In a September 17 letter, the American Association of State Highway and Transportation Officials formally endorsed efforts underway at the U.S. Department of Transportation to streamline the documentation requirements for National Environmental Policy Act or NEPA compliance efforts, as well as supporting the application of the One Federal Decision process to state DOT projects.
[Above photo by the Oregon DOT.]
Yet the organization stressed that USDOT not establish an immutable 150 page “limit” for NEPA documentation, which the agency said it would expand to 300 pages for projects of “unusual scope or complexity.”
“The page limits should be goals rather than specific limits,” AASHTO argued in its letter. “Establishing goals – along with requiring the lead agency to concur with state DOT project sponsors in determining … appropriate environmental document page limits and the application of exceptions – will provide the state DOTs the flexibility to ensure the documents are legally sufficient.”
The organization added that most project delivery delays in the NEPA and permitting processes are related to procedures and requirements within current environmental laws, such as the Endangered Species Act, the Clean Water Act, and the Clean Air Act.
“Imposing the page limits and timeframes … to address the NEPA and permitting processes, without addressing the process issues within the substantive environmental laws” could result in more complications, AASHTO said in its letter. “We recommend USDOT work with the federal resource agencies and Congress to modernize these substantive laws, regulations and policies.”