Highway Infrastructure: Stakeholders' Views on Time to Conduct
Environmental Reviews of Highway Projects (23-MAY-03,
GAO-03-534).
The federal government has a long-term commitment to helping
states construct, improve, and repair roads and bridges to meet
the nation's mobility needs. The Federal Highway Administration
(FHWA) expects to provide states about $20 billion for highway
construction projects in fiscal year 2003. State departments of
transportation are primarily responsible for initiating and
completing projects. Many federal and state agencies with
environmental responsibilities (called resource agencies) help
ensure that environmental issues are considered. The
environmental review of a federally funded highway project can
take from several days to several years. GAO is reporting on the
(1) activities involved in the environmental reviews of federally
funded highway projects and (2) stakeholders' views on the
aspects of environmental review, if any, that unduly add time to
gaining environmental approval. GAO obtained stakeholder views
from 16 transportation improvement and 12 environmental officials
from a variety of federal, state, and private organizations with
responsibilities for or interests in constructing federally
funded highways. The Department of Transportation had no comments
on a draft of this report. Other agencies provided either
technical comments or did not respond to our request for
comments.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-03-534
ACCNO: A06964
TITLE: Highway Infrastructure: Stakeholders' Views on Time to
Conduct Environmental Reviews of Highway Projects
DATE: 05/23/2003
SUBJECT: Environmental monitoring
Highway planning
Strategic planning
Transportation costs
Road construction
Federal aid for highways
Maryland
North Carolina
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GAO-03-534
A
Report to the Chairman, Committee on Transportation and Infrastructure,
House of Representatives
May 2003 HIGHWAY INFRASTRUCTURE Stakeholders* Views on Time to Conduct
Environmental Reviews of Highway Projects
GAO- 03- 534
Letter 1 Results in Brief 2 Background 7 Environmental Reviews Become More
Complex the Greater the Expected Impact on the Environment 10
Stakeholders* Views Differed on Which Aspects Frequently Add Undue Time to
Environmental Reviews 20 Agency Comments and Our Evaluation 25
Appendixes
Appendix I: Scope and Methodology 27
Appendix II: Environmental Reviews of Projects in Maryland and North
Carolina Requiring an Environmental Impact Statement 31
Appendix III: Aspects Identified by Stakeholders as Unduly Adding Time to
Environmental Reviews 35
Tables Table 1: Attributes of Categorical Exclusions and Environmental
Assessments for Federally Funded Highway Projects 13
Table 2: Aspects Identified by a Majority of Environmental Stakeholders 22
Table 3: Aspects Identified by a Majority of Transportation Improvement
Stakeholders 24
Table 4: Organizations Contacted 28 Table 5: Frequency of Occurrences of
Aspects That Unduly Add
Time to the Environmental Review, as Identified by Stakeholders, by Rating
and Type of Stakeholder 35 Figures Figure 1: Key Activities under
Different Types of Environmental
Review 5 Figure 2: Stakeholders* Views on Aspects That Frequently Add
Undue Time to Environmental Review 6 Figure 3: Activities Involved in
Completing Environmental
Reviews of Projects in Maryland and North Carolina Requiring Environmental
Impact Statements 32
Abbreviations
FHWA Federal Highway Administration NEPA National Environmental Policy Act
This is a work of the U. S. Government and is not subject to copyright
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materials separately from GAO*s product.
May 23, 2003 Let er t The Honorable Don Young Chairman, Committee on
Transportation and Infrastructure House of Representatives
Dear Mr. Chairman: In order to meet the mobility needs of the United
States, the federal government has had a longtime commitment to helping
fund needed maintenance and expansion of the nation*s road network* from
interstate highways to rural roads* in an environmentally sound manner.
Given the importance of transportation to the nation*s economy, mobility,
and security and the need to improve the nation*s roads to meet these
needs, many transportation improvement stakeholders* such as the Federal
Highway Administration (FHWA), state departments of transportation, and
others* have said that completing a federally funded highway project takes
too long, and that the most time consuming aspect involves environmental
review. 1 Transportation improvement stakeholders acknowledge that
environmental reviews result in better project decisions, but say that
reaching decisions is difficult and time consuming. 2 The Transportation
Equity Act for the 21st Century, enacted in 1998, contained provisions
designed to streamline environmental reviews. As the reauthorization of
this act approaches, the Congress may again consider measures for reducing
the time it takes to complete a federally funded highway project so that
transportation benefits are realized sooner. You requested that we (1)
describe the activities involved in the
environmental review of federally funded highway projects and (2) report
on stakeholders* views on which aspects of these environmental reviews, if
any, unduly add time to gaining environmental approval. To carry out this
work, we reviewed laws and documents related to environmental review. We
asked officials from FHWA and the departments of transportation from
Maryland and North Carolina to identify the activities involved in
1 U. S. General Accounting Office, Highway Infrastructure: Perceptions of
Stakeholders on Approaches to Reduce Highway Project Completion Time, GAO-
03- 398 (Washington, D. C.: April 9, 2003).
2 U. S. General Accounting Office, Highway Infrastructure: Preliminary
Information on the Timely Completion of Highway Construction Projects,
GAO- 03- 1067T (Washington, D. C.: Sept. 19, 2002).
environmental review and to identify federal, state, and local agencies
that routinely participate in reviews of federally funded highway
projects. 3 To obtain stakeholders* views on aspects that add undue time*
more time
than they view as necessary* to environmental reviews, we asked officials
from federal and state agencies with responsibilities relating to the
construction of federally funded roads, transportation professional
organizations, historic preservation organizations, and environmental
organizations to identify laws, behaviors, resource issues, or project
management approaches, if any, that unduly add time to environmental
review. We asked these officials to identify other stakeholders with
expertise in such reviews and asked those individuals to identify aspects
that they felt add undue time. Overall, 39 stakeholders identified 43
aspects they have encountered during environmental reviews that they felt
add undue time to these reviews. We then asked these stakeholders to rate
each aspect on how frequently, if at all, they occur. Twenty- eight
officials
representing different interests provided these ratings (of these 28, 16
stakeholders had primary transportation improvement responsibilities or
interests, and 12 stakeholders had primary environmental responsibilities
or interests). The approach we used makes two contributions. First, it
captures the views of a wide range of stakeholders that are identified by
their peers as knowledgeable. Second, it provides a systematic assessment
of the perceived frequency of the aspects that knowledgeable stakeholders
indicated add undue time to environmental reviews. We did not attempt to
corroborate whether or not particular aspects actually occur or the
reasons why stakeholders rated individual aspects as occurring more or
less
frequently. In addition, because of the relatively small number of
stakeholders who rated approaches, we did not extrapolate our results more
broadly. (See app. I for additional details on our scope and methodology.)
Results in Brief Environmental review activities typically consist of (1)
identifying and assessing the environmental impacts of projects,
evaluating alternatives,
gaining input or approvals from FHWA, federal and state agencies with 3 We
chose these two states because transportation officials that we
interviewed identified these states as those that have studied their
environmental review procedures and have taken steps to improve the
timeliness of environmental reviews. When discussing activities involved
in environmental review, we include environmentally related activities,
such as determining whether environmental resources are present or
obtaining permits, that may be
undertaken before environmental reviews are started or after they are
completed as well as the activities that take place during environmental
review.
environmental responsibilities (resource agencies), and the public and (2)
obtaining environmental permits. The activities become more complex if
significant environmental impacts are anticipated. (See fig. 1.) FHWA
estimates that:
Approximately 91 percent of federally funded highway projects
(representing about 76 percent of the $17.6 billion in federal funding
distributed to states for highway projects in fiscal year 2001) have
minimal environmental impacts, and therefore receive *categorical
exclusions,* qualifying them for limited environmental review. These
projects are limited in scope* and some are so routine (such as
installation of traffic signals) as to be pre approved by FHWA* and seldom
add new miles of road to the road system, according to FHWA. For projects
that qualify for a categorical exclusion, state departments of
transportation need only identify environmental features, sufficiently
establish that environmental impacts are minor, obtain approval for
projects in some circumstances, and address known and foreseeable public
and agency concerns. While there is no standard method for computing the
length of time for environmental review, environmental review activities
for these projects have been estimated to take an average of 6 to 8 months
to complete, according to FHWA, and could take as long as an average of 22
months to complete, according to a
report prepared for the American Association of State Highway and
Transportation Officials.
Approximately 6 percent of federally funded highway projects
(representing about 15 percent of the $17.6 billion in federal funding
distributed to states for highway projects in fiscal year 2001) receive a
more extensive environmental review when it is initially unclear whether
significant environmental impacts may occur (called an environmental
assessment). Projects that qualify for environmental
assessments do not typically add new miles of road to the road system
according to FHWA. For these projects, state departments of transportation
conduct additional review activities, which include (1) evaluating the
environmental impacts of one or more alternatives to the proposed project,
(2) consulting with the public and affected federal and
state resource agencies, and (3) obtaining FHWA approval. While there is
no standard method for measuring length of time for environmental review,
environmental review activities for these projects have been estimated to
take an average of 14 to 18 months to complete, according to FHWA, and
could take as long as an average of 41 months to
complete, according to a report prepared for the American Association of
State Highway and Transportation Officials. About 3 percent of federally
funded highway projects (representing about 9 percent of the $17.6 billion
in federal funding distributed to states for highway projects in fiscal
year 2001) are likely to have significant environmental impacts. For these
projects, state
departments of transportation conduct the same types of additional
activities as they do for environmental assessments, but on a more
comprehensive basis, resulting in an environmental impact statement. For
example, state departments of transportation evaluate all reasonable
alternatives (rather than evaluating one or more alternatives as is done
for environmental assessments) and, in Maryland and North Carolina, gain
concurrence from affected federal and state resource
agencies (rather than consulting with them). Other states may interact
with resource agencies differently. Environmental review activities for
these projects take an average of 5 years to complete, according to FHWA.
This duration is measured using formal FHWA decision points. States, such
as Maryland and North Carolina, may conduct some
environmental review activities before or after these decision points,
such as early identification of expected impacts and obtaining permits
from federal agencies with responsibilities for such things as water
quality and wetlands that extend this duration.
Figure 1: Key Activities under Different Types of Environmental Review
Categorical
Environmental Environmental
Activity exclusion
assessment impact statement
Identify environmental features Evaluate alternatives a Assess impacts
Public involvement FHWA approval Consult with affected agencies Obtain
permits, if needed
Required Required to some extent or under certain circumstances Not
required
Source: GAO analysis of FHWA data. a For an environmental assessment,
states must evaluate one or more alternatives, whereas for environmental
impact statements, states must evaluate all reasonable alternatives.
Transportation improvement and environmental stakeholders differed in
their views of which of the 43 aspects they identified as frequently
adding undue time to conducting environmental reviews. In no case did a
majority of transportation improvement and a majority of environmental
stakeholders agree. (See fig. 2.) A majority of environmental
stakeholders, such as resource agencies, state historic preservation
agencies, and environmental advocacy organizations, told us that undue
time is added to environmental reviews because state departments of
transportation do not consider environmental and historic preservation
impacts early enough (7 of 10 of these stakeholders responding or 70
percent), and they do not include important stakeholders early enough (7
of 11 stakeholders responding or 64 percent). In contrast, transportation
improvement stakeholders, such as state departments of transportation,
FHWA division offices, and transportation advocacy organizations,
typically did not identify these aspects as adding undue time. A majority
of transportation improvement stakeholders told us that a lack of
sufficient staff at state departments of transportation and federal
resource agencies (11 of 16 responding or 69 percent), meeting the
stringent statutory requirements for
historic preservation projects on public lands (* section 4( f)
requirements;* 9 of 16 of these stakeholders or 56 percent) and obtaining
permits for projects on wetlands (9 of 16 stakeholders or 56 percent)
frequently added undue time to environmental reviews. Environmental
stakeholders typically did not identify these aspects as frequently adding
undue time. While stakeholders had identified these aspects as adding time
to environmental review, generally they could not estimate how much time
these aspects added.
Figure 2: Stakeholders* Views on Aspects That Frequently Add Undue Time to
Environmental Review
State departments of
70
transportation do not consider impacts early enough
13
State departments of transportation do not include
64
important stakeholders
19
early enough State departments of
50
transportation and federal resource agencies lack
69
sufficient staff The statutory section 4( f)
30
requirement protecting historic properties on public lands is
56
burdensome Requirements for obtaining
0
wetland permits are time consuming
56 01020 3040 5060 70
Percentage of stakeholders identifying aspects as occurring frequently
Environmental stakeholders Transportation stakeholders
Source: GAO analysis of responses of 28 stakeholders. Note: Not all
stakeholders rated each aspect. At least 26 stakeholders (93 percent)
rated each of the 5 aspects shown in this figure.
The Department of Transportation responded that it had no comments on a
draft of this report. Maryland offered several technical comments, which
we have incorporated into this report. The Department of Interior and
North Carolina did not provide a response to our request for comments on
our report draft.
Background Federally funded highway projects vary in size, from new lane
striping or installing traffic signals to resurfacing an existing road or
building a new
road or interchange. Of the federally funded highway projects in 2000 that
took place on approximately 27,000 miles of road (latest data available),
about 26,000 miles (96 percent) involved either the addition of capacity,
preservation, or improvements (such as widening lanes, resurfacing, and
rehabilitating roadways) and the remaining 1,000 miles (4 percent)
involved new road construction projects. For fiscal year 2003, FHWA
expects to fund about $20 billion for highway infrastructure improvements
and projects designed to relieve congestion. Regardless of their size and
scope, federally funded highway projects are typically completed in four
phases: Planning: State and local planning organizations and state
departments
of transportation assess a project*s purpose and need and consider its
need in relation to other potential highway projects.
Preliminary design and environmental review: State departments of
transportation identify project cost, level of service, and construction
location; identify the effect, if any, of the proposed project and
alternatives on the environment; and select the preferred alternative.
Final design and right- of- way acquisition: State departments of
transportation finalize design plans, acquire property, and relocate
utilities.
Construction: State departments of transportation award construction
contracts, oversee construction, and accept the completed project. Local,
state, and federal governments all have a role in the planning, designing,
and construction of federally financed highway projects. Local governments
carry out many transportation planning functions, such as scheduling
improvements and maintenance for local streets and roads. State
departments of transportation are typically the focal point for
transportation project planning and construction and are responsible for
setting the transportation goals for the state, planning safe and
efficient transportation, designing most projects, identifying and
mitigating
environmental impacts, acquiring property for highway projects, and
awarding and overseeing construction contracts. At the federal level, FHWA
is the primary agency providing funding, training, approving state
transportation plans, and certifying that states have met requirements
related to environmental protection and historical preservation.
Many of the organizations with a role in highway project completion have
concluded that completing major highway construction projects takes too
long* in some cases about 20 years. 4 The construction of highway projects
using federal funds can be complicated and time consuming because state
departments of transportation must adhere to a number of federal laws
pertaining to transportation, the environment, and historic preservation
and involve multiple stakeholders representing all levels of government
and the public; and for some controversial projects, this could involve
litigation. As a condition of receiving federal funds for highway
projects, state
departments of transportation must comply with the National Environmental
Policy Act of 1969 (NEPA), which requires that federal agencies consider
the potential impacts on environmental resources when considering approval
of a proposed action. FHWA is responsible for ensuring that state
departments of transportation identify, assess, and, if necessary,
mitigate impacts to the natural and human (e. g., health) environment and
historic properties that may result from the construction of a highway
project. In this regard, state departments of transportation involve
federal agencies with environmental responsibilities (called resource
agencies), such as the Army Corps of Engineers, Fish and Wildlife Service,
Environmental Protection Agency, and Advisory Council on Historic
Preservation, in addition to FHWA and state resource agencies when
assessing the potential impacts of a highway project in order to comply
with NEPA and other federal and state environmental requirements. Along
with NEPA, state departments of transportation must
comply with other federal statutes that may apply to a highway project,
including: The Clean Water Act of 1977. The Clean Water Act of 1977 was
designed to restore and maintain the chemical, physical, and biological
integrity of the nation*s waters through the prevention and elimination of
pollution. Any project, including the construction of a highway 4 GAO- 03-
398.
project, that involves the discharge of pollutants into waters of the
United States must comply with the Clean Water Act. The act generally
prohibits the discharge of pollutants into the waters of the United States
without obtaining a permit from the Environmental Protection Agency, or in
the case of discharges involving dredge or fill material, from the Army
Corps of Engineers under section 404.
The Federal- Aid Highway Act of 1966. Section 15( a) of the act,
popularly known as section 4( f), 5 was designed to preserve publicly
owned natural resources, such as parklands, recreation areas,
waterfowl and wildlife refuges, and significant historic sites. Publicly
owned lands may be used for federal highways only if there is no prudent
and feasible alternative to using that land; and the program or project
includes all possible planning to minimize harm to the park, recreation
area, wildlife and waterfowl refuge, or historic site from the use. Each
highway proposal developed by the state departments of transportation must
include avoidance and mitigation alternatives for publicly owned lands
that may be affected by the project. The Departments of the Interior,
Agriculture, and Housing and Urban Development and state or local agencies
have jurisdiction over natural resources. State historic preservation
offices and the Advisory Council on Historic Preservation have
jurisdiction over historic sites.
The National Historic Preservation Act. Section 106 of the National
Historic Preservation Act requires that federal agencies consider the
effect that a project may have on a property (e. g., districts, sites,
buildings, structures, and objects) that is included in, or eligible for
inclusion in, the National Register of Historic Places. The Endangered
Species Act of 1973. Section 7 of the Endangered
Species Act requires federal agencies to ensure that actions they
authorize, fund, or carry out are not likely to jeopardize the continued
existence of threatened or endangered species (including fish, wildlife,
and plants facing extinction) or result in the destruction or adverse
modification of critical habitat for these species. In some cases, FHWA
and state departments of transportation work with the Fish and Wildlife
Service, National Marine Fisheries Service, and state resource agencies to
ensure compliance with the act.
5 From section 4( f) of the Department of Transportation Act, which
contained similar language.
Environmental Environmental review of federally funded highway projects
typically Reviews Become More
begins when state departments of transportation, in consultation with
FHWA, determine that a proposed project may or will affect the quality of
Complex the Greater
the environment. For projects that state departments of transportation the
Expected Impact demonstrate are likely to have minimal environmental
impacts or in
on the Environment situations in which the existence of significant
environmental impacts is
initially unclear, FHWA provides for a simplified and less structured
review of environmental impacts. 6 More extensive and structured
environmental review is required from FHWA for projects in which
significant environmental impacts are anticipated. This report describes
environmental review activities that states carry out to meet NEPA and
other federal environmental laws. States may carry out other environmental
review activities to meet state environmental requirements. Projects with
Minimal or
A highway project that is expected to have minimal environmental impacts
Initially Unclear
may qualify for limited federal environmental review (called a categorical
exclusion) under FHWA regulations implementing NEPA. 7 These projects
Environmental Impacts
are limited in scope* and some are so routine (such as installation of
Require Limited
traffic signals) as to be preapproved by FHWA* and seldom add new miles
Environmental Review
of road to the road system. According to FHWA, approximately 91 percent of
approximately 31,000 federally funded highway projects (representing
6 According to Council on Environmental Quality regulations, the magnitude
or significance of environmental impacts should be considered in the
context of (1) society as a whole, the affected region, or the locality
and (2) the intensity or severity of impacts, including the degree to
which the project affects public health or safety; unique characteristics
of the geographic area; resources listed in or eligible for listing in the
National Register of Historic Places; an endangered species or threatened
species or their habitat; or establishes a
precedent for future actions with significant effects; level of
controversy; relationship to other actions with cumulative impacts;
presence of unique or unknown risks; or potential to threaten a violation
of federal, state, or local law or requirements imposed for the protection
of the environment. 7 Under these regulations, states may determine that a
project falls within a class or category
of projects that do not have significant environmental impact. These
determinations are called categorical exclusions. FHWA regulations define
categorical exclusions as actions, which based on past experience with
similar actions, do not induce significant impacts to planned growth or
land use for the area; require the relocation of significant numbers of
people; have a significant impact on any natural, cultural, recreational,
historic or other resource; involve significant air, noise, or water
quality impacts; have significant impacts on travel patterns; or
otherwise, either individually or cumulatively, have significant
environmental impacts.
about 76 percent of the $17.6 billion in federal funding distributed to
states for highway projects in fiscal year 2001) received categorical
exclusions in 2001.
In an informal survey conducted by FHWA in 1999, its division staff
reported that it took an average of 6 months to complete the environmental
review of projects that qualified for a categorical exclusion in 1998. 8
FHWA officials reported that it takes even less time, sometimes as little
as several days, to complete categorical exclusions for projects that FHWA
has
preapproved for limited environmental review (for example, landscaping or
installation of road signs). In a survey conducted for the American
Association of State Highway and Transportation Officials in 2000, state
transportation officials estimated that it took an average of 8 months to
complete the activities involved in environmental review of categorical
exclusion projects that they had classified as not delayed. 9 However,
these state transportation officials also reported that, for projects they
selected for the survey, it took an average of 22 months to complete
activities involved in environmental review for categorical exclusion
projects that they had identified as delayed. There is no standard method
for measuring length of time for environmental review.
Some of the projects that qualify for a categorical exclusion are
considered by FHWA to be routine* with little or no environmental impact
such as bus and rail car rehabilitation, construction of bike paths,
landscaping, installation of traffic signals, ride- sharing activities, or
improvements to existing rest areas* and have been preapproved by FHWA for
limited environmental review. For preapproved projects, state department
of transportation need only to sufficiently establish that there are no
significant impacts. State departments of transportation do not need to
identify mitigation measures, address public and agency concerns, or gain
8 FHWA officials told us that these results should be considered as a
general exploration of
time frames, rather than a definitive assessment. 9 The researchers
defined delay to mean the amount of time beyond what state officials
estimated was a reasonable length of time for completing environmental
review. State department of transportation officials were asked to
estimate what would be a reasonable length of time for environmental
review and also report the actual time for environmental review of two
projects that typified delays their state had experienced with categorical
exclusions. In total, 51 projects that qualified for categorical
exclusions were identified.
TransTech Management, Inc., Environmental Streamlining: A Report on Delays
Associated with the Categorical Exclusion and Environmental Assessment
Process (Washington, D. C.: October 2000).
FHWA*s approval of the state*s assessment of environmental impacts. Other
projects* such as bridge rehabilitation, construction of bus or rail
storage or maintenance facilities, or adding shoulders* have somewhat
greater potential for environmental impact but may also qualify for a
categorical exclusion. However, because of the greater potential to cause
significant environmental impacts or generate substantial controversy,
they are not preapproved by FHWA. Instead, for these types of projects,
FHWA advises state departments of transportation to conduct environmental
review activities commensurate with the level of impact, including (1)
identifying environmental features that will be affected by the project
(if any); (2) assessing the environmental impacts caused by the project to
the extent that it is clearly established that impacts are minor; (3)
addressing public, federal, and state resource agency concerns where
adverse impacts are likely to occur; (4) gaining FHWA*s approval for
classification as a categorical exclusion; and (5) obtaining permits, if
needed, to clearly
establish that there is little potential for significant impacts and that
the project*s classification as a categorical exclusion is appropriate.
(See table 1.)
Tabl e 1: Attributes of Categorical Exclusions and Environmental
Assessments for Federally Funded Highway Projects Activity Categorical
exclusion Environmental assessment
Identify environmental Identify environment features that may require
Identify environment features that may require additional features
additional environmental review. environmental review.
Evaluate alternatives Not required. Consideration of alternatives is
required and must include the impact of not building the project, but need
not evaluate all reasonable alternatives.
Assess impacts Projects that involve no construction or limited For each
alternative considered, determine the severity of construction may
automatically qualify for limited
impacts and any mitigation to reduce or eliminate environmental review;
for other projects, the level of unavoidable impacts, but need only
address those analysis should be sufficient to clearly establish that
features that have a reasonable possibility for significant
impacts are minor. impacts. Involve public Where adverse impacts are
likely to occur, public
Environmental assessments do not need to be circulated concerns should be
addressed. for comment, but must be made available for public
inspection and invite comments from the public. Obtain FHWA approval Not
required for most categorical exclusion projects.
FHWA must approve the environmental assessment However, for unusual
circumstances, including before it is made available to the public. FHWA
will either significant impacts or substantial controversy, FHWA find that
the project has no significant impact on the approval is needed to
determine whether the environment or that the impact is significant and an
classification is proper.
environmental impact statement must be prepared. Consult with resource
Where adverse impacts are likely to occur, resource Obtain feedback from
resource agencies on the scope of agencies agency concerns should be
addressed. project, which aspects of the project have the potential for
environmental impact, identify alternatives, and measures to mitigate.
Obtain permits, if Required. Required. needed Source: GAO analysis of FHWA
regulations and technical guidance on preparing environmental documents.
If it is initially unclear whether a transportation project will have a
significant impact on the environment, then FHWA requires that the state
department of transportation prepare an environmental assessment.
According to FHWA, projects that qualify for environmental assessments do
not typically add new miles of road to the road system. FHWA estimates
that approximately 6 percent of approximately 31,000 federally funded
roadway projects (representing about 15 percent of the $17.6 billion in
federal funding distributed to states for highway projects in fiscal year
2001) required an environmental assessment in 2001. In an informal survey
conducted by FHWA in 1999, its division staff reported that it took an
average of 18 months to complete the activities involved in an
environmental assessment in 1998. In a survey conducted for the American
Association of State Highway and Transportation Officials in 2000, state
transportation officials estimated that it took an average of 14 months to
complete the review of environmental assessment projects that they
classified as not delayed. However, state transportation officials also
reported that, for projects they selected for the survey, it took an
average of 41 months to complete the review of environmental assessment
projects that they classified as delayed. 10 For projects that will likely
require an environmental assessment, such as
road widening or interchange construction projects, the state department
of transportation, in consultation with FHWA, must conduct more extensive
environmental review activities than are required for projects that
receive a categorical exclusion, commensurate with the potential for
significant environmental impact. For an environmental assessment, the
state department of transportation must (1) identify environmental
features that will be affected by the proposed project; (2) evaluate one
or more alternatives (but need not evaluate all reasonable alternatives);
(3) assess impacts to the environment caused by the project or any of its
alternatives and determine measures to mitigate unavoidable environmental
impacts; and (4) invite comments and obtain feedback from the public and
interested federal, state, and local agencies. Additionally, states must
obtain permits if required by other environmental laws. FHWA must approve
the environmental assessment and it must be made available
for public inspection. If FHWA determines that no significant
environmental impacts have been identified, then it will issue a finding
that there is no significant impact. If at any point during the
assessment, FHWA determines that the project is likely to have a
significant impact on the
environment, then an environmental impact statement will be required.
Significant Expected NEPA requires federal agencies to prepare an
environmental impact Environmental Impacts statement for all actions
(including federally funded highway projects) that
Require Substantial are likely to significantly affect the environment. An
environmental impact
Environmental Review statement is a public document that discusses the
purpose of and need for
the project, alternatives to the project, the affected environment, the
impacts of the alternatives to the affected environment and public and
agency comments received. While the requirements for the information
included in an environmental impact statement are consistent across
states, the steps taken in the environmental review of projects requiring
an environmental impact statement are not the same in all states, and
there exists no common model among states for undertaking the review
10 In total, 50 projects that qualified for environmental assessments were
identified.
activities that are required to produce an environmental impact statement.
Federally funded highway projects that are likely to require an
environmental impact statement include the construction of a new segment
of controlled access freeway or fixed rail, or projects which make it
likely that there will be significant environmental effects. Typically,
state departments of transportation are responsible for coordinating the
activities of environmental review involving environmental impact
statements.
According to FHWA, approximately 3 percent of approximately 31,000
federally funded highway projects (representing about 9 percent of the
$17.6 billion in federal funding distributed to states for highway
projects in fiscal year 2001) required an environmental impact statement
in 2001. According to FHWA, projects requiring an environmental impact
statement and for which FHWA approved the environmental impact statement
in 2001, environmental review took an average of approximately 5 years to
complete. 11 While FHWA reports that the average time to complete an
environmental review for these projects decreased by about 8 months
between 1999 and 2001, it nevertheless still takes approximately twice as
long to complete environmental review as it did in the 1970s. 12 A report
prepared for FHWA stated that for projects constructed in the last 30
years, environmental review for projects requiring an environmental impact
statement accounted for 3. 6 years, or approximately 28 percent of the
overall time for project completion. 13 In this section of the report, we
describe the steps that two states,
Maryland and North Carolina, typically take in identifying and assessing
significant environmental impacts and gaining concurrence for major
transportation projects. (See app. II for a flow chart depicting these
activities.) These two state departments of transportation typically carry
11 This duration is measured using formal FHWA decision points. States,
such as Maryland and North Carolina, may conduct some environmental review
activities before or after these decision points, such as early
identification of expected impacts and obtaining permits from federal
agencies with responsibilities for such things as water quality and
wetlands that extend this duration.
12 In 2002, the average time to complete an environmental review for
projects requiring an environmental impact statement was 6.5 years,
according to FHWA. 13 Federal Highway Administration, Evaluating the
Performance of Environmental Streamlining: Development of a NEPA Baseline
for Measuring Continuous Performance (Washington, D. C.: May 8, 2001).
out environmental review activities in four phases: (1) developing an
understanding of the extent to which the project is expected to affect the
environment, (2) identifying alternatives and assessing environmental
impacts, (3) gaining approval on draft environmental impact statement and
selecting the preferred alternative, and (4) gaining final approval for
environmental analysis. Resource agencies, the public, and other
stakeholders provide input at each of these phases. However, these states
may carry out some environmental activities even before the first phase,
such as considering whether environmental impacts are likely when they
develop their state transportation improvement plan. Further, attention to
environmental impacts may occur even after FHWA and permit agencies
approve the project if the environmental analysis is challenged in court.
14
Developing an understanding of expected environmental impacts. In this
phase, the Maryland and North Carolina departments of transportation
develop the scope and purpose of and need for the proposed transportation
project. To determine the potential for environmental impacts, the state
department of transportation incorporates existing environmental
information and feedback from stakeholders about the project that may have
been obtained through the development of the state*s transportation
improvement plan. 15 In addition, Maryland and North Carolina departments
of transportation identify preliminary information on environmental
features and resources including wetlands, floodplains, historic sites,
parklands, and endangered species, as well as the area to be affected by
the proposed project. FHWA notifies the public through the Federal
Register that detailed environmental review is needed for the proposed
highway project (called a notice of intent). In addition, Maryland and
North Carolina
departments of transportation invite local officials, federal, state, and
local agencies with environmental responsibilities, and the public at
large to discuss the purpose and need, the proposed scope, environmental
features identified, and substantial issues related to the project. In
addition to environmental review activities required by NEPA, permits or
consultation required by other environmental laws may be needed (e. g.,
coastal
14 Federal law allows court challenges within 6 years of final federal
approval of an environmental impact statement. 15 States are statutorily
required to undertake a continuous transportation planning process which,
among other things, considers the environmental effects of transportation
decisions to develop a transportation improvement program which identifies
and prioritizes only those transportation projects proposed that are
reasonably expected to have funding
available.
resources). For projects in Maryland or North Carolina that require a
permit under section 404 of the Clean Water Act, the state department of
transportation will also normally obtain concurrence on the purpose of and
need for the proposed project from the Army Corps of Engineers, the
Environmental Protection Agency, the Fish and Wildlife Service, and FHWA.
Other states may not obtain concurrence. In addition, Maryland and North
Carolina state departments of transportation may also obtain concurrence
from the National Park Service, the Coast Guard, the Forest Service, and/
or the National Marine Fisheries Service, if the project is in the
vicinity of a geographic area for which an agency has jurisdiction.
Identifying alternatives and assessing environmental impacts. This
phase typically begins with Maryland and North Carolina state departments
of transportation identifying alternatives to the proposed project.
Following guidance from the Council on Environmental Quality, FHWA
requires that the state department of transportation consider a reasonable
range of alternatives that accomplish its objectives, including an
alternative of not building the project. 16 For each alternative, state
departments of transportation must identify the environment that will be
affected. Maryland and North Carolina departments of transportation then
obtain feedback on the alternatives they have developed from the public
and from federal, state, and local agencies that have environmental
responsibilities.
Maryland and North Carolina state departments of transportation evaluate
comments from the public and agencies and select a subset of alternatives
for more detailed study. For alternatives selected for detailed study,
Maryland and North Carolina state departments of transportation conduct
detailed engineering and environmental analyses of the impacts to natural,
socioeconomic, and cultural resources, including historic resources and
endangered species, and begin identifying measures to avoid, minimize, or
mitigate impacts. The last activity in identifying alternatives and
assessing environmental impacts is to invite the public, local officials,
and federal,
state, and local agencies with environmental responsibilities to discuss
the rationale and issues related to the subset of alternatives selected.
For projects in Maryland or North Carolina that require a permit under
section 404 of the Clean Water Act, the state department of transportation
will also
16 According to the Council on Environmental Quality, which developed
regulations implementing NEPA, reasonable alternatives are those that are
practical or feasible from the technical and economic standpoint, rather
than simply desirable from the standpoint of the
agency. For example, reasonable alternatives for a major urban highway
project could include considering options such as fringe parking,
ridesharing, high occupancy vehicle lanes, and mass transit.
normally obtain concurrence on the criteria for alternative selection and
the alternatives to be evaluated from the Army Corps of Engineers, the
Environmental Protection Agency, Fish and Wildlife Service, and FHWA.
Other states may not obtain concurrence. In addition, Maryland and North
Carolina state departments of transportation may also obtain concurrence
from the National Park Service, the Coast Guard, the Forest Service, and/
or the National Marine Fisheries Service, if the project is in the
vicinity of a geographic area for which an agency has jurisdiction.
Gaining approval on draft environmental impact statement and selecting the
preferred alternative. In this phase, Maryland and North Carolina state
departments of transportation attempt to gain approval from FHWA on
preliminary efforts to meet environmental requirements and concurrence
from resource agencies on selecting the preferred alternative. If FHWA is
satisfied that the state department of transportation has adequately
identified all reasonable alternatives to the proposed action and
discusses the reasons why other alternatives were eliminated from detailed
study, then FHWA will provide approval of the state*s preliminary efforts
in meeting environmental requirements. After receiving FHWA*s approval,
state departments of transportation will obtain and analyze comments from
the public and from resource agencies to help the state department of
transportation in selecting the preferred alternative. 17 After Maryland
and North Carolina state departments of transportation select the
preferred alternative, they develop additional avoidance and mitigation
efforts, if needed. Finally, Maryland and North Carolina state departments
of transportation will obtain feedback from the public and agencies on its
selection of the preferred alternative and address any concerns in the
final environmental impact statement. For projects in Maryland or North
Carolina that require a permit under section 404 of the Clean Water Act,
the
state department of transportation will also normally obtain concurrence
on the preferred alternative from the Army Corps of Engineers, the
Environmental Protection Agency, the Fish and Wildlife Service, and FHWA.
Other states may not obtain concurrence. In addition, the state department
of transportation may also obtain concurrence from the National Park
Service, the Coast Guard, the Forest Service, and/ or the
17 According to the Council on Environmental Quality, the preferred
alternative is the alternative which the state department of
transportation believes would best fulfill its statutory mission and
responsibilities, giving consideration to economic, environmental,
technical, and other factors.
National Marine Fisheries Service, if the project is in the vicinity of a
geographic area for which an agency has jurisdiction.
Gaining final approval for environmental analysis and permits. In this
phase, the state department of transportation attempts to gain final
approval from FHWA on its efforts to meet environmental review
requirements. If FHWA is satisfied that the state department of
transportation has adequately identified the preferred alternative;
evaluated all reasonable alternatives considered; and complied, to the
extent possible, with all applicable environmental laws and executive
orders; or has provided reasonable assurance that these requirements can
be met, then FHWA issues final approval on the state*s efforts in meeting
environment review requirements. The state department of transportation
will then circulate the final environmental impact statement for public
and agency comment. The state department of transportation will respond to
comments and FHWA will issue its decision (called a record of decision).
18
In addition to the activities described above, state departments of
transportation may need to undertake additional activities to consult with
or obtain permits or approvals from federal, state, and local agencies
before they can begin construction when a project may impact coastal
resources, air quality, wetlands, historic and cultural resources,
floodplains, ecosystems, national park lands, and endangered species,
among others in order to complete environmental review. Finally, the
environmental review process may have to be reopened in situations such as
when a project does not move forward because of funding shortages and
stakeholders believe that possible environmental impacts have changed and
in cases of successful lawsuits involving environmental issues
associated with the project. Only after lawsuits, funding, or other
environmental issues have been resolved will Maryland and North Carolina
state departments of transportation typically allocate funding to begin
construction.
18 FHWA cannot issue its decision until 30 days have elapsed from when the
public and resource agencies had an opportunity to comment on the final
environmental impact statement.
Stakeholders* Views Stakeholders of highway construction projects we
contacted identified 43
Differed on Which aspects that they said added undue time (more time than
what
stakeholders viewed as necessary to complete the review) to Aspects
Frequently
environmental reviews of federally funded highway projects. A majority of
Add Undue Time to
stakeholders with primary responsibilities for environmental and
historical Environmental
preservation issues, and those with primary responsibilities for
transportation improvement, identified five aspects as occurring
Reviews frequently; but there was no agreement across groups about which
aspects
add undue time. (See table 5 in app. III for how stakeholders rated each
of the 43 aspects.)
The stakeholders we contacted indicated that aspects adding undue time to
environmental reviews generally occurred at about the same frequency,
regardless of whether the type of environmental review was a categorical
exclusion, environmental assessment, or environmental impact statement.
While the stakeholders we contacted identified various aspects of
environmental reviews as adding undue time, generally, they could not
estimate how much time these aspects add to environmental reviews.
Environmental and While stakeholders with similar responsibilities or
interests identified
Transportation several aspects as frequently adding undue time to
environmental reviews,
Improvement Stakeholders no agreement existed across groups. For the most
part, environmental
Differed in Their Views of stakeholders, such as resource agencies, state
historic preservation
agencies, and environmental advocacy organizations, told us that state
Which Aspects Frequently
departments of transportation waited too long to consider environmental
Add Undue Time
impacts and involve important stakeholders. On the other hand,
transportation improvement stakeholders, such as state departments of
transportation, FHWA division offices, and transportation advocacy
organizations, identified aspects related to environmental laws and
staffing adequacy. Of the 43 aspects identified by all stakeholders, a
majority of the environmental stakeholders identified 2 aspects as
frequently adding undue time to environmental reviews. 19 (See table 2.)
19 Stakeholders rated each aspect according to the following scale: 1 =
almost never or never; 2 = less than half of the time; 3 = about half of
the time; 4 = more than half of the time; 5 = all or almost all of the
time. Stakeholders also could indicate that they did not know or that the
aspect was not relevant.
Impacts not considered early enough. Seventy percent of the
environmental stakeholders (7 of 10) who provided a rating for this
aspect, told us that undue time is frequently added to environmental
reviews because state departments of transportation generally do not
consider environmental and historic preservation impacts early enough in
the environmental review. 20 An official with the Council on Environmental
Quality, which oversees federal agency implementation of the environmental
impact assessments, stated that when environmental activities related to
NEPA are not considered during the planning phase of a highway project,
agreements made during the planning phase must be revisited once a NEPA
review starts, thus unduly adding time to environmental reviews. In
contrast, 12 percent of transportation improvement stakeholders (2 of 16)
cited this aspect as occurring frequently. Important stakeholders not
included early. Sixty- four percent of the
environmental stakeholders (7 of 11) who provided a rating for this aspect
told us that undue time is frequently added to environmental reviews
because state departments of transportation generally do not include
important stakeholders early in the environmental review. For example, a
state historic preservation officer said that the state historic
preservation office often was involved too late in the environmental
review, leading to time delays on the project. The state department of
transportation had spent time and money developing projects prior to
allowing the state historical preservation office to review project plans.
When the state historical preservation office had a concern with a
project, the state department had to change or redesign its plans causing
cost increases and time delays. In contrast, 19 percent of the
transportation improvement stakeholders (3 of 16) cited this aspect as
frequently adding undue time to reviews.
20 Not all stakeholders rated each aspect. At least 25 stakeholders (89
percent) responded to every aspect.
Table 2: Aspects Identified by a Majority of Environmental Stakeholders
Percent of stakeholders rating aspect as occurring frequently (number of
stakeholders in parentheses)
Transportation Aspect cited by Environmental
improvement All
stakeholders stakeholders
stakeholders stakeholders
State departments of transportation do not consider environmental and
historic impacts early enough in the
environmental review. 70 (7 of 10) 12 (2 of 16) 35 (9 of 26) State
departments of transportation do not include important stakeholders early
in the environmental review. 64 (7 of 11) 19 (3 of 16) 37 (10 of 27)
Source: GAO analysis of responses from 28 stakeholders. Note: Includes
only those aspects identified by a majority of the environmental
stakeholders as occurring frequently. Percentages are based on the number
of stakeholders rating each aspect.
Of the 43 aspects identified overall, a majority of transportation
improvement stakeholders identified 3 aspects as frequently adding undue
time to environmental reviews. (See table 3.)
State departments and federal resource agencies lack sufficient staff.
Sixty- nine percent of transportation improvement stakeholders (11 of 16)
who provided a rating for this aspect told us that undue time is
frequently added to environmental reviews because state departments of
transportation and federal resource agencies lack sufficient staff to
handle their responsibilities in a timely manner. This aspect was cited as
occurring frequently by a majority of the transportation improvement
stakeholders and by half of the environmental stakeholders (5 of the 10)
who provided ratings for this aspect. According to FHWA, state departments
of transportation are using different methods to attempt to provide
sufficient staff to carry out environmental reviews, such as hiring
consultants to complete environmental analyses when their own staff
resources are limited. In addition, according to FHWA, 34 states are
funding additional staff at state and federal environmental agencies to
facilitate environmental reviews and approval. In a recent report,
stakeholders identified this latter approach as a promising approach
that states are using to reduce the overall time it takes to complete
federally funded highway projects. 21 Section 4( f) historic
preservation requirement considered
burdensome. Fifty- six percent of the transportation improvement
stakeholders (9 of 16) told us that section 4( f) adds undue time to
environmental reviews because it is inflexible and, therefore, burdensome
to comply with. Section 4( f) prohibits the Department of Transportation
from approving any highway project that uses, among
other things, publicly owned land of an historic site of national, state,
or local significance unless it finds that (1) there is no prudent and
feasible alternative that avoids such resources or causes less harm to
them and (2) the project includes all possible planning to minimize harm
to those
resources. In April 2003, we reported that many stakeholders consider
these reviews as burdensome and inflexible and that alternative approaches
could protect historic properties and take less time to reach resolution.
22 In that report, a large majority of the stakeholders we contacted
indicated that historic property protections under section 106 of the
National Historic Preservation Act of 1966 (which requires that projects
subject to federal agency jurisdiction or licensing consider the effects
on any properties included in, or eligible for inclusion in, the National
Register of Historic Places) offered a flexible mediation process that
brings all parties into discussion and allowed for more productive
outcomes that preserve the goals of the transportation project, while
creating meaningful protections of historic properties. In contrast, 30
percent of the environmental stakeholders (3 of 10) who provided a rating
for this aspect cited it as occurring frequently, resulting in undue time
being added to environmental reviews.
Obtaining wetlands permits considered time consuming. Fifty- six percent
of the transportation improvement stakeholders (9 of 16) told us that
section 404 of the Clean Water Act, which requires that projects receive a
permit from the Army Corps of Engineers if water impacts exist, frequently
adds undue time to environmental reviews. These stakeholders described a
variety of issues, including that section 404 adds undue time because the
Corps requires extensive alternative analysis, even for minor projects, to
demonstrate that there is no 21 GAO- 03- 398.
22 GAO- 03- 398.
practicable alternative to building on wetlands. None of the environmental
stakeholders rated this aspect as occurring frequently in adding undue
time to environmental reviews.
Tabl e 3: Aspects Identified by a Majority of Transportation Improvement
Stakeholders
Percent of stakeholders rating aspect as occurring frequently (number of
stakeholders in parentheses)
Transportation Aspect cited by improvement
Environmental stakeholders
stakeholders stakeholders All stakeholders
State departments of transportation and federal resource agencies lack
sufficient staff to handle their
responsibilities in a timely manner. 69 (11 of 16) 50 (5 of 10) 62 (16 of
26)
The section 4( f) requirement that the state department of transportation
prove there is no prudent and feasible alternative is burdensome. 56 (9 of
16) 30 (3 of 10) 46 (12 of 26)
Section 404 causes delays since it values water resources over other
resources leading state departments of transportation to complete time-
consuming analysis. 56 (9 of 16) 0 (0 of 10) 35 (9 of 26)
Source: GAO analysis of responses from 28 stakeholders. Note: Includes
only those aspects identified by a majority of the transportation
improvement stakeholders as occurring frequently. In our April report on
stakeholders* perceptions of the most promising
approaches for reducing highway project completion time (covering all
aspects of a highway project from planning through construction),
stakeholders identified 13 most promising approaches. Nine of these
approaches involved environmental review, such as funding specialized
staff at resource agencies and unifying section 404 and NEPA reviews. Four
of the five aspects that stakeholders told us add undue time to
environmental reviews relate specifically to promising approaches cited in
the April report. These are approaches for increasing resource agency
staff, providing early consideration of environmental impacts by state
departments of transportation, inclusion of important stakeholders early
in
environmental review, and handling the exacting requirements of section 4(
f). In our April report, we recommended that FHWA consider the benefits of
the 13 most promising approaches and act to foster the adoption of the
most cost effective and feasible approaches. FHWA generally agreed with
this recommendation and stated that most, if not all, of the promising
approaches coincide with the streamlining activities that the department
and its partners, such as state departments of transportation and resource
agencies, have been developing and implementing under section 1309 of the
Transportation Equity Act for the 21 st Century. We believe that acting on
that recommendation will address some of the concerns identified by the
environmental and transportation improvement stakeholders in this report.
Agency Comments and We provided the Departments of Transportation and
Interior with a draft of
Our Evaluation this report for their review and comment. The Department of
Transportation responded that it had no comments, and the Department of
Interior did not provide a response to our request for comments. We also
provided Maryland and North Carolina with the portion of the draft report
dealing with environmental review activities in their states. Maryland
offered several technical comments, which we have incorporated into this
report. North Carolina did not provide a response to our request for
comments.
As arranged with your office, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after the date of this letter. At that time, we will send copies of this
report to congressional committees with responsibilities for highway and
environmental issues; the Secretary of Transportation; the Secretary of
Defense; the Secretary of the Interior; the Administrator, Federal Highway
Administration; and the Director, Office of Management and Budget. We will
also make copies available to others upon request. This report will be
available at no charge on our home page at http:// www. gao. gov.
If you or your staff have any questions about this report, please contact
either James Ratzenberger at ratzenbergerj@ gao. gov or me at siggerudk@
gao. gov. Alternatively, we may be reached at (202) 512- 2834. Key
contributors to this report were Samer Abbas, Michelle Dresben, Brandon
Haller, Hiroshi Ishikawa, Gail Marnik, Kristen Massey, and James
Ratzenberger.
Sincerely yours, Katherine Siggerud Acting Director, Physical
Infrastructure Issues
Appendi Appendi xes I x Scope and Methodology To perform our work, we
reviewed laws and regulations governing environmental reviews of federally
funded highway projects. We discussed the activities involved, the time it
takes to complete environmental reviews, and aspects that may increase the
time it takes to complete such reviews
with officials from the Federal Highway Administration (FHWA), state
departments of transportation, federal resource agencies, transportation
advocacy organizations, environmental advocacy organizations, and historic
preservation agencies. We also reviewed federal, state, and private
studies on environmental reviews of transportation projects.
To determine the activities required to complete environmental reviews of
federally funded highway projects and the stakeholders involved in the
reviews, we obtained information from FHWA, the Maryland Department of
Transportation, and the North Carolina Department of Transportation. We
chose these states because officials we interviewed identified these
states
as those that have studied their environmental review procedures and taken
steps to improve the timeliness of environmental reviews. While the
general requirements for an environmental impact statement (identify
environmental features, evaluate alternatives, assess impacts, involve the
public, etc.) are the same for all states, each state may implement the
requirements differently.
To determine stakeholders* views on the aspects that frequently add undue
time to environmental reviews of federally funded highway projects, we
contacted 51 organizations with a role or interest in highway project
environmental reviews. (See table 4.) Of these 51 organizations, officials
from 39 agreed to participate in interviews, including federal and state
agencies with responsibilities relating to the construction of federally
funded roads, federal agencies with responsibilities relating to the
protection of the environment, transportation engineering organizations,
transportation professional associations, environmental organizations, and
historic preservation organizations. To identify the 51 organizations, we
initially contacted agencies and organizations that have a role or
interest in highway project environmental reviews or that have been vocal
on the issue. We asked these officials to identify, for subsequent
interviews, other agencies or organizations undertaking or knowledgeable
about environmental reviews. We continued to ask for names from the
subsequent organizations until we began getting duplicate referrals.
Tabl e 4: Organizations Contacted Organizations
Advisory Council on Historic Preservation American Association of State
Highway and Transportation Officials American Highway Users Alliance
American Road and Transportation Builders Association American Society of
Civil Engineers ARCADIS Association of Metropolitan Planning Organizations
Binghamton Metropolitan Transportation Study California Department of
Transportation Colorado Department of Transportation Connecticut
Department of Transportation Conservation Law Foundation Council for
Environmental Quality Defenders of Wildlife Denver Regional Council of
Governments East- West Gateway Coordinating Council Endangered Species
Coalition Environmental Defense Federal Highway Administration *
Connecticut Division
Federal Highway Administration * Texas Division Federal Highway
Administration * Virginia Division Florida Department of Transportation,
Environmental Management Office Indiana Department of Natural Resources
Institute of Transportation Engineers Kentucky State Historical
Preservation Office Kentucky Transportation Cabinet a Louisiana Department
of Transportation and Development, Environmental Section Maryland State
Highway Administration, Project Planning Division Metroplan National
Coalition to Defend NEPA National Conference of State Historic
Preservation Officers Natural Resources Defense Council National Trust for
Historic Preservation New Hampshire Department of Transportation,
Environmental Bureau North Carolina Department of Transportation, Planning
and Environmental Office
(Continued From Previous Page)
Organizations
Ohio Department of Transportation, Office of Environmental Services Oregon
Department of Transportation, Environmental Services Section Parsons
Brinckerhoff Puget Sound Regional Council R. J. Behar & Company, Inc.
South Carolina Department of Transportation Surface Transportation Policy
Project Texas Department of Transportation, Environmental Affairs Division
U. S. Army Corps of Engineers, New Orleans District U. S. Environmental
Protection Agency U. S. Fish and Wildlife Service, Division of Federal
Program Activities U. S. Fish and Wildlife Service, Pennsylvania
Ecological Services Field Office U. S. Institute for Environmental
Conflict Resolution Vermont Agency of Transportation, Technical Service
Unit Vermont Division for Historic Preservation Washington State
Department of Transportation Source: GAO. a The official from the Kentucky
Transportation Cabinet participated as part of a group of officials from
the American Association of State Highway and Transportation Officials in
the semi- structured interview to identify aspects and individually in
rating the frequency of aspects.
Using a semi- structured interview, we asked knowledgeable stakeholders at
each of the 39 organizations to provide information about the aspects of
laws, stakeholders* behaviors, resource availability, or project
management approaches, if any, that unduly add time to environmental
reviews. We used these categories because they are related to components
of the environmental review process. For each aspect cited, we asked
stakeholders to provide information on (1) how the aspect leads to an
undue increase in review time; (2) the positive and negative outcomes, if
any; (3) at what stage in the review the aspect occurred; (4) an example
and the amount of time it added to the review; and (5) the type of
environmental review (e. g., categorical exclusion, environmental
assessment, or environmental impact statement) where the aspect occurred.
We did not define the term undue time but relied on the stakeholders*
professional judgment to determine which aspects added time that would not
be added ordinarily. Most stakeholders did not provide estimates of the
amount of time the aspect added to the review. To determine how frequently
the aspects occur, we compiled a list of 43 aspects identified by
stakeholders as adding unnecessary time to
environmental reviews and asked each of the 39 stakeholders we interviewed
to rate how frequently each aspect adds undue time to environmental
reviews for highway projects involving categorical
exclusions, environmental assessments, and environmental impact statements
using a scale of 1 to 5. 1 Twenty- eight stakeholders agreed to
participate in this segment of our work. The 11 stakeholders who did not
participate in this segment chose not to do so for a variety of reasons.
At least 25 stakeholders (89 percent) rated each of the 43 aspects. We
identified the most significant aspects as those where a majority of the
stakeholders responding to the question indicated it occurred frequently
(more than half to all or almost all the time).
Stakeholders made a significant distinction by type review in less than 8
percent of all responses. We defined a significant distinction as a
response that had a greater than 1 point difference (on the 1- 5 scale)
between the rating of either the categorical exclusion, environmental
assessment, and
environmental impact statements from the rating averages of responses for
a given aspect.
We did not attempt to corroborate whether or not particular aspects
actually occur or the reasons why stakeholders rated individual aspects as
occurring more or less frequently. We conducted our work from November
2002 through May 2003 in accordance with generally accepted government
auditing standards.
1 1 = almost never or never; 2 = less than half of the time; 3 = about
half of the time; 4 = more than half of the time; 5 = all or almost all of
the time. Stakeholders could also indicate that they did not know or that
the aspect was not relevant.
Environmental Reviews of Projects in Maryland and North Carolina Requiring
an
Appendi I I x Environmental Impact Statement Figure 3 depicts the types
and duration (assuming no significant disagreements with stakeholders at
key decision points) of all federally required, environmental- related
review activities (including those that may be undertaken prior to notice
of intent and after record of decision) involved in the environmental
review of federally funded highway projects in Maryland and North Carolina
requiring an environmental impact statement. 1 State requirements are not
depicted. The flowchart depicts
Maryland and North Carolina departments of transportation undertaking
permit- related activities early in the process. Other states may not do
so.
Maryland and North Carolina carry out some environmental activities even
before the first phase, such as considering whether environmental impacts
are likely when they develop their state transportation improvement plan.
Further, attention to environmental impacts may occur even after FHWA and
permit agencies approve the project if the environmental analysis is
challenged in court. 1 The duration of environmental reviews involving
environmental impact statements is typically determined by measuring the
length of time between when FHWA notifies the public that detailed
environmental review of a project is needed (notice of intent) to when
FHWA issues its decision that projects have complied with environmental
laws (record of decision). FHWA reports that for highway projects
requiring an environmental impact statement and for which FHWA signed a
record of decision in 2001, environmental review took an average of
approximately 5 years from notice of intent to record of decision. The
flowchart should not be interpreted as suggesting that environmental
review of projects (as measured from notice of intent to record of
decision) in Maryland and North Carolina typically takes 7 years or more.
Permit activities NEPA 3: Activities Involved in Completing Environmental
Reviews of Projects in Maryland and North Carolina Requiring Impact
Statements
Develop an understanding of Identify and Potential stakeholders activities
Figure Environmental alternatives Gain approval on draft EIS
expected environmental impacts assess environmental impacts and select
preferred alternative
Total time: North Carolina 10.5 years; Maryland 7 years (assumes no
significant disagreement; not to scale)
North 12 months 9 months 12 months 24 months 9 months 7 months Carolina
Maryland 5 months 1 month 15 months 4 months 3 months 9 months
Revise draft EIS
NO
Consider Develop
Identify
YES
Hold public likely
Public Obtain
and Develop
Assess Prepare
Draft EIS hearing on
environmental notice transportation
environmental develop
Selectalternativesfor preliminary environmental
draft EIS approved
corridor impacts in
Identifyprojectneed purpose
information preliminary
detailedstudy design
impacts and design
STIP and need
alternatives issues
Agree on Agree on
Apply for purpose and
alternatives section 404
Public need
for detailed and other
notice
YES
study
YES permits
NO NO Resolve differences Resolve differences
FHWA Public
FHWA FHWA FHWA FHWA FHWA Regional ACHP
ACHP ACHP
ACHP ACHP
planning EPA
EPA EPA
EPA EPA
agencies FEMA
FEMA FEMA
FEMA FEMA
State FS
FS FS
FS FS
legislators FWS
FWS FWS
FWS FWS
County NMFS
NMFS NMFS
NMFS NMFS
governments NOAA
NOAA NOAA
NOAA NOAA
Municipal NPS
NPS NPS
NPS NPS
governments USACE
USACE USACE
USACE USACE
Public USCG
USCG USCG
USCG USCG
State State
State State
State agencies
agencies agencies
agencies agencies
Public Public
Public Public
Environmental activities Environmental activities
Environmental activities
State considers likely environmental impacts, including those State
identifies a reasonable range of alternatives to the
State prepares draft EIS, including identified during development of the
STIP.
project, including not building the project. alternatives selected,
environmental
State includes project in STIP after receiving public and State
obtains and evaluates public and agency feedback
impacts identified, and mitigation agency feedback.
on alternatives identified. measures planned.
State identifies essential environmental features, including State
selects alternatives for detailed study.
FHWA reviews and approves draft EIS historical and archaeological sites
and natural resources.
If permits are required, then state requests concurrence proposal for
compliance with NEPA.
FHWA notifies public that detailed environmental review is within 30
days from resource agencies on alternatives
State submits section 404 and other needed (called notice of intent).
selected (for Maryland applies only to section 404 permits). permit
applications (such as for coastal
State obtains public and agency feedback on purpose and need, State
resolves differences on alternatives selected, if any,
management) to responsible scope of project and environmental features
affected.
with resource agencies. agencies, where applicable.
If permits are required, then state requests concurrence within State
develops preliminary design, including measures to
State holds public hearing and 15 days from resource agencies on purpose
and need (for
avoid, minimize or mitigate environmental impacts for all circulates draft
EIS and permit
Maryland applies only to section 404 permits). alternatives selected.
applications for a minimum of 45 days State resolves differences on
purpose and need, if any, with
State identifies and assesses impact of alternatives on historical/ for
public and agency comment on the
resource agencies. archaeological sites, natural resources and endangered
species.
state*s environmental review efforts. Events related to environmental
review
ACHP: Advisory Council on Historic Preservation (historic resources) FEMA:
Federal Emergency Management Agency (floodplains)
Events not related to environmental review EIS: Environmental impact
statement
FHWA: Federal Highway Administration (financing, technical EPA:
Environmental Protection Agency (air and water quality;
assistance, ensuring compliance with NEPA) Events related to permit review
wetlands preservation) FS: Forest Service (national forest resources)
Source: GAO's analysis of data from Maryland and North Carolina
departments of transportation.
Gain approval on draft EIS Gain final approval for environmental analysis
and permits and select preferred alternative
29 months 24 months
12 months 36 months
... cont'd
Revise final EIS Resolve differences
NO NO
Develop
YES 30- day
YES
Complete Complete
Resolve any Select
additional Prepare
Approve/ public
Issue right- ofway right- of- way
lawsuits, preferred
avoidance and final
issue final notice of
record of acquisition and
funding, or other alternative
minimization EIS
EIS final EIS
decision design
begin final plan issues/ begin
efforts plans
preparation construction
YES
Resource Submit
Agree on Apply for
final Final
Permit preferred
agencies section 404
section 404 public
alternative review
and other and other
decision
YES
applications permits
notice permits
NO NO
Resolve differences Resolve differences
FHWA FHWA FHWA FHWA FHWA FHWA
Public FHWA ACHP ACHP
ACHP ACHP
ACHP EPA
EPA EPA
EPA EPA
FEMA FEMA
FEMA FEMA
FEMA FS
FS FS
FS FS
FWS FWS
FWS FWS
FWS NMFS
NMFS NMFS
NMFS NMFS
NOAA NOAA
NOAA NOAA
NOAA NPS
NPS NPS
NPS NPS
USACE USACE
USACE USACE
USACE USCG
USCG USCG
USCG USCG
State State
State State
State agencies
agencies agencies
agencies agencies
Public Public
Public Public
Environmental activities (continued)
Environmental activities
State obtains and evaluates public and State prepares final EIS,
including preferred alternative. agency feedback on preferred alternative.
FHWA reviews state*s final EIS proposal for compliance with NEPA.
State selects preferred alternative.
FHWA circulates final EIS for a minimum of 30 days for If permits are
required then state requests
public and agency comment. concurrence within 30 days on preferred
FHWA issues its decision on whether the project complies with NEPA
alternatives (for Maryland applies only to
(called record of decision). section 404 permits).
State submits final section 404 and other permit applications (such as
State resolves differences on preferred
for coastal management) to responsible agencies, where applicable.
alternative, if any, with resource agencies.
Resource agencies decide whether to issue permits. State addresses
compensatory mitigation
State resolves differences on final environmental review efforts,
options.
if any, with resource agencies. Responsible federal agencies review
permit applications. FWS: Fish and Wildlife Service (endangered species)
NOAA: National Oceanic and Atmospheric Administration STIP: State
Transportation Improvement Program
NEPA: National Environmental Policy Act of 1969 (coastal resources)
USACE: Army Corps of Engineers (water resources, NMFS: National Marine
Fisheries Service (fish and
NPS: National Park Service (archaeological, cultural and including
wetlands)
spawning grounds) historic resources in national parks)
USCG: Coast Guard (bridge and navigation responsibilities)
Potential stakeholders Permit activities NEPA activities
Note: Activities not related to environmental review were compressed and
can take a significant amount of time. According to FHWA, it typically
takes between 9 to 19 years to plan, gain approval for, and construct a
new, major federally funded highway project that has significant
environmental
impacts.
Aspects Identified by Stakeholders as Unduly
Appendi I I I x Adding Time to Environmental Reviews Stakeholders with
different primary interests or responsibilities typically had divergent
views about aspects that unduly add time to environmental reviews. (See
table 5.)
Table 5: Frequency of Occurrences of Aspects That Unduly Add Time to the
Environmental Review, as Identified by Stakeholders, by Rating and Type of
Stakeholder Number of stakeholders primarily Number of stakeholders
primarily affiliated with environmental and historic affiliated with
transportation preservation issues a indicating that
improvement issues b indicating that aspect occurs: aspect occurs:
Less Less than half Did not
than half Did not
More About the time
know More
About the time
know Aspects identified by than half half the
or /not
than half half the or
/not stakeholders
the time time
never relevant
the time time
never relevant Total State departments of transportation and federal
resource agencies lack sufficient staff to handle their responsibilities
in a timely manner. 5 1 3 1 11 3 2 0 26
The section 4( f) requirement that the state departments of transportation
prove there is no
prudent and feasible alternative is burdensome to a state department of
transportation 3 0 6 1 9 1 6 0 26
State departments of transportation go to great lengths to avoid a project
on public lands because they regard section 4( f) as too difficult
to accommodate. 4 0 4 2 8 2 6 0 26
National Environmental Policy Act of 1969 and federal and state
environmental and historic preservation laws are not administered
concurrently. 4 1 5 0 7 3 5 1 26
State departments of transportation lack the ability to absorb budget
increases from the Transportation Equity Act for the 21 st Century. 3 0 2
5 8 3 4 1 26
FHWA has changed its role from being a *leader* to being a *facilitator.*
2 1 4 3 8 2 6 0 26
(Continued From Previous Page)
Number of stakeholders primarily Number of stakeholders primarily
affiliated with environmental and historic affiliated with transportation
preservation issues a indicating that
improvement issues b indicating that aspect occurs: aspect occurs:
Less Less
than half Did not than half
Did not More
About the time know
More About
the time know
Aspects identified by than half half the or
/not than half half the
or /not
stakeholders the time
time never
relevant the time
time never
relevant Total Section 4( f) standards do not associate requirements with
the level of impact a project has on a historic resource. 2 1 5 2 8 3 5 0
26
State departments of transportation do not include important stakeholders
early in the environmental review. 7 1 3 0 3 2 11 0 27
State historical preservation offices are not able to complete surveys of
state historic resources and/ or maintain database of historic properties
due to resource constraints. 4 2 2 3 6 1 6 3 27
State departments of transportation do not consider environmental and
historic impacts early enough in the environmental review. 7 0 3 0 2 1 13
0 26
Section 404 causes delays since it values water resources over other
resources leading state
departments of transportation to complete time- consuming analysis. 0 3 3
4 9 3 4 0 26
State departments of transportation and federal resource agencies are
unable to maintain institutional expertise due to staff turnover. 3 1 4 2
6 4 5 1 26
State departments of transportation underestimate project costs and the
review stalls while state seeks funding. 5 0 2 3 3 2 11 0 26
State departments of transportation and resource agencies do not provide
agency comments in a timely manner. 1 2 6 1 7 1 8 0 26
(Continued From Previous Page)
Number of stakeholders primarily Number of stakeholders primarily
affiliated with environmental and historic affiliated with transportation
preservation issues a indicating that
improvement issues b indicating that aspect occurs: aspect occurs:
Less Less
than half Did not than half
Did not More
About the time know
More About
the time know
Aspects identified by than half half the or
/not than half half the
or /not
stakeholders the time
time never
relevant the time
time never
relevant Total Federal environmental protection laws do not accommodate
local transportation needs so additional coordination required to consider
local needs. 1 1 6 1 6 1 8 1 25
A resource agency*s antitransportation agenda leads it to use permitting
authority as a means of delaying transportation projects. 0 1 8 0 7 5 4 0
25
Advocacy groups use environmental laws as means to delay or stop projects
even when their disagreement is not over environmental issues. 1 1 7 0 6 3
6 1 25
FHWA does not delegate approval authority to state departments of
transportation
for projects involving lower levels of environmental review. 2 0 3 5 5 1 8
2 26
Resource agencies wait until permitting requires their action to express
concerns and opinions about a proposed project. 2 0 8 0 5 4 6 1 26
State departments of transportation and resource agencies interpret laws
and regulations differently. 2 2 5 0 4 4 7 1 25
State laws protecting certain resources conflict with section 404
regulations. 2 1 5 2 4 1 10 0 25
State departments of transportation and resource agency leaders follow
personal agendas to the point where each decision must be elevated to
headquarters for resolution. 0 0 8 1 6 2 7 1 25
(Continued From Previous Page)
Number of stakeholders primarily Number of stakeholders primarily
affiliated with environmental and historic affiliated with transportation
preservation issues a indicating that
improvement issues b indicating that aspect occurs: aspect occurs:
Less Less
than half Did not than half
Did not More
About the time know
More About
the time know
Aspects identified by than half half the or
/not than half half the
or /not
stakeholders the time
time never
relevant the time
time never
relevant Total Issues are revisited because state departments of
transportation and resource agencies back out of agreements or do not
follow through on promises made. 0 1 7 1 6 3 7 0 25
Groups opposing a transportation project do not use public hearings to
express concerns with a project but wait until after the environmental
review is completed to file
lawsuits. 1 2 5 1 5 1 10 0 25
Section 404 evaluates created and natural wetlands similarly so state
departments of transportation must complete similar environmental reviews,
regardless of environmental value. 0 1 5 4 6 1 9 0 26
State departments of transportation may have to wait up to a year or more
for the appropriate season to demonstrate existence of species. 2 0 3 4 3
6 6 1 25
The permit application process is sequential. 1 2 3 4 4 0 10 2 26
Inadequate staff at FHWA division offices and state departments of
transportation leads to inadequate environmental analysis. 3 0 3 4 2 3 10
1 26
State departments of transportation and resource agencies lack way to
resolve disagreements about traffic models. 3 2 5 1 2 3 10 1 27
(Continued From Previous Page)
Number of stakeholders primarily Number of stakeholders primarily
affiliated with environmental and historic affiliated with transportation
preservation issues a indicating that
improvement issues b indicating that aspect occurs: aspect occurs:
Less Less
than half Did not than half
Did not More
About the time know
More About
the time know
Aspects identified by than half half the or
/not than half half the
or /not
stakeholders the time
time never
relevant the time
time never
relevant Total State departments of transportation and resource agencies
do not work to resolve technical and analytical differences. 0 3 8 0 5 3 7
1 27
The National Environmental Policy Act of 1969 process does not readily
accommodate unexpected issues during existing reviews. 1 1 5 2 3 1 12 0 25
Resource agency centralization of permit approval adds another level of
review. 1 0 3 6 3 2 9 2 26
Environmental reviews are heldup because changes in state or local
political leadership alters
project*s priority and funding. 3 0 5 2 1 2 13 0 26
State departments of transportation fail to consult with Native American
tribes during the environmental process. 3 1 3 3 0 1 12 3 26
FHWA division offices do not adequately verify state departments of
transportation environmental categorization or oversee state review
process. 3 2 4 1 0 1 15 0 26
Resource agencies and state departments of transportation are unable to
communicate due to a lack of common understanding of technical terms. 2 2
4 2 1 1 13 1 26
Federal resource agencies* lack of technical resources hampers their
analytic performance. 1 4 3 2 2 5 8 1 26
(Continued From Previous Page)
Number of stakeholders primarily Number of stakeholders primarily
affiliated with environmental and historic affiliated with transportation
preservation issues a indicating that
improvement issues b indicating that aspect occurs: aspect occurs:
Less Less
than half Did not than half
Did not More
About the time know
More About
the time know
Aspects identified by than half half the or
/not than half half the
or /not
stakeholders the time
time never
relevant the time
time never
relevant Total State departments of transportation find it difficult to
resolve conflicting criteria inherent in projects covered under section 4(
f) and section 106. 1 0 9 1 2 4 10 0 27
State departments of transportation misclassify level of environmental
review. 2 1 5 2 0 1 15 0 26
FHWA will require the state departments of transportation to conduct
additional analysis of project alternatives that a state department of
transportation
has already discarded. 0 1 5 4 2 3 10 1 26
Resource agency field offices do not consult with headquarters to resolve
disputes. 0 0 3 7 2 2 9 3 26
Metropolitan planning organizations and state departments of
transportation struggle over leadership. 0 0 3 7 1 0 13 1 25
State departments of transportation don*t prioritize projects by size. 0 0
2 8 1 1 11 3 26
Source: GAO analysis of Responses from 28 stakeholders. a Environmental
stakeholders include federal resource agencies, environmental advocacy
organizations, and state historic preservation agencies. b Transportation
improvement stakeholders include transportation advocacy organizations,
state
departments of transportation, and FHWA division offices.
(542014)
a
GAO United States General Accounting Office
Environmental review activities typically consist of identifying and
assessing environmental impacts, evaluating alternatives, and gaining
input and/ or approvals from FHWA, resource agencies, and the public; and
become more complex if significant environmental impacts are anticipated.
For the 91 percent of projects that are expected to have minimal
environmental impacts, state departments of transportation need only to
identify environmental features, assess possible impacts, address any
resource
agency and public concerns, and obtain permits, if needed. For the 6
percent of projects where it is initially unclear whether significant
environmental impacts may exist, additional activities occur, including
evaluating alternatives to the proposed project and obtaining FHWA
approval. For the 3 percent of highway projects with expected significant
environmental impacts, states conduct extensive environmental review,
including evaluating all reasonable alternatives and their environmental
impacts and consult with resource agencies.
Stakeholders we contacted identified 43 aspects that they said frequently
(more than half the time) add more time than viewed as necessary to
environmental reviews of federally funded highway projects. A majority of
stakeholders with primary responsibilities for environmental and
historical preservation issues and those with primary responsibilities for
transportation improvement identified five aspects as occurring
frequently. However, there was no overall agreement about which aspects
frequently
add undue time to environmental reviews. A majority of environmental
stakeholders told us that state departments of transportation waited too
long to consider environmental impacts and involve important stakeholders.
In contrast, a majority of transportation improvement stakeholders told us
that state departments of transportation and federal resource agencies
lack sufficient staff to handle their workloads and that meeting statutory
criteria for historic preservation projects on public lands and obtaining
wetlands
permits are too time consuming. However, the stakeholders generally could
not tell us how much time these aspects add to the reviews. Aspects Viewed
as Frequently Adding Undue Time to Environmental Reviews The federal
government has a longterm commitment to helping states
construct, improve, and repair roads and bridges to meet the nation*s
mobility needs. The Federal Highway Administration (FHWA) expects to
provide states
about $20 billion for highway construction projects in fiscal year 2003.
State departments of transportation are primarily responsible for
initiating and
completing projects. Many federal and state agencies with environmental
responsibilities
(called resource agencies) help ensure that environmental issues are
considered. The environmental review of a federally funded highway project
can take from
several days to several years. GAO is reporting on the (1) activities
involved in the environmental reviews of federally funded highway projects
and (2)
stakeholders* views on the aspects of environmental review, if any, that
unduly add time to gaining
environmental approval. GAO obtained stakeholder views from 16
transportation improvement and 12 environmental officials from a variety
of federal, state, and private
organizations with responsibilities for or interests in constructing
federally funded highways. The Department of Transportation had no
comments on a draft of this
report. Other agencies provided either technical comments or did not
respond to our request for comments. www. gao. gov/ cgi- bin/ getrpt? GAO-
03- 534. To view the full product, including the scope
and methodology, click on the link above. For more information, contact
Katherine Siggerud at (202) 512- 2834 or siggerudk@ gao. gov. Highlights
of GAO- 03- 534, a report to the
Chairman, House Committee on Transportation and Infrastructure May 2003
HIGHWAY INFRASTRUCTURE
Stakeholders* Views on Time to Conduct Environmental Reviews of Highway
Projects
Page i GAO- 03- 534 Highway Project Environmental Review
Contents
Contents
Page ii GAO- 03- 534 Highway Project Environmental Review
Page 1 GAO- 03- 534 Highway Project Environmental Review United States
General Accounting Office Washington, D. C. 20548
Page 1 GAO- 03- 534 Highway Project Environmental Review
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Appendix I
Appendix I Scope and Methodology
Page 28 GAO- 03- 534 Highway Project Environmental Review
Appendix I Scope and Methodology
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Appendix I Scope and Methodology
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Appendix II
Appendix II Environmental Reviews of Projects in Maryland and North
Carolina Requiring an Environmental Impact Statement
Page 32 GAO- 03- 534 Highway Project Environmental Review
Appendix II Environmental Reviews of Projects in Maryland and North
Carolina Requiring an Environmental Impact Statement
Page 33 GAO- 03- 534 Highway Project Environmental Review
Appendix II Environmental Reviews of Projects in Maryland and North
Carolina Requiring an Environmental Impact Statement
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Appendix III
Appendix III Aspects Identified by Stakeholders as Unduly Adding Time to
Environmental Reviews
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Appendix III Aspects Identified by Stakeholders as Unduly Adding Time to
Environmental Reviews
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Appendix III Aspects Identified by Stakeholders as Unduly Adding Time to
Environmental Reviews
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Appendix III Aspects Identified by Stakeholders as Unduly Adding Time to
Environmental Reviews
Page 39 GAO- 03- 534 Highway Project Environmental Review
Appendix III Aspects Identified by Stakeholders as Unduly Adding Time to
Environmental Reviews
Page 40 GAO- 03- 534 Highway Project Environmental Review
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