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STAMP-2025: Sensible Alternatives to the Meadow Creek Parkway
Tuesday, 10 January 2006
Draft Purpose and Need Statement is Inadequate
Topic: Purpose and Need


Here is a copy of the email I sent to the Route 250 Bypass/McIntire Interchange at McIntire Road Steering Committee regarding the inadequacy of the draft Purpose and Need statement in the January 11, 2006 Steering Committee Agenda Packet.

Route 250 Bypass/McIntire Interchange at McIntire Road Steering Committee:

I am providing for you the introductory text and a link to the FHWA guidance regarding the role of the ‘Purpose and Need’ Statement in development of Federal-aid Highway Projects. I am hopeful that the Steering Committee will discuss development of a suitable Purpose and Need statement for the Interchange project study that conforms to this guidance. The Draft Purpose and Need statement included in your agenda packet falls far short of what appears to be necessary for development of project alternatives, consideration of Section 4(f) analysis, adequate consideration of a suitable no-build alternative, etc.

I encourage you to review the FHWA website link, and browse through the other guidance provided by FHWA relevant to project development. I also encourage you to compare the four bullets provided as the Draft Purpose and Need statement from your agenda (below) with the FHWA guidance. I believe you will agree that significant effort in development of the Purpose and Need is needed.

Draft Purpose and Need (from Jan. 11, 2006 Agenda Packet)
• To maintain and enhance mobility for local residents
• To improve the efficiency and safety of the Route 250 Bypass – a key transportation corridor for the City of Charlottesville
• To safely accommodate projected (future) traffic volumes
• To provide pedestrian and bicycle improvements in the project area

From FHWA Guidance on Project Development

The Importance of Purpose and Need in Environmental Documents (from http://environment.fhwa.dot.gov/projdev/tdmneed.htm)

Introduction

The purpose and need section is in many ways the most important chapter of an environmental impact statement (EIS). It establishes why the agency is proposing to spend large amounts of taxpayers' money while at the same time causing significant environmental impacts. A clear, well-justified purpose and need section explains to the public and decisionmakers that the expenditure of funds is necessary and worthwhile and that the priority the project is being given relative to other needed highway projects is warranted. In addition, although significant environmental impacts are expected to be caused by the project, the purpose and need section should justify why impacts are acceptable based on the project's importance.

As importantly, the project purpose and need drives the process for alternatives consideration, in-depth analysis, and ultimate selection. The Council on Environmental Quality (CEQ) regulations require that the EIS address the "no-action" alternative and "rigorously explore and objectively evaluate all reasonable alternatives." Furthermore, a well-justified purpose and need is vital to meeting the requirements of Section 4(f) (49 U.S.C. 303) and the Executive Orders on Wetlands (E.O. 11990) and Floodplains (E.O. 11988) and the Section 404(b)(1) Guidelines. Without a well-defined, well-established and well-justified purpose and need, it will be difficult to determine which alternatives are reasonable, prudent and practicable, and it may be impossible to dismiss the no-build alternative.

The transportation planning process, which includes regional, sub-area, and corridor planning, can serve as the primary source of information for establishing purpose and need as well as evaluating alternatives. Information and forecasts of vehicle miles of travel, travel demand, highway and travel speeds, traffic diversion, time of day characteristics, and traffic accident rates can be provided by the planning process. This information can be used to evaluate congestion, air quality, safety, and other environmental issues for various transportation alternatives including the no-build alternative. Planning can also estimate the benefits and costs associated with highway and transit projects that can be used in the development of project "purpose and need."

posted by: Peter Kleeman techniquest@netscape.net

Posted by va3/stamp2025 at 1:31 PM EST
Updated: Tuesday, 10 January 2006 1:32 PM EST
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