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Recap: Using NEPA to Define and Shape Better Projects

Friday, October 6, 2023

The U.S. DOT’s September 27th virtual event on “Using NEPA Review to Define and Shape Better Projects” featured Nancy Daubenberger, Minnesota Transportation Commissioner; Kammy Horne, Senior Vice President of Development and Planning at VIA Metropolitan Transit; Emily Biondi, Associate Administrator for Planning, Environment, and Realty, Federal Highway Administration (FHWA); and Megan Blum, Director for the Office of Environmental Programs, Federal Transit Administration (FTA). The event was part of the thought leadership series on Delivering the Benefits of the Bipartisan Infrastructure Law. The session was hosted and moderated by U.S. DOT Volpe Center Director Anne D. Aylward.

Commissioner Daubenberger has worked for the Minnesota Department of Transportation (MnDOT) for over 23 years in engineering and management positions. She has been the agency’s Commissioner since 2022, after serving for three years as Deputy Commissioner and Chief Engineer. Previously, she served as the Assistant Commissioner for Engineering Services and State Bridge Engineer, as well as in planning, project management, and design roles for the MnDOT Bridge Office and Metro District. Before joining MnDOT, she worked in consulting for 6 years, in both bridge and road design.

As Senior Vice President of Development and Planning for VIA Metropolitan Transit in San Antonio, Texas, Horne leads multiple departments with teams covering operational scheduling and planning, strategic planning, capital project engineering and development, service checking, real estate, and a bus stop/shelter program. She has worked on projects and policy at every level of government and in both the private and public sectors. In addition to her consultant experience for agencies around the country, Horne has worked in the public sector for both the Texas Department of Transportation and the Federal Transit Administration.

As the Associate Administrator for Planning, Environment, and Realty at FHWA, Biondi provides executive leadership to a comprehensive planning and environmental program supporting the development of multimodal plans, programs, and environmental policies and practices that assure that transportation decisions serve national, state, and local transportation priorities and goals. Prior to this position, she served as the Director of the Office of Project Development and Environmental Review, where she oversaw the development and implementation of programs and activities that advanced environmental stewardship and accelerated project delivery.

Blum is the Director for the FTA Office of Environmental Programs, responsible for environmental policy development and streamlining efforts. She has worked in the National Environmental Policy Act (NEPA) field for more than 19 years. She has led many environmental regulation and guidance efforts for FTA. Most recently she has led implementation of FTA’s various environmental initiatives, as well as Climate Challenge: Sustainable Transit for a Healthy Planet. She also served as Deputy Associate Director for NEPA at the Council on Environmental Quality from September 2016 through April 2017.    

This post provides a recap of the conversation. You can watch the full event video here

Enhancing NEPA through Public Engagement: Minnesota's Transportation Projects 

Nancy Daubenberger shed light on Minnesota's approach to NEPA, showcasing key projects that highlight the state's commitment to meaningful public engagement and community-centric decision-making. She noted that NEPA regulations guide MnDOT in conducting environmental reviews for projects and permits. Daubenberger stressed that NEPA encourages consideration of potential impacts on both the natural and human environments, fostering a comprehensive understanding of a project's consequences. 

Early and Continued Engagement

Daubenberger emphasized the importance of early and sustained engagement with citizens, public officials, and stakeholders at key milestones. This approach aids in problem definition, information gathering, alternative development, and the establishment of evaluation criteria. It helps reduce rework, project risks, costs, and delays, while building public trust. “So, it's not about better environmental documents or processes, but better engagement and decision making in the project development process,” said Daubenberger.

Prioritizing Communities and Rethinking I-94

Daubenberger highlighted key projects that offer best practices for future success on project delivery. The projects prioritized community engagement to ensure community members have a “share in the power of transportation decisions.” 

One of the projects, Rethinking I-94, focuses on a 7.5-mile stretch between Minneapolis and St. Paul, an area that is economically and ethnically diverse. Daubenberger acknowledged the past impacts of freeway construction in the 1960s on lower-income, minority, and immigrant communities. She also noted that the Rethinking I-94 Project is one of the efforts that exemplifies MnDOT’s current prioritization of the wellbeing of people. MnDOT's approach centers around community voices and engages stakeholders in every phase of a project. Daubenberger underscored that they want to understand the needs and aspirations of community members so their work “builds and sustains healthy communities.” 

This approach includes various opportunities for involvement throughout the project's lifecycle, from planning to construction and maintenance. “We're centering community voices in our approach and asking how people want to engage and what is important to them, and reflecting that in our work and in our alternatives,” said Daubenberger. This commitment to community engagement ensures that the community's perspectives are heard before significant project decisions are made.

Twin Ports Interchange Project in Duluth

MnDOT’s Twin Ports Interchange Project in Duluth, Minnesota, is a $435 million interchange reconstruction initiative. MnDOT uses the Construction Manager, General Contractor (CMGC) delivery method, which allows for better identification of construction impacts during development. It also ensures that alternative development aligns with informed decision-making, avoiding unnecessary delays and costs.

Daubenberger noted that public engagement during the NEPA process for the Twin Ports Interchange Project led to a partnership with the City of Duluth's Workforce Center. This collaboration focuses on diversifying the workforce for construction trades, benefiting the local community and the project. “The relationship with the workforce center will continue for future projects in this area,” Daubenberger added.

Minnesota's approach to NEPA emphasizes public engagement, community-centric decision-making, and a commitment to addressing past harms. Projects like Rethinking I-94 and the Twin Ports Interchange Project exemplify the state's dedication to creating more livable and connected communities. Through meaningful public involvement and partnerships, MnDOT strives to build better transportation projects that benefit everyone.

Navigating NEPA: Via Metropolitan Transit's Path to Success  

Kammy Horne shared how NEPA plays a pivotal role in shaping successful projects in San Antonio. She highlighted Via Metropolitan Transit's journey and the importance of early coordination, deliberate outreach, and creative tools to define and refine projects for the benefit of the community.

Transit and Improved Access and Opportunities

Horne noted that San Antonio is one of the largest U.S. cities without a significant high-capacity transit system and is also one of the most economically segregated U.S. cities. To address this disparity, Via Metropolitan Transit embarked on an ambitious project, the Rapid Green Line, to provide better access and opportunities for the city's underserved areas.

The Rapid Green Line encompasses nearly 12 miles and 26 new stations primarily along an exclusive guideway and is scheduled to open in 2027. It promises to revolutionize transportation in San Antonio by enhancing connectivity and accessibility, especially in areas experiencing persistent poverty. Horne emphasized how the NEPA process and its interdisciplinary coordination provided an excellent framework for planning a successful project, “because we are introducing something new to our community that will provide much better access to many and will support the foundational ladder of opportunity that is public transportation.”

Lessons from Early Coordination

Horne noted that early coordination with FTA played a crucial role in shaping the project. FTA’s insights from other bus rapid transit projects, such as those in Indianapolis and Albuquerque, provided critical lessons and best practices. “FTA strongly encouraged us to get out with as much information as possible early in the process, and find creative ways to share information, even during COVID,” said Horne, emphasizing the importance of open communication.

Deliberate Public and Stakeholder Outreach 

Deliberate outreach to stakeholders, including the public and other interested parties, helped Via Metropolitan Transit identify concerns and areas requiring mitigation. Horne suggested that one-on-one outreach proved invaluable in understanding the community’s needs and tailoring the project accordingly. “We were deliberate in asking questions from the public, and also our other stakeholders, in terms of what are your concerns?“

Amid the challenges posed by the pandemic, Horne shared that Via Metropolitan Transit employed creative tools for outreach. Teletown hall presentations, panel discussions, and an informative website were used to disseminate project information. A project outreach office on the corridor allowed for face-to-face interactions, enhancing community engagement.

Rapid Green Line in San Antonio

Horne also recommended sharing information about community enhancements to highlight a project's broader benefits. With the Rapid Green Line, early communication of safety improvements and community enhancements, such as sidewalk access and pedestrian crossings, allowed the public to understand the project’s positive impact.

Via Metropolitan Transit’s experience demonstrates the power of NEPA in shaping successful projects that prioritize equity and community well-being. Early coordination, deliberate outreach, and creative tools enable project sponsors to define and refine their initiatives effectively. Via’s Rapid Green Line project serves as a testament to how NEPA can contribute to creating more inclusive and sustainable transportation systems for communities across the United States.

Navigating NEPA: A Path to Better Decision-Making 

Megan Blum shed light on how NEPA serves as a critical planning tool to significantly improve our approach to decision-making. She shared key insights and recommendations, highlighting how NEPA can be harnessed effectively to drive better outcomes for projects and the environment.

Setting the Standard and Embracing Different Perspectives

“We can make NEPA work for us, and our project work,” Blum said, noting that NEPA establishes a benchmark for responsible decision-making. It outlines the necessary requirements but also provides a substantial degree of flexibility, allowing project teams to tailor strategies for optimal efficiency. She suggested the key is to identify what truly matters to achieve the best results and the most significant impact. “When we drafted our FTA environmental SOPs, we really focused on identifying what’s required versus what is nice to have.”

Blum suggested that one of NEPA’s strengths lies in its encouragement of diverse perspectives. She added that by involving various stakeholders, including the public and agency partners, NEPA enables project teams to gain a holistic view of a project's implications. This inclusive approach fosters a more comprehensive understanding of how different parties perceive the project and its potential effects.

Back to the Basics: Early Planning and Annotated Outlines 

To ensure the success of a project under NEPA, early planning is crucial. Blum recommended early collaborations and discussions with FTA Regional Offices: “FTA is your partner.” She also recommended the use of tools such as annotated outlines. These outlines, completed early in the environmental review process, help project teams meticulously plan document requirements, timing, and information structure and presentation. They also serve as a roadmap, streamlining the process and reducing potential revisions.

She acknowledged that this may seem simplistic, but it’s critical. “Sometimes going back to the basics is the way to go. It’s the best way to move forward, and by having these conversations early in the process, the team should experience an expedited environmental review and document development.” 

Horne also reiterated Blum’s recommendation to use annotated outlines. She noted that Via made an early determination to proceed with a categorical exclusion under NEPA. The annotated outline has been foundational to the project, helping to maintain clarity and focus, as well as define the project purpose and need at the outset.

In addition, Horne highlighted how deep dives into potential schedule impacts and regulatory processes, such as Section 4(f) and Section 106, allowed for the incorporation of design elements early in the project. This ensured that design changes were not rushed, resulting in a more realistic and well-thought-out project plan.

Best Practices for Success

Blum shared several additional best practices to enhance the NEPA process. These include considering mitigation during the planning phase, adopting a bottom-up approach for classification, well-defined scoping, and ensuring that the analysis aligns with the scale of environmental issues. Moreover, concise and reader-friendly documents are recommended. 

Graphics are great tools for synthesizing complex information efficiently. By using visuals effectively, project teams can save time and enhance understanding, reducing the need for lengthy textual explanations. “Remember that ultimately NEPA documents are for the public and decision-makers, and so we should be doing our best to make them readable and to tell a story.”

Blum stressed that NEPA is not just a set of regulations but a roadmap to better decision-making. By embracing its principles, incorporating diverse perspectives, early planning, and utilizing tools like annotated outlines and graphics, project teams can streamline their NEPA journey. With a clear focus on setting standards, embracing flexibility, and adhering to best practices, NEPA can lead us toward better decisions and a more sustainable future.

Leveraging NEPA for Better Transportation Projects: A Federal Highway Perspective 

Emily Biondi provided insight into FHWA’s role in utilizing NEPA to streamline decision-making processes and achieve better outcomes for communities across the United States.

NEPA as an Umbrella for Environmental Considerations

FHWA refers to NEPA as an "umbrella law" because it encourages agencies to encompass various environmental and historic preservation requirements into a single analysis. This approach streamlines decision-making by addressing multiple regulations, including Section 4(f), the Endangered Species Act, and executive orders, within a unified framework.

Biondi emphasized the need for the NEPA process to be open and collaborative. Extensive public involvement is a crucial element that leads to better projects. Engaging the community, both those benefiting from and potentially impacted by the project, is vital for its success.

FHWA and NEPA Implementation

“Federal Highway Administration has long been a leader in improving the environmental review and permitting process,” said Biondi. She noted that recent changes in statutory provisions, such as the Bipartisan Infrastructure Law and the funding received through the Inflation Reduction Act, aim to facilitate the development and review of environmental documents. Additionally, changes to NEPA and proposed revisions to the Council on Environmental Quality's regulations offer further opportunities for improvement.

Projects That Shape the Future

Biondi highlighted projects that exemplify FHWA's commitment to delivering better transportation projects:

  • South Carolina I-526 Low-Country Corridor West Project: This project in North Charleston aims to relieve traffic congestion and improve travel for area residents. The South Carolina Department of Transportation conducted extensive public outreach, resulting in a robust mitigation plan. Early engagement, community advisory councils, canvassing, and targeted outreach ensured that community concerns were heard and addressed. In addition, the Acquisition Fairness Program was designed to compensate property owners affected by past highway projects.
  • I-35 Improvement Project in Detroit, Michigan: This project seeks to replace outdated freeway infrastructure while enhancing safety and connectivity. Robust public outreach and the formation of advisory committees allowed Michigan DOT to address past impacts and engage with local communities. The project prioritizes safety, connectivity, and environmental considerations. Innovative approaches, like wildlife crossings, demonstrate the project's commitment to the environment and community values.
  • I-70 Floyd Hill in Colorado: Focused on improving safety, reliability, and environmental considerations, this project also incorporates transit service, rural broadband access, and electric vehicle charging stations. It takes a holistic approach to address both transportation and environmental needs. The project followed the I-70 Mountain Corridor Context-Sensitive Solutions process, emphasizing interagency collaboration and community engagement.

Resources for Best Practices

Biondi recommended several resources that share best practices and innovative approaches in the NEPA process including Environmental Excellence Awards recognizing outstanding contributions in environmental considerations and project delivery; public involvement case studies; a toolbox for crowdsourcing, mapping, and virtual public involvement; case studies highlighting projects with notable practices and meaningful public involvement; and an environmental review toolkit for NEPA-related information.


View the event recording for the full discussion.  


*The views of the speakers do not represent the views of U.S. DOT.


Sponsored by the USDOT Project Delivery Center of Excellence  

Hosted by the U.S. DOT Volpe Center, the Delivering the Benefits of the Bipartisan Infrastructure Law event series is sponsored by the new USDOT Project Delivery Center of Excellence.  

The U.S. DOT Volpe Center is committed to principles of accessibility and inclusion. If you require reasonable accommodations, please contact collateral duty Disability Program Specialist Stephanie Chase and carbon copy EEO Manager Eliot Sutler on your request.   

Sponsored by the USDOT Project Delivery Center of Excellence