The PEL Study Advantage
By Jason Longsdorf, AICP, and Gina McAfee
If you thought Planning and Environmental Linkages (PEL) were getting more popular over the last decade, you were right — but that is just the beginning. With new Council on Environmental Quality (CEQ) regulations in place putting strict time limits on Environmental Assessments (1 year) and Environmental Impact Statements (2 years), PEL studies are more beneficial than ever for projects that will require in-depth NEPA analysis.
So what is a PEL process? As the name implies, it is a linkage between the planning and environmental review processes. As planners, we know that formal transportation planning processes have been around for almost 100 years to help envision the future of our transportation networks. Essentially, PEL studies allow local, state and federal agencies to use the results of transportation planning processes to inform and streamline the NEPA process — but only if FHWA or FTA are involved and if certain elements of the planning process are appropriately documented and shared with the public, agencies and tribes.
The formal Planning and Environmental Linkages process was initiated by federal guidance in 2005 and has evolved and been reinforced in the years since by several federal laws, regulations and guidance documents. So, without boring you by citing all the specific regulations and codes, let’s get into why you might want to use a PEL study for your project.
What are the benefits of using the PEL process?
PEL studies offer an opportunity to build consensus on key planning products such as purpose and need or recommended alternatives prior to starting the NEPA process. This is useful for identifying funding and speeding up the subsequent NEPA process. One example of this is the Wadsworth Boulevard PEL Study completed by the City of Wheat Ridge, Colorado in September 2015. This study of a 2-mile urban arterial corridor included a purpose and need statement that was thoroughly vetted with the FHWA. When it came time to proceed into the NEPA process, the project team was able to use the same statement with only updated travel demand forecasts. The extensive public involvement program was also instrumental in the City of Wheat Ridge receiving a positive vote on a public referendum that was critical to receipt of Transportation Improvement Program funding.
I-70 mountain corridor lanes: Two PEL processes were used to develop purpose and need and to screen alternatives on the I-70 Mountain Corridor project in Colorado. These were applied in two different NEPA processes: the Twin Tunnels EA and the Westbound Peak Period Shoulder Lane Categorical Exclusion.
The I-70 Mountain Corridor project in Colorado also benefited from the increased efficiency of PEL studies. Two PEL processes were used to develop purpose and need and to screen alternatives. These were applied in two different NEPA processes: the Twin Tunnels EA and the Westbound Peak Period Shoulder Lane Categorical Exclusion. Both of these NEPA processes used planning analyses developed in their respective PEL processes to jumpstart the NEPA process with one cross-sectional alternative. In both cases, the NEPA process proceeded faster because this work had been done and accepted. Troy Halouska, PEL Manager from CDOT, noted: “In both cases, work done during the PEL processes ended up reducing the subsequent NEPA processes by 6 to 9 months.”
PEL studies are also useful to refine alternatives ahead of a NEPA process. In Idaho Falls, Idaho, multiple alternatives were initially developed on the I-15/US-20 Connector project and then reduced to only two build alternatives to carry into the subsequent EIS. This saved time in the EIS process. “The I-15/US 20 PEL study helped us narrow down the alternatives and gave us lots of information to carry directly into NEPA,” said Ryan Day, project manager on the PEL study for the Idaho Transportation Department. “Without it, there would be no way to complete an EIS under the new 2-year timeframe requirements.”
The I-70 Mountain Corridor project in Colorado benefited from the increased efficiency of PEL studies. Planning analyses developed during PEL processes helped reduce subsequent NEPA processes by 6 to 9 months.
Involving resource agencies in the PEL process can also help to screen alternatives and expedite future permitting. The Egan-Yandukin PEL process in Juneau, Alaska, for instance, studied a major road intersection in response to concerns about safety. The U.S. Army Corps of Engineers was very involved in helping craft the purpose and need statement and reviewing impacts of alternatives on regulated waters during the PEL Process. Taylor Horne, the HDR project manager, pointed out the benefits of this coordination: “Since the USACE representative was so closely involved, as the project moves into the NEPA and Section 404 permitting stage, we anticipate continued collaboration and acceptance of the documentation.”
The PEL process is also very flexible, allowing planners to focus on one or two of the planning products identified in the regulation, rather than all of them. On the statewide PennDOT Pathways PEL process in Pennsylvania, for instance, the planning products developed were purpose and need for alternative funding, analysis of reasonable funding solutions, and methodology for environmental justice analysis and mitigation to implement tolling.
Wide applicability
As the examples above illustrate, the PEL process has wide applicability. It can be used by planners at state DOTs and transit agencies, planners at the MPO level, and planners in cities, counties and boroughs. It is applicable for highway and roadway projects, bridge projects, rail and bus transit projects, interchange projects and pedestrian or bicycle projects — basically any project that might be eligible for federal surface transportation funding.
The Wadsworth Boulevard PEL Study completed by the City of Wheat Ridge, Colorado proved useful for identifying funding and speeding up the subsequent NEPA process.
The Federal Transit Administration is currently using PEL processes on two new transit line projects in Austin, according to Tom Underwood with HDR. And in Denver, the Regional Transportation District is using a PEL process to determine a cost-effective solution for its high-profile Northwest Rail project.
The PEL process also can be used in states with NEPA Assignment, by clearly delineating the responsibilities of the DOT. “In Alaska, our new PEL Guidebook identifies concurrence points in the process for review by our Statewide Environmental Office,” said Emily Haynes with Alaska DOT & Public Facilities.
An important tool in the toolbox
If you or a client are embarking on a transportation planning process, especially one that may require a NEPA clearance, consider whether a PEL study could be beneficial. Chances are you are probably already going to do most of the things a PEL requires: engage the public, develop alternatives, document why you eliminated some and why you made the recommendations you did.
In Idaho Falls, Idaho, multiple alternatives were initially developed on the I-15/US-20 Connector project and then reduced to only two build alternatives to carry into the subsequent EIS. This saved time in the EIS process.
The benefits — making your project eligible for federal funding, not having to repeat any of your work, and building stakeholder support along the way — will help move your project that much closer to implementation.
The PEL process doesn’t have to replace every study currently being done, but it’s one more tool in the toolbox that can be pulled out when it makes sense.
For additional information you can reference FHWA’s PEL website, review this recent HDR webinar on the topic or feel free to contact either of the authors for input on how to take advantage of this innovative planning process.
About the Authors
Jason Longsdorf is HDR’s transportation planning group lead in Denver and helps lead HDR’s PEL practice group. With over 20 years of experience managing multimodal corridor studies, he has worked on or managed six PEL studies in multiple states, covering both rural and urban areas.
Gina McAfee is an environmental planning program manager for HDR with four decades of work primarily focused on NEPA projects. Her PEL experience includes preparation of training and guidance materials for multiple departments of transportation and work on 12 PEL studies in six states.