234.1 Access to Interstate Highways

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Useful Documents
Sample Outline for Interstate System Access Requests
FHWA Policy Prompt List
Interstate Design Prompt List
Interstate System Access Informational Guide

New or revised access to an interstate highway requires approval from FHWA. A change in access is considered as any modification to the control-of-access for right of way on an interstate highway. This includes locked gate access, access to ramps or collector-distributor roadways or other facilities that are functionally part of an interstate highway. Re-configuration of an interchange that affects the operational characteristics of an interstate highway is also considered as a change in access. Only MoDOT, as the owner and operator of interstate highways in Missouri, is authorized to submit a request for new or revised access to FHWA for consideration. Proposed changes in access to interstate highways in Missouri are presented to FHWA in the form of an Access Justification Report (AJR).

Due to the complexity of adding or revising Interstate access, FHWA has developed an Interstate System Access Informational Guide, hereafter referred to as "the Guide", that clearly defines and explains what should be included in the request for new or revised access and the AJR. The analysis of Interstate System access changes requires the consideration of many factors including the planning, environment, design, safety, and operational context for any proposed changes. Quantifying and comparing the impacts of each of these key factors is an important aspect of ensuring any change in access protects the integrity of the Interstate System. The purpose of the AJR is to provide the information necessary for FHWA to make informed decisions on requests for new or modified access to an interstate highway. The Guide recognizes that AJRs should be evaluated as part of an integrated transportation system. The type of analysis necessary will vary on a request-by-request basis. At a minimum, the system analysis will include upstream and downstream interchanges, as well as the local road system feeding into the affected interchanges.

The requirements of the Guide has increased the level of detail to be included in AJRs and has also tied the approval of the AJR with the NEPA approval. Previously these two actions were provided as separate approvals by FHWA. The Guide states "The FHWA approval of Interstate System Access Requests constitutes a Federal Action, and as such, requires that the National Environmental Policy Act (NEPA) is followed." In many instances the requirements for very specific details in the AJR are in direct conflict with MoDOT's desire to have the greatest flexibility possible and very generic details included in the NEPA approval. Through consultation with staff at the FHWA Missouri Division, the following guidance has been developed.

The AJR approval can be provided in a two-step process to help MoDOT manage risk and provide flexibility. This allows the AJR to be prepared and submitted for FHWA review in a corresponding two-step process for those projects where it will be beneficial. The Step 1 approval is a finding of Operational and Engineering Acceptability. The Step 2 approval is the Final Approval. Often both of these approvals are done at the same time, but it is not necessary that they occur simultaneously. Compliance with the NEPA procedures need not precede the determination of engineering and operational acceptability. However, final approval of access change cannot precede the completion of NEPA. Once NEPA has been completed, approval of the access change is granted as long as there are no changes to the location or design of the accepted concept. This two-step process can be used with both Design/Build and traditional Design/Bid/Build projects. Each request for new or revised access and the most efficient method for preparing the AJR (one step or two-step process) will be determined from collaborative discussions between MoDOT and FHWA.

The AJR document prepared for Step 1 is intended to identify fatal flaws and to help ensure the investment in the subsequent phases of production, including preparation of any environmental documents, is not wasted. This document can be thought of as a draft AJR that takes a high level look at the traffic analysis for the types of access changes that are being considered without the detailed design information that will be necessary for the Final Approval. More than one alternative, possibly a range of interchange alternatives, can be included in the Step 1 AJR document. An example description for an access change at this stage could be: "a new full access interchange will be provided between mile marker XX and mile marker XX and provides all four movements". The Step 1 AJR analysis may be used to provide multiple interchange alternatives, otherwise noted as the "box," for final design.

Contents

234.1.1 Step 1 AJR Approval

The finding of Operational and Engineering Acceptability requires consideration of all of the Eight Policy requirements identified in the Guide, but they may be discussed at a high level. Including the identification of LOS for all movements in both the build and design years. These considerations provide confidence that there are no fatal flaws in the proposed change in access, and that those alternatives can reasonably be included as part of the NEPA document. As a part of this early review, it is not anticipated that environmental studies will be completed; however, the largest footprint of the multiple interchanges identified in the AJR must be reviewed and should contain adequate information to identify potential flaws, substantial environmental requirements and the potential for public controversy. If potential flaws are identified, close coordination between the FHWA and MoDOT is needed to determine whether the project should move forward, and if it does, under what conditions.

234.1.2 NEPA Approval

Assuming that no fatal flaws or any other environmental concerns are identified, FHWA can then provide the appropriate NEPA approval (CE, FONSI, ROD). Even though the AJR information prepared for the Step 1 approval may contain data for a range of alternatives, the NEPA approval must be based on the selected preferred alternative included in the NEPA document. Therefore, the preferred Step 1 AJR interchange must be identified and form part of the preferred alternative. The Step 1 AJR analysis of multiple alternative interchanges can be included as a technical appendix within the NEPA document.

Once the Step 1 AJR and NEPA approvals are received, the Step 2 AJR document can be prepared. Preparation of this document will occur when the project design has progressed enough to provide the detailed engineering analysis of the preferred alternative included in the NEPA document. The analysis from the Step 1 AJR document should be the starting point for the Step 2 AJR document and should build on those details to provide the detailed engineering analysis required by the Guide.

234.1.3 Step 2 AJR Approval

Final Approval can only be given by the FHWA upon successful completion of the NEPA document, even if no Federal funds are used. This Final Approval of the AJR is contingent on the consistency of the chosen NEPA alternative with the proposed access change approved in Step 1. FHWA regulations (23 CFR 771.113 (a)) state that “final design activities, property acquisition …” (with exceptions), “…or project construction shall not proceed” until FHWA accepts the general location and concepts as described in the environmental document. If the Step 2 AJR includes any changes to concepts approved in the Step 1 AJR or the preferred alternative included in the NEPA document a re-evaluation of the NEPA document will be required.

Possible risks for MoDOT associated with the two-step process are those AJRs that require FHWA HQ approval. FHWA HQ does not provide the Step 1 AJR approval. It is only reviewed and approved at the Missouri Division level. However, the Missouri Division will coordinate and discuss the Step 1 AJR with FHWA HQ to ensure that they have a good understanding of any issues involved with the AJR. Hopefully this coordination will help facilitate a successful Step 2 AJR approval by the FHWA HQ.

For Design/Build projects the review times for FHWA are established in the Design Build Program Agreement. For projects utilizing Alternate Technical Concepts or other innovative contract delivery methods, AJR review times for MoDOT and FHWA will be established in the project specific partnering agreement between MoDOT and FHWA.

234.1.4 Additional Guidance

Completion of the AJR in accordance with the Interstate System Access Informational Guide does not guarantee approval of any new access or changes to the access. However, it does provide a framework for the analysis of the potential benefits and consequences of the proposed project. Regardless of the funding source, since approval is considered a Federal Action, the project's final approval is contingent on the successful completion of the same process as used in the planning, engineering and environmental phases for any federally funded project. The improvements included in the AJR also must be adopted as part of a conforming transportation plan and transportation improvement program (TIP) or a STIP in non-urban areas to receive final approval.

A more detailed explanation of the process for reviewing and approving an AJR in Missouri can be found on the FHWA Missouri Division website. Information describing access changes that will require an AJR as well as those that will require something less than a complete AJR can be found at this location. This site should also be referenced to determine the appropriate level of FHWA approval required for the particular access change (FHWA Headquarters Office or FHWA Missouri Division Office).

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