Category:126 Location Study and Alternatives Analysis
126.1 Introduction
| Forms and Figures |
| Location Study Report Format |
| Request for Environmental Services (RES) |
| CE2 Form Example |
| Design Exception Form |
| Typical Roadway Sections |
A location study (LS) is required for all projects with an environmental impact statement (EIS), an environmental assessment (EA) or of a complexity that precludes the use of a conceptual study. A location study is prepared to determine the most advantageous location and type for a proposed highway improvement based on project purpose and need and on engineering and environmental constraints. The location study and the environmental analysis are developed in conjunction with each other. They are not stand-alone documents.
A location study is not a programming activity; rather it is a method to determine the most advantageous way of fulfilling the program intent. This does not preclude the necessity for sometimes studying additional portions of the routes beyond the limits of the section programmed or recommending a type of improvement not originally the intent of the program. Any deviation from or extension to program intent is set out clearly in the study.
A glossary of terms used frequently in this article is available.
126.2 Location Study Preparation
The Location Study (LS) consists of two parts: the Purpose and Need (P&N) and the Alternatives Analysis. The preliminary P&N is developed early in the study, prior to holding a prelocation study meeting with public and agency input (SAFETEA - LU Section 6002 specifically addresses these requirements). MoDOT and FHWA can modify the P&N over the life of the project. The Alternatives Analysis section is prepared with public and agency input following the prelocation study meeting and is combined with the P&N to form the LS. The district submits the LS to the liaison engineer (with a copy to the environmental section) in Design. All information developed for the LS must consider the environmental constraints identified during scoping prior to the prelocation study meeting as well as all subsequent substantive information developed or received. The district submits the LS to the liaision engineer in the Design Division.
126.2.1 Preliminary Information Needed
| How Does MoDOT Evaluate the Range of Alternatives? | ||||||||||||||||||||||||||||||||||||||||||||
| To narrow the preliminary range to a reasonable range of alignments, MoDOT evaluates public input and technical, cultural and environmental data. | ||||||||||||||||||||||||||||||||||||||||||||
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Upon initiation of a LS, the district submits two copies of a written request for environmental services to the Design Division requesting preliminary screening and early constraint identification for a specified study area. The district will define the study area limits, in coordination with the environmental section of the Design Division, including logical termini, that should be large enough to accommodate the possible range of alternatives which could be considered throughout the study. The necessary study area will be unique to each project and will vary in size based on length of the project, scope of possible improvement, the identified needs and the known physical constraints. The study area is drawn on aerial mosaics and/or USGS quadrangle maps and labeled "Study Area Limits". Two copies of the maps should be submitted with the RES. Environmental and historic preservation specialists will use these maps to research and screen the area for known environmental and cultural constraints. This information will be returned to the district for use in the location study and for use at the prelocation study meeting and the agency scoping meeting. This information is requested at least 2 months prior to the desired date for the prelocation study meeting or the agency scoping meeting, to allow ample time for the screening and constraint identification to be completed.
126.2.2 Consultant Prepared Location Study
In the event the district does not believe they have adequate staff to prepare the LS, the district will submit a draft P&N document to the Design Division as part of the documentation used to support the need for additional professional services. If necessary, Design will submit the draft P&N document to the FHWA for review and comment prior to accepting the draft P&N. Once accepted by the Design Division, the documentation to justify the need for additional professional services will be submitted to the Professional Services Committee for their concurrence. After concurrence of the Professional Services Committee, the procedures set out for consultant selection and contract implementation will be followed for the solicitation and selection of the consultant. As part of the LS preparation (and throughout the course of the project), the draft P&N may be modified and/or updated as additional information is known.
126.3 Purpose and Need
District and Central Office staff will work together and with others to formulate a project P&N document. The P&N is extremely important in the development of any project since it is the basis that establishes why MoDOT is proposing to spend large amounts of taxpayers' money. In other words, it justifies the need. The project P&N is the basis for the range of alternatives that will be considered, their in-depth analysis and the ultimate selection of a preferred alternative. Without a well-defined, well-established and well-justified P&N, it becomes difficult, if not impossible, to determine the range of reasonable and prudent alternatives to study. More importantly, it may be impossible to dismiss the "no-build" alternative as undesirable.
The P&N for a project is comprehensive and specific. This document completely describes the existing facility, if there is one, and all of the facility need plus local and regional needs associated with the facility. The P&N identifies the transportation problem(s), safety issues, roadway deficiencies and planned development. Other possible elements are system linkage issues, modal interrelationships, and legislative directive. Each project needs to be evaluated individually to determine which elements contribute to its P&N, which will be unique to that project. For a very simple project, the entire P&N may be existing deficiencies, as with some bridge replacement jobs. For complex projects, the P&N may be a combination of all of the above items and additional needs not listed here.
It is possible that after completing a thorough P&N evaluation, it will be determined that a P&N sufficient to justify a project does not exist at this time. In this event, the process and decisions reached are documented and brought to the attention of public officials, other agencies and/or the public, as necessary. It is for this situation that we do not begin consultant negotiations to provide for the design of an improvement before the draft P&N is endorsed by MoDOT and FHWA.
The draft P&N, reviewed by the Design Division and the FHWA, is made available at the prelocation study meeting. Input from the public and others (e.g., agencies) at the prelocation study meeting may reveal information that causes the P&N to be revised. The P&N may continue to change until the final environmental document is completed. The P&N begins with a detailed description of the project area and the existing facility type. The remainder and bulk of the document details the project need.
126.3.1 Project Description
Project History
This section includes a summary of how the project was identified in the planning process and any public involvement to date including involvement with any Regional Planning Commissions or Metropolitan Planning Organizations (MPOs). In an urban area, include a discussion of why the project was included on the current Regional Long-Range Transportation Plan. The project history highlights the relative importance of this project to the local area, the region and the state. The planning process itself might have generated a P&N for a project. As long as that was done according to Federal requirements, and as long as it is reviewed and confirmed, that planning P&N can be adopted at this stage (SAFETEA - LU Section 6002 specifically addresses these requirements).
Program Data
The most current program data is tabulated. This information is used as a comparison to the cost estimates developed for the feasible alternatives. The fact that a project has been programmed is not justification for the purpose and need. The solution that has been programmed may not address the purpose and need either. The purpose and need is defined for the study independent of the program data, and alternatives should address the purpose and need for the study, not fulfill the program.
Description of Existing Transportation Facility (ies)
The description of the existing facility (ies) should include tables detailing the condition of the roadway and any bridges and railroad crossings in the project limits.
Proposed Design Criteria
The study considers both construction year (the year in which construction begins) and design year (normally 20 years after the construction year) traffic including residual traffic remaining on the existing facility. Traffic data for existing routes near the proposed corridor, as well as all intersecting state routes, need to be analyzed. All traffic information is requested from the Transportation Planning Division as early as possible so that the traffic information is available as the study progresses. Early submittal of the request is especially important where an origin and destination (O & D) study may be necessary.
Basic design criteria (reflecting functional classification, traffic and terrain) used to evaluate the alternatives considered in the study are contained in numerous EPG locations:
- 230.1 Horizontal Alignment
- 230.2 Vertical Alignment
- 231 Typical Section Elements for Roadways
- 232 Facility Selection
- 233 At – Grade Intersections
- 234 Interchanges
The district traffic engineer is consulted for the anticipated posted speed of the proposed facility. The anticipated posted speed is used to select the design criteria discussed in location study.
It is desirable to design rural divided roadways with a 70 mph (110 km/h) posted speed. Roadway sections, which contain features that cannot satisfy these design criteria are addressed by the Design Exception Process. The majority of the roadway can still be designed to the preferred design criteria in an economical manner through use of this method. However, where a considerable percentage of the roadway's length is in the "rolling" or "mountainous" category, the roadway should use the corresponding design criteria for the terrain encountered with appropriate design exceptions.
System Linkage
A brief discussion of the link that this project plays in the Missouri Transportation Plan, including a description of the facility at each terminus, is provided. All major actions (not just transportation activities whether federal, state or local) in the vicinity of this project are discussed. This discussion includes what stage in NEPA review these projects are.
If there is a gap between improvements so that logical termini are not readily apparent, the report documents the schedule for closing the gap between improvements. Logical termini can include other state highways or traffic generators in the project area. Logical termini must be set on all projects so that the section being studied demonstrates independent utility and does not require actions beyond the scope of the proposed action.
It may be that system linkage is also an element of the P&N. As such, there needs to be a separate discussion of system linkage in the report. This section is strictly to clarify how and where this project fits into the state of Missouri highway system.
126.3.2 Overview of Purpose and Need
A general overview, or listing, of the elements of the P&N is required. A detailed discussion of each item should follow the list. Only list and discuss those items that are considered to be a problem associated with this project. For this discussion, safety and capacity are assumed to be elements of all P&N statements. However, if a project does not have a safety or a capacity problem, then the crash data and the level of service (LOS) data is summarized after System Linkage and before the Overview of Purpose and Need. For all other items listed and described hereafter, if they are not a need for the project, then they do not need to be included as an element of the project’s P&N.
For long projects, different sections may have different P&N's. For example an add-a-lane project that includes a bypass of a community may have one P&N for the rural add-a-lane sections and a separate, different P&N for the urban bypass section.
Crash Data and Safety Enhancements
A crash rate is calculated, as shown in EPG 128 Conceptual Studies, for each project and compared to the statewide rate for a similar class of highway. Crash rates are calculated for logical sections of long corridors based on change in traffic volume or site conditions. The statewide rate can be obtained from district traffic personnel. A 5-year injury rate and fatal crash rate are also calculated by substituting the 5-year total injuries value or total fatalities value for the 5-year total crash value in the formula. If these rates are greater than the statewide rate for a similar class of highway, the comparison is included in the study. The statewide rates used in the assessment are provided in the report.
Breaking a long project into sections will help in evaluating why crash rates are high. There may be a high crash rate going through a city while the rural sections show no problem. Additionally, sometimes crashes will be concentrated at specific intersections that might imply spot locations with safety problems rather than the entire route having a problem.
As an element of safety enhancements, bicycle and pedestrian facilities that are provided as part of the project are discussed.
Roadway Capacity
Existing roadway capacity is discussed in terms of Level of Service (LOS) as calculated with the Highway Capacity Software (HCS). Calculations are presented for the existing facility (the no-build option) for both construction year and design year. If there will be many years that pass between the date of the study and the anticipated construction year, an analysis of existing traffic volumes is also included. LOS is evaluated at all intersections with state highways or with cross roads having sufficient traffic to warrant concern. The LOS is also calculated for the ramps, the ramp termini and the weaving areas of an interchange, when applicable.
Based on the project length, change in facility conditions or changes in traffic volumes, the LOS calculations are done on logical sections in sequence. All information is summarized and discussed as it relates to the need of the project. Generally, MoDOT considers a LOS of C (off-peak) acceptable for rural roadways and a LOS of D (off-peak) acceptable for urban roadways in the design year. However, each project must be considered individually.
Roadway Deficiencies
A complete discussion and tabulation of roadway deficiencies needing correction is presented. This may include substandard vertical grades, horizontal or vertical curvature, pavement or shoulder width, stopping sight distance, clear zone, and so on. Any deficiencies discussed are tabulated and/or illustrated in some manner so the reader knows where the deficiencies occur and what percent of the total length is considered deficient.
Additional Justification
Additional information such as needs associated with system integrity, flooding, legislative directive and public request, planned development or any other identified need may be used to justify the P&N of the proposed improvement. Each item used is discussed separately and in sufficient detail so the reader can understand the extent of the concern.
126.4 Alternatives Analysis
This portion of the LS contains documentation of how the study has progressed from initiation of a P&N to a preferred alternative. Beginning with the first wide range of alternatives considered, which are developed before, during and following the prelocation study meeting and the agency scoping meeting, this section explains in detail all alternatives considered in the development of the project in enough detail to justify why they were either dismissed from further study, modified, or carried forward. Sketches (these can include corridors on a map, typical sections etc.) of all ranges of alternative development should be included. As the range of alternatives is studied and screened down to a reasonable number, the screening process used is documented for inclusion within the environmental document.
Alternative corridors are defined by the district with input from the environmental section of the Design Division and are set at a width that will accommodate the maximum expected right of way width plus some additional width to allow for minor modifications. The width of the corridor must also be sufficient to address potential environmental impacts caused by the project. For example, for a new four-lane divided highway, the typical right of way width required is 250 ft. (76 m), but in an area of hilly terrain it may be necessary to acquire 350 to 400 ft. (107 to 122 m) of right of way to accommodate the cut and fill slopes. In this case, the alternative corridor width could be 400 ft. plus 200 ft. for adjustments, which amounts to a 600-foot corridor (122 m plus 61 m for a 183 m corridor). Each project will need to be analyzed for what the district designer and the environmental specialist believe to be a reasonable corridor width. In the case of a complex EIS, it may be advisable to look at preliminary study alternative corridors of 1000 ft. (305 m) or more that are later adjusted to final study alternative corridors of possibly 500 feet (152 m). As the study progresses, environmental analysis is performed on these alternative corridors and ultimately detailed analysis is performed on the corridor for the preferred alternative. So it is imperative that the corridors be a reasonable width minimizing the work effort required but wide enough to accommodate minor adjustments in alignment that normally occur during the study or preliminary design. The final alternative corridors that are analyzed for each alternative are shown and labeled on the LS exhibits as "Corridor Limits". During all phases of study, corridors need to accommodate the ultimate expected facility even if the initial project will be only a stage of the ultimate.
Significant points along the routes are numbered or labeled on the maps or mosaics for easy reference in the discussion of the alternatives. These points may be at intersections, bridges, county lines, direction reversals, alternate crossings, or any other point deemed significant to the route.
Within the corridor limits of the preferred alternative, a full environmental evaluation will have been completed prior to the final environmental document being approved. However, this does not mean that the corridor is "clear" of future environmental obligations. Alignment modification within the final corridor may impact areas or sites previously evaluated and identified, but not "cleared" because the original right of way limits needed would not have impacted it. The final corridor identified will clearly show the area studied and evaluated as a part of the environmental document preparation. Any modification to the alignment that would shift the improvement footprint outside of this corridor must go through additional environmental analysis as if it were a new corridor.
126.4.1 Final Study Alternatives
The LS generally includes consideration of several reasonable alternative locations along with the "no build" alternate. In urban areas, a TSM alternative may deserve consideration. The minimum number of "build" alternates carried forward in the report for consideration is two. The alternates proposed must be based on engineering and environmental constraints and must be reasonable build alternates that MoDOT would construct. Sufficient information must be provided concerning each alternate to clearly establish the fact that the preferred alternate is the best.
126.4.2 Cost Estimates
Complete right of way, utility adjustment, and construction cost estimates are an essential part of the analysis of alternates. Estimates are prepared for each alternate under consideration. All estimates are broken into sections that correspond to the description of the alternates. The cost estimates are broken into the following categories:
- Grading
- Paving
- Bridges
- Miscellaneous
- Utilities
- Right of Way (include relocation costs as a separate item)
- Environmental Mitigation (if substantial)
Also include with the estimates a tabulation of displacements (including businesses) for each alternate. This includes type and number of people (including employees) involved.
126.4.3 Satisfaction of the Purpose and Need
All final study alternates must be discussed in terms of how they satisfy the stated P&N of the project. In the event that capacity is stated as an issue in the P&N, then there needs to be a capacity and operational analysis of the final study alternates. LOS is calculated for logical sections for both construction year and design year traffic for the proposed facility. If the proposed facility is on relocation and the existing route will remain in service, the LOS must also be calculated for the traffic volumes (construction year and design year) remaining on the existing route. LOS must also be calculated for all major intersections for both years. When staged construction is involved, LOS must be calculated for the various stages.
126.4.4 Land Use Within the Study Area
This refers to how land within the study area is used. It could include agricultural, commercial, industrial, residential, conservation or others uses, or a combination of these.
Special land uses are identified. They generally include schools, churches, airports, golf courses, water and sewage treatment plants, commercial areas, watershed projects, undisturbed areas of natural flora, and other features of environmental significance.
Public lands (possible Section 4(f) or 6(f) lands) are defined as publicly owned lands having national, state or local significance that may include any of the following:
- Public parks and national forests.
- Recreational areas.
- Wildlife and waterfowl refuges.
- Historic sites (privately or publicly owned).
- City parks and local facilities available to the general public.
- Department of Conservation land.
Section 6(f) lands are parklands that have been funded with monies from the Land and Water Conservation Fund through the National Park Service. The Design Division has a current listing of parks and recreation areas, by county, that have Section 6(f) funds invested in them.
A description of the public areas or known historic sites, including maps, boundaries, area, master plans, local contacts, etc., are provided in the report so that coordination can begin with the FHWA regarding Section 4(f). A thorough investigation is made to determine the effect of the proposed location on these developments and lands. Land use plans and comprehensive traffic studies should be considered. Alternate locations must be considered to avoid Section 4(f) or Section 6(f) lands to possibly justify why an alternate impacting such areas must be selected. The Design Division will assist the district in coordinating efforts involving public lands.
The conceptual stage relocation information, furnished by district right of way personnel for the various locations studied, is summarized in the report. A statement concerning the social, economic, and environmental effects the location will have on any community is included by the Design Division.
Specific locations of above or below ground petroleum storage tanks or other hazardous waste sites are identified. A list of typical land uses associated with hazardous waste sites is available. Every effort must be made to avoid identified waste sites on the selected location unless the cost to mitigate the sites is less than that to avoid them.
When none of the alternates include a significant encroachment on any floodplain, a statement is included to that effect. If any alternate includes significant encroachment on the floodplain, it is identified and discussed in accordance with 23 CFR 650A.
The necessity of Section 404 permits is indicated. A discussion concerning the effect that each of the alternates will have on wetlands is also included.
The presence of any known archaeological and historical sites is described. Any buildings or other structures that are nearly 50 years old or greater, including bridges, are noted.
These factors are an important part of the LS and thorough investigation at the location stage will avoid complications at the design stage.
126.4.5 Construction Impacts
Utilities
A brief discussion is included to describe any major transmission lines, fiber optic lines, pipelines, sub-stations, railroads, water or sewage treatment plants or any other utility of significance in the vicinity of the improvement.
Handling Traffic
The method of handling traffic during construction is an important consideration. The need for short construction bypasses or long route bypasses or route closures is discussed here.
126.4.6 Disposition of Existing Route
The disposition of the existing roadway is considered very early in the preparation of the study. There are many ways in which to dispose of the existing roadway. Some of these may result in the roadway being retained by the Commission for its use and others may result in transfer of the roadway to a local government agency or even total abandonment.
Decisions regarding the disposition of the existing roadway will have a large impact on the amount of effort that needs to be focused on this area of the study. Alternatives which call for the retention of the existing roadway by the Commission will not need the same level of local government agency involvement and amount of discussion in the report as those which call for the roadway to be transferred to another agency.
The discussion of alternatives which call for the existing roadway to be retained by the Commission will need to include the comments of the local government agencies and show that they were taken into consideration while developing the alternatives, but will not require the concurrence of the local government agency in order to be considered viable. Alternatives that call for sections of the existing roadway to become the responsibility of the local government agency will require their concurrence in order to be considered viable. The discussion included in the report for these alternatives should fully discuss the level of effort which has been made to involve the local government agencies in the decision to transfer the responsibility to them and written documentation of their concurrence in that decision.
Where there is a high probability that portions of the existing roadway will not be incorporated into the new facility, but will need to be remain in place to serve local public or private interests, contact with the local governments is made as soon as possible to gain their comments regarding the possible options for the disposition of the existing roadway. In this case, the initial contact with the local governments should occur as close to the same time as the prelocation study meeting or the agency scoping meeting as possible. The local government's comments regarding the disposition of the existing roadway will need to be taken into account as the alternatives are developed for the study. The district is encouraged to begin this discussion early with local officials so the coordination information can be included in the environmental document.
Convey to Local Government Agency
Alternatives which call for the local government agency to accept responsibility for a section of the existing route will need the concurrence of the local government agency before it can be considered as a viable alternative for the study. Even though this may be the best option for disposing of the existing roadway, the alternative will need to be revised to include another method of disposal if the local government agency is not receptive to accepting responsibility for the section of existing roadway.
In order to document that the local government agency has given its concurrence in accepting the responsibility for a section of the existing roadway, some form of written documentation is needed. The best form of written documentation would be an agreement executed by the local government agency and the appropriate department staff that outlines the project in general terms and describes the general location of the sections to be accepted by the local government agency. If an executed agreement cannot be obtained, the next best form of documentation would be a copy of a resolution or an ordinance which conveys the governing body's intention to accept the sections of existing roadways and gives a general description and location of the sections to be accepted and a general description of the overall project.
If neither of these documents can be obtained, a letter from the local government agency, addressed to the district engineer, stating that they agree to accept responsibility for the sections of existing roadway will be acceptable. Even though this form of documentation is not as desirable as the other two, it will convey the intention of the local government to accept the sections of the existing roadway. This letter should also provide a general description of the location of the sections to be accepted and the project in general.
All three forms of documentation should also include language which indicates the local government agency will execute a roadway relinquishment agreement at the time the plans are developed in enough detail to allow the transferred sections to be described in specific terms. The specific terms of the roadway relinquishment agreement will include the right of way limits, station limits of the sections to be transferred, estimated maintenance costs, etc. Therefore, execution of this agreement will not be possible until the Change in Route Status Report has been approved.
Once the written documentation expressing the local government agency's willingness to accept the sections of the existing roadway is obtained, it is included in the study. This documentation may be included as an appendix and referred to in the study.
In the event that the local government agency refuses to accept responsibility for the recommended sections of existing roadway or will not provide the necessary written documentation, the alternative will need to be revised to include some other method for disposal of the existing roadway. These other methods might call for the sections of existing roadway to be retained in the state highway system or to be abandoned completely.
In any case, if none of the other methods for disposal of sections of the existing roadway can be utilized and the local government agencies refuse to accept responsibility for them, then the study must indicate that this alternative is not viable for these reasons. The alternative will then receive no further consideration in the study.
Convey to Adjacent Property Owners
Alternatives that recommend that sections of the existing route be conveyed to adjacent property owners will include a discussion of the efforts that were made to transfer the roadway to a local government agency prior to choosing this method of disposal. The report will focus on the efforts made to contact the property owner and discuss their willingness to accept the section of the existing roadway. If possible, the property owners written concurrence in these decisions is included in the report. If it is not possible to obtain the written concurrence of the property owner, but verbal commitments can be obtained this alternative can still be considered as viable. If the property owner strongly objects to this method of disposal of the existing route then one of the other methods for disposal must be chosen for the alternative to be considered as viable. If no other method of disposal can be utilized, then the alternative will receive no further consideration in the study.
Abandon the Route
When no other method of disposing of the existing route can be found then the option of abandonment should be explored. The report will include a discussion of the opinion of the district counsel or Chief Counsel's Office as to the ability of the department to successfully abandon the existing route. The report will also include discussion of the efforts that were made to seek some other methods for disposing of the existing route and a summary of the discussions with local government agencies and adjacent property owners about the disposal of the existing route. If the legal opinion is that the department can successfully abandon the section of the existing roadway, then this can be considered as a viable alternative for the study. However, if the legal opinion suggests that the department cannot successfully abandon the existing roadway and no other method of disposal can be found, then the alternative cannot be considered as viable. The alternative will then receive no further consideration in the study.
126.4.7 Comments and Recommendations
The district is to provide a brief summary of the prelocation meeting in this section. This summary will include the date of the meeting, the location and the number of people attending, as well as a summary of comments received either during or after the hearing. Specific public or agency comments concerning the purpose and need and on alternatives are to be noted.
The location study/environmental document addresses the ultimate facility. If construction of the facility will occur in stages, this is discussed in this section with the proper amount of information to document why a portion of the facility is not needed until in the future.
If a preferred alternative is going to be stated, that will occur in this section along with the reasons for the choice of any preferred alternative.
126.5 Attachments to the Location Study
The narrative portion of the study is followed by:
- Estimate sheets, if the estimate is not carried in the body of the study (estimate is as complete and accurate as possible, including right of way, utility and construction costs broken down into sections that correspond to the description of the alternates).
- General location map (copy of the county map showing the entire project limits on one sheet).
- Typical section.
- Any special drawings that might be needed.
- Location sketch (aerial mosaic, USGS quadrangle sheets, etc.) showing the various alternates considered and any constraints, labeled consecutively.
- Results of environmental scoping, including wetlands, historic sites, hazardous waste, threatened and endangered species habitat, and archaeological sites are identified on the location sketch. Archaeological sites are not located specifically since that information is sensitive and not to be publicized.
In order to standardize color-coding of the exhibits in the study, red is used for the recommended location, green for the first alternate, and blue for the second alternate. Brown is used for any previously approved location and yellow for existing MoDOT routes. Where stage construction is contemplated, the second stage work is shown as a dashed line. Work materially beyond the limits of the program is also shown with a dashed line, using a different length dash than for stage construction. Color-coding is not required; different line symbols may be used. It should be easy to identify the various alternates either by color or by distinctive symbols.
126.6 Location Study Procedures
126.6.1 Location Study with CE or CE2 Environmental Classification
Two completed copies of the LS are signed by the preparer and sent to the Design Division for review. The Design Division reviews the LS sending any significant comments to the district engineer in letter form. The district reviews the comments and provides their final recommendations to the district engineer. The study, with all recommendations, is provided to the district engineer for approval. A section is included, following the preparer's signature, for the recommendation or comments and signature of the district engineer. If necessary to add more detail, the district engineer's comments may be included with a separate letter.
Three approved copies of the LS (one for Design’s file, one for Design Environmental and one for FHWA) are submitted to Design Division. A copy of the approved LS is sent to the FHWA with the CE2 form for comment and approval. Once the FHWA approves the CE classification, the district is advised to hold a location public hearing if required or advisable. Preliminary plan design can then begin. If the FHWA reclassifies the project as an EA, the following procedures are used.
126.6.2 Location Study with an EA or EIS Environmental Classification
The LS is written into the EA/EIS as an element of the environmental document. District environmental documents and any location study are not individually prepared because they are redundant. Design Division and district personnel review the completed draft study. Once they review all comments made concerning the draft study, a final draft study is prepared. The final draft study must include a draft Section 4(f) evaluation if applicable. This study is sent to the State Design Engineer for review. The Design Division discusses alternate locations with MoDOT upper management and/or the commission as needed based on the complexity of the project. A copy is then sent to the FHWA for comment and approval. Once the FHWA signs the EA or Draft EIS, the district holds a location public hearing and provides a transcript of the hearing for review by the Design Division and the FHWA so substantive comments can be addressed in the FONSI or final EIS. The location public hearing cannot be scheduled until FHWA has signed the EA or Draft EIS. The district provides a transcript of the hearing with recommendations and summary to the Design Division for consideration in the FONSI or final EIS document. Phase I and Phase II archaeology, if needed, and wetland delineation must be completed on the preferred alternative prior to the EA or final EIS being completed. The district must obtain property owner permission prior to archaeological work. In addition, the FONSI or final EIS must include the final Section 4(f) evaluation if applicable. The final document may be discussed with MoDOT upper management and/or the commission by Design Division as needed. This study will then be sent to the FHWA for approval. Upon receipt of the FHWA's approval of a Finding of No Significant Impact (FONSI) for an EA or of a Record of Decision (ROD) for an EIS, the district engineer will present the study to the commission for their final location approval. Detailed design can then begin. (There will be approximately a 45-day period between the final EIS being approved by the FHWA and the preparation and approval of the ROD.)
The district is responsible for reproduction of all attachments to the LS report for the Design Division through distribution of the final document. In some instances this may involve approximately 100 copies of the exhibits. The district will coordinate this with the Design Division during the preparation of the report and exhibits.
126.7 Future Considerations
Once an alternative is selected in the ROD issued for an EIS or the FONSI for an EA or when FHWA confirms a project's CE classification, the requirements of NEPA have been satisfied. However, a project may not be environmentally cleared at this point. Some issues may still need to be resolved, such as Section 404 permitting by the Corps of Engineers. The district needs to maintain contact with the Design Division to ensure that all environmental permits and clearances have been obtained.
Once a ROD or FONSI is approved, the environmental document has a shelf life of three years. This is not a problem if project development (detailed design, right of way acquisition, etc.) proceeds in a timely fashion even beyond three years. However, if the project is shelved for a number of years without any major project development or if detailed design results in changes to the selected alternative, the FHWA may require an environmental re-evaluation. The environmental re-evaluation updates the project scope and the environmental context of the proposed action. Its form may resemble a letter or an abbreviated EA, depending on the complexity and nature of the project changes. The reevaluation focuses on the changes in the project, its surroundings and impacts as well as any new issues identified since the ROD or FONSI was approved. FHWA may decide that a supplemental EIS or EA is not needed, or the FHWA may indicate that the EIS or EA process must be restarted and completed. The district, through the Design Division, will initiate the re-evaluation process.
The cultural resources evaluation for structures looks at those that are 50 years old or older at the time of the writing of the document. As project development may continue for several years, structures that were less than 50 years old in the document may be 50 years old or older at the time of right of way acquisition and will need to be re-evaluated for their significance. The district needs to maintain contact with the Design Division during the project development process.
126.8 Glossary of Terms
Corridor: A band of varying width, different for each project, that is used in the environmental document to represent the study alternatives. The corridor is wide enough to accommodate the maximum expected right of way plus contains adequate room to allow for minor modifications of the alignment.
Environmental Assessment (EA): A concise public document prepared in compliance with the National Environmental Policy Act (NEPA), that briefly discusses the purpose and need for an action, alternatives to such action, and provides sufficient evidence and analysis of impacts to determine whether to prepare an environmental impact statement or a finding of no significant impact.
Environmental Impact Statement (EIS): A detailed written statement required by Section 102 (2) (C) of the National Environmental Policy Act (NEPA), analyzing the environmental impacts of a proposed action, adverse effects of the project that cannot be avoided, alternative courses of action, short-term uses of the environment versus the maintenance and enhancement of long-term productivity, and any irreversible and irretrievable commitment of resources.
Finding of No Significant Impact (FONSI): If it is determined that there will be no significant impacts, a Finding of No Significant Impact (FONSI) will be prepared to conclude the process and document the decision. A FONSI is issued when environmental analysis and interagency review during the EA process find a project to have no significant impacts on the quality of the environment.
Location Approval: Location approval is granted by the MHTC at one of its regular monthly meetings. Location approval cannot be granted until after a FONSI for an EA or a ROD for an EIS has been approved. For CE projects, an approved conceptual plan is required prior to location approval. For EA or EIS projects, location approval is required before final design can begin on the selected alternative.
Preferred Alternative: The alternative within the range of alternatives presented in an environmental assessment or environmental impact statement that the agency believes would best fulfill the purpose and need of the proposed action.
Reasonable Range of Study Alternatives: The final study alternatives are presented and evaluated in the environmental document. They are the preliminary study alternatives that are found to satisfy the purpose and need and are the least environmentally, economically and socially damaging to the area. The final study alternatives are presented to the public at the Location Public Hearing.
Record of Decision (ROD): A concise public record of decision prepared by the federal agency, pursuant to NEPA, that contains a statement of the decision, identification of all alternatives considered, identification of the environmentally preferred alternative, a statement as to whether all practical means to avoid or minimize environmental harm from the alternative selected has been adopted (and if not, why), and a summary of monitoring and enforcement where applicable for any mitigation.
Selected Alternative: In an EA or EIS, the FONSI or ROD must declare a selected alternative. The preferred only becomes the selected after all comments have been addressed after the Location Public Hearing.
Study Area: The area defined at the beginning of a location study which is used by the environmental specialists for preliminary screening, scoping and early constraint identification.
Transportation Systems Management (TSM): Measures taken to improve the operation or efficiencies of an existing transportation facility, usually small scale improvements that focus on improving existing systems such as traffic signals or changes in access.