications
3. Provide Expert Staffing
4. Build an Environmental Culture
5. Support Improved Land Use
6. Invest in Environment
7. Nurture Relationships with Resource Agencies
8. Invest in GIS
9. Develop Programmatic Agreements
10. Shift from Projects to Ecosystems
11. Be J udicious With Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs)
12. Continually Streamline Environmental Processes
Below is a more detailed description of each of
the 12 themes.
1. Provide Two Levels of Leadership: Two
forms of leadership are essential: (a) CEOs and
other DOT executives, and (b) career
environmental managers.
CEOs, their Deputies, and Chief Engineers need
to provide personal, highly visible leadership on
environmental issues both within their
organizations and with resource agencies.
Although these executives face many pressing demands on their time, they are well
advised to devote significant attention to environmental issues, reflecting by their words
and deeds a commitment to environmental stewardship and streamlining. Forward-
thinking executives recognize that public support for environmental stewardship is rising
and that many environmental issues warrant or require strategic, executive leadership.
“Executive support for
environment is essential – not
through issuing directives, but by
continuously integrating
environment into the way AOT
jobs are done and by keeping
environment in the top tier of
priorities, even in the face of tight
resource constraints.”
-- Rich Tetreault, Vermont Agency
on Transportation, Director of
Program Development, 2007
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DOT executives who are personally engaged in addressing high-profile environmental
issues not only lend their insights and authority, but their participation conveys a
message to all parties, both within the DOT and beyond, about priorities and values.
This then improves the possibility that future issues can be resolved by career
managers, without having to have them “bucked upstairs.”
Engaged executives must be matched by capable leadership of career environmental
managers within a state DOT. These career leaders must reflect the philosophy and
policy direction of agency leaders. Career environmental managers need to be strong
leaders in their own right, with an ability to interact effectively at all levels, including
with their own executives. Career leaders and managers at this level require:
a thorough understanding of environmental procedures and science
excellent communication skills
the ability to build constructive relationships with environmental agencies and
also with other units in their own state DOT, especially field managers.
In the face of CEO changes every few years, career environmental managers provide
needed continuity and day-to-day, year-to-year direction and decision-making.
2. Organize for Environmental Awareness and Accountability and Assure
Effective Communications throughout the DOT: State DOTs need both: (a) a
strong core environmental staff in headquarters, and (b) environmental staff and
responsibilities appropriately dispersed in other parts of the organization. For maximum
effectiveness, environmental responsibilities and environmental staff should reside in
virtually all functions, as well as in the field, in DOT regions and districts. This often
takes the form of environmental liaisons within district/regional construction and
maintenance units. Continuous communications and face-to-face meetings with
environmental liaisons are essential, however, to stay on the same page and maintain a
consistent direction. The decentralized structure of large state DOTs (like New York and
Florida) is a major challenge, requiring greater time and effort in coordinating and
maintaining consistency on environmental policies and procedures. The DOT’s core
environmental staff may need to shift their internal coordination efforts over time, based
on shifting needs and priorities. For example, originally FDOT’s Environmental
Management Office (EMO) focused heavily on coordinating with construction staff in the
FDOT districts, then EMO shifted its attention to linking to the FDOT planning function in
order to create FDOT’s Efficient Transportation and Environmental Decision Making
(ETDM) process, and now is moving back to put more attention on
coordination/communications with FDOT districts.
Placement of environmental units within the state DOT hierarchy is also important. A
decade or more ago, environmental units were often placed on a lower organizational
tier, in engineering units where environmental scientists and experts were often given
relatively little credence. In recent years, many state DOTs have moved environmental
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units up to a higher level within the state DOT, to the first or second tier below the CEO
or chief engineer. Among the states interviewed, New York and Tennessee are
examples of significant elevation of the environmental unit within the state DOT, in both
cases as a result of CEO awareness and commitment to improving environmental
stewardship and streamlining.
3. Provide Expert Staffing: As environmental issues have grown more important
and complex, state DOTs need to make a significant investment in building strong
environmental expertise among their staff. In doing so, state DOTs gain credibility with
resource agencies, which is essential to resolving the wide range of issues regarding
wetlands, water quality, air quality, wildlife, and other issues that can block important
transportation improvements. Over time, a state’s expertise on specific environmental
issues can build trust and lead to break-through agreements. In Vermont, for example,
the AOT’s expertise in historic preservation led to a programmatic agreement in which
the Vermont State Historic Preservation Office (SHPO) essentially has delegated its
responsibilities to the AOT, reducing the time previously spent in coordination and giving
the AOT greater flexibility in meeting responsibilities relating to historic preservation.
The use of expert environmental consultants is widespread and understandable to
address peak workloads and technical specialties. However, each state DOT needs to
maintain core environmental competency and a base of institutional knowledge to direct
in-house work, to relate to resource agencies, to guide and manage outsourced
activities effectively, and to perform quality assurance on those activities.
4. Build an Environmental Culture: To be successful in the 21
st
century, state
DOTs need to have a strong environmental ethic shared throughout the DOT workforce,
from transportation planners, to construction engineers, to maintenance staff. Creating
a pervasive environmental culture doesn’t happen overnight; it takes time to build and it
takes constant communication with the workforce. The more the workforce sees and
hears from DOT CEOs, their Deputies, and Chief Engineers about environmental values,
the better. It may take longer in some states
than in others, depending on the past culture of
the organization. In addition to organizational
structure and communication, environmental
recognition and awards programs can be
extremely helpful in building a strong
environmental ethic. Environmental training
programs are also important, to explain environmental policies and provide employees
with the environmental skills and knowledge to be successful.
A common pitfall is the notion that environmental stewardship and streamlining are
primarily the domain of environmental specialists. However, just as customer-driven
“If we can’t deliver a project that
is environmentally responsible,
we shouldn’t be building it.”
Astrid Glynn, New York State DOT
Commissioner, 2008
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organizations empower all employees to satisfy their customers, so can environmental
values and accountability be engrained among all DOT employees and reflected in their
day-to-day work.
5. Support Improved Land Use: Virtually all the interviewed state DOTs saw land
use as a critical issue for state DOTs. All of the state DOTs had limited or no land use
authority, even those states (like Vermont, Maryland, and Oregon) with strong state-
level land use planning. Despite their lack of authority, however, the state DOTs
recognized they could and should help influence land use in ways that are good for the
environment and good for transportation. For example, several state DOTs are
providing technical assistance to local governments on land use planning. Also, some
states give higher priority to transportation investments that reinforce “good” land use
policy. In Tennessee, TDOT provided State Planning and Research funds to local
planning organizations in central Tennessee to develop a toolkit/cookbook of regional
land use tools, and has adopted a Type II noise policy that rejects requests for installing
noise barriers if development occurred after a highway improvement was made.
Notwithstanding these efforts, several of the states are concerned about a growing
“collision” between land use and transportation, because transportation agencies don’t
have adequate authority to influence land use and prevent land use changes that are
adverse for both environment and transportation. Some of the DOTs cited the need for
state laws to allow assessing land developers for infrastructure costs.
6. I nvest in Environment: Every state is faced with tight budget constraints, forcing
difficult choices to be made. None of the interviewed states saw an “either-or” choice
between funding environmental protection/enhancements and transportation
improvements. Instead, they emphasized that environmental features are essential
elements of transportation projects, just as
safety features are essential in the design of
transportation projects. All of the interviewed
states had a track record of investing in
environmental staff, environmental mitigation,
environmental enhancement, and
environmental process improvement. While
none of the states cited specific figures, and none supported levels of environmental
investment beyond reasonable limits, all believed that these investments were wise, by
responding to public expectations and enabling them to move the transportation
program forward with fewer delays.
7. Nurture Relationships with Resource Agencies: All the interviewed state DOTs
emphasized the importance of building and maintaining effective relationships with
“TDOT won’t trim needed
environmental work, but TDOT
also won’t promise frills.”
Ed Cole, TDOT Environmental
Bureau Chief, 2008
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resource agencies, both on the state and federal levels. They invest in these
relationships in a variety of ways:
Regular meetings at staff level
Periodic executive level meetings
Funding of positions at the resource agencies to facilitate streamlining
Early coordination with resource agencies
Data sharing
Efforts to establish ecosystem/transportation planning
J oint goal-setting
Despite these efforts, results can be slow and mixed.
While some states emphasized their efforts have paid
off with strong, effective relationships, other states
cited ongoing issues, such as a regulatory mindset, a
tendency for issues to be raised late in the
environmental process, having to “prove a negative,”
staff turnover among resource agencies,
inconsistencies among and within resource agencies, and reluctance to invest in early
coordination. None could cite a silver bullet to address these difficulties, other than a
persistent, step-by-step process of establishing relationships and building trust.
8. Invest in GIS: A comprehensive Geographic Information System (GIS) database
was cited repeatedly as an invaluable tool for both environmental stewardship and
streamlining. DOTs in most of the interviewed states invested and continue to invest in
a high quality GIS database and expert GIS staff to make full use of the database. This
earns credibility and respect from resource agencies, facilitates early coordination with
resource agencies, and enables states to do better, more efficient, and more effective
transportation planning and environmental mitigation planning. FDOT located its GIS
database at the University of Florida, which was able to develop the database fully and
is seen by resource agencies as a neutral, highly credible third party repository of
environmental information, including sensitive information that needs to be treated
confidentially.
9. Develop Programmatic Agreements: The interviewed states cited a variety of
Programmatic Agreements (PAs) that have been invaluable in improving the
environmental process, both through improved stewardship and timelier project
development. These successful PAs include:
“Focusing on win-win outcomes
has been the key to success in
working with resource agencies.”
Neil Pedersen, Maryland State
Highway Administrator, 2007
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The aforementioned Vermont AOT’s Memorandum of Agreement with the
Vermont SHPO, which essentially delegates to the AOT the SHPO’s historic
preservation responsibilities for transportation projects
ODOT’s Collaborative Environmental and
Transportation Agreement for
Streamlining (CETAS), which is a pact
among ODOT and 10 of its partners in
state and federal government to
collaborate on environmental and
transportation planning and projects,
using monthly meetings, early
coordination, and four key concurrence points for decision-making
FDOT’s Efficient Transportation and Environmental Decision Making (ETDM)
process, which involves 24 state and federal signatory agencies, heavy emphasis
on early planning-stage coordination, a GIS database, Environmental Technical
Advisory Teams within each of FDOT’s seven districts, and continuous
coordination through planning and project development.
10. Shift from Projects to Ecosystems: All the state DOTs saw the need to move
away from project-by-project environmental planning and mitigation, to ecosystem
planning and mitigation. Vermont and Oregon were particularly emphatic about the
need for this change, because a project-level focus limits environmental options and is
often less effective and more costly than ecosystem planning and mitigation. Tennessee
cited its Stream Mitigation Program and wetland banking as successful ecosystem
approaches, which are beneficial for the environment and more flexible and cost-
effective than project-by-project mitigation. A valuable tool for ecosystem planning and
mitigation is the handbook Eco-Logical: An Ecosystem Approach to Developing
Infrastructure Projects, which was issued by FHWA and seven Federal resource agencies
(Fish and Wildlife Service, Forest Service, Environmental Protection Agency, Bureau of
Land Management, Army Corps of Engineers, National Park Service, and the National
Marine Fisheries Service) in 2006. The challenge is to get resource agency staff and
transportation agency staff to set aside the old regulatory, project-by-project approach
and fully engage in ecosystem planning and mitigation, which requires a substantial
change in mindset as well as additional staff time for early involvement in planning. In
addition, the approach outlined in the Eco-Logical handbook may entail changing state
or Federal laws, by modifying or eliminating narrow, project-focused requirements so as
to maximize ecosystem benefits.
11. Be J udicious with Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs): Most of the state DOTs saw value
in Environmental Management Systems (EMS) and Environmental Performance
Measures (EPMs) and were implementing them to some degree. For the most part,
“Vermont is our hero. The VT
AOT – SHPO agreement is the
model we want to emulate.”
Hal Gard, Oregon DOT Geo-
Environmental Section Manager,
2007
“Be innovative and try new
approaches – because the old,
traditional approaches just aren’t
working. Try to stay ahead of the
regulations, instead of playing
catch-up.”
Matt Garrett, Commissioner of
Oregon DOT, 2007
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these states’ use of EMS and EPMs is a work in progress – only partially implemented --
although most of the states intend to develop them further. One state (Vermont)
attended a workshop on EMS and concluded that EMS would require too much
bureaucratic process and would be of limited value to them, as a small state with a
strong environmental program and no environmental compliance problems. Oregon
understood the concern from Vermont, but felt that the basic EMS steps of “do-check-
act” are valuable, without the necessity of full-blown, elaborate EMS procedures. For
that reason, Oregon is implementing EMS one program or function at a time, starting
with Maintenance, rather than through a full-blown, all-at-once approach. FDOT
characterized its ETDM process as a type of EMS.
12. Continually Streamline Environmental Processes: Environmental
streamlining is a work in progress in all the states, with differing levels of emphasis and
differing levels of success. As one might expect, streamlining is a higher priority in
high-growth states (like Tennessee and Florida)
which have more major capacity expansion
projects than in states with established
transportation systems and relatively few
capacity expansion projects (like Vermont and
New York). Guidelines for states seeking to
streamline project delivery vary based on the
variety of experiences among the six states;
they include:
Start with environmental stewardship.
Stewardship is the sine qua non for streamlining, because without stewardship a
state will not have the credibility and expertise to be successful with
streamlining.
For the most comprehensive streamlining, plan to invest significant time and
effort in mapping your current environmental process in detail.
Build a planning/project development process that emphasizes: (a) early
coordination with resource agencies, and (b) continuous coordination and
communications through project development and permitting. Consider
incorporating explicit concurrence points at key junctures.
Emphasize accountability and timeliness for both environmental and
transportation staff.
For individual projects, assign a multi-functional team with responsibility and
accountability for advancing the project from cradle to grave, together with a
project manager to continually integrate across all the functional silos.
Thoroughly document all procedures and decisions (always important, but
especially so when there is staff turnover within the DOT or at resource
agencies).
“When we created ETDM, we laid
out our previous environmental
process in a 36-foot-long road
map that we taped to the walls.
It was very enlightening for us
and for the resource agencies.”
Buddy Cunill, Environmental
Program Development
Administrator, Florida DOT, 2007
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Fund positions at key environmental agencies – positions which report to the
environmental agencies and focus full-time on transportation. It is valuable for
these positions to work with state DOTs at three different levels: (a) advancing
individual projects; (b) coordination and screening at the planning/systems level;
and (c) improving the overall environmental process. Establish performance
expectations or measures for these positions; assure that the individuals who fill
these positions have a thorough understanding of transportation procedures and
missions; maintain constant contact and communications with those individuals,
and have at least annual performance reviews by the state DOT to evaluate
performance and ensure that all the components of this effort stay on track.
Develop a project prioritization process that relies on quantification, includes
environment as a weighting factor, takes input from regional/local planning
commissions, and strikes a balance among competing needs.
For potentially controversial projects, engage the attention of senior executives
in the DOT and resource agencies, and arrange for joint briefings to interested
elected officials and the news media.
Utilize sound project management principles and Environmental Management
Systems to track schedules, ensure commitments are documented and delivered,
and measure performance in meeting critical milestones.
Utilize the statutory time frames and procedures in the Safe, Accountable,
Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU),
in a constructive, problem-solving manner – not as a cudgel over environmental
agencies.
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3.2 Additional Specific Advice from One or More State DOTs
Other themes emerged from the initial interviews that were not quite as widespread, but
which are particularly germane to the research and potentially applicable to other state
DOTs. These additional themes are:
If you have dispersed environmental functions throughout your organization,
create an Environmental Council to coordinate, share information, create
synergy, and foster widespread ownership. (Maryland)
Try to understand the perspective of the resource agencies, their missions and
values, and the resource constraints they face. (Oregon, New York, and
Tennessee)
In building relationships with resource agencies, be diligent and expect it to take
time. In Vermont, it took 6-7 years to earn the trust of resource agencies.
(Vermont)
Participate in peer exchanges with other states to learn new ideas, good ideas,
things to avoid, and to obtain multiple insights. (Tennessee)
Focus on “a lot of little things” where a state DOT can improve the environment,
such as roadside tree planting, composting dead animals, improving culverts,
diesel retrofits for the DOT vehicle fleet, and incorporating bike lanes when a
bridge is rehabbed. (New York)
Over communicate and overeducate – never underestimate the need for
constantly reiterating and reinforcing environmental values, policies and
procedures. (Oregon)
Practice multimodalism – multimodal programs and investments are good for the
environment and earn respect and credibility with resource agencies and the
public. (Maryland, Tennessee, and New York)
Bring in an independent facilitator when you are headed towards (or have
reached) an impasse with resource agencies or communities. (Maryland)
For Global Climate Change (GCC), create a cross-cutting DOT staff team to build
awareness of climate change, develop ownership of the issue, create excitement
among staff, and identify a wide range of potential GCC activities. (New York)
When taking the DOT environmental commitment to a higher level, use highly
visible projects as an opportunity to send a dramatic message of change and
make the change visible to everyone. (Tennessee)
Incorporate and emphasize Context Sensitive Solutions (or Context Sensitive and
Sustainable Solutions, as in Oregon) as a core business practice. Seehttp://www.contextsensitivesolutions.org/. (Vermont, Oregon, Minnesota,
Tennessee, New York, and Maryland)
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Update and upgrade the state Environmental Procedures Manual. Tennessee
has done so, and posted it on the TDOT website, as a useful reference for other
states as well as for TDOT and resource agency staff. (Tennessee)
Give permission to DOT staff to practice environmental stewardship (i.e., go
beyond engineering requirements to incorporate features that benefit the
environment) and constantly reward/legitimize innovative environmental
stewardship. (New York)
Consider establishing a Stream Mitigation Program to provide in lieu fees for
stream mitigation, to be paid to a nonprofit organization, instead of relying on
more costly/less effective project by project mitigation of stream impacts.
(Tennessee)
Shine a spotlight on environmental successes – make them visible within the
DOT, to resource agencies, and to the public. (New York)
Consider these “12 Factors for Success” from ODOT:
1. Secure leadership support for making big changes.
2. Ensure that the right people are in place to make changes.
3. Involve, understand, and support key stakeholders and help them
meet their missions (collaborate).
4. Don’t give in to “That’s nice but it won’t work here.”
5. Understand laws and regulations AND their flexibility.
6. Remove your internal roadblocks to streamlining.
7. Build on your and others’ past successes.
8. Plan for and facilitate conflict/dispute resolution. Have a
structure/process in place for dealing with conflicts.
9. Don’t let the perfect be the enemy of the good.
10. Monitor, evaluate and improve (beta tests, end user reviews).
11. Train and educate.
12. Anticipate and prepare for personnel turnover.
3.3 Relationship of the Literature Review to the 12 Themes
From the outset, the research for this project relied predominantly on interviews of state
DOTS, with a literature review that played a smaller, supporting role. The “References”
section at the end of this report cites and describes 27 reports that contain findings,
recommendations, and tools that could help state DOT efforts advance environmental
stewardship and streamlining. Some of these documents are specific to the surface
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transportation sector, while others are based on research and analysis of environmental
stewardship in the private sector and other arenas.
Among the documents reviewed, one stood out as having particularly valuable and
relevant information: “Promoting Environmental Sensitivity: Business Organization and
Operations -- Volume 1: Private Sector Companies.” (1) This report was prepared by
The Townsend Consulting Group, of Denver Colorado, for the Federal Highway
Administration in the early 1990s. However, the report was apparently never published
and was only available from the personal files of FHWA staff. It is not accessible on the
internet.
Although “Promoting Environmental Sensitivity” is at least 15 years old, certain sections
are particularly insightful, so key information is summarized and reproduced here, with
some additional commentary from the research team for this NCHRP project (NCHRP 25-
25, Task 37).
“… environmental sensitivity is not incompatible with the successful
accomplishment of a company’s mission. I ncorporation of
environmental sensitivity into the day-to-day operations of a company
may in fact contribute to the company’s financial well-being and long –
term survival.” (1)
In the years since the above statement was written, environmental sensitivity has grown
in importance. In the 21
st
century, environmental performance is essential to an
organization’s success, not only to comply with legal requirements but to meet public
and customer expectations. Environmental performance is as relevant to the success of
public sector agencies, such as state DOTs, as it is to the private sector. Environmental
credibility and performance affect the public’s willingness to support funding referenda
for transportation, as well as legislative appropriation of funds for transportation
agencies. Further, environmental credibility and performance affect the ability of
government agencies to attract and retain a high quality workforce, and to advance
needed transportation improvements through the planning and environmental review
process.
“I ncorporating environmental sensitivity into a company’s operations is
an evolutionary process that requires a corporate-wide effort at all levels
of the organization to build environmental awareness into the corporate
culture, and make such considerations standard operating procedure.”
(1)
The above point emerges clearly from the NCHRP interviews of 11 state DOTs, as they
emphasized that environmental leadership is needed at multiple levels. And
environmental performance cannot be assigned to a single unit within a state DOT; it
must be integrated into and embraced by the entire organization, from planning to
design to construction, operations, and maintenance.
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“Companies that are proactive will keep on top of the environmental
wave and will be among the more profitable in an economy increasingly
influenced by environmental regulation and consumer activism. Rather
than being attacked by critics for being environmentally destructive,
some companies are now looked to as the instiller of environmental
values. Instead of the antagonistic relationship that had existed,
industry, government, and consumers have joined hands in finding ways
to improve.” (1)
The above point is echoed in the state DOT interviews, by DOT executives and
environmental managers who have worked steadfastly not only to protect the
environment, but also to find ways to enhance the environment through their projects
and their planning. Minnesota DOT emphasized how their years of environmental
commitment and close working relationships with state and Federal resource agencies
paid high dividends when, after the collapse of the I-35W bridge in Minneapolis,
environmental agencies came forward to expedite the environmental clearances and
permits necessary to replace the bridge span. The above point is also echoed in the
experience of the VT AOT, whose expertise and commitment to historic preservation led
to a groundbreaking Programmatic Agreement in which the VT State Historic
Preservation Officer (SHPO) entrusts to VT AOT the SHPO’s responsibilities.
“Companies should provide systematic training related to their core
environmental values. Training programs need to be increased and
enhanced in areas where skills are needed to carry out the
environmental mission of the company. .. Similarly, material should be
incorporated related to the core values in all or most supervisory and
management training programs as managers and supervisors must set
the example where values are concerned. Training involves more than
classroom or group activities. Executives should take every opportunity
to coach employees on a one-on-one basis, sharing core values with new
people, and reaffirming them with long time employees.” (1)
This point too was emphasized in the state DOT interviews, in several ways: Many of
the DOTs emphasized the importance of qualified, well-trained staff, not only in the DOT
environmental unit, but in other parts of the organization. Also, AHTD emphasized the
role that their long-time Commissioner, Dan Flowers, has played by continually
communicating and demonstrating his support for environmental policies and his
willingness to provide needed funding for environmental protection and enhancement
efforts.
“Promoting Environmental Sensitivity” (1) synthesized its findings in the following
summary of 50 business and organizational actions/activities that management can
implement to improve their organization’s environmental success:
1. Take a proactive role in driving the environmental ethic into the organization,
operations, and culture.
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2. Conduct a comprehensive review of operations and environmental efforts to
understand the business and financial advantages of proactively addressing
environmental concerns.
3. Establish the environment as part of the vision, mission, and core values of the
organization.
4. Actively communicate vision, mission, and values statements to all employees.
5. Continually reinforce environmental awareness with employees so the
environment becomes part of the organization’s culture.
6. Ensure that management’s actions and decisions are consistent with the overall
environmental vision and goals set forth.
7. Conduct an environmental audit of all current operations to provide a baseline of
the current status of the environmental and environmental concerns in the
company. The audit serves as a benchmark for environmental planning
purposes.
8. Develop environmental policies backed up by detailed, comprehensive strategies
and action plans for implementation.
9. Develop policy statements which inform all employees of the company’s
commitment to act responsibly, incorporate environmental considerations into
business, and hold each employee accountable for his actions.
10. Integrate environmental initiatives into corporate long term planning processes
and business strategy.
11. Strive for a stretch goal mentality in which environmental goals are developed
that exceed the requirements of environmental laws and regulation.
12. Develop goals that allow for clear measurement criteria to be applied across all
phases of the operation.
13. Continually revise and update environmental goals and initiatives as actions are
completed and new opportunities are identified.
14. Formulate action plans with specific timetables for implementation and designees
from operating departments responsible for these actions.
15. Utilize Management by Objectives (MBO) processes to drive environmental goals
to the lowest levels of the organization. Establish accountability and ownership
for compliance to environmental regulations and company expectations to the
lowest levels of the organization.
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16. Develop planning and decision-making processes which include environmental
considerations.
17. Establish processes for design projects that make use of organized approaches,
including project summaries, design for efficiency models, or life cycle
assessment.
18. Include environmental considerations early in a project development cycle and as
an integral part of the project approval process.
19. Generate company specific Environmental Protection guidelines that define the
performance requirements to be achieved in design, construction, operation, and
maintenance of facilities.
20. Establish processes such as Total Quality Management (TQM) that emphasize
continuous environmental improvements.
21. Actively keep environmental policy and environmental values in front of
employees through programs, reporting, checklists, charts, and meetings.
22. Establish programs to drive environmental awareness into daily operations such
as recognition of performance, promoting employee/customer awareness, and
measurement and tracking performance.
23. Develop relationships with supplies and vendors who demonstrate the ability and
willingness to support the company’s environmental initiatives.
24. Include environmental considerations in the vendor selection process.
25. Establish an internal environmental audit process that periodically reviews and
documents environmental regulation compliance of operation groups in the
company. Publish audit results to all levels of management above the level
being investigated. Make use of external, independent firms for environmental
audits to add value to the management process and add credibility to the
company’s environmental reporting.
26. Establish senior level, internal task groups that regularly review compliance and
regulatory citations of operating groups.
27. Establish working relationships with external environmental groups and
organizations which can serve as a cutting edge resource for information,
provide support in driving environmental behaviors, and provide assistance in
environmental goal setting and strategic planning processes.
28. Recognize that institutionalization of environmental sensitivity may necessitate a
cultural change in the company.
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29. Give the same level of importance to the environment that is given to the
traditional concerns of health and safety.
30. Create corporate environmental positions that are an officer level position
reporting directly to the highest level of management.
31. Organize environmental positions in a matrix reporting relationship.
32. Create on-site field environmental positions to provide expertise and knowledge
to local operations while monitoring compliance to environmental regulations.
33. Establish a “future oriented” issues function or group to serve as a resource on
environmental information and to serve as a technical resource to anticipate and
develop contingencies for anticipated environmental issues.
34. Make environmental organizations very flat to promote quick decision making.
35. Establish self directed work teams with responsibility for solving and resolving all
types of environmental concerns at a team level.
36. Send a consistent message to employees that if you don’t accept environmental
compliance as a top priority, you can risk losing your job.
37. Incorporate changes into hiring and selection processes to make sure candidates
fit in with the environmental culture of the organization.
38. Consider hiring managers who are from nontraditional discipline ranks who offer
a different environmental perspective to the company.
39. Establish environmental positions as part of the management development plan
for advancement to higher level positions in the organization.
40. Institute performance appraisals and performance based compensation at all
levels of the organization which include environmental goals.
41. Establish mechanisms for reporting of company-wide environmental
performance.
42. Establish a hierarchical system that captures environmental data and measures
performance form the lowest operating levels consolidating to the total company.
The reports should receive wide distribution and should be regularly reviewed by
senior management.
43. Develop a process in which environmental incident reporting is a developmental,
educational opportunity as opposed to a cause for punitive action.
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44. Establish employee awards that recognize individual and team achievements for
environmental actions internal and external to the company. Winners should be
recognized at awards ceremonies attended by company senior executive and in
company publications.
45. Put in place aggressive communication programs that target employees, business
partners, media, students, and the general public to create awareness of the
company’s vision and mission and environmental policies.
46. Utilize a variety of media for employee communications programs, including
meetings, videotape, posters, brochures, checklists, charts, and awards.
Companies have to take a proactive approach in dealing with communities and
the media.
47. Speak directly to employees through on-site visits and meetings to communicate
the importance of their environmental actions.
48. Integrate environmental training with job training so the environment becomes
part of the procedures of a job.
49. Print job specific environmental requirements on work orders.
50. Integrate environmental training as part of new employee orientation programs.
Although this is a long list, it is valuable as it synthesizes insights gained in the private
sector. Moreover, virtually all of the above recommendations also emerged from the
interviews of the 11 state DOTs for this NCHRP report, directly or indirectly.
In addition to “Promoting Environmental Sensitivity,” there were two dozen other
reports with helpful information, which appear in the References section. For each of
the 12 themes identified during the state DOT interviews, the table below cites
references relevant to each theme, as well as describes how the literature review
compares or contrasts to the interview results.
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Table 2: Comparison of 12 Themes to Literature Review
Provide Two
Levels of
Leadership
The literature strongly supports the need for top management
support; however, it does not mention the importance of
leadership by career environmental managers, as emerged from
the interviews of state DOTs. Amekudzi and Meyer (2) list top
management support as the #1 institutional strategy to implement
change. “Promoting Environmental Sensitivity” (1) also lists senior
management commitment as its first consideration. Executive
leadership was also noted as a key element in coordination with
resource agencies, as FDOT was able to improve coordination with
resource agencies following an “executive summit” (3).
Organize for
Environmental
Awareness and
Accountability
throughout the
DOT and Assure
Effective
Communications
throughout the
DOT
While much of the literature mentions the value of communication,
and specifically communication from the executive leadership (2, 4,
5, 6, and 7), the state DOT interviews provided specifics relevant
to the unique needs of the DOT. Don Emerson’s work on Linking
Planning and NEPA (3) provides recommendations that would
support that specific goal. Steve Lockwood’s analysis of factors
affecting future state DOTs institutionally provides a broader
organizational context (8).
Provide Expert
Staffing
Per the experience with the Oregon bridge streamlining efforts (5),
training and education are important for streamlining, as well as
stewardship. “Environmental Streamlining that involves innovative
approaches to project delivery such as outcome-based
(performance) standards may be vague and confusing to agency
staff.” NCHRP report 25-24 (9) mentions having adequate numbers
of environmental staff as an important factor in environmental
streamlining, but this report’s finding also points to the quality of
the staff. This is similar to Richard Florida’s finding (7) where he
looks at manufacturing plants which have successfully
implemented environmentally conscious manufacturing (ECM)
practices. He finds that “organizational resources – particularly
specialized environmental resources – provide the embedded
capacity to…implement environmental innovations.”
Build an
Environmental
Culture
Dechant and Altman (10), in the paper about general best
practices not specifically focused on transportation, found that best
practices include “A mission statement and corporate values that
promote environmental advocacy”. This report’s finding goes
beyond stated mission and value statements to encompass the
difficult task of changing an organization’s culture to encompass
environmental values.
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Support
I mproved Land
Use
NCHRP 25-25-04 (11) identifies land use as a key component of
sustainable design. NCHRP Report 582 (12) provides specific
guidance and strategies for rural communities to link
transportation and land use effectively.
I nvest in
Environment
Amekudzi and Meyer (2) recognize that resources are critical to
ensuring that environmental stewardship, and lack of sufficient
resources is the most important obstacle cited by DOT and MPO
officials to achieving successful stewardship. The literature points
to resources as an issue in both stewardship and streamlining (9),
(5), respectively. Gaines and Lurie (5) note that this is a good
investment: “Senior management must be committed to proactive
environmental goals recognizing that short-term costs will probably
be outweighed by long-term benefits.”
Nurture
Relationships
with Resource
Agencies
A review of FHWA Environmental Excellence Awards reveals that a
primary driver of environmental excellence is successful
interagency cooperation (13). AASHTO’s “Accelerating Project
Delivery” (14) notes that the chasm in missions, culture and work
practices between transportation and resource agencies has been
a significant source of delay. Since inadequate staffing in resource
agencies was noted as a problem, the Transportation Equity Act
for the 21
st
Century (TEA-21) has allowed transportation agencies
to fund positions at resource agencies. This has provided some
relief but comes at a cost to the transportation agencies. As of
2005, more than 68% of DOTs funded positions in external
support agencies for environmental review purposes; one third are
in federal agencies and two thirds are at state resource agencies
(15).
Invest in GIS In 2007, FWHA held a Peer Exchange on GIS as a tool to link
planning and the environment (16). GIS was identified as an
important tool to share data that facilitates better coordination
with resource agencies. NCHRP published “Management Guide for
Implementation of Geographic Information Systems (GIS) in State
DOTs” in 1993 (17).
Develop
Programmatic
Agreements
The state DOT interviews emphasized that programmatic
agreements have been a major contributor to streamlining the
environmental process. Excellent examples of programmatic
agreements can be found in FHWA’s “Successes in Stewardship”
newsletters (18), Gaines and Lurie’s description of the Oregon
State Bridge Delivery Program (5), and AASHTO’s “Programmatic
Agreements Library” (19). In addition, AASHTO provides a
detailed, step-by-step guide to programmatic agreements (19).
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Shift from
Projects to
Ecosystems
Schilling and Schultz (20) provide an unprecedented approach to
environmental management which involves organizing agencies by
ecosystem rather than traditional agency divisions. “Eco-Logical”
(21), an FHWA publication developed in collaboration with a
number of other federal agencies, provides a more practical
approach to ecosystem-level approach to project development. It
outlines eight steps for integrated planning and effective
mitigation. The report states that “No agency acting on its own can
effectively implement an ecosystem approach to infrastructure
development.” Resource and other agencies are critical to planning
in this integrated way.
Be J udicious
with
Environmental
Management
Systems (EMS)
and
Environmental
Performance
Measures
(EPMs)
The literature (22 and 23) describes the benefits of an EMS and
provides instructions for implementation. However, the DOTs
interviewed for this report have found that they prefer to
implement these concepts selectively.
Similarly, the literature strongly supports environmental
performance measures (4, 6, 11, and 12) but in practice, agencies
are selective in applying these tools.
Continually
Streamline
Environmental
Processes
Since much of the literature on streamlining is based on case
studies of successful streamlining efforts (9, 14, 24, and 25), the
focus is on the process and benefits of streamlining efforts.
However, the state DOT interviews emphasized that streamlining
efforts should be ongoing, consistent with the philosophy of
continuous improvement. Also, reports on effective NEPA
documentation (26 and 27) provide important advice relevant to
streamlining, since solid NEPA documents are critical to
environmental streamlining. AASHTO’s Center for Environmental
Excellence provides 17 valuable case studies on environmental
streamlining, athttp://environment.transportation.org/environmental_issues/proj_d
elivery_stream/case_studies.aspx (14) Also, FHWA has
catalogued environmental streamlining practices, by state, athttp://www.environment.fhwa.dot.gov/strmlng/es3stateprac.asp
(25)
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3.4 I ndividual Summaries of the First Phase of State DOT I nterviews
(FL, MD, NY, OR, TN, VT)
Below is a summary of each individual interview with the first six states – the Phase I
interviews.
3.4.1 I nterview with Florida DOT (FDOT)
December 18, 2007
PARTI CIPANTS – Florida Department of Transportation (FDOT)
Kevin Thibault, Assistant Secretary for Engineering and Operations
Carolyn Ismart, Manager, Environmental Management Office (EMO)
Buddy Cunill, Environmental Program Development Administrator, EMO
Robert Crim II, State Environmental Programs Engineer, EMO
PARTICIPANTS – PB
Cindy Burbank
CONTEXT
Florida faces both (a) significant growth and development and (b) high expectations for
environmental stewardship. FDOT must deliver a transportation program that responds
to growth and development, while maintaining high environmental standards.
FDOT is a large organization, with an $8 billion annual program and 7,450 employees, of
which 1,000 are in FDOT headquarters (HQ). FDOT is highly decentralized, with eight
districts (one of which is the Florida Turnpike Enterprise.)
There are 19 environmental staff in HQ and 10-12 environmental staff in each of the
districts. Also, Construction has hired environmental staff, and the FDOT legal staff has
dedicated environmental expertise. Through the Efficient Transportation Decision
Making Process (ETDM), FDOT has entered into operating agreements with 19 federal
and state resource agencies, and agreed to fund up to 36 environmental liaison
positions within those agencies FDOT expects to see a significant number of
environmental staff retirements in the next five years. Approximately 80% of
environmental work is outsourced to consultants.
BEST PRACTICES FOR ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
Leadership: FDOT has been fortunate to have consistency and continuity from FDOT
leadership in implementing environmental stewardship and streamlining. Environmental
process improvements take years to implement and to get results. This requires
continuous support and leadership from the executive level.
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Documentation: FDOT believes it is essential to thoroughly document process
improvements, decisions, and agreements reached both internally and with resource
agencies. Documentation is important for continuity and consistency. Documentation is
especially valuable when there is staff turnover at resource agencies or within FDOT.
Without good documentation, the state DOT is are vulnerable to whims and varied
interpretations.
Partnerships: FDOT sees partnerships as essential to effective environmental
stewardship and streamlining, and has strong partnerships with the Florida Department
of Environmental Protection, FHWA Division, and Federal resource agencies. “Trust with
resource agencies is huge.” Also valuable has been FHWA support -- “FHWA has always
wanted FDOT to succeed environmentally.” Good relationships are especially important
at the District level. One of the biggest challenges in maintaining good partnerships and
trust is staff turnover, within the resource agencies and within FDOT, so relationships
require constant reinforcement – and partnership arrangements and expectations need
to be documented (as noted above).
Efficient Transportation Decision Making (ETDM): In mid-1999, with help from
FHWA, FDOT leadership initiated a major re-engineering of the environmental process,
with the goal of producing good transportation projects in an efficient manner, while
simultaneously achieving both enhanced environmental stewardship and a more efficient
environmental process. It took several years to hammer out the details of the process.
This included mapping the then-existing process in a 36-foot long environmental process
map – a map which was enlightening for everyone in its complexity and detail. In 2004,
FDOT started screening projects through ETDM; for the first year, ETDM was optional.
ETDM is working well, enabling FDOT to keep moving forward with transportation
improvements that meet environmental goals. Features of ETDM include two major
screening points (at which input is obtained from resource agencies much earlier than
they have traditionally been involved); Environmental Technical Advisory Teams (ETATs)
within each District, which meet at least once/year; and a statewide meeting of all
participating resource agencies every few years. Transitioning a new process like ETDM
into practice was a challenge, especially for projects already in the pipeline and
especially in a decentralized organization like FDOT. So far, ETDM impact on project
delivery time is still being evaluated. Nationally, ETDM is viewed as a groundbreaking
model, and FDOT continues to be visited by other states seeking to learn from FDOT’s
experience in developing and implementing ETDM.
Geographic Information Systems (GIS): GIS data are critically important to ETDM
– one of the most important ingredients in successful environmental stewardship and
streamlining. With the help of other agencies, FDOT created a large GIS database of
environmental information at the University of Florida, including a GIS Helpdesk. FHWA
provided the seed money for this initially (about $200K); now, because of its value, the
FDOT Executive Board makes about $4.5 million/year available for ETDM, including
resource agency support and support for technology development for the Environmental
Screening Tool (EST). By creating the GIS database at the University of Florida, FDOT
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was able to facilitate the collection of a variety of environmental and land use data from
other state and local sources in a database outside of the FDOT, and available to all
appropriate governmental and private entities. It took a lot of time and effort to create
the database, but now both FDOT and resource agencies have ready access to the data
for transportation planning and project development purposes. This has significantly
improved the environmental review process. as well as enhancing the long range
transportation planning process. To maximize the use of the GIS database, FDOT
provides training sessions for FDOT and resource agency staff (which is especially
important due to the constant staff turnover).
Organizational Linkages within FDOT: FDOT environmental managers recognize
the need to overcome organizational stovepipes and develop/maintain strong linkages to
all FDOT functions and all FDOT districts. But it isn’t possible to focus on all the
organizational bases at once, so sometimes the pendulum has to swing. Two examples:
(a) In the past 7-8 years FDOT has focused on emphasizing linkages between the
Environmental process (via ETDM) and Planning functions, and the need for
earlier resource agency involvement. This has been positive, but it has also
meant that while FDOT environmental staff has focused on establishing ETDM as
a process there has been a decreased emphasis on linkages with other parts of
FDOT. Now that ETDM has been established, environmental staff is refocusing
on (a) project development and other down-line production phases such as
Design and Construction, and also (b) integrating input gained through the ETDM
process into those functions. There have also been recent policy initiatives to
reestablish Quality Assurance/Quality Control as a program.
(b) At times in the past FDOT HQ environmental staff has been more “hands on”,
with a closer day-to-day working relationship with FDOT districts; but the need
to devote significant resources to developing ETDM, necessitated pulling back
somewhat from regular involvement in the hands-on work activities with the
districts. Now that ETDM is in place and working well, the FDOT environmental
staff is focusing on reestablishing closer working relationships with each district
in all environmental areas.
Environmental Management Systems (EMS) and Environmental Performance
Measures (EPM): FDOT sees its ETDM, QA/QC, environmental commitment tracking,
and performance measures program as combining to serve as an EMS. Also, FDOT is
bringing an environmental performance management system on line in 2008, in which
all FDOT districts will input data. (Some environmental data are already automated in
this system via the EST.)
Staff Training and Development: It is important to invest time and effort in staff
training – both FDOT staff as well as resource agency staff. FDOT wants to invest more
in developing and delivering good training, especially training to clarify roles,
responsibilities, and expectations.
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CHALLENGES TO ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
FDOT Decentralization: FDOT decentralization poses challenges in achieving
continuity in environmental stewardship and streamlining It requires a huge amount of
ongoing, two-way communications. The nature of the environmental process allows
little room for disconnects in carrying out environmental requirements. There was some
concern among the Districts when ETDM started, especially for big projects already in
the pipeline, which had to be brought into the ETDM process. To foster continuity, in
addition to regular e-mail communication, phone calls and on going training, FDOT HQ
environmental staff meets twice a year with district environmental staff, including
permitting staff, on ETDM and NEPA.
Project by Project Mitigation: Project level mitigation is of limited value compared
to the possibilities with big, regional mitigation. FDOT is moving to large-scale
mitigation and would like to have more funding to invest in it. An example is the Platte
Branch mitigation area, which focuses on species protection.
Time: Change takes time – time to implement change and time to see results.
Although ETDM has been in place for several years, FDOT has not yet seen an overall
reduction in environmental document processing time (there have been successes in this
area in some districts). FDOT believes time savings may not show up in the
environmental phase, but may occur downstream. If real reductions in time don’t occur,
there may be pressure to try something else. Also, if there are long time lapses
between planning and construction, the risk rises that revenue changes will require
rethinking the project. To avoid constant recycling, it is important to go quickly from
environmental screening into project development and implementation.
I ssues With Resource Agencies: Late Hits, Out-of-J urisdiction Comments,
Narrow Focus, Left Hand/ Right Hand Disconnects: FDOT cited four challenges
they face in working with resource agencies:
“Late hits” are a huge challenge – when new issues are raised late in the
process, or someone wants to revisit a decision reached earlier.
FDOT has noticed an increase in agencies commenting on matters outside their
jurisdiction, and is considering convening a meeting to discuss this.
Narrow focus is sometimes a problem. Most resource agencies, and particularly
Florida’s water management districts, have not traditionally worked early within
the NEPA process providing “input”. Their outlook has been more regulatory in
nature. This poses challenges for them and there is still reluctance on the part of
some to “get outside the box” and proactively work up front, in the NEPA
process, with FDOT and other resource agencies.
Although the ETDM process has specific procedures for coordination, sometimes
the resource agencies don’t do the internal coordination within their agencies
that they are supposed to. The left hand doesn’t always know what the right
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hand is doing. This has caused problems similar to those noted in the first
bullet.
FDOT acknowledged that they experience some of these same problems within their
own organization.
Global Climate Change (GCC): FDOT recognizes the importance of GCC and is trying
to figure out what they need to do. The Governor established a GCC task force, which is
starting to focus on transportation. FDOT’s Policy Planning Office has been the most
involved. FDOT believes that GCC will strengthen the need for better ties between land
use and transportation, to mitigate VMT increases.
3.4.2 Interview with Maryland State Highway Administration (SHA)
December 13, 2007
PARTI CIPANTS – Maryland SHA
Neil Pedersen, State Highway Administrator
PARTICIPANTS – PB
Hal Kassoff
CONTEXT
The Maryland DOT (MDOT) is perhaps the most multimodal of state Departments of
Transportation, with ownership and operating responsibilities for highways, transit,
aviation, and ports. The largest of the modal administrations is the SHA with over 3,000
employees and a capital program in excess of $1 billion.
Chesapeake Bay preservation goals, air quality issues, and smart growth are reflections
of Maryland’s strong commitment to the environment. SHA has the largest and
strongest environmental capability of any transportation organization in the state and
not surprisingly has been a national leader in environmental stewardship and Context
Sensitive Solutions (CSS).
Unlike most DOTs, environmental functions are intentionally dispersed throughout the
agency - not geographically but functionally. For example - environmental assessment
for project development is in a project planning office, permitting and mitigation design
is in an environmental programs office, compliance with hazardous materials storage
and removal on state highway facilities (including buildings and maintenance shops) is
led by the maintenance and operations people. Responsibility for water related issues
ranging from erosion and sediment control and storm water management to wetlands
and water quality are dispersed in over a dozen different organizational elements.
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SHA’s philosophy is to infuse an environmental ethic throughout the organization by
placing functions in offices that can best take responsibility for actions that can avoid or
minimize harm, mitigate harmful effects, or provide environmental enhancements. This
approach is seen as more effective than concentrating environmental responsibilities in a
single office, which may be neither close to an environmental issue or problem nor in
the best position to do address it. Therefore, the Project Planning Division, which has
the lead responsibility for project development is responsible for conceptual engineering
and environmental analyses and documentation required to satisfy both the National
Environmental Policy Act and the Maryland Environmental Policy Act. On the other hand
the Environmental Programs Division (EPD) is responsible for the preparation of plans,
for wetland mitigation and stream restoration projects, including all related permitting
and compliance with environmental regulations as well as ensuring that all natural,
cultural and social-economic commitments made during the planning phase are met
during final design of all SHA capital projects.
SHA leadership also takes a pragmatic view of organizational issues in terms of where
the technical and leadership talent may be, and is prepared to make changes so that
organization charts enhance and leverage rather than constrain available human
resources. In a geographically compact state such as Maryland specialty areas such as
structures and environmental functions are centralized in the Baltimore headquarters
office. However recent challenges have arisen in terms of complying with federal and
state requirements for dealing with hazardous material storage and handling and other
activities in maintenance shops. SHA is leading efforts on behalf of the entire MDOT on
this issue, and the desire to reinforce the agency’s environmental ethic have led to
consideration of environmental liaison staff in District offices.
BEST PRACTICES FOR ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
Leadership from the Top: The natural focus of transportation agencies is
transportation – it takes a clear message from the top (from the CEO as well as other
senior managers) for transportation agencies to embrace broader objectives such as
environmental stewardship
Dispersed Organizational Approach: Strengths lie in a more widespread infusion of
environmental responsibilities, and buy-in from those with the ability to implement
positive results and solutions to problems. This kind of dispersed approach creates the
need for a strong coordination role to ensure a reasonable level of consistency as well as
to avoid gaps or overlapping responsibilities. At SHA this coordinating function is
provided by an Environmental Council comprised of representatives of offices with
significant environmental functions. They meet monthly to coordinate and quarterly
with the Administrator and Deputy Administrators to ensure a well integrated approach
notwithstanding the dispersion in responsibilities.
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Embracing the Transformation from Mitigation to Stewardship: The key to
environmental stewardship is acceptance of the idea that mitigation is a minimum
requirement and stewardship requires more -- such as enhancement.
Performance Measurement: Environment has been one of SHA’s six key
performance areas for some time, with good results. But there is some concern about
the number of measures and resources required to gather data. Examples of
performance measures in the storm water management area include:
Number of NPDES Phase I and Phase II J urisdictions for which SHA has Valid
MS 4 Permits
Number of SWM Facilities I nventoried and Inspected
Number of Outfalls Reported with Illicit Discharges Annually
Percentage of NPDES Permits in Compliance
Percentage of non-compliance findings addressed
Environmental Management System: SHA has a formal environmental
management system for tracking compliance with hazardous materials storage and
disposal actions. This has worked well but EMS has not yet expanded beyond that area.
Relationships with Environmental Resource Agencies and the US DOT: SHA’s
relationship with environmental resource agencies and with FHWA is generally very
good. Focusing on ‘win-win’ outcomes has been the key to success. Building trust (a
long, slow process) requires walking in the other person’s shoes. Commitment by
agency leadership to make it happen and then serving as role models has been
essential. Providing funding to resource agencies for staffing that would otherwise not
have been possible has been a key.
Utilizing an I ndependent Facilitator: The use of an independent facilitator has
been invaluable when transportation and resource agency staff cannot otherwise resolve
issues on major projects. Gaining acceptance from these agencies in this approach
required a high degree of trust.
Green Highways: Embracing the principles and practices of the “Green Highways”
movement clearly manifests environmental stewardship. This requires a more holistic
view of benefiting the environment through transportation actions, recognizing that
environmental effects cross jurisdictional boundaries. A good example is SHA’s
movement toward watershed-based mitigation looking at actions involving public and
private sectors as well as government agencies at all levels. (Note: Maryland is one of
the strongest participants in the FHWA/EPA sponsored Green Highways Partnership,
currently focused in the Mid-Atlantic States.
CHALLENGES TO ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
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Staff Turnover Within Environmental Resource Agencies: Turnover at the staff
level of resource agencies has been particularly challenging often putting relationships
back at ground zero in terms of the need to build trust. Staff members who are more
accustomed to adversarial relationships are a particular concern.
Commitment Tracking: SHA’s EMS does not yet include a system for tracking
environmental commitments, to ensure they are carried over into construction,
operations, and maintenance. There have been past problems with ensuring that all
commitments by all SHA representatives – planners to designers, headquarters to field
staff, all commitments regardless of size are being tracked and fulfilled. SHA has
implemented an environmental commitment tracking system, but it is separate from a
formal EMS.
Organizational Challenges: While the dispersed approach has been generally
successful, a limitation lies in the time and attention required for coordination. Although
Maryland is a relatively small state with many responsibilities centralized, there is a need
for greater “field presence” when it comes to environmental issues. SHA’s goal is to
establish environmental presence in the districts, primarily to handle hazardous
materials storage and disposal issues as well as other maintenance facility issues at the
outset, but with broadened responsibility as well to ensure appropriate environmental
presence in all project phases, including construction and maintenance.
There is a constant need to remind headquarters staff of their role to focus on policy,
training and oversight functions while ensuring that field personnel focus on
implementation in areas that lie within their responsibility and not take independent
policy level actions which may be outside the realm of headquarters’ guidance. There is
a need to strengthen ability to implement environmental awareness and stewardship in
construction and maintenance
Climate Change and Energy Conservation: SHA needs to build the capability to
address energy conservation and other climate change issues such as carbon footprint -
- particularly in terms of how the agency is managed. At the moment there is little or
no information on how much energy is used or used needlessly in some very major
areas - - for example, electric power use, unnecessary engine idling, and the like.
Role in Influencing Land Use: Tools for dealing with land use are limited even with
Smart Growth legislation. A Smart Growth sub-cabinet coordinates state actions,
generally limited to restricting financial support for infrastructure (roads, utilities, etc.) if
Smart Growth policies are not adhered to. But beyond state funding issues, local
jurisdictions retain their powers. If the State DOT is expected to address Vehicle Miles
Traveled (VMT) reduction then they must have a greater ability to influence land use
decisions.
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3.4.3 I nterview with New York State DOT (NYSDOT)
J anuary 3, 2008
PARTI CIPANTS – New York State Department of Transportation (FDOT)
Astrid Glynn, Commissioner
Stan Gee, Executive Deputy Commissioner
Mary Ivey, Director, Office of Environmental Analysis
Bob Dennison, Chief Engineer (follow-up interview on J anuary 30)
Mark Silo, Delivery Division (follow-up interview on J anuary 30)
Dan D’Angelo, Office of Design (follow-up interview on J anuary 30)
PARTI CIPANTS – PB
Cindy Burbank
Amy Zwas
CONTEXT
NYSDOT is a large, decentralized organization with 10,000 employees, 11 regions, and
an annual program of $1.8 billion in 2008.
There are 32 environmental professionals on the staff in NYSDOT headquarters. Within
each region, there is a staff of 5-15 people, including an environmental
liaison/coordinator within (a) Maintenance and (b) Construction.
75% or more of NYSDOT’s program is for rehabilitating and preserving existing
infrastructure. There are relatively few capacity expansions, other than modifications to
ramps or interchanges to improve safety or eliminate bottlenecks.
BEST PRACTICES FOR ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
Leadership: At NYSDOT, environmental success hinges heavily on two forms of
leadership, both of which are crucial:
Strong, continuing career leadership, like NYSDOT’s current Office of
Environment Bureau director – someone who can keep a steady hand through
changing times, and
Strong commitment for environment from the executive level (Commissioner and
Deputy).
NYSDOT Environmental Ethic/ Culture: Starting 5-7 years ago, NYSDOT
emphasized building a strong environmental ethic within the agency, something to last
for the long haul, part of the organizational foundation. This includes having dedicated
professionals who will “do the right thing” on a continuous basis over the years.
Commissioner Glynn summed up NYSDOT’s environmental ethic by stating, “If we can’t
deliver a project that is environmentally responsible, we shouldn’t be building it.”
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“A Lot of Little Things”: NYSDOT ‘s environmental ethic recognizes that there are a
lot of areas NYSDOT touches in which it can make an environmental contribution, e.g.,
composting dead animals found along roadsides,
diesel retrofits for NYSDOT’s vehicle fleet,
improving culverts,
roadside tree planting,
fish ladders; and
incorporating bike lanes whenever a bridge is rehabbed.
NYSDOT has captured its commitment to the wide range of environmental efforts like
these in a video, “Better than Before.”
Organization: To further emphasize environment, NYSDOT elevated the
environmental function by creating a new Office of Environment, which has higher
placement in the organization than its previous organizational form as a Bureau. Also,
the new Office will be strengthened by adding a Landscape Architecture Bureau.
(Several years ago, NYSDOT’s Landscape Architecture Bureau was dissolved, with the
staff re-assigned to Design at that time.) Further, NYSDOT takes pains to ensure that
environment is integrated into everyone’s responsibility, throughout all the NYSDOT
functions and throughout the regions, so that environment is not seen as the isolated
function of a single HQ office. There are environmental liaisons in all the regions, in
Maintenance and in Construction, with ties to the HQ Office of Environment. However,
it is easy for liaisons in the field to feel isolated and to become cast in a role of bearer of
bad news. A partial solution has been the formation of “Knowledge Teams” among the
regional environmental liaisons, formed around specific needs (e.g., asbestos issues).
In this way, they are less isolated and they can pool their expertise to provide the best
advice and assistance across multiple NYSDOT regions.
Relationships with Resource Agencies: NYSDOT starts by recognizing/accepting
that resource agencies have a regulatory mission, and that NYSDOT needs to be in
compliance with environmental requirements. (To understand resource agencies, it is
important to mentally switch to their perspective.) The NYSDOT administration has put
a lot of emphasis on good agency-to-agency coordination. Three examples:
NYSDOT formed a working group with 2 Army Corps of Engineers (ACOE)
districts and FHWA to synchronize NEPA, the 404 permitting process, and the
NYSDOT Project Development Manual. The ACOE headquarters has committed
to making this work.
“INTERACT” is a partnership to work on culvert issues with ACOE, NY
Department of Environmental Conservation (DEC), NY Parks and Recreation, and
NYSDOT’s Design, Structures, and Environmental units. This is in response to a
newly instituted ACOE requirement that will have a huge impact on NYSDOT.
Fortunately, the partners are working together, sharing perspectives, and coming
to agreements.
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NYSDOT has executive-level meetings with the NY Department of Environmental
Conservation on a regular, monthly basis.
In building relationships with resource agencies, NYSDOT has also found it valuable to
be creative with mitigation opportunities, especially by building mitigation partnerships
with local stakeholders and resource agencies.
Despite NYSDOT’s strong environmental stewardship over the past 5-7 years, NYSDOT
engineers feel there is a lack of recognition for their progress and trust on the part of
some resource agencies, which has impeded environmental streamlining efforts.
Relationships vary among staff and offices within the NY DEC and with Federal resource
agencies. It has been challenging to move resource agencies away from a regulatory
mindset, to a collaborative relationship.
At the time of the interview, NYSDOT was not funding positions within resource
agencies (as other states are), because of a major mis-step with a funded position at
the State Historic Preservation Office about 15 years ago. In that case, there were no
performance measures established for the position and NYSDOT’s needs were not being
served. So NYSDOT and OPRHP mutually agreed to terminate the arrangement, but it
took over a year and it left a lot of bad feelings. Funding positions with the U.S. Army
Corps of Engineer (ACOE) district offices in NY may be considered if NYSDOT and ACOE
are successful with a new partnering agreement then being negotiated.
Geographic Information Systems (GIS): NYSDOT considers GIS very important to
being successful with both environmental streamlining and stewardship. NYSDOT has
invested in an excellent GIS database, for which it gets high marks from others, and has
also invested in having GIS coordinators in each of its regions. NYSDOT is always
willing to share its GIS data with partners, and regulatory agencies do find the data
useful and draw on it. Looking to the future, NYSDOT is working on a better managed
GPS program to gather data for GIS. NYSDOT has lots of GPS equipment, but needs
better processes for inputting and using data consistently.
Environmental Streamlining: NYSDOT hopes that the Section 6002 streamlining
process in SAFETEA-LU will be valuable in advancing a couple of projects in New York.
This is important because (a) many NYSDOT projects involve both FHWA and FTA,
which is an added layer of complexity; and (b) if issues are discovered late in the
environmental process, the resulting delay causes cost increases which can be
substantial, which may force the project to be reprogrammed in a later year, which can
cause further cost increases, in a vicious cycle. So NYSDOT hopes the Section 6002
process will lead to more predictable schedules – but is less optimistic about Section
6002 leading to faster project delivery.
Global Climate Change (GCC): NYSDOT sees GCC as a major challenge and already
analyzes carbon emissions in environmental documents (which puts NYSDOT in front of
other states). In addition, NYSDOT has formed a Climate Change/Energy Efficiency
Team, drawing on a cross-section of the agency, to develop ideas for reducing
greenhouse gas emissions and energy consumption. This has created a lot of energy
among the staff within NYSDOT. The team is looking at a wide variety of measures –
policy changes in support of telework, the need for adapting the transportation
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infrastructure to withstand climate change (as underscored by three major storms that
led to flooding in the New York City subway system), etc. It has high level executive
support from Commissioner Glynn and Executive Deputy Commissioner Gee. The
emphasis is on cross-agency collaboration to generate a wide variety of good initiatives.
Environmental Management Systems (EMS) and Environmental Performance
Measures (EPM): NYSDOT definitely supports performance measures, but doesn’t
really have an EMS and EPMs in place yet. There are some environmental performance
measures, but NYSDOT hasn’t really focused on using them to manage the program. An
IT project is underway to enable NYSDOT to put an environmental tracking system in
place and connect EPMs to strategic goals.
Ecosystem Management: NYSDOT believes that shifting from project-by-project
mitigation to ecosystem management will lead to environmental improvements as well
as better transportation projects. One tool for moving in this direction is encouraging
resource agencies to manage mitigation properties, by taking the handoff from NYSDOT.
Land Use: The Governor issued an Executive Order on Smart Growth, and NYSDOT is
looking at how they can support good land use. Because NY is a “home rule” state,
NYSDOT has to defer to local governments on land use, so NYSDOT is looking at
providing technical assistance to local governments and also making good land use
policies a factor in the competition for state transportation funding. NYSDOT sees good
land use planning by local governments as the first step, with supportive transportation
investments as the second step. NYSDOT is radically enlarging its Planning and Policy
Division staff focusing on land use – from 1 to 15 people – and has someone in each
NYSDOT region working on land use. Another part of NYSDOT’s response to land use
concerns is to give a lot of emphasis to maintaining the existing system.
Strategic View: Commissioner Glynn emphasized that it is important to take a
strategic view of environment and transportation, because new issues arise constantly,
roles shift among Federal vs. state. vs. local governments, etc.. Taking a strategic view
provides the flexibility to adapt and respond to new issues.
CHALLENGES TO ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
Decentralized Organization: Decentralization should be a source of strength, due to
the importance of environmental protection at the local level, where it is real and
tangible, not just a concept. But a decentralized organization comes with many
challenges:
There is much unevenness across regions.
Some regions “read” their environmental partners better than others.
Some regional staff is reluctant to bring in NYSDOT headquarters as issues arise
in developing EISs.
It is easy for a HQ office to overestimate the regions understanding of
environmental issues and policies.
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To strengthen environmental capabilities and performance in the regions, NYSDOT has
an environmental staff of 5-15 people in each region, including an environmental liaison
in the Construction function and an environmental liaison in the Maintenance function.
These liaisons can play a critical role in spotting potential problems early, so NYSDOT
HQ can assist and advise. However, over time, there has been a tendency of these
liaisons to lose touch with their regional Environmental/Landscape Architecture Units
and with the Headquarters Environmental Office, so NYSDOT is taking steps to
strengthen that linkage (e.g., through more frequent participation of liaisons in
environmental meetings with the Environmental Office).
In addition, NYSDOT has formed a “Delivery Division” to improve coordination with and
across the NYSDOT regions, and to provide a network to talk through problems. Finally,
the Adirondacks Park Agency (APA) has had a unifying effect on three of NYSDOT’s
Regions, because all of the Adirondack Park lies within portions of these Regions and
they work closely with APA to meet the special environmental needs of the Adirondacks.
The Department has appointed an Adirondack Park/Catskill Park Coordinator to facilitate
these efforts.
Resource Agencies: Although NYSDOT has made a strong commitment to
environment and is carrying it out in many different ways, there are still issues in
working with resource agencies. For example, problems arise when a transportation
improvement is needed but the available science is insufficient to establish an
environmental standard (as occurred in an issue over bridge height impacts on
migratory birds) or when an agency appears to be on board with a project, only to raise
issues late in the process. Or a resource agency staffer retires and NYSDOT has to
spend time catching that individual up so the project can move forward. The resulting
delays have real consequences when inflation is 10% a year and the budget is very
tight. It can become a vicious cycle as you have to reprogram, delay other projects, etc.
NYSDOT, ACOE and FHWA efforts to synchronize processes and the implementation of
SAFETEA-LU 6002 for major projects should help with these issues.
Funding Silos: Different funding streams stand in the way of integrating the
environmental mission of NYSDOT and the environmental regulatory agencies. There
are a lot of funding silos to overcome.
Staffing: When NYSDOT needs new environmental skills, it faces many hurdles in the
civil service process. It can take a lot of time to vault over those hurdles, to hire staff
with the kinds of skills that are needed. On the other hand, when success occurs in
recruiting the needed skills, the results help diversify the range of professional skills in
the workforce, which makes it stronger. This is an issue that cuts across the entire
NYSDOT organization.
Environmental Competency: High-end competency in the environmental process is
critically needed at state DOTs, but there are relatively few who have the experience
base to see how it all comes together. NYSDOT sees this as an issue for consultants as
well as for NYSDOT staff.
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Publicizing Success: Commissioner Glynn observed that NYSDOT should probably do
more to publicize its environmental achievements to resource agencies, as this could
improve trust and working relationships.
3.4.4 I nterview with Oregon DOT (ODOT)
December 13, 2007
PARTI CIPANTS – Oregon Department of Transportation (ODOT)
Matthew Garrett, Director
Hal Gard, Geo-Environmental Section Manager
Frannie Brindle, Natural Resources Unit Manager, Geo-Environmental Section
Bill Ryan, Program Support Manager, Geo-Environmental Section
J im Norman, Environmental Planning Unit Manager, Geo-Environmental Section
PARTICIPANTS – PB
Cindy Burbank
Hal Kassoff
CONTEXT
Oregon is a very environmentally oriented state overall, with strong public support for
environment and smart growth policies.
ODOT has about 4,600 employees in total, with about 70 environmental staff.
In 2004, ODOT reorganized, shifting to increased reliance on outsourcing and increased
delegation of work and staff to the five ODOT regions. Under this structure, there are
about 20 environmental staff in HQ. Each of the five ODOT regions has a technical
center for environment, with about 10 environmental professionals in each technical
center. Each region has a leadership team that is linked to ODOT HQ. Environmental
staffing is robust in the functions of Project Development and in Operations &
Maintenance. Within the Planning function, environment doesn’t get as much emphasis,
but ODOT is working towards a stronger environmental emphasis in Planning.
ODOT relies on Project Development Teams (PDT) to develop and advance projects.
Senior environmental staff are key members of the PDT. These environmental project
managers participate in shaping Purpose and Need and Alternatives, vet the project with
resource agencies, oversee the preparation of environmental documents (which is done
by consultants), and stay with the project, cradle to grave. (The latter was instituted in
2007.)
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ODOT has an environmental policy statement. They view stewardship (sustainability) as
key to streamlining. They won’t let streamlining “lower the bar.”
BEST PRACTICES FOR ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
Twelve Factors for Success: Prior to the interview, Hal Gard provided the following
list of 12 factors for success, all of which were amplified during the interview:
Secure leadership support for making big changes.
Ensure that the right people are in place to make changes.
Involve, understand, and support key stakeholders and help them meet their
missions (collaborate).
Don’t give in to “That’s nice but it won’t work here.”
Understand laws and regulations AND their flexibility.
Remove your internal roadblocks to streamlining.
Build on your and others’ past successes.
Plan for and facilitate conflict/dispute resolution. Have a structure/process in
place for dealing with conflicts.
Don’t let the perfect be the enemy of the good.
Monitor, evaluate and improve (beta tests, end user reviews).
Train and educate.
Anticipate and prepare for personnel turnover.
Innovation: ODOT Commissioner Matt Garrett emphasized that traditional approaches
just aren’t working, and that all the easy fixes have either been implemented or were
taken off the table a long time ago. Now, it is necessary to be innovative and try new
things in order to succeed with environmental stewardship and streamlining. To get
new ideas, ODOT looks regularly to AASHTO and to other DOTs for specific good
examples to learn and apply in Oregon. ODOT also looks for regional trends, especially
in the adjacent states of Washington and California, seeking good ideas and
opportunities that can be applied in Oregon.
Relationships with Resource Agencies: ODOT understands and values the missions
of their resource agency partners. ODOT has invested in resource agency relationships
and it has been a good investment. Every partnering effort has exceeded expectations.
ODOT’s message to resource agencies is that environment is embedded throughout
ODOT’s mission and work.
Programmatic Approaches -- CETAS (Collaborative Environmental
Transportation Agreement for Streamlining): Programmatic Agreements (PA)
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have led to tremendous efficiencies. The Collaborative Environmental Transportation
Agreement for Streamlining (CETAS) was chartered in 2002 and has been instrumental
in ODOT’s approach to environmental stewardship and streamlining. ODOT owns it, and
resource agencies are integral players – Environmental Protection Agency, ACOE, Fish
and Wildlife Service, National Marine Fisheries Service, Oregon Department of
Environmental Quality, Oregon SHPO, FHWA, and the state land agency. Under CETAS,
the participants meet monthly at the technical level, to work on: (a) project triage and
(b) overall process streamlining. There is a Project Agreement Reporting and
Implementation Team which reviews all projects. CETAS also provides for quarterly
meetings at the management level, conducted individually with resource agencies, as
well as development of an Annual Work Plan through joint efforts.
Staff Training: Once you have developed new approaches, it is absolutely essential to
do face-to-face classroom training. You have to do it every year, repeatedly, not just a
one-time shot. Keep sharing what you are doing and get everyone on board, and
reinforce it constantly. “Over-outreach and over-educate.”
Liaison Positions: ODOT funds 17 liaison positions across state and Federal resource
agencies. These positions are critical to success. The individuals in these 17 positions
sit in resource agencies and help those agencies understand ODOT’s mission and
procedures. They focus on both (a) avoiding and resolving project-level problems and
(b) developing new/improved procedures.
Mapping Environmental Resources: ODOT is putting a lot of energy into upgrading
its environmental spatial information and integrating the use of that information into the
way ODOT does business. The ODOT GIS group provides three staff to this effort. An
approach was pioneered under ODOT’s statewide bridge program in which
environmental resources were identified and assessed before design started, so design
can place as much weight on environmental data as on engineering data. The mapped
data are saved in a GIS database for future use on other projects. Full integration
hasn’t yet been achieved, but is a work in progress.
“Context Sensitive and Sustainable Solutions” (CSSS): ODOT fully supports CSS
– and takes it one step further by emphasizing sustainable CSS. Context Sensitive and
Sustainable Solutions (CSSS) is an agency-wide approach, with a systems focus (as
opposed to the project focus of CSS in many other states). CSSS focuses on five goals:
(a) economic development; (b) community involvement; (c) sustainability; (d) mobility;
and (e) environment. Within ODOT, CSSS has had the most traction in the Bridge
Program and also in Region 4. There has, however, been some pushback, e.g., when
the FHWA Division questioned spending federal funds on non-regulated features such as
protection for bats, a non-ESA species.
Environmental Management Systems: ODOT believes EMS is valuable, especially
the “do – check – act” steps of EMS. Procedures for measuring, checking in, learning
from mistakes, and feeding that knowledge back into improved approaches are valuable.
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However, ODOT is not focused on detailed–level, ISO-type EMS. Currently, ODOT has
an EMS in place for Maintenance, which provides detailed guidelines for storing,
handling, and disposing of materials used at maintenance yards. (For more information,
seehttp://egov.oregon.gov/ODOT/HWY/OOM/EMS.shtml.) ODOT also has benchmarks
for specific Programmatic Agreements and the Fish Passage program, but EMS is not yet
in place for other functions. ODOT is advancing EMS stepwise, a program or piece at a
time, rather than trying to do it all at once.
CHALLENGES TO ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
The Current Process: ODOT is very frustrated with the current environmental
process, which emphasizes process over outcomes, is full of “Mother, may I?” controls,
and focuses too much at the individual project level. This is frustrating and stifling. It is
not helpful to environment or transportation. They cited recent changes at the FHWA
Division, which has challenged long established agreements, programs, and processes.
ODOT is committed to moving to a focus on good outcomes, ecosystem-level planning,
and increased delegation of authority to ODOT. “Conserve energy on process, invest
energy in outcomes.” ODOT admires and would like to emulate the Vermont AOT
agreement under which the SHPO entrusts its historic preservation responsibilities to the
Vermont AOT. The ODOT Bridges Program is a very successful example of moving to a
programmatic level, with a single set of terms and conditions negotiated ahead of time
with all the resource agencies.
Staff Turnover: ODOT has experienced a large amount of staff turnover in recent
years. In addition, there is turnover among the resource agency staff. As a result,
there has been some loss of shared vision. New staff doesn’t readily embrace the
processes that were jointly developed to meet the needs of environmental stewardship
and streamlining. “A new kid on the block can be very disruptive.” This requires more
frequent check-ins with staff, constant outreach among staff, and well-documented
formal agreements. ODOT may need to mentor new staff more. All too often, when a
new person comes on board, ODOT has to re-hash agreements and decisions reached
previously. There have been multiple cases of disconnect, and the weakest link has
been in middle management. When new people join the DOT, it is important to lead
them to “own” the environmental processes and commitments you have developed. It
is important for them to see environment as not only the right thing to do but also good
business for the agency. Expect and plan for staff turnover, and plan on the efforts
necessary to train new staff in your environmental procedures and goals.
ODOT Staff and Organizational Culture: ODOT is a conservative organization, with
a long oral history and embedded culture. Some staff haven’t caught up to ODOT’s
environmental commitment. ODOT managers have to work with this and inculcate
environmental values, especially among the maintenance staff. In the end,
environmental success comes down to individuals. Environmental champions are
needed.
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Environmental Commitment Tracking: This is an on-going challenge within ODOT.
Within the agency, there are five different approaches in five different ODOT districts.
FHWA did a statewide scan on environmental commitment tracking. ODOT Region 3
has one of the best commitment tracking systems.
Global Climate Change: This is a “terrifying” issue; it will require major efforts by
everyone, including DOTs; and it is coming at us fast. It has major policy implications
and investment impacts. (An example played out on Highway 101, where heavy storms
forced road closures and caused heavy erosion.) ODOT doesn’t have the staff or the
expertise to respond to GCC. There is currently only 1 air quality specialist within
ODOT, and that person is not a GCC expert. On the other hand, Oregon Department of
Environmental Quality has staffed up with 30 personnel focusing on GCC. GCC is
fraught with tough political issues, and some of the debate has already begun within the
Oregon Transportation Commission.
Land Use and VMT: ODOT supports the state’s strong approach to land use and
smart growth, with a goal of getting people to live close to where they work and
worship. However, Oregon is facing “a collision between land use and transportation.”
Even in Oregon, the DOT has little authority over land use, which is vested in local
governments. Oregon’s approach to land use has “leapfrogged” over transportation
issues. What are the implications of local land use decisions for Oregon’s multi-billion
highway asset? If new development has no direct access to a state highway, who will
ensure appropriate mitigation? The state needs to be able to secure appropriate
reimbursement from developers for costs. ODOT’s charge is to protect the multi-billion
highway asset and also protect quality of life. To do that, ODOT needs mechanisms for
value capture, maybe a statewide system development charge to help pay for the
system and needed improvements to serve development.
3.4.5 I nterview with Tennessee Department of Transportation (TDOT)
J anuary 4, 2008
PARTICIPANTS – TENNESSEE DEPARTMENT OF TRANSPORTATION (TDOT)
Gerald Nicely, Commissioner
Ed Cole, Environment and Planning Bureau Chief
Doug Delaney, Assistant Chief of Environmental Bureau
PARTICIPANTS – PB
Cindy Burbank
Nancy Skinner
CONTEXT
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TDOT is a medium-size DOT, with 4,700 employees, 4 regions, and an annual program
of over $700 million in 2007.
At TDOT, Environment is a centralized function, managed from HQ, even though other
TDOT functions (Maintenance, Construction, and Design) are decentralized to the 4
regions.
TDOT’s environmental staff numbers approximately 100, most of whom are located in
TDOT headquarters in Nashville.
TDOT underwent a major change in 2003, when a new Governor and new TDOT
administration took office and began to transform TDOT into an organization that placed
high emphasis on environment and planning.
BEST PRACTICES FOR ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
Status of Environment within TDOT: Historically, the Environment and Planning
functions within TDOT had low stature and significant morale problems. In 2002-03,
TDOT put environment on equal status with other TDOT functions, by elevating
Environment from a subordinate function under Engineering to equal status in a new
Bureau of Environment and Planning. When the new Bureau was created, a new
manager was brought in (Ed Cole) to strengthen TDOT’s environmental processes and
performance and raise morale. TDOT management emphasized that everyone is on the
same team, and that the environmental staff are there to help and avoid problems. To
help convey that message, Commissioner Nicely traveled to TDOT facilities throughout
the state, including maintenance garages, to speak to TDOT staff. TDOT is committed to
making and keeping Environment as a priority, raising its prominence within the agency,
mainstreaming the environmental process, and holding Environment to the same
standards as other areas of the organization.
Highly Visible Policy Shift: At the time the new Bureau was created, it had to deal
with a very contentious project (E-40 South). The Bureau worked through issues in a
very visible way, renegotiating terms, dramatically changing environmental mitigation,
and working closely with environmental agencies. This change sent a big, highly visible
signal of change within and outside TDOT.
Project Management System: TDOT had a “pretty good” project management
system, but has mounted a major effort to strengthen it and increase accountability.
Key features of the new system:
Expands and elevates the TDOT Project Management Office.
Assigns one project manager to be accountable for overseeing the scope,
schedule, and budget of a project, from inception to completion.
Increases number of project managers from 20-25 now to about 40 in the future
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Relies on “Project Accountability Teams,” with cradle-to-grave staffing that cuts
across Bureau lines
Covers all projects above a certain size (probably 50-60 projects)
Establishes a schedule for each project, with “red flag reports” for those that fall
behind
Emphasizes staying on schedule, but also allows for schedule adjustments as
projects progress.
Reports to Commissioner Nicely
In designing the environmental phase of the Project Management System, TDOT did a
lot of research on how to improve the environmental process and eliminate delays.
They participated in a peer exchange with other states to understand different
approaches (the other states included Florida, North Carolina, Ohio, Washington, Texas,
and Kentucky). TDOT was particularly interested in Florida’s Efficient Transportation
Decision Making (ETDM) process, and visited Florida to understand how ETDM works.
TDOT’s approach emphasizes accountability in the environmental process – for both
sides (transportation and environment).
Tennessee Environmental Procedures Manual (TEPM): In 2007, after five years
of work, TDOT issued TEPM. TEPM embodies a major overhaul of TDOT’s
environmental philosophy and procedures, and provides a handy reference for
navigating the NEPA process, implementing the SAFETEA-LU environmental review
requirements, and standardizing technical analysis and documentation. TDOT believes
TEPM, now available on the TDOT website, will be useful to other states looking to
update older manuals or create new manuals to meet the requirements of SAFETEA-LU.
Relationships with Resource Agencies: TDOT has historically had good working
relationships with the various federal and state environmental resource agencies. In
recent years, a greater effort has been placed on improving the coordination and
communication process to ensure the agencies understand the purpose and need for
particular projects and are involved from the very beginning stages of a project. It has
been important to educate the agencies about TDOTs recent changes to improve the
environmental process. It has also been important to help the agencies understand that
as TDOT changes its process, they need to change their process as well. The new
Governor made it clear he expects the agencies to work together, and TDOT has worked
hard to improve relations. TDOT provides half the funding for eight new positions in the
Tennessee Department of Environmental Conservation (TN DEC). Several years ago,
TDOT funded three positions at TN DEC, but their role wasn’t at the right point in the
process (they were too far downstream) so they weren’t that effective. Having
strengthened relations with state resource agencies, TDOT is now working on building
better relations with Federal resource agencies through new agreements.
Geographic Information Systems (GIS): TDOT sees GIS as key to an accountable,
timely environmental process and is building a GIS database and procedures over
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several years. Meanwhile, TDOT has put interim GIS tools in place and will expand on
them. TDOT studied FDOT’s GIS closely and learned a great deal from Florida about
how to build and use GIS.
Context Sensitive Solutions (CSS): CSS is a very important policy and process
within TDOT. It is especially important as a tool to foster discussion with local
governments about land use and smart growth.
Mitigation Programs: There is one wetlands bank in Tennessee, which TDOT has
used successfully for mitigating wetland impacts. In addition, TDOT has created a
Stream Mitigation Program (SMP) to provide in lieu fees of $200/linear foot for stream
mitigation, to be paid to a nonprofit organization which administers the revenue for
stream protection and restoration. This has been very successful. (However, TN DEC’s
new antidegradation rule is driving more on-site mitigation within relatively narrowly
drawn Hydrologic Unit Codes, which is causing conflict with the SMP.)
Long Range, Multimodal Planning: For future success, TDOT is committed to
implementing the goals of the Department’s Long range Multimodal Transportation Plan
to ensure there is a truly multi-modal approach to addressing transportation needs
throughout the state.
Environmental Management System: TDOT is developing an environmental
management system, in concert with the Tennessee Environmental Streamlining
Agreement.
Leading Change with Experience Rather than Ideas: In Tennessee, the best way
to lead change in a positive direction is through direct, on the ground experience, rather
than trying to communicate ideas. For example, when commuter rail was instituted in a
small town east of Nashville, there was a positive response to putting new retail shops
near the train station – which will lead to more transit-oriented development (TOD)
through the positive experience, not through promulgating TOD as a concept.
Reward System: TDOT believes a reward system is important, to recognize and
reinforce positive environmental contributions – especially from within the engineering
culture. It can be as simple as an awards program. Constantly legitimizing desired
behavior is important.
Peer Exchanges: TDOT has found peer exchanges with other state DOTs to be
extremely valuable, and recommends them to other states. Peer exchanges are an
excellent example of effective adult learning. They provide a low-stress atmosphere,
with highly credible sources of advice and information. TDOT has learned a great deal
from peer exchanges with other states, and now is in a position to share its successes
through peer exchanges with other states.
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CHALLENGES TO ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
Land Use: Land use is a major issue in Tennessee. Some TDOT staff has tended to
respond by saying “We don’t do land use. We do transportation.” But TDOT executives
and environmental managers recognize that highways impact land use. “Highways are
either impacting or chasing land use.” TDOT has made progress in forging an
understanding with Metropolitan Planning Organizations (MPOs) and Rural Planning
Organizations (RPOs) that TDOT will work with and support local communities on land
use issues. (For example, TDOT provided SPR funds to Middle Tennessee to develop a
toolkit/cookbook of regional land use tools. Another example occurred in the planning
process for a new road south of Nashville; during the CSS process, the Citizen Resource
Team recognized potential land use changes that could result from the new road, so
land use recommendations were put forth to be considered by the community.) One of
TN DOT’s seven guiding principles is to take account of local goals, including land use
goals, and being a positive factor in communities. In recent public meetings across the
state on I-40/81, much of the discussion focused on the need for driving less, and how
TDOT can deal with land use so as to reduce driving. TDOT recognizes that land use is
heavily influenced by decisions on location of housing and schools (over which TDOT
has little influence), but TDOT can help people understand the transportation
consequences of different land use decisions, and vice versa. Also, TDOT is instituting a
new Type II noise wall program – if development occurs after the roads are built, TDOT
will not pay for noise walls. Instead, TDOT encourages local governments to adopt
noise-compatible land use policies to avoid this problem.
Funding Resources: As in most states, Tennessee faces a resource challenge – how
to stretch a constrained budget to meet all the needs. TDOT refuses to make it an
“either-or” choice between environment and transportation. It is essential to have both
good transportation and a high quality environment. On the one hand, TDOT won’t trim
needed environmental work, but TDOT also won’t promise frills. Projects have to focus
more on the most critical needs.
Global Climate Change (GCC): TDOT recognizes GCC as a major issue, and feels a
need to focus more heavily on GCC. However, there is not a lot of awareness of GCC
among the public in Tennessee, and there is no state policy on GCC. TDOT believes it
has a responsibility to help change this, through educating the public and stimulating
discussions about GCC and how it relates to transportation. This will fit well with
TDOT’s efforts to shift from being project focused to focusing on big, systemic policy
issues. TDOT has moved out on one GCC initiative – “Green Islands” -- by establishing
a policy that anyone driving on TN’s Interstate system should always be within 100 miles
of E-85 or biodiesel fueling. TDOT is using Congestion Mitigation and Air Quality
(CMAQ) funds to help implement this within nonattainment areas, by helping retailers
install or replace tanks and creating a logo program to alert travelers to E-85 and
biodiesel fueling stations. TDOT will be seeking support of other DOTs to expand this
program throughout the Southeast.
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3.4.6 I nterview with Vermont Agency of Transportation (AOT)
December 5, 2007
PARTI CIPANTS – Vermont Agency of Transportation (AOT)
Rich Tetreault, Director of Program Development Division (comparable to Chief
Engineer)
Mel Adams, Director of Policy and Planning Division
Gina Campoli, Environmental Policy Manager
J ohn Narowski, Environmental Services Engineer
Bill Ahearn, Materials and Research Engineer
J ames McCarthy, Engineering Services Engineer
PARTICIPANTS – PB
Cindy Burbank
Amy Zwas
Alan Lubliner
CONTEXT
Vermont is a very environmentally-oriented state overall, a culture which carries over to
the AOT staff.
Vermont is not adding transportation capacity; rather, most projects are reconstruction
with more subtle environmental challenges.
Vermont is a small state and AOT is small – about 1,300 employees – making
communication and coordination easier than in large states.
AOT’s main priority is to keep the transportation system functioning, in face of tight
funding.
AOT has nine districts, with small staffs in each. Districts carry out projects.
In the past 15 years, AOT has been cited for only 1 environmental violation.
BEST PRACTICES FOR ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
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Executive Commitment: Executive commitment to environment is key – not in the
form of issuing directives, but by continuously integrating environment into the way AOT
jobs are done and by keeping environment in the top tier of priorities, even in the face
of tight resource constraints. Executives have to show they give environment as much
weight as structures, have to show parity of environment with other functions, especially
in the face of tight budgets.
Example: About 15 years ago, an AOT executive “stepped up” AOT’s environmental
commitment significantly -- brought in environmental expertise, revised policies, and
built trust with resource agencies.
Staff Expertise and Capacity: Strong environmental staff expertise is key to gaining
trust of resource agencies and meeting environmental challenges. AOT started building
up environmental staff capability about 15 years ago, and has continued to build it up
since then. Three years ago, AOT added an environmental position in Construction, to
ensure that field environmental work is done right; second and third positions have been
added for this purpose. AOT’s capabilities in historic preservation became so strong
that the SHPO essentially delegated its role to the AOT, relying totally on AOT to fulfill
historic preservation requirements for transportation. (Note: In subsequent PB
interview, Oregon DOT cited Vermont AOT as their “hero,” for AOT’s historic
preservation model).
Relationships with Resource Agencies: Earning the trust of resource agencies is
essential. If you have their trust, you can be more creative, have more options, and
move decisions along more efficiently, with better results. Essential ingredients for
trusting relationships with resource agencies are:
Strong environmental staff expertise: to the point that AOT can legitimately
question resource agencies on their turf, and suggest alternatives. In one case
(SHPO), AOT expertise has been so successful that the SHPO has essentially
delegated its responsibility to AOT. SHPO realized that AOT could be counted on
to carry out historic preservation responsibilities and that if the SHPO relied on
AOT, it would free up SHPO resources to devote to other areas needing
attention.
Regular meetings with resource agencies: Regular meetings with resource
agencies are extremely valuable. Two different kinds of meetings are needed –
one at technical level and one at management level, both occurring regularly. 15
years ago, ACOE initiated every-other-month meetings with AOT and with state
and Federal resource agencies, focusing on ACOE process and requirements.
AOT uses the meetings to present concept level projects and get feedback,
which is very helpful. Participation of resource agencies ebbs and flows.
Participation by Vermont Agency on Natural Resources (ANR) is spotty. AOT has
considered alternative forums, but this serves the purpose for now. Also, AOT
holds separate quarterly meeting with ANR, which is helpful.
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Early coordination: It is very important to start coordination with resource
agencies up-stream, at the conceptual stage, not after the project is already in
design.
Field mapping of environmental resources: Resource agencies really appreciate
AOT’s pre-project process of going into the field and mapping potentially
sensitive resources on the survey plan before any project design is done.
Common goal setting: AOT has successfully achieved common goal setting with
SHPO, and is working to achieve it with other resource agencies. AOT believes
common goal setting is key, could be the major break-through to successful
relationships.
FHWA Division support: FHWA Division has been very supportive and helpful in
environment generally, and in helping coordinate with resource agencies.
Organizational Structure: AOT integrates environmental responsibilities across the
organization – doesn’t concentrate them all in one organization unit. Environmental
staff and responsibilities reside in both (a) Policy and Planning Division and (b) Program
Development Division. Policy and Planning focuses on big picture process, planning, and
policy issues, while Program Development focuses at the project level. These two units
and the respective staff clearly coordinate closely, on an ongoing basis. Also, AOT has
increased the environmental responsibilities and staffing in the nine AOT districts. Three
years ago, AOT created an environmental performance engineering position in
Construction, specifically to ensure that field environmental work was done right.
Further, within each district, one staff person is specifically responsible for meeting
environmental requirements and commitments – and HQ Program Development has
three staff dedicated to working with the district staff closely. AOT contemplates
increasing cross-agency environmental coordination, through regular meetings and
creating feedback loops.
Programmatic Agreements (PA) and Memoranda of Understanding (MOA):
AOT’s PA with the SHPO has made a huge difference; enjoys unique top level support; is
articulated within both agencies; and includes “executing to reasonable standards.” For
air quality, AOT has an MOA with ANR, reinforced by quarterly meetings with DNR,
which creates a framework for prevention of air quality deterioration. Also, AOT has a
MOA with ANR Fish & Wildlife Department. AOT still has problems with stormwater,
with two offices at Vermont’s Department of Natural Resources (DNR) and an ACOE
office, each pulling toward extremes.
Holistic, Ecosystem Approach: AOT wants to move away from project-by-project
mitigation to a holistic ecosystem approach. In mid-December 2008, AOT participated
in a meeting with northern New England states DOTs, FHWA, and state and federal
resource agencies, convened by Defenders of Wildlife, to develop a more ecological,
holistic approach to transportation and environment. The meeting focused on the
approach laid out in “Eco-Logical,” a 2006 guidebook from FHWA and Federal resource
agencies on ecosystem approaches. AOT sees this as a major opportunity to move from
project “pinpricks” to a new level in environment and transportation.
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Mapping of Environmental Resources: The biggest change in the last 10 years was
when AOT environmental staff starting going into the field before design commenced,
in order to map environmental resources first. The data are entered electronically on
the survey plan before the designers start design and this has made a huge difference.
This information is key to early coordination with resource agencies and to good project
design. AOT now has compiled a significant GIS-based map of environmental resources,
and is continuing to add to it.
Project Prioritization Process: In recent years, AOT developed a quantitative
process for prioritizing among projects which is systematic, documented, takes input
from regional planning commissions and Vermont’s sole MPO, and gives weight to
environment. Since AOT adopted this process, the Vermont legislature has stepped
back from detailed involvement in project selection, deferring to the prioritization
process. J udging by its acceptance, the process seems to strike a good balance among
competing needs, including environment.
CHALLENGES TO ACHIEVI NG ENVI RONMENTAL STEWARDSHIP AND
STREAMLI NING
Limited Resources: AOT funding is tightly limited, and the future outlook is even
more constrained. Should a state DOT advance 10 projects with strong environmental
stewardship – or 15 with compromises? Limited funding requires compromises,
balancing environmental needs with other needs, especially the constant need to
maintain and rehabilitate Vermont’s aging bridges and roads. AOT is constantly
challenged to figure out what their tight transportation budget can afford and must
negotiate with resource agencies and others on the environmental features that the
state can afford. What are the high-value environmental investments, vs. amenities?
Environmental laws, regulatory culture, and lawsuits: There are multiple,
interconnected issues:
Federal and state environmental laws present a “Rube Goldberg” challenge in
their complexity and detail.
Resource agency staff tends to have a regulatory mindset, bogged down in
project details, focused on their individual mission, reluctant to shift to more
holistic, creative approaches.
Resource agencies have conflicting views and goals, both within individual
agencies and across agencies. (For example, ANR and ACOE have some
conflicting views that create problems for AOT.)
Coordination and communications among and within resource agencies need
improvement.
Resource agency regulators are not planners and don’t have the resources to
focus on systems-level planning.
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Resource agencies need to give AOT more credit for expertise and being
environmentally conscientious. In some cases, AOT has more data than ACOE,
but ACOE’s strict procedures thwart the use of this data in permitting.
AOT needs more flexibility from Federal and state requirements, more delegation
of authority, more ability to focus on environmental outcomes as opposed to
procedural requirements.
Lawsuits come from mindset of “controlling” project, rather than getting good
projects done to meet both environmental and transportation needs of the state.
To overcome some of the above challenges, AOT wants to get to the point where it
is entrusted with doing its own permitting – comparable to the AOT being entrusted
with the SHPO role.
Timeframes and Diligence: It takes significant time and diligence to make progress,
build relationships, and earn trust. After AOT staffed up in environment, it took 6-7
years to earn trust of environmental agencies and improve the environmental clearance
process. For the AOT, environmental stewardship requires:
constantly navigating complicated set of procedures and requirements;
getting individual design engineers within AOT to understand connection of
environmental stewardship to their work; and
continuous efforts to break down organizational silos, within AOT as well as with
resource agencies.
Project-by-Project Permitting: AOT is determined to get away from project-by-
project micro-design. Is determined to move to managing the network, planning on a
system level will have much higher payoff, for environment and for transportation –
especially in an era of limited resources for both. But this will require the support and
cooperation of resource agencies – a big change for them. And it will require dedicated
staff and dollar resources to move to systems approach.
ADDITI ONAL NOTES:
Environmental Management System: AOT does not have a formal EMS. AOT staff
attended a workshop on EMS for highway agencies a few years ago; AOT concluded it
wouldn’t serve them well, as it was too convoluted, too bureaucratic for a small state
which has a strong environmental track record. (AOT had only 1 environmental
violation in the past 15 years.) AOT can see how EMS could be valuable for larger
states and for states that have significant environmental compliance issues.
Energy and Climate Change: Vermont has a state mandate to write an energy plan,
reduce energy consumption, and meet greenhouse gas reduction goals. AOT is working
with operations staff, looking at AOT garages, reducing idling, computer use, copy
machines, etc.. Global Climate Change (GCC) will require AOT to do more travel
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demand management and regional land use planning. GCC will also require more
systems-level analysis; AOT is thinking about doing more corridor-level analysis. Fuel
availability may become an issue in Vermont.
Land Use and VMT: Vermont has progressive state laws on land use, although local
governments still have land use authority. Few Vermont towns have professional
planners. AOT has done some land use studies. Vermont is looking at a system of
allocating costs to developers, and wants to ensure the last developer doesn’t have to
pick up the entire cost.
Design Standards: AOT doesn’t go by the AASHTO “Green Book” on highway design
standards. In the late 1990’s, AOT wrote its own highway design standards. ANR was
integrally involved in doing this, and FHWA endorsed the result. AOT’s approach
provides flexibility for community needs, which makes a big difference in the impact of
projects on communities. AOT won an award for its design standards.
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3.5 I ndividual Summaries of the Second (“beta”) Phase of State DOT
I nterviews (AR, I L, MN, MT, NM)
3.5.1 Interview with Arkansas State Highway and Transportation
Department (AHTD)
April 23, 2008
PARTI CIPANTS – Arkansas State Highway and Transportation Department
(AHTD)
Lynn P. Malbrough, Division Head, Environmental Division
Scott Bennett, Assistant Chief Engineer for Planning
Randall Looney, FHWA Division in Arkansas
PARTICIPANTS – PB
Cindy Burbank
CONTEXT
AHTD is a small-medium size DOT, with 3,700 employees, 16,000 miles of state-
administered highways, 10 districts, and a program of approximately $340 million in
FY07.
AHTD has been headed by Dan Flowers since 1994, which is the greatest longevity of
any state DOT head in the U.S., enabling substantial continuity and stability for AHTD
policies and programs.
At AHTD, Environment is a centralized function, managed from HQ, even though other
AHTD functions are decentralized to the 10 districts.
AHTD has 55 environmental staff, all located in HQ. There has been no downsizing of
environmental staff – in fact the number of staff has increased from 10 years ago.
AHTD FEEDBACK ON THE 12 MAJ OR THEMES IDENTI FIED I N PHASE 1 OF THE
STUDY
1. Provide Two Levels of Leadership: AHTD strongly concurs with the
importance of two levels of leadership. AHTD has been extremely fortunate to
have consistent and supportive leadership from Director Dan Flowers, who has
held the position of Director since 1994. From the beginning, Flowers supported
the environmental function, emphasizing to all staff “We have to do what’s right
for the environment.” He also gave full support, trust, and responsibility to
AHTD’s environmental managers, and promoted greater openness to tackling
environmental issues. Flowers also supported environmental workshops for
AHTD staff, saying it is important for staff to understand and be trained to carry
out environmental responsibilities. This type of CEO leadership has enabled the
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career environmental managers to build a strong staff, develop excellent
relationships with resource agencies, carry out strong environmental programs
and policies, and achieve a reliable, appropriate environmental process.
2. Organize for Environmental Awareness and Accountability Throughout
the DOT and Assure Effective Communications: AHTD has a centralized
environmental function, with 55 staff in HQ, who have the benefit of strong
training and skills. Within the 10 districts, there are no environmental liaisons
per se. Instead, AHTD has a very strong ongoing environmental training
program for AHTD staff (stormwater, archeology, etc.) that enables all the
district staff to serve as environmental liaisons. The district staff are the eyes
and ears of the HQ environmental unit.
3. Provide Expert Staffing: AHTD believes expert staffing is very important.
AHTD has been able to hire very capable wetland specialists, archeologists,
stream specialists, freshwater mussel experts (including one Ph.D. level scientist
with expertise in mussels). The expertise is so high that resource agencies
actually call on AHTD for expertise on specific environmental matters. This is not
a recent phenomenon in AHTD. The agency has a long history of having expert
in-house staff. Only by exception does AHTD turn to environmental consultants.
Among many other advantages, this internal expertise allows the AHTD
environmental staff to have a close working relationship with roadway design
and right-of-way staff in avoiding and resolving environmental issues during
design and property acquisition.
4. Build an Environmental Culture: AHTD has had a strong environmental
culture for many years. It is well-engrained and has helped make AHTD more
effective in both environmental stewardship and streamlining. This
environmental culture is embedded in other AHTD functions (EEO, R&D, design,
maintenance, etc.), enabling very positive interdisciplinary staff work. This is
especially valuable in developing the preferred alternative for projects, because
all the necessary information comes together to enable a consensus decision.
5. Support I mproved Land Use: Land use planning is definitely a local
prerogative in Arkansas and is largely limited to metropolitan areas. There is
little to no long range land use planning at the state level. AHTD has a limited
role and a small influence on land use, through MPO plans. Land use impacts
rarely arise as an issue in projects, except occasionally for new EIS-level projects
in areas where land use is rapidly changing.
6. Invest in Environment: Costs of environmental mitigation and stewardship
haven’t been an issue for AHTD. Environmental costs are considered just part of
normal project needs. In a few cases, resource agencies have proposed
environmental elements that were high in cost, but AHTD has always been able
to work it out with them. AHTD projects haven’t been held up due to
unreasonable environmental demands. When warranted, AHTD is willing to
delay a project in order to do environmental studies – e.g., potential project
impacts on the hot water recharge area for Hot Springs. In that case, AHTD
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agreed with the need for more information and agreed to a three-year study, for
which the National Park Service was very appreciative.
7. Nurture Relationships with Resource Agencies: AHTD has very positive
relationships with resource agencies, and they are longstanding in duration.
AHTD funds positions at resource agencies – 1 at the Corps of Engineers (COE),
1 with Fish and Wildlife Service, and 1 with the State Historic Preservation Office.
The individuals occupying theses positions regularly attend AHTD’s Monday
morning environmental meetings, which enables strong communications and
prevents surprises. In addition, AHTD is able to take these individuals out to
field sites as needed, which is very helpful in reaching agreement. The position
at the COE is especially valuable, as there are three COE districts for Arkansas
and this position is the single point of contact for all AHTD coordination with
COE. This has been enormously valuable as it provides for consistency across
the three COE districts and AHTD knows what to expect. AHTD also took the
initiative to promote better coordination between Arkansas’s seven MPOs and a
comparable number of resource agencies, by hosting a special event for MPOs to
meet and talk with resource agencies.
8. Invest in GIS: AHTD considers GIS a very valuable environmental tool and has
been an early leader in its use. AHTD created a GIS section within the AHTD
Environmental Division in 2000 (fully operational by 2001) and have also
increased GIS environmental staffing. In addition to the value of GIS for internal
planning and coordination with resource agencies, AHTD believes GIS
visualization tools can be vital to public involvement and AHTD is increasing its
development of GIS visualization tools for the public. AHTD is also updating and
expanding their archeological database, working closely with the Arkansas
Archeological Survey. AHTD is also trying to work with the Arkansas Department
of Heritage to map historic and archeological resources, but this has a long way
to go due to limited funding for the Arkansas Department of Heritage to digitize
its information. FHWA’s newsletter “Successes in Stewardship” featured AHTD’s
use of GIS mapping to streamline the transportation decision-making and
permitting process for the I-69 SE-Connector in 2000-2001. GIS helped project
sponsors and reviewers consolidate environmental and engineering data, refine
the study area in order to focus review efforts, and screen project alternatives
efficiently. Participating agencies and affected communities were able to select
an alternative with minimal impacts to wetlands, farmland soils, archaeological
resources, businesses, churches, and other community properties and natural
and cultural resources, which were also mapped. The newsletter quoted AHTD’s
Lynn Malbrough, "The GIS process allowed for alternatives to be effectively and
efficiently evaluated in response to public or agency comments.” The subtle
differences in the study corridors and project alignments were consistently
compared and evaluated. The public and resource agencies were well informed
with both the graphical and tabular presentations of the environmental
constraints and how the proposed alignments related to these constraints. (Seehttp://environment.fhwa.dot.gov/strmlng/newsletters/mar02nl.asp) .
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9. Develop Programmatic Agreements: AHTD has several types of
programmatic agreements in place, including a Memorandum of Agreement with
several resource agencies on streamlining and several specialized agreements
with the Arkansas SHPO (relating to resurfacing or signalization projects and
notification requirements). Overall, however, AHTD’s solid relationships with
resource agencies and AHTD’s respected environmental expertise appears to
have reduced the need for programmatic agreements.
10.Shift from Projects to Ecosystems: AHTD sees the value of ecosystem
planning and practices it in several areas. For wetlands, AHTD has relied on an
ecosystem approach for many years, and has seven or eight ecosystem banks in
place – essentially one wetland bank for each of the seven or eight ecosystem
regions in Arkansas. AHTD is also moving to an ecosystem approach to stream
mitigation, working with the Fish and Wildlife Service (F&WS) and the Corps of
Engineers (COE). AHTD would like to create stream mitigation banks, because
they feel they can do more effective stream mitigation than through mitigation
limited to the project boundaries. Fortunately, F&WS and COE are supportive.
11.Be J udicious with Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs): AHTD does not have an
EMS per se. Instead of a formal EMS, AHTD relies on a sound project delivery
process. AHTD has stayed away from performance measures in general,
including EPMs. They report on some performance measures but don’t set
targets, because they have little control over performance.
12.Continually Streamline Environmental Processes: To achieve timely
environmental reviews, AHTD focuses on concurrent work as much as possible, a
high level of staff environmental expertise, and solid relationships with resource
agencies. Also, AHTD Division heads and the Chief Engineer have a staff
meeting every Monday morning with emphasis on project delivery. For a handful
of capacity-expanding projects, AHTD has used multi-disciplinary project teams,
with a tracking system, but makes limited use of this because they want all
projects to stay on schedule, which could be undermined by selectively focusing
on a few projects. AHTD is satisfied that they are moving projects forward as
expeditiously as possible.
Additional Environmental Success Themes: AHTD did not have any additional
suggestions for major themes to achieve success in environmental stewardship and
streamlining.
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3.5.2 I nterview with Illinois Department of Transportation (I DOT)
April 22, 2008
PARTI CI PANTS - Illinois Department of Transportation (IDOT)
Kathy Ames, Deputy Director, Planning and Programming
Barbara Stevens, Chief, Environment Section
PARTI CIPANTS - Federal Highway Administration (FHWA)
Matt Fuller, FHWA Division in Illinois
J .D. Stevenson, FHWA Division in Illinois
PARTICIPANTS - PB
Cindy Burbank
Amy Zwas
CONTEXT
IDOT is a large state DOT, with approximately 5,400 employees, a multimodal annual
program of approximately $5 billion, nine district offices, and a state highway system of
17,000 miles, within a larger network of approximately 140,000 miles of state, county,
municipal and toll roads – the third largest system in the nation.
IDOT FEEDBACK ON THE 12 MAJ OR THEMES IDENTI FIED I N PHASE 1 OF THE
STUDY
1. Provide Two Levels of Leadership: IDOT concurs that two levels of
leadership on environment are valuable. Executive leadership sets the tone for
the organization. However, environmental staff believes they have little impact
on the decisions made by upper management.
2. Organize for Environmental Awareness and Accountability Throughout
the DOT and Ensure Effective Communications: IDOT’s organizational
approach relies on centralized specialists in headquarters, linked with
environmental generalists in the nine districts (usually at least two environmental
staff in each district). The HQ staff numbers 14, with outsourced cultural,
geologic and natural resource statewide survey crews of approximately 100. The
HQ staff is located in the Environment Section, within the Bureau of Design and
Environment, in the Division of Highways. IDOT districts identify the highway
projects. Consultants are selected to complete the Phase I work, including the
preparation of NEPA documents. HQ environmental staff reviews all EISs and
most EAs and coordinate these documents with FHWA. District office
environmental managers may opt to coordinate EAs directly with FHWA if they
have been certified to do so. Decentralization is not a significant challenge at
IDOT, due largely to the Bureau of Design and Environment Manual, which is
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now being updated. Because this manual contains detailed procedures as to the
HQ and district roles, it is a valuable resource to ensure consistency.
3. Provide Expert Staffing: Environmental expertise is essential, but IDOT’s
environmental expertise is at a less than desirable level due to recent agency-
wide downsizing and a hiring freeze. Any further downsizing of IDOT
environmental staff may result in significant damage. IDOT environmental staff
would like to do more environmental research and pursue new angles to carrying
out environmental responsibilities but are unable to do so because of staff
limitations.
4. Build an Environmental Culture: IDOT is building an environmental culture
among the workforce largely through training programs, including FHWA
environmental training. In recent years, after the Illinois legislature passed a law
in support of Context Sensitive Solutions (CSS), IDOT has particularly
emphasized CSS training, with 3-day classes on CSS for project managers and
for maintenance and construction staff. IDOT also conducts a CSS awareness
class for upper-level managers, which is a half-day in length. IDOT sponsors
CSS training for local agencies, and on-line training in CSS is currently being
developed. IDOT believes the CSS classes have been effective in getting the
environmental message out to IDOT employees as well as to local agencies.
Despite the demands on their time, IDOT’s environmental staff made a conscious
decision that CSS training be conducted by IDOT staff rather than by consultants
or others outside the agency.
5. Support I mproved Land Use: While recognizing that there are very strong
private property rights in the United States, IDOT staff have been dealing with
land use issues for as long as they can remember. IDOT particularly tries to
involve local governments in dealing with land use changes that may occur as a
result of highway improvements. One example is the Prairie Parkway EIS project
southwest of Chicago that affects farmland. Residents are concerned about the
development the highway could bring. Because it is the local governments that
have the authority to adopt land use policies that deal with the citizen concerns,
IDOT formed a citizens’ advisory group with planners from local governments. A
few Illinois MPOs are funding local land use studies, but this is relatively limited.
IDOT has been funding MPO GIS work, which may lead to more involvement of
MPOs in influencing local land use policies.
6. Invest in Environment: IDOT has not had to make any major sacrifices in
environmental funding due to budget cuts. However, lack of funds for out-of-
state travel has precluded IDOT environmental staff from participating in
AASHTO and TRB events, which limits their ability to gain insights and learn
environmental approaches that could be helpful in Illinois. When resource
agencies ask for more mitigation or costly design changes, IDOT staff do what
they can to accommodate the requests.
7. Nurture Relationships with Resource Agencies: IDOT has made it a
priority to have good relationships with resource agencies and believes their
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relationships are excellent. IDOT meets with resource agencies three times a
year under the NEPA-404 merger agreement, and these regular meetings (and
the agreement itself) have been particularly valuable. When problems arise, it is
often due to understaffing at the resource agencies, e.g., when the Corps of
Engineers had just one person handling wetland permits for two states. There
have also been some issues with the Illinois Department of Natural Resources
(I DNR), but these have not strained the relationships. IDOT invites resource
agencies to participate in IDOT’s CSS training and to participate in IDOT’s
statewide planning discussions, but resource agency staffing constraints have
limited participation.
8. Invest in GIS: IDOT’s environmental staff believes GIS is an important tool but
have not had much success in developing it. GIS staffing is located in a different
Bureau (Information Processing) which is strong in GIS technology but does not
really understand environmental science and needs. As a result, the IDOT
environmental unit pays to use other agencies’ GIS databases (e.g., those of
IDNR and the Illinois State Geological Survey).
9. Develop Programmatic Agreements (PAs): PAs are very helpful, and IDOT
has five different PAs for Section 106, as well as an Interagency Agreement with
IDNR, and an agreement with the Illinois Department of Agriculture that outlines
coordination thresholds.
10.Shift from Projects to Ecosystems: IDOT would like to move in this direction
if more resources were available to do so. A representative of the National
Wildlife Council suggested integrating the state wildlife plan and state
transportation plan, which IDOT environmental staff would like to be able to do.
11.Be J udicious with Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs): IDOT has a limited EMS,
focused on roadway maintenance facilities, and would like to develop more
widespread EMS coverage. Currently IDOT has no EPMs but is trying to develop
performance measures.
12.Continually Streamline Environmental Processes: IDOT understands and
embraces the goal of environmental streamlining. They want to reduce
unnecessary steps while taking care not to cut corners. The changes in federal
regulations and guidance on 4(f) have been helpful. However, the Section 6002
environmental process in SAFETEA-LU is not necessarily helpful as it brought
changes and some new requirements. There are concerns within IDOT that
Context Sensitive Solutions (CSS) is not helpful to streamlining the process, but
even so, IDOT has been proactive in training and promoting CSS after the Illinois
legislature mandated CSS into law four years ago. In 2007, the Illinois
legislature established new requirements in support of “complete streets.” With
the constant changes in requirements and procedures, it is always challenging to
make progress with streamlining.
Additional Environmental Success Themes: IDOT staff identified peer exchanges
as a particularly valuable way for state DOTs to learn new approaches to advancing
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environmental stewardship and environmental streamlining. Despite all the limitations
on environmental staff time, peer exchanges can be a good investment to learn from
other states what works and what does not work.
3.5.3 Interview with Minnesota Department of Transportation
Department (MNDOT)
April 17, 2008
PARTI CIPANTS – Minnesota Department of Transportation (MNDOT)
Frank Pafko, Director, Office of Environmental Services
J ennie Ross, Environmental Assessment Unit
Gerry Larson, Environmental Analysis Section
Tim Henkel, Director, Planning, Modal and Data Management Division
PARTICIPANTS – PB
Cindy Burbank
Hal Kassoff
CONTEXT
MNDOT has eight districts, and a highway program of $1.2 billion in FY08.
MNDOT’s environmental functions are centralized in Headquarters, with a staff of 36 in
the Office of Environmental Services and about a dozen other staff in other units – down
from a high of 75-80 staff at one time).
MNDOT FEEDBACK ON THE 12 MAJ OR THEMES IDENTIFIED I N PHASE 1 OF
THE STUDY
1. Provide Two Levels of Leadership: Two strong levels of leadership are
important and useful – but not essential. Career leadership can still achieve a lot
in the environmental area without strong executive support, as long as there is
neutrality. It is easier with top level support, but it is possible to work from the
middle out, rather than top down.
2. Organize for Environmental Awareness and Accountability Throughout
the DOT and Assure Effective Communications: MNDOT’s environmental
staff is concentrated in headquarters, while project management is always in the
districts. Each of the eight districts has only about 1 environmental specialist
(except the Minneapolis-St. Paul Metro District, with 2-3 environmental staff).
However, there are many “environmental contacts” within the districts (e.g.,
contacts in the district maintenance units who help get the word out when
needed). Having environmental staff in districts is useful, but not essential.
J ennie Ross indicated that “Environmental education of project managers is as
important as having environmental staff in the field.” The HQ staff have also
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found that carrying out a role as problem solvers for field staff, rather than
problem causers, builds trust and cooperation among district staff.
3. Provide Expert Staffing: Environmental technical expertise is extremely
important. MNDOT’s environmental staff adhere to the philosophy of former
environmental manager Larry Foote – “Know the science and know the
regulations better than the regulators.” MNDOT has seen other DOTs have to
cut environmental staff, to the point they don’t have technically sound staff able
to adequately oversee consultants’ environmental work. Frank Pafko emphasized
that “Environment is the same as the core engineering function of a DOT – you
need that expertise on board.” As a result of MNDOT belt tightening, MNDOT is
relying on a smaller environmental staff, but “we have an office of aging baby
boomers” and there is no succession planning. There is significant concern
about future environmental staffing as experienced staff are lost to retirement.
4. Build an Environmental Culture: MNDOT agrees that a strong
environmental culture throughout the workforce is important, and achieves it
primarily through a well-established environmental training program. For 20-25
years, MNDOT has had an environmental training road show. Originally a one-
day training curriculum, it is now typically two days. These environmental
workshops are open to district staff, consultants, and counties. MNDOT also
offers training in key individual environmental topics, e.g., erosion control
training that is carried out in partnership with the UMN Extension Service. Other
training includes lead paint removal for bridges and salt storage.
5. Support I mproved Land Use: Land use planning in Minnesota is definitely a
local function – land use authority resides at the lowest level of government.
MNDOT’s role is limited to influence land use decisions. For example, MNDOT
districts can review and comment on local land use plans. Another tool for
MNDOT to influence land use is its access management manual, which provides
guidelines on how local developments and roads can connect to the Minnesota
state highway system. By withholding access approvals or highway funding,
MNDOT has some influence on land use. Tim Henkel observed, “I don’t want
this Department to be responsible for land use.” Land use is best handled at the
local level of government. MNDOT doesn’t have land use planning expertise and
doesn’t want to have land use authority or responsibility. Unfortunately,
however, “local governments are approaching land use from a tax base
perspective, not from a transportation or environmental perspective.”
6. Invest in Environment: MNDOT is seeing the need for increased investment
in water quality and erosion control in particular, as a result of increasing water
regulations and requirements. These costs are rising to 5-10% of construction
costs. However, you don’t always have to spend a lot of money to be a good
steward of the environment. An example is using native species plantings
instead of ornamentals. That is environmentally preferable and also costs less.
7. Nurture Relationships with Resource Agencies: Frank Pafko emphasized
that “Positive relationships with resource agencies are key – and everything else
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will follow from that. All our good relationships paid off in 1 week after the
I-35W bridge collapse. We had permits and environmental signoffs nine days
after the bridge went down. The Fish and Wildlife Service even contacted us
first, to initiate informal consultation. We had the Corps of Engineers’ permit
within seven days after the collapse (even though it turned out we didn’t need a
permit, because the design had no piers in the water.”
8. Invest in GIS: GIS is important. MNDOT has been using GIS for
environmental functions on a topic-by-topic basis, but wants to merge the GIS
databases, so “they talk to each other.” Unfortunately, the GIS databases and
applications have been developed in isolation and they need to be integrated.
9. Develop Programmatic Agreements (PAs): MNDOT places great emphasis
on PAs and finds them very valuable, particularly historic PAs, such as a MNDOT
PA on historic bridges with the State Historic Preservation Office, the Advisory
Council on Historic Preservation, and FHWA. Another valuable PA is with the Fish
and Wildlife Service, establishing an agreement as to when formal consultation is
necessary under the Endangered Species Act. MNDOT finds the value of PAs is
much increased when the formal words on paper are supplemented with trust
and informal understandings that enhance the use of the PA.
10.Shift from Projects to Ecosystems: MNDOT has been shifting to an
ecosystem/programmatic approach, e.g., for wetlands, bridge work, and
endangered species. “Let’s try to site wetlands mitigation where they will most
effectively support ecosystems” instead of project-bounded mitigation.
Unfortunately, resource agencies have a regulatory project-based mindset, and
few have come around to a holistic approach. MNDOT has been trying to get
state resource agencies to work with them on wildlife corridor planning, instead
of individual species planning. More work is needed to explain ecosystems to the
layman and to persuade resource agencies to embrace it in practice.
11.Be J udicious with Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs): MNDOT doesn’t have
much experience with EMS. There are some isolated examples of topical EMS
(e.g., cultural resources). For transportation performance measures in general,
MNDOT has been a leader in their development and use, but the environmental
staff hasn’t been satisfied with EPMs. The problem with EPMs is they are a
series of topic-specific, isolated indicators, forcing a DOT to measure the
negatives – the environmental damage you don’t do, rather than something
positive.
12.Continually Streamline Environmental Processes: There are no magic
bullets in streamlining. Instead, streamlining is a lot of little things:
Concurrent reviews are a big help.
Solid relationships with resource agencies pay off big – as amply demonstrated in
the aftermath of the I-35W bridge collapse.
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A strong, stable environmental staff is one of the most important ingredients in
streamlining. Conversely, staff turnover and loss of experienced staff can be a
major setback.
The best streamlining percolates from the bottom up – not through a top-down
process.
“The environmental process can get done as fast as you need, as long as you
can make decisions quickly” -- something that was observed in the aftermath of
the I-35W bridge collapse, when project development decisions were made in
hours rather than days or weeks or months.
Additional Environmental Success Themes: MNDOT did not have any additional
suggestions for major themes to achieve success in environmental stewardship and
streamlining.
3.5.4 Interview with Montana Department of
Transportation (MDT)
May 5, 2008
PARTI CIPANTS –Montana Department Of Transportation (MDT)
Tom Martin, Chief, Environmental Services Bureau
Heidy Bruner, Supervisor, Engineering Section, Environmental Services Bureau
Bonnie Steg, Supervisor, Resources Section, Environmental Services Bureau
PARTICIPANTS – PB
Cindy Burbank
Alan Lubliner
CONTEXT
MDT has approximately 2,000 employees and is responsible for 25,000 lane miles of
highways, with an annual federal aid construction program of approximately $300
million.
At MDT, Environment is a centralized function, managed from HQ, housed within the
Preconstruction Engineering section of the Highways and Engineering Division.
MDT has 29 environmental staff in HQ, plus at least one environmental staff in each of
the five MDT district offices.
MDT FEEDBACK ON THE 12 MAJ OR THEMES IDENTIFIED I N PHASE 1 OF THE
STUDY
1. Provide Two Levels of Leadership: MDT environmental staff wholeheartedly
agrees with the value of 2 levels of environmental leaders, at the executive level
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and through career environmental managers. In recent years MDT senior
managers have shown increased interest in environment, which has been very
helpful. MDT’s project development team includes both environmental and civil
engineers. Although environmental management is several levels below
executive level management in the organization, influence has been filtering up
to the Chief Engineer level.
2. Organize for Environmental Awareness and Accountability Throughout
the DOT and Assure Effective Communications: At MDT, environment is a
centralized HQ responsibility (as are project delivery functions in general), with
29 staff in the Environmental Services Bureau (ESB). Several years ago, as a
result of concerns raised by resource agencies about the environmental aspects
of some projects, the head of the environment function had reported to the MDT
Director. This changed six years ago, when the function was moved to the
Environmental Services Bureau within the Preconstruction Program of the
Highways and Engineering Division – an organizational arrangement which is
somewhat misleading because ESB provides a full range of environmental
services, not just preconstruction activities. Its organizational location tends to
dictate the primary metric for judging its performance. Because many other
changes were happening at the same time, it really isn’t possible to say whether
the organizational change was adverse or beneficial. ESB strives for an effective
working relationship with MDT’s five districts, and found it generally beneficial
when a few environmental staff members were added to the districts a few years
ago. However, as in most state DOTs, the ESB finds it is a challenge to ensure
that HQ and district staff are working from the same page and maintaining
consistency; also, day-to-day priorities can be switched and not always well
communicated between HQ and District staff. ESB is working to strengthen its
organizational ties to the Planning function, trying to find a way through to
linking planning and NEPA. It has been challenging, but they have done a
couple of projects where a lot has been learned along the way.
3. Provide Expert Staffing: MDT concurs with the importance of this and is
confident that it has a high level of environmental expertise among its staff. The
top levels of MDT are very much in favor of developing core skills in house,
rather than contracting out to consultants. MDT does rely on consultants for EAs
and EISs and also for some hazardous waste work, due to current staffing levels
in MDT. MDT believes its environmental staff has as much expertise or more
than their counterparts at resource agencies, which creates some challenges,
especially with resource agency permitting staff, in which case MDT relies on
coaching.
4. Build an Environmental Culture: MDT believes it has come a long way in
the last 10 years in building an environmental culture throughout the
department, although there are still some holdouts. Now, ESB can usually find
support for what it is needed by working through the issues. To build that
culture, MDT has conducted a great deal of environmental training for
construction staff, maintenance staff, and others – and conferences. As
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managers turned over in MDT, key new managers have been increasingly
supportive of environment, having learned from ESB and seen the issues MDT
has with resource agencies, and support a new direction in what MDT needs to
do to foster good environmental practices and projects. Another factor in
heightening environmental awareness and good environmental practices has
been some negative incidents (e.g., where wetlands were filled that shouldn’t
have been, leading to litigation) and some other violations, which received high
visibility and caused the workforce to be more diligent in environmental matters.
5. Support I mproved Land Use: MDT environmental staff is largely in
agreement with this theme, although MDT has little control. It is difficult to
predict land use impacts when a highway is built or expanded. Given that lack of
control, MDT is modifying its approach to noise management. This involves
increased communication with cities and counties about MDT’s projection of
noise levels associated with new or expanded highways and local government
responsibility to guide development so as to minimize impacts. Montana is
seeing tremendous population growth, with a lot of new subdivisions being
developed next to the highways. MDT is doing a good job in its upfront
projections and sharing that information, so that others can work with the
roadway as/where it is, making this information available to developers, as an
important factor in the location and design of new developments.
6. Invest in Environment: “Sensitivity to the environment” is part of MDT’s
mission statement, and environmental stewardship is part of what MDT does. As
in many other states, MDT considers environmental impact avoidance,
minimization, and mitigation part of the core cost of carrying out transportation
improvements. But it is sometimes tough to discern when environmental costs
are an “extra” above and beyond the Department’s core environmental
responsibilities. MDT programs off-site wetland mitigation projects separately
(unless the wetland is directly in the project right-of-way) and has had success in
receiving funding approval from the Transportation Commission for all nominated
wetland mitigation projects. Most funding for construction comes from federal
aid, and not enough of that limited source trickles down to all areas of MDT
where it is needed. One area where environmental funding has been tight is
internal environmental staffing and related costs. GIS is an area of keen interest
to MDT right now, albeit one with limited resources. MDT’s Information Services
Division (ISD) provides good internal training, but if more funds were available,
MDT environmental staff would very much like to hire a GIS expert to take
advantage of this “awesome tool,” develop its GIS environmental capabilities and
use GIS to a greater extent in environmental planning and coordination.
7. Nurture Relationships with Resource Agencies: MDT agrees that good
relationships with resource agencies are extremely important, but finds this area
uneven, depending on the particular resource agency and the people involved.
ESB sees the value of developing these relationships, and is pursuing this as an
important endeavor, but can’t say that MDT is completely successful with this
right now. For the most part MDT has good relationships with resource
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agencies. Relationships run the gamut, with MDT developing very positive
relationships with some and making strides with others, but there is one difficult
relationship, wherein MDT encounters baffling and unnerving behavior by
resource agency staff. MDT participated in a 3-day training course offered by
USGS on “negotiating with regulators,” and it was extremely valuable. MDT has
Memoranda of Agreement and Memoranda of Understanding; it is now funding 1
position at a federal resource agency and previously funded another position.
Year-by-year, it looks at the tools available to further these relationships and
adjusts its approach. ESB is looking for advice and insights to be more
successful. To improve relationships, MDT has regular meetings (Corps of
Engineers, state Fish, Wildlife and Parks) and periodic meetings with others, as
well as project-specific meetings. One of the major issues in relationships with
resource agencies is lack of resource agency staff. This is exacerbated by the
number of new environmental policies, regulations, and interpretations that
create more work for understaffed agencies and set back efforts to get needed
permits or other environmental decisions in a timely manner.
8. Invest in GIS: As noted above in section 5 on “Invest in Environment,” MDT
sees high potential value in using GIS for environmental planning and
coordination, but hasn’t been able to invest in hiring a GIS staffer for the
environmental unit. Although MDT has capable ITS people, such an investment
in GIS would help MDT move forward in several environmental issue areas.
9. Develop Programmatic Agreements (PAs): MDT considers PAs helpful, but
not a panacea, and hasn’t placed high emphasis on developing PAs. MDT has a
couple of PAs or MOUs with other state agencies, including an MOU with the
Montana Department of Environmental Quality, which is quite beneficial.
Personal relationships may be more important than the terms of these
agreements.
10.Shift from Projects to Ecosystems: MDT sees the value of shifting from
project level environmental planning and mitigation to an ecosystem approach,
and has been moving in that direction. In 2007, MDT initiated a pilot project to
work with resource agencies to apply the principles and tools from the Federal
“Eco-logical” handbook to the Highway 83 project in western Montana. The
name of the initiative is “Integrated Transportation and Ecological Enhancements
for Montana” or ITEEM.
11.Be J udicious with Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs): ESB is very much in favor
of EMS and hopes to develop an EMS, but it will require a lot of discussion. It
would be especially valuable to help ensure that project-level environmental
commitments are carried forward and fulfilled, which is a challenging area for
MDT. MDT currently has 4 EPMs within an FHWA Partnering agreement signed
5-20-08. They are:
Deliver FONSI in 24 months from beginning of environmental documentation
process. Tracked by FHWA.
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FHWA will prepare de minimus letter to SHPO within two weeks. Tracked by
FHWA.
For environmental documents with negotiated timelines, FHWA and MDT will
meet all timeframes barring unanticipated events. J ointly tracked by FHWA
and MDT.
Deliver all Records of Decision (RODs) within 48 months from Notice of
Intent. Tracked by FHWA.
12.Continually Streamline Environmental Processes: The environmental
process is shaped by regulations and litigation, which are constantly changing, so
it is difficult to make progress with streamlining the environmental process. MDT
has made some improvement in the EA process, which is now much quicker than
10 years ago. Streamlining and increasing the speed of the process has caused
some consternation. Department staff can only handle so many EAs and EISs at
a time, and streamlining often requires increased focus from busy MDT
executives. While MDT has had some successes with streamlining, ESB is
concerned about making it happen every time.
Additional Environmental Success Themes: ESB believes the above 12 themes
are thorough and does not have any additions to suggest.
3.5.5 I nterview with New Mexico Department of Transportation
(NMDOT)
May 8, 2008
PARTI CIPANTS – NEW MEXICO DEPARTMENT OF TRANSPORTATI ON
(NMDOT)
Rochelle Byars, Director, Environmental Design Division
Blake Roxlau, Cultural Resources & Archaeology Program Manager
Steve Reed, Environmental Programs Manager, Human and Natural Resources Staff
Colleen Vaughn, Environmental Analyst, Human and Natural Resources Staff
PARTICIPANTS – Parsons Brinckerhoff
Cindy Burbank
Amy Zwas
CONTEXT
NMDOT is a large state DOT, with a multimodal program and six district offices.
NMDOT FEEDBACK ON THE 12 MAJ OR THEMES IDENTIFIED I N PHASE 1 OF
THE STUDY
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1. Provide Two Levels of Leadership: Over the years, NMDOT has
experienced many different executives and different levels of interest about
environment. It is not always possible to rely on executive level support. When
that is the case, it is important to have effective written environmental policies
and procedures.
2. Organize for Environmental Awareness and Accountability Throughout
the DOT and Assure Effective Communications: In NMDOT, environment
is a centralized function, with approximately 21 staff in the Environmental Design
Division, which is part of the Office of Programs. The Division is made up of the
Human and Natural Resources Bureau (human and natural environmental
analysis), the Cultural Resources Bureau, and the Environmental Geology Bureau
(hazardous material investigations). To maintain communications and
consistency with NMDOT’s six districts, each of the districts has a human and
natural resources liaison assigned. There is a well-established handbook,
“Location Study Procedures,” which includes all project development procedures,
including environmental. The handbook is particularly valuable for larger
projects. There are challenges, however, with helping district staff understand
what is needed for smaller district maintenance projects. In addition, there is a
handbook, Hazardous Material Assessment Handbook, for Environmental
Geology.
3. Provide Expert Staffing: NMDOT agrees that expert staffing is important,
and describes its current environmental expertise as “remarkable.” NMDOT
notes that their environmental staff are able to hold their own in discussions with
resource agencies, even though gaining the respect of resource agencies is an
ongoing challenge due to turnover at the resource agencies, which requires
reestablishing credibility. NMDOT credits an exceptional environmental training
program (in wetlands, NEPA, Endangered Species Act, etc.) with developing and
retaining high quality environmental expertise. It took years to build up the
current level of expertise and there were times over the past 13 years when the
expertise was uneven. Maintaining a high level of expertise is precarious, in part
because the pay for NMDOT employees is low and retention of staff is a
challenge, but living and working in New Mexico is a draw for people that help
offset the low pay.
4. Build an Environmental Culture: Establishing and maintaining a strong
environmental culture in the NMDOT workforce boils down to communications
and meeting with individual personnel. Environmental staff tries to attend
project manager meetings regularly and uses them to explain environmental
requirements and needs. In the field, there is respect for environmental legal
requirements, but beyond that the presence of an environmental ethic is mixed.
The current Chief Engineer has respect for the Environmental Design Division
and supports them as issues arise.
5. Support I mproved Land Use: NMDOT is not drawn into land use issues
often, and there is a reluctance to get involved in land use. However, land use
issues do arise on large, complicated projects. Also, the New Mexico state
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climate change plan expects to achieve significant reductions in greenhouse gas
emissions from transit-oriented development and smart growth associated with
the “Rail Runner,” a new commuter rail system serving the metropolitan areas of
Albuquerque and Santa Fe.
6. Invest in Environment: The ability to fund environmental mitigation has not
been a significant issue for NMDOT and to date NMDOT has been able to satisfy
resource agencies. However, there are a couple of pending projects in which the
environmental mitigation costs are expected to be so high that NMDOT may not
proceed with the projects. Recently, the most high-profile environmental
expenditures have been in historic resources (especially data recovery). If
additional funds were available internally, the environmental staff would like to
do more training and be able to fund out-of-state travel.
7. Nurture Relationships with Resource Agencies: NMDOT has excellent
relations with land management agencies. Relations with other resource
agencies are also excellent in general, although there are specific issues with
specific people. The biggest challenge is with the State Historic Preservation
Officer, a challenge which his shared by other state agencies and which relates
to how the SHPO views its role. Overall, NMDOT believes that good
communications and early coordination are the key to good relations and has
emphasized that in working with resource agencies. NMDOT funds (or partially
funds) positions at the NM Environment Department, the SHPO, and the NM
Archeological Records Management Section. NMDOT believes funding liaison
positions is a good idea, but it has been a challenge to get the right person or
personality into these positions. Also, effectiveness may be limited by lack of a
detailed scope of duties and the fact that NMDOT does not participate in annual
performance reviews, for both of which NMDOT is considering making changes.
8. Invest in GIS: NMDOT uses GIS extensively in environmental applications and
NMDOT’s environmental staff believes that GIS has “definitely” helped with both
environmental stewardship and streamlining. Many of the NMDOT
environmental staff are proficient in GIS, as a result of taking advantage of
ample GIS training that is available. As a result of new planning requirements in
SAFETEA-LU, NMDOT’s Planning Bureau is looking into GIS applications in
planning which will strengthen environmental elements of planning.
9. Develop Programmatic Agreements (PAs): PAs with the SHPO have been
a major timesaver for NMDOT – notably PAs with the SHPO for negative findings
and for bridge repair and replacement. The NMDOT Human and Natural
Resources staff do not rely on any PAs (except for some programmatic
Categorical Exclusions), because the positive relations with the resource agencies
have not precipitated the need for PAs.
10. Shift from Projects to Ecosystems: NMDOT has looked into shifting from a
project-by-project focus to planning and mitigating impacts at an ecosystems
level, but hasn’t moved in that direction because project level mitigation has
been effective in NM. NMDOT does not participate in wetland banking and until
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recently, wetland mitigation had to be achieved in the same drainage area for
each project, but the resource agencies are now permitting mitigation within the
affected watershed. The resource agencies appear to be interested in ecosystem
planning and mitigation, including wetland banking that would provide advance
credit for later projects.
11. Be J udicious with Environmental Management Systems (EMS) and
Environmental Performance Measures (EPMs): For EMS, NMDOT is
starting to work with FHWA to track environmental commitments to make sure
they are followed in design and construction (and subsequently, when needed).
Otherwise, NMDOT is not that familiar with EMS. For EPS, NMDOT has a
database to track wetlands, including 5-year performance of wetlands, but this is
still in its infancy. In general, however, NMDOT noted that it is difficult to come
up with meaningful environmental measures and EPMs are limited by the fact
they usually measure the negative – i.e., environmental damages avoided.
12. Continually Streamline Environmental Processes: There isn’t a strong
feeling that the environmental process takes too long. NMDOT goes through the
process as quickly as it can while meeting all the requirements. NMDOT
environmental staff emphasizes good communications with the public and with
resource agencies, and recognizes that the environmental process hinges on
individual resource agencies and individual reviewers and their personalities.
The NMDOT Secretary had experience in the trenches as a project development
engineer, so she understands the environmental process and has reasonable
expectations. The public in New Mexico is often vocal about protecting the
environment, which can generate controversy and cause delays – and NMDOT
recognizes it will take time to work through the process when there is public
controversy. There is one area that NMDOT is now actively seeking to change:
the STIP process hadn’t been working well, so NMDOT is moving to do more
environmental review of projects before putting them in the STIP – following the
concepts of “Linking Planning and NEPA.”
Additional Environmental Success Themes: Above all, NMDOT environmental
staff felt that the keys to environmental stewardship and streamlining are
(a) effective communications with the public and resource agencies;
(b) a strong, expert environmental staff; and
(c) a strong environmental training program.
Finally, the NMDOT environmental staff stated that a common saying in New Mexico is
“Whatever works anywhere else doesn’t always work in New Mexico.”
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4.0 CHAPTER 4
CONCLUSI ONS
At both the national and state level, the American public expects a high level of
environmental quality and a safe, sound, and efficient transportation system. The
relative level of emphasis varies from state to state, and varies over time.
To meet these high expectations, state DOTs must be successful with both
environmental stewardship and environmental streamlining, must deliver projects that
are good for the environment and improve transportation, and must overcome
perceptions that transportation agencies sacrifice the environment to make
transportation improvements.
Many state DOTs have made significant progress in their environmental
accomplishments, in streamlining, in delivering projects that are good for the
environment and transportation, and in building credibility with resource agencies and
the public. Their insights are documented in this report in the 12 major themes about
management practices and organizational structures that contribute to environmental
success. While all 12 themes are important, several merit special attention here:
Leadership (theme 1) is particularly important. Indeed, leadership is absolutely
essential, not only at the state DOT executive level but also through the leadership of
environmental unit managers. From New York to Oregon to Arkansas to Vermont to
Florida and many other states, the message was clear that sustained environmental
leadership at both levels plays a major role in strong, continuous improvement in
environmental stewardship and streamlining. It is a form of leadership that projects a
strong environmental message, “walks the talk,” and invests time in relationships with
resource agencies and in building environmental support and competency throughout
the state DOT.
State DOT organizational structure (theme 2) is also critical, in two ways:
(1) Placing the state DOT environmental unit relatively high in the
organization sends a message about the DOT’s commitment to
environment and ensures that environmental experts have a voice in key
policies and decisions at a level commensurate with public expectations.
(2) It is essential to have strong organizational linkages between the
environmental unit and other major functions of the state DOT:
planning, design, construction, maintenance, and operations. This can
be achieved through a variety of organizational linkages (e.g., designated
liaisons and internal management councils that cut across functions.
From the interviews and other evidence, it is clear that more progress is occurring on
environmental stewardship, while progress on environmental streamlining (theme
12) is slower, more challenging, and anecdotal or sporadic. None of the interviewed
states pointed to measureable, systemic, reductions in the time required for the
environmental process, although there were many examples of Programmatic
Agreements and improved relationships with resource agencies. (MN DOT’s experience
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with replacing the I-35W bridge after the structure collapsed is a notable project
exception, in which resource agencies bent over backwards to expedite the
environmental permits and clearances needed to rebuild the collapsed structure. This
streamlining success probably was due in equal parts to MN DOT’s efforts over the years
to maintain good relationships with resource agencies and to the extraordinary
circumstances of the project.)
The lack of systemic evidence of reduced time in completing environmental reviews is
likely because streamlining is inherently more difficult, due to the large number of laws
and agencies on which streamlining depends, and because public expectations and
environmental advocacy and litigation over the environmental process continue to rise.
State DOTs need to be proactive on environment, especially in responding to new issues
and changes in expectations for the state DOT role. As hockey superstar Wayne Gretzky
said when asked how he became the greatest hockey player of his era, “I skate to
where the puck will be.” State DOTs need to “skate to where the [environmental] puck
will be” – not just where the puck was yesterday or is today.
There are three areas where being proactive on environment is particularly important:
Land Use – Transportation Linkages (theme 5): Many of the state DOTs
interviewed for this project emphasized their efforts to work with local
governments to encourage better land use planning and to provide
transportation support to those efforts. These state DOTs emphasized that they
did not have the authority to change land use, but they can play a supportive
role in improving land use – especially in ways that avoid or minimize or mitigate
the adverse transportation effects of poor land use.
Ecosystems/ Planning Emphasis (theme 10): There are many limitations to
the traditional, long-standing emphasis on project-level avoidance, minimization,
and mitigation of environmental impacts. There is a growing need to build
environmental policies and practices in at the planning stage, with a focus on
ecosystems-level avoidance, minimization, and mitigation. It will require a
sustained effort to be successful at this level and to make it pay off in better and
more streamlined project decisions.
Global Climate Change: While this did not emerge as a dominant theme, it is
a rising issue of public concern and potential for legislative requirements. As
noted in some of the interviews, state DOTs need to understand the issue,
develop policies and plans to respond to climate change, and adjust their
organization to be proactive on both greenhouse gas reductions and climate
adaptation for transportation infrastructure. Moreover, state DOT CEOs need to
actively engage in state climate action planning, to be a voice in state climate
policies, and to educate their workforce and the public.
The interviews brought home how different every state DOT is. While all state DOTs
would benefit from focusing on all 12 themes from this study, the specific management
practices and organizational structures that will best advance stewardship and
streamlining depend greatly on different state circumstances and opportunities, as well
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as the expectations of the citizenry of each state. There is no “cookbook” for success,
but there are many useful insights, case studies, and lessons learned that can help state
DOTs that are seeking to elevate their environmental stewardship and streamlining.
Several other points are noteworthy:
Smaller and small/medium states can be environmental leaders, and can provide
examples and tools that are worthy of recognition on a national level. In this
regard, Vermont, Arkansas and Maryland had impressive stories and
accomplishments in environmental stewardship.
The greater the overall public support for environment in a state, the greater the
need for the state DOT to be at the high end on environmental stewardship.
Thus, Oregon DOT, Minnesota DOT, Maryland DOT, Florida DOT, and Vermont
DOT have faced and met the challenge to have some of the strongest
environmental track records.
Suggestions:
Based on the interviews, the literature review, and the research team’s overall
experience, these suggestions are offered:
Every state DOT could evaluate itself against the 12 themes that emerged from
this study. This evaluation would be best as a joint effort of the state DOT
executives and the environmental unit leaders. Each state could ask itself: How
is it performing in each of the 12 themes? Based on the information in the
study, what could it do to improve its organizational structure and management
practices to achieve a higher level of environmental stewardship and
streamlining?
AASHTO, FHWA, and TRB could conduct workshops, conferences, domestic
scans, and peer exchanges to promote cross-fertilization of experience among
state DOTs on the management practices and organizational structures that
contribute to environmental stewardship and streamlining. These cross-
fertilization opportunities could be provided at multiple levels – for state DOT
executives (CEOs, Deputy CEOs, and Chief Engineers), for project managers, for
leaders of environmental units, and for environmental staff.
For other state DOT functions, such as planning, design, construction,
maintenance, and operations, AASHTO, FHWA, and TRB could support research
to document success stories and achievements in environmental performance
specific to those functions. The results could be highlighted in conferences,
workshops, and other events that are attended by leaders and staff of those
other DOT functions, including AASHTO Standing Committees and
Subcommittees.
When a state DOT has a criticism or frustrating experience with an
environmental resource agency or FHWA, it can be an opportunity to make
positive change. If a state carefully analyzes the specific problem, it may be
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able to develop specific and constructive recommendations for change, to avoid
a recurrence. Some issues and recommendations may warrant elevation to a
higher level, to gain a broader perspective and possibly a broader solution.
Additional Research:
Given the lack of evidence of improved environmental review times, it would be
helpful to conduct follow-up work (possibly through intensive focus groups) on
these questions: To what extent have state DOTs made a significant effort to
integrate environmental budgets, scheduling, resource allocation, performance,
and information management within the corporate project delivery process?
Have these efforts reduced project delivery time? What has worked? What has
not worked?
How are state DOTs funding higher levels of environmental stewardship,
including environmental mitigation, environmental enhancements, and improved
internal environmental databases, training, and staffing? While this question was
posed during the 11 state interviews, the responses were rather general.
Further research would be valuable on the costs of environmental stewardship
over time and viz a viz the total DOT budget, and on the sources of funding for
these costs. This would probably need to be a fairly significant research project.
How were state DOT environmental functions affected by the economic recession
of 2008-2009 (and perhaps beyond)? Were environmental budgets and staff
curtailed? How was environmental stewardship and streamlining affected? If
there were fewer new capacity projects entailing NEPA work during this period,
were environmental staff redirected to other environmental work? Were efforts
made to preserve the environmental competencies that many DOTs have worked
hard to build?
What are some best practices in providing environmental training – both for
state DOT environmental staff and also for other staff in the state DOT
(planners, designers, project managers, executives, maintenance staff, etc.)?
What is the nature of the training? How many hours per year? How frequent is
it? How does a state know if its environmental training program is effective?
How many employees are trained? On what subjects? Is any of the training
conducted jointly or in cooperation with resource agency staff?
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5.0 REFERENCES
1. Townsend Consulting Group, “Promoting Environmental Sensitivity, Business
Organization and Operations -- Volume 1: Private Sector Companies, and
Volume 2: State Departments of Transportation,” unpublished FHWA report,
available from FHWA Office of Project Development and Environmental Review,
undated, but prepared in the early 1990s.
This study sponsored by the FHWA looks at practices to promote
environmental sensitivity in both private sector companies and state DOTs.
It identifies the key conditions for environmental sensitivity and evaluates the
way in which companies and DOTs meet those criteria. The report includes
an analysis on how study findings from the private sector organizations can
be applied to state DOTs.
2. Amekudzi, A. and Meyer, M., “Consideration of Environmental Factors in
Transportations Systems Planning,” NCHRP Report 541 (Project 8-38). 2005.
The authors present an approach for integrating environmental stewardship
into transportation planning and decision-making. Most relevant to this
project is a discussion of institutional strategies to implement change, which
include ensuring top management support, conducting an organizational
assessment, changes in standard operating procedures and defining benefits.
This document provides a list of steps that DOTs can take to put such a
system in place.
3. Emerson, D. and Hoeffner, C., “Improved Linkage Between Transportation
Systems Planning and the National Environmental Policy Act (NEPA),” NCHRP 8-
36, Task 48, J anuary 2006.
This report looked at the way DOTs are organized to facilitate the NEPA
process. One of the main conclusions is that DOTs should be organized in a
way that facilitates coordination between the planning department and the
NEPA compliance staff, preferably in the same department. This way,
environmental considerations become a factor before projects are selected
for development.
The report also discusses organizational hurdles to collaboration, such as
differing missions or cultures or unwillingness to provide information.
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
Achieving Environmental Stewardship and Streamlining
Page 80
4. Kober, W., “Strategies to Integrate Environmental Stewardship into ADOT’s
Business,” October 2004. Available:http://www.dot.state.az.us/TPD/ATRC/publications/project_reports/PDF/AZ543.p
df.
This comprehensive plan is designed to make the Arizona DOT a good
steward of the environment. It includes specific objectives and performance
measures on agency-wide and departmental levels.
5. Gaines, L. and Lurie, S,. “Innovation in Environmental Streamlining and Project
Delivery: The Oregon State Bridge Delivery Program.” Oregon Department of
Transportation, J anuary 2007.
This article analyzes lessons learned from Oregon’s award-winning bridge
delivery program, a model of environmental streamlining. The report outlines
the nine best practices/lessons learned from the program.
6. Sharma, S, “Managerial Interpretations and Organizational Context as Predictors
of Corporate Choice of Environmental Strategy.” The Academy of Management
J ournal, Vol. 43, No 4, August 2000, pp. 681-697.
This article highlights the human dimension in an organization’s
environmental strategy. I t describes the continuum of interpretation of
environmental issues by management from being viewed as an opportunity
to being viewed as a threat. The article also presents the continuum of an
organization’s environmental strategy from compliance through voluntary
actions. The authors argue that the more management views environmental
issues as an opportunity, the more their strategy involved voluntary actions
rather than simply compliance. Clearly, more voluntary actions lead to better
stewardship. Furthermore, the article discusses management methods, such
as the amount of slack given to employees and whether environmental
consideration appear in performance reviews, as predictors of the level of
voluntary actions in an organization’s environmental strategy.
7. Florida, R., Atlas, M., and Cline, M., “What Makes Companies Green?
Organizational and Geographic Factors in the Adoption of Environmental
Practices,” Economic Geography. Vol. 77, No. 3, J uly 2001, pp 209-224.
This article focused on factors that can play a role in a manufacturing facility
adopting environmental innovations. Factors that are positively correlated
with environmental innovations in this context are overall resources,
environmental resources (such as experienced staff) and performance
monitoring systems.
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
Achieving Environmental Stewardship and Streamlining
Page 81
8. Lockwood, S., “Factors Affecting the Future State of DOTs as Institutions,”
NCHRP 8-36, Task 12B, Part 2, 2001. Available:http://www.transportation.org/sites/planning/docs/nchrp12A.doc
This document looks at a number of factors, including environmental
regulation and stewardship trends, and their impact on the state DOT. The
paper recommends that AASHTO consider institutional issues as well as
technical/programmatic considerations in its strategic plan. Reorganizations,
streamlining and partnering are some of the institutional developments
discussed in the paper. Steve Lockwood also discusses precedents in other
networked public service sectors – telecommunications, power, and
water/wastewater – which can be studied further for their efforts in
environmental stewardship and streamlining.
9. Bracaglia, F., “Monitoring, Analyzing, and Reporting on the Environmental
Streamlining Pilot Projects,” NCHRP Project 25-24, November 2005.
This project analyzed ten selected pilot projects in environmental
streamlining to come to conclusions regarding environmental streamlining in
general and best practices.
10. Dechant, K. and Altman, B, “Environmental Leadership: From Compliance to
Competitive Advantage,” Academy of Management Executive. 1994, Vol. 8 No.
3.
This article looks at firms that have turned their environmental leadership
into a competitive advantage. Some common themes among companies
studied are:
o Have a comprehensive environmental management
framework/strategy for the entire organization
o Include the environment in the statement of mission and/or
values
o Stay ahead of regulations
o Adapt to continuously improve processes
o Offer training or another employee growth component
o J ustify short term costs with long term gains
11. Venner Consulting and Parsons Brinckerhoff, “Environmental Stewardship
Practices, Procedures, and Policies for Highway Construction and Maintenance,”
NCHRP 25-25 Task 4, September 2004. Available:http://www.trb.org/NotesDocs/25-25(4)_FR.pdf
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
Achieving Environmental Stewardship and Streamlining
Page 82
This is a giant compendium of best practices in all areas of highway
construction and maintenance. Notably, Chapter 2 of the of the document
focuses on organizational practices to promote environmental stewardship.
These practices include training and certification programs, performance
measures, environmental management systems and standardized
procedures.
12. Twaddell, H. and Emerine, D, “Best Practices to Enhance the Transportation-
Land Use Connection in the Rural United States,” NCHRP Report 582, 2007.
This report provides guidance for rural areas seeking to integrate land
use and transportation. It includes key principles for successfully
integrating land use and transportation, specific approaches for a range
of rural community types, and investment strategies and programs to
support community development and livability in combination with
improved transportation.
13. FHWA, Environmental Excellence Awards, 1997-2007. Available:http://www.fhwa.dot.gov/environment/eea.htm
Environmental excellence awards provide case studies of effective
implementation of environmental goals. The FHWA awards from streamlining
and environmental leadership are especially relevant to this project. An
analysis of the past few years of these awards demonstrates that the primary
driver of excellence is interagency cooperation.
14. AASHTO, “Accelerating Project Delivery.” August 2007. Available:http://www.transportation1.org/tif7report/tif7.pdf
This paper by AASHTO discusses ways to accelerate project delivery. One
chapter is dedicated to accelerating planning and environmental reviews. In
that chapter, a number of legislative and policy recommendations are made
and the authors present case studies of successful EISs written in a short
timeframe. Some of these case studies have interesting ideas, such as the
Denver T-Rex project which co-located its project team and consultants.
15. AASHTO, “DOT-Funded Positions and Other Support to Resource and Regulatory
Agencies, Tribes and Non-Governmental Organizations for Environmental
Stewardship and Streamlining Initiatives,” May 2005. Available:http://environment.transportation.org/center/products_programs/dot_funded.as
px
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
Achieving Environmental Stewardship and Streamlining
Page 83
As of 2005, more than 68% of DOTs funded positions in external support
agencies for environmental review purposes; one third are in federal
agencies and two thirds are at state resource agencies. The article discusses
the results of a survey done to all 50 state DOTs regarding this practice.
16. US Department of Transportation, “Applications of Geographic Information
Systems for Planning and Environment Linkages: Peer Exchange Summary,”
October, 2007. Prepared by the Volpe National Transportation Systems Center
for the Federal Highway Administration. Available:http://www.gis.fhwa.dot.gov/documents/PeerEx_Report_112607.pdf
This is a summary of a peer exchange meeting that was organized by the
FHWA in follow up to the work done to link planning and NEPA, like the
Emerson article above. At the exchange, the peer DOTs discussed how
they can use GIS as a tool to better link planning and the environment.
17. Vonderohe, A., Travis, L., Smith, R., and Tsai, V., “Management Guide for
Implementation of Geographic Information Systems (GIS) in State DOTs,”
NCHRP Research Results Digest 191, 1993.
This report provides information on GIS and GIS for transportation (GIS-
T) and describes the factors involved in planning and implementing GIS-T
successfully.
18. FHWA, Successes in Stewardship Newsletters, 2001 and beyond.
Available:http://environment.fhwa.dot.gov/strmlng/es4newsltrs.asp
Relevant recent topics include process improvements for NEPA compliance
and adapting environmental procedures for alternative project delivery
methods.
19. AASHTO, “Programmatic Agreements Library Database.” Available:http://environment.transportation.org/pal_database/. Also, “Programmatic
Agreement Toolkit – A How-To Guide.” Available:http://environment.transportation.org/center/products_programs/programatic_agr
eement.aspx
This is an excellent source of programmatic agreements used by state DOTs,
plus a detailed, step-by-step “how-to” guide to creating a programmatic
agreement.
20. Schilling, M. and Schulz, M., “Improving the Organization of Environmental
Management: Ecosystem Management, External Interdependencies and Agency
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
Achieving Environmental Stewardship and Streamlining
Page 84
Structures,” Public Productivity and Management Review. Vol. 21 No. 3, March
1998, pp 293-308.
According to the article, government agencies often have outdated
organizational structures that do not match their current missions.
Organizational theory suggests that organizations group inter-dependant
functions together. The article applied this theory to three environmental
agencies in Washington State and recommended that they be combined and
grouped by ecosystem (coastal, mountains, etc.) The thinking in this article
may encourage the researchers on this project to consider interdependencies
between state DOTs and other agencies.
21. FHWA, “Eco-Logical: An Ecosystem Approach to Developing Infrastructure
Projects,” April 2006.
This document provides guidance to infrastructure agencies on doing
ecosystem-level environmental planning instead of a project-by-project
approach. It outlines and eight-step integrated planning process, an
alternative approach to mitigation decisions and relevant performance
measures.
22. AASHTO, "Developing and Implementing an Environmental Management System
in a State DOT," September, 2007.
www.environment.transportation.org/pdf/practitioners_handbook08.pdf
Environmental Management Systems (EMS) can lead state DOTs to
measurable improvements in both environmental stewardship and
streamlining benefits. According to the article, the definition of an EMS is “the
organizational structure and associated responsibilities and processes,
procedures and tools for integrating environmental considerations and
objectives into the ongoing management decision-making processes and
operations of an organization.”
23. Dotson, J , "Development of an Environmental Information Management System
for Transportation Agencies," NCHRP project 25-23 (2), 2002. Available:http://www.trb.org/news/blurb_detail.asp?id=7310
This paper summarizes work done to create a prototype software that can be
used as part of an EMS. While the article focuses on the specific practices of
managing environmental study information, Appendix A provides a list of
representative environmental management initiatives at a number of state
DOTs.
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NCHRP 25-25, Task 37 Organizational Structures and Management Practices for
Achieving Environmental Stewardship and Streamlining
Page 85
24. Larson, K., Hess, K., D'Avanzo, E., Stanley, M., and Sumpter, M.. “Successful
Efforts in Environmental Streamlining: Eight Case Studies in Project
Development: An Introduction.” Available:http://www.environment.fhwa.dot.gov/strmlng/casestudies/index.asp Accessed
29 October 2007
This authors of this study noted lessons learned from each of the case
studies, as well as recurring lessons from the group of studies. Examples of
recurring lessons are creating interagency agreements and conducting
environmental assessments prior to beginning the NEPA process.
25. FHWA, “State Practices Database.” Available:http://www.environment.fhwa.dot.gov/strmlng/es3stateprac.asp Access May 25,
2009.
This FHWA website provides a catalogue of environmental streamlining
practices.
26. AASHTO, American Consulting Engineers Council, and FHWA, "Improving the
Quality of Environmental Documents," May 2006. Available:http://environment.transportation.org/center/products_programs/improving_qual
ity_nepa.aspx
This report provides advice on how to improve the quality of NEPA
documents to help practitioners comply with both the spirit and the letter of
the NEPA statute. It provides the following definition of quality: Quality
NEPA documents effectively “tell the project story” through clear, concise
writing; effective organization and formatting; and effective use of visual
elements. Documents must explain project decisions in simple, concise terms
that are understandable to the public, while clearly demonstrating compliance
with regulatory and legal requirements.
27. Crossett, J , “Synthesis of Data Needs for EA and EIS Documentation,” NCHRP
25-25, Task 1, J anuary 2005.
The relevance of this report is its conclusion that changes are needed to how
NEPA documents are done. As one of the most important functions of a DOT
environmental unit, this can well have organizational implications.
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