Developing a Purpose & Need Statement

Objectives

Understand when the P&N is developed in the PDP

Understand the importance of a well-written/well-justified P&N statement

Understand how a P&N is used

Understand the public’s role

What is a Purpose & Need Statement and

why do I need it?

Regulations

Council on Environmental Quality40 CFR 1502.13 – Purpose and Need

Federal Highway Administration23 CFR 771.111(f)

Importance of Purpose & Need

• A well-written Purpose and Need can be used to justify:

The need for a project

Use of taxpayer’s money

Environmental impacts

• Used to evaluate alternatives

Importance of Purpose and Need

• Specific enough so range of alternatives developed offer solutions to the existing transportation problem

• Not so specific as to “reverse engineer” a solution

• May reflect other priorities and limitations in the area (i.e., environmental resources, growth, land use, and economic development)

Purpose & Need and ODOT’s PDP

ODOT’s PDP

ODOT’s PDP

• P&N is developed in the Planning Phase– Scoping Task 1.3.G

• Refined as the project advances through the Preliminary and Environmental Engineering Phases

• Considered draft until the environmental document is approved

ODOT’s PDP

Five Project Paths

Path 1 Path 5 Least Complex Most Complex

Purpose and Need

Online CE form has P&N format built in for D level projects (not required on C level projects)

Section in EA and EIS

PDP Path Env. Doc. Level—2015 CE PA

Env. Doc. Level—Previous CE PA

Formal P&N Required?

Paths 1 & 2

C1 and C2 Exempt and CE 1 No

Path 3 D1-D2 CE 2 and CE 3 LikelyPaths 4 &

5 D3, EA, EIS CE 4, EA, EIS Yes

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Roles

• ODOT District– Research and prepare P&N

• Include in consultant’s scope, if necessary

– LPAs and consultants must send P&N to district for review and concurrence

– Seek local stakeholder concurrence

– Ensure consistent quality control

Roles

• ODOT OES– Advise and assist

– Concurrence on D2 projects and above

– Concurrence and submittal to FHWA for D3, EA, and EIS projects• Will not require FHWA concurrence

after NEPA Assignment—Only OES concurrence

Roles

• Public– Especially on more complex projects (Path 3,

Path 4, and Path 5)

• Provide public an opportunity to comment

• Input can be used to refine the P&N

Developing a Purpose & Need

Project History

• Background on existing facility– How the project was initiated/developed

• Prior investigations/studies– Traffic– Safety– Planning

Purpose Statement

• States primary objectives to be attained• Articulates the intended positive outcomes

– An alternative that does not achieve primary purposes would be eliminated

• Do not include any reference to solutions

What Are Needs?

• Quantified data obtained through technical analysis that determines if well-defined and supported needs exist

– Defines:• Existing and future conditions• Desired condition

Transportation Needs

• Mobility• Congestion• Facility Deficiencies• Safety• System Linkage• Modal Inter-relationship• Access

Non-Traditional Needs

• Emergency Evacuation• Economic Development/Growth• Environmental Protection• National Defense

Must have a transportation

focus!

Goals & Objectives

• Optional and discretionary– Out of planning

• Community perspective, not transportation perspective

• Consistent with and follows local development plans

• Considers aesthetic design

Logical Termini

• Transportation problem begins and ends– State, city, or municipal boundaries are not

end points

Independent Utility

• Establishes independent significance/independence from any other action

• Distinct from project construction phasing

Alternative Analysis

• The P&N is used to analyze alternatives

– Do proposed alternatives meet the P&N? Do they fix the problem? Can Goals and Objectives be met?

– May not be able to fix all of the problems. Things to consider:• What needs can be met? Relative importance of

meeting those needs?• Cost-effectiveness of each alternative versus meeting

all needs or addressing Goals and Objectives?

Points to Remember

• Define existing transportation problem(s)– Measurable, quantifiable data– Identify and quantify needs to the level that

logical termini and independent utility can be established

• P&N is needed to adequately evaluate, eliminate, and advance alternatives

• Update P&N as appropriate

Project Development Process