Maintaining Project Consistency throughout the Project

Development Process

Megan Kenney Environment and Air Quality Division, Texas A&M Transportation Institute

505 E. Huntland Dr., Suite 455, Austin, TX 78752 Tel.: (512) 407-1133 Fax.: (512) 467-8971 Email: m-kenney@ttimail.tamu.edu

and

Mohamadreza Farzaneh, Ph.D., P.E.

Environment and Air Quality Division, Texas A&M Transportation Institute 505 E. Huntland Dr., Suite 455, Austin, TX 78752

Tel.: (512) 467-0946 Fax.: (512) 467-8971 Email: mfarzaneh@tamu.edu

and

Jolanda Prozzi Environmental and Air Quality Division, Texas A&M Transportation Institute

505 E. Huntland Dr., Suite 455, Austin, TX 78752 Tel.: (512) 401-1104 Fax.: (512) 467-8971 Email: j-prozzi@ttimail.tamu.edu

Total words: 4914 + (8 figures and 2 tables) × 250 = 7414

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ABSTRACT

Federal and state transportation planning statutory and regulatory laws require transportation projects to be consistent with transportation plans and improvement programs before a federal action can be taken on a project requiring one. Significant delays in project delivery can occur if the federal funding is withheld when projects are found to be inconsistent with transportation plans and improvement programs. This issue is especially critical for projects in nonattainment and maintenance areas because an inconsistent project might trigger a conformity failure or delayed determination for the entire plan and/or program. This paper describes the main challenges leading to project inconsistencies are insufficient communication over the changes to projects’ design concept and scope, cost, and estimated letting date. The research team developed a comprehensive background informational, Project Consistency Guidebook, and a project consistency checklist for practitioners to check for consistency during the project development process. The guidebook explains how project planning and development interact with the regional and project level air quality conformity process, and details procedures and tools that Department of Transportations and Metropolitan Planning Organizations can use to understand and maintain project consistency.

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INTRODUCTION 1

Streamlined project delivery is consistently a goal for state department of transportation 2 (DOT). Any unnecessary delay in the project delivery process may exacerbate the cost of the 3 project. Federal and state transportation planning statutory and regulatory laws require 4 transportation projects to be consistent with metropolitan transportation plans (MTP) and 5 transportation improvement programs (TIP) before the Federal Highway Administration or the 6 Federal Transit Authority (FTA) take federal action on a project requiring one.1 7

The main purpose of this paper is to describe the work completed by the researchers to 8 assist transportation practitioners maintain project consistency through the project development 9 process and identify what causes and leads to project inconsistencies. Project consistency is 10 especially critical for projects in nonattainment and maintenance areas. This is because an 11 individual project’s conformity is directly linked to the consistency of the projects with 12 appropriate transportation plans (MTP) and improvement programs (TIP and Statewide 13 Transportation Improvement Program [STIP]); a non-conforming project might trigger a 14 conformity failure for the entire TIP. For example, a project is no longer conforming to the State 15 Implementation Plan (SIP) if it becomes inconsistent with the Metropolitan Transportation Plan 16 and the Transportation Improvement Program. 17

This project was conducted for the Texas Department of Transportation’s Environmental 18 Affairs Division to understand the causes leading to project inconsistency and how to best 19 address them. Federal and state requirements state that transportation projects must be described 20 consistently in all applicable plans, programs, conformity documentation and environmental 21 documents with regards to the following elements: 22

23

• Design concept, including project limits, location, type of facility, and scheduled 24

letting date. 25

• Design scope, including specific information such as number of lanes, length, 26

signalization, etc. 27

• Project cost. 28

In general, if a project does not meet the federal project consistency requirements, the 29 FHWA will not take action on the project. When federal action cannot be taken due to project 30 inconsistency, delays occur, and those delays put TxDOT at financial risk. More importantly, 31 without these federal actions, TxDOT cannot be reimbursed with federal funds for eligible 32 project costs. 33

The project investigated the various aspects of the project development process that 34 TxDOT conducted and focused on how to maintain project consistency through the letting stage. 35 The research team gained an understanding of the regulations of transportation planning, the 36 project development life cycle, and how they relate to the general and project-level transportation 37 conformity process. The researchers developed a guidebook for practitioners outlining the causes 38

1 Including signing a Record of Decision (ROD), Finding of No Significant Impact (FONSI), or approval of a Categorical Exclusion (CE) for a project.

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of project consistency and how to prevent inconsistencies from occurring. For the purposes of 1 this project, maintaining project consistency is relevant to projects listed in the MTP, TIP, STIP, 2 and conformity documentation. TxDOT uses the Unified Transportation Program (UTP) as 3 TxDOT’s 10 year plan to guide transportation project development. According to state 4 regulations, projects listed in the UTP also must be consistent with project listed in the MTP, TIP 5 and STIP. This paper will describe the project, the study approach, methods used and the results 6 of the project. 7

STUDY APPROACH 8

The overall approach for achieving the objectives of this study consisted of the following 9 four basic steps: 10

1. Identify information sources and obtain and review appropriate information through 11

literature review and interviews; 12

2. Process the information and obtain details on key issues (i.e. processes and practices); 13

3. Identify needs and problem spots based on detail information of previous steps; and 14

4. Develop solutions to address the needs based on findings of steps 2 and 3. 15

Researchers conducted a literature review on the transportation planning process, project 16 development process and also conducted interviews with key stakeholders in the planning and 17 project development process in the state of Texas. The following section describes study’s 18 approach. 19

Literature Review 20 The researchers conducted an extensive literature search and synthesis to provide 21

context/understanding of project consistency regulations and practices, with a focus on the PD 22 process’s relationship with the planning and programming documents. 23

The literature synthesis was assembled based on preliminary interviews with TxDOT 24 staff, a review of current practices, findings from published and internet sources, and other 25 information sources. The primary information sources include materials from FHWA, TxDOT, 26 MPOs, TxDOT partner agencies, state DOTs, or other agencies from outside Texas. The research 27 team compiled a list of target information sources see Table 1. 28

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Table 1. Literature Review Information Sources. 1

Agency Year Title

FHWA/FTA 2007 The Transportation Planning Process Key Issues, A Briefing Book for Transportation Decision Makers, Officials, and Staff

FHWA 2010 Transportation Conformity, A Basic Guide for State & Local Officials TxDOT 2001 Transportation Planning Manual TxDOT 2012 Project Development Process Manual TxDOT 2004 Environmental Manual TxDOT 2011 Standards of Uniformity for Projects without Federal Highway Administration

Involvement, Transportation Planning Consistency, and Fiscal Constraint TxDOT 2012 Project Scope and Environmental Issues Checklist for CEs, BCEs, and PCEs TxDOT 2012 Project Scope for Environmental Review Documents TxDOT 2012 Project Scope Amendment City of Port Angeles

2011 Project Development Checklist

Colorado DOT 2003 Non-Programmatic Categorical Exclusion Environmental Review Summary University of Princeton

2012 Project Audit & Review Checklist

Arizona DOT 2009 Development Process Checklist Georgia DOT 2011 Plan Development Process Kentucky Transportation Cabinet

2011 Local Public Agency Project Development Checklist

2 3

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Federal and state transportation planning statutes and regulations require transportation 1 projects to be consistent with transportation plans and programs. This way, the FHWA (under 2 NEPA regulations) can sign a Record of Decision, Finding of No Significant Impact, or approve 3 a Categorical Exclusion for a project delegated to TxDOT/ENV under MAP-21 effective 4 February 12, 2014. Figure 1 summarizes the requirements of federal regulations with regard to 5 the plans and programs that are subject to maintaining project consistency. Each project or 6 project phase included in the TIP, in metropolitan planning areas, must be consistent with an 7 approved MPO transportation plan. 8 9 10

11 12

Source: Adapted from 23 CFR 450 (i) and Texas Administrative Code 43 TAC 16 (ii) 13

Figure 1. Federal and State Project Consistency Requirements. 14

Stakeholder Interviews 15 In addition to the literature synthesis, researchers conducted a series of interviews to 16

document current practices and efforts in maintaining project consistency. The interviews helped 17 the research team to gain an understanding of the stakeholders’ roles and responsibilities during 18 the project life cycle. The interviews were conducted in person, through conference calls, and 19 email. 20

The research team contacted state DOTs that have similar characteristics as TxDOT such 21 as large population, many transportation projects, and nonattainment metropolitan areas. The 22 interviews with state DOTs occurred through conference calls. A majority of DOTs have 23 developed their own process for project development. The research team reviewed three other 24 DOTs project development process—California, Florida, and Ohio. All state DOTs have 25 developed their own project development process and manual identifying their specific problems 26 and concerns during project development process; however, the tools and resources shared with 27 the research team did not directly correlate to this specific project of maintaining project 28 consistency throughout the project development process. Table 2 shows the final list of the 29 interviews. 30

Must be fiscally constrained and must include a financial summary that is fiscally constrained to funding forecasts of TxDOT’s Finance Division.

Inclusion of projects only if consistent with state and local long-range plans.

The timing of subsequent phases should be consistent with the MTP and the environmental document.

TIP

& S

TIP

Projects described in ROD, FONSI, or CE shall be consistent with the MTP.

All project phases planned within the life of the transportation plan have to be included in the fiscally constrained MTP for FHWA approval. M

TP

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Table 2. Final List of Interviews. 1

District Austin, Beaumont, Dallas, El Paso, Fort Worth, Houston, Pharr, Paris, San Antonio, and Waco

MPOs Beaumont, Brownwood, Capital Area MPO (CAMPO), El Paso, Harlingen, Houston-Galveston Area Governments, San Antonio, Sherman, and Waco

TxDOT Divisions Right-of-Way (ROW), Toll Authority, Transportation Planning and Programming (TPP), Environmental Affairs (ENV), Finance (FIN), Project Management Office (PMO)

Federal Agencies Federal Highway Administration (FHWA)

State DOTs California, Ohio, Florida

2 The research team gained an understanding of the transportation planning process 3 through the literature review and interviews. The MPOs and the state DOT are the major partners 4 in the transportation planning process. Transportation planning is a cooperative process because 5 no single agency is responsible for the entire transportation system. In metropolitan areas, the 6 MPO is responsible for actively seeking the participation of all relevant agencies including 7 transit agencies and stakeholders in the planning process, whereas the state DOT is responsible 8 for activities outside metropolitan areas. 9

The research team identified three TxDOT manuals and a SOU guide that directly relates 10 to the project development process to maintain project consistency obtained from interview with 11 TxDOT staff. These manuals provide streamlined guidance to ensure that the project 12 development process complies with both federal and state transportation planning requirements 13 and regulations. A list of the manuals and the SOU reviewed are listed below: 14

Environmental Manual 15 This manual provides technical information for the ENV Division of TxDOT. The 16

manual outlines the policies and practices relating to environmental analysis and the 17 transportation project development process. The manual also provide information on guiding 18 projects through the environmental clearance process of NEPA. 19

Transportation Planning Manual 20 This manual provides guidance on the Texas planning process for rural and metropolitan 21

areas and the statewide transportation plan. The manual outlines the federal and state 22 requirements and regulations. 23

Project Development Process Manual 24 The manual provides technical guidance for the project development process and how 25

stakeholders can properly move a project through the process to meet all state and federal 26

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regulations. The intended audience is TxDOT personnel and describes each development process 1 from the project initiation to letting. 2

Standards of Uniformity for Projects without Federal Highway Administration 3 Involvement 4

TxDOT’s ENV Division has developed the guide to projects without FHWA involvement 5 in proposed projects (NFPPs), called Standards of Uniformity (SOU) for Projects without 6 Federal Highway Administration Involvement. The SOU is designed to ensure that all NFPPs 7 using it during the development process will comply with air quality-related requirements. 8

RESULTS/FINDINGS 9

The research team found after conducting interviews with TxDOT districts and MPOs 10 that a diverse audience and various staff was involved and responsible for maintaining project 11 consistency. Therefore, the research team needed to provide background on transportation 12 planning, project development process, conformity and environmental documents. Staff would 13 be involved in one phase of the project development process but needed the background all the 14 elements to understand why and how to maintain consistency. Staff needed to understand how 15 their role relates to the entire process and how any inconsistency in their area can impact the 16 project planning documents. The research team then developed a training package for 17 practitioners which included background information on key elements of the process, a 18 guidebook covering project consistency elements and a tool in the form of a check list to check 19 for consistency in planning documents. The following sections will describe the background, 20 project consistency guidebook and checklist. 21

Background Overview 22 The background material provided practitioners with a general understanding of the 23

transportation planning process, federal environmental regulations specifically the National 24 Environment Policy Act of 1969 (NEPA) and conformity regulations and its relevance to 25 maintaining project consistency. 26

Transportation planning is used by state and local governments to decide which 27 transportation projects to fund. Because transportation has broad impacts, transportation planning 28 involves not only transportation goals such as mobility, accessibility, and connectivity, but it also 29 involves social aspects, such as economic vitality, the environment, livability, social equity, 30 safety, security, and financial constraints. An effective transportation planning process is one that 31 is continuing, cooperative, and comprehensive. Transportation planning is conducted at the 32 statewide and metropolitan levels. 33

The two most important agencies/institutions involved in planning for publicly funded 34 transportation infrastructure projects in Texas are TxDOT and MPOs. TxDOT is responsible for 35 the state maintained road network, which is commonly referred to as “on-system” facilities. 36 MPOs are responsible for planning for transportation infrastructure in the current and expected 37 urbanized areas over a 20-year forecast period. Texas has four planning documents that must 38 remain consistent which includes the MTP, UTP, TIP and STIP. The figure below shows the 39 planning documents has they relate to the project development process. 40

41

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1 Figure 2. Key Transportation Planning Documents. 2

Project Development Process 3 Generally, a project life cycle shows the distinct phases a project passes through as it 4

progresses. Organizations can divide projects into phases to provide better management control. 5 Collectively, these phases are known as the project life cycle. TxDOT identifies four general 6 stages in the project life cycle: project initiation, planning, development, and construction. 7 TxDOT districts, in conjunction with MPOs, manage the project through these four stages. 8 Figure 3 shows a simplified overview of the TxDOT project development process and where key 9 TxDOT divisions are involved. 10

Funding Contract

Long-Range Planning – System Planning

Develop Construct

MTP/LRTP TIP/STIP UTP

Project Initiation

Plan

Programming – Project Planning

Letting Schedule

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1 2

Figure 3. Overview of TxDOT Project Development Process. 3 Source: Adapted from TxDOT Project Development Process Flowchart. 4

5

Planning and Conformity 6 The background section described the relationship between the environment and 7

transportation planning. The National Environmental Policy Act of 1969 (NEPA) established a 8 national policy to promote the protection of the environment through the actions and programs of 9 federal agencies. A direct link between NEPA and transportation planning is the requirement that 10 a project in a nonattainment or maintenance area be included in a conforming plan and TIP 11 before it can be advanced; a major change in the project scope and design as it evolves during the 12 NEPA process triggers a conformity and plan reassessment. Figure 4 shows an overview of the 13 major elements of the transportation conformity process. 14

PROJECT INITIATION

PLAN Authority Required

DEVELOP Authority Required

CONSTRUCT Authority Required

PLANNING AND PROGRAMMING

PRELIMINARY DESIGN

RIGHT OF WAY AND UTILITIES

PS&E DEVELOPMENT

LETTING

Identify needs Prioritize project Scoping

Construction Funding

Identification

Design Concept Conference

Geometric Schematic

Approval

Environmental Clearance

Start Right of Way Map

Right of Way Release

Utility & Right of Way Certifications

Design Conference

PS&E Assembly

30% 60% 90%

Time

ENVIRONMENTAL

Environmental Scoping

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1 Figure 4. Overview of Transportation Conformity Process. 2

3 4

Project Consistency Guidebook 5 Researchers developed a guidebook for TxDOT to provide an understanding of causes of 6

project inconsistency and how to address project consistency. The guidebook assists practitioners 7 identify causes of project inconsistency and how to address inconsistencies and prevent them 8 from occurring in the future and has three basic goals: 9 10

• Define project consistency and identify the causes of project inconsistencies. 11

• Identify resources and best practices that minimize project delays and financial risk, 12

including the Project Consistency Checklist. 13

FHWA/FTA signs a decision for the environmental document FHWA/FTA approves the federal funding for the project

Project Approval

TCEQ sets emissions budgets for the region SIP Emissions Budget

MPO performs regional air quality analysis of MTP and TIP Total emissions from the regional transportation activities after

implementation of MTP and TIP should not exceed SIP emissions budget

MTP and TIP are fiscally constrained

Plan and Program Conformity Determination

FHWA/FTA determines that MTP and TIP are conforming to SIP MTP and TIP Approval

Project must come from a conforming MTP and TIP Project must be consistent with MTP and TIP (Project Consistency) Hot spot analysis is maybe needed for PM and CO Determined based on information on the environmental document

Project–Level Conformity Determination

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• Provide contact information for external entities as well as communication guidelines 1

for resolving project inconsistencies. 2

To meet these goals, this guidebook was organized into chapters as follows: 3 • Chapter 2 defines project consistency and provides an overview of its elements. 4

• Chapter 3 identifies the causes of inconsistencies and outlines where project 5

consistency should be reviewed. 6

• Chapter 4 discusses project consistency management throughout the project 7

development process to minimize delay and financial risk. In addition, this chapter 8

identifies the tools helpful in this process. 9

The following sections highlight important sections from the guidebook. 10

Causes of Inconsistencies 11 Through the literature review and interviews with various stakeholders, the research team 12

identified four of the most common causes that lead to project inconsistencies. The causes of 13 project inconsistency can be numerous, but the following is a summary of the most common 14 causes: 15

• Projects evolve – The long periods of time that elapse between stages in the planning, 16

project development, and environmental processes increase the chances that a 17

project’s design, scope, estimated cost, or estimated letting date will change. When 18

changes are not communicated, it is difficult to maintain project consistently in every 19

document in which the project has been listed. 20

• Inconsistency in regulatory processes – Though inadvertent, some of the regulatory 21

requirements for planning, transportation conformity, and NEPA evaluations are 22

inconsistent in terms of the timing and criteria under which the federal actions related 23

to each process can occur. 24

• Communication – More to the point, there can be a lack of communication between 25

the numerous local, state, and federal entities responsible for the completion of the 26

plans, programs, and processes to advance a project from inception to construction. 27

For example, if the project description is changed during the preliminary design 28

phase, TxDOT would need to notify the MPO to update the project description in the 29

MTP before that project is carried into the TIP with an inconsistent (or rather, 30

incorrect) project description. 31

• Complexity of Funding Scenarios – Programming transportation projects is a dynamic 32

process. Changes in funding levels, fund sources, agency operations, economic 33

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conditions, current law, timing of project schedules, and other factors2 such as 1

changes in the estimated cost of a project over the time it takes to develop a project, 2

will result in changes to one or more aspects of a project’s scope, design, or 3

description. The changes would have to be revised in the appropriate planning and 4

environmental documents. 5

Examples of possible inconsistencies are listed below: 6 • The project design concept and scope are not consistent with that provided in the 7

MTP, TIP, and/or STIP, and/or the scopes do not match the funding amounts that are 8

projected. 9

• The project is not fiscally constrained because: 10

o It is not included in the fiscally constrained portion of the MTP. 11

o The project funding type is not consistent with that in the MTP, TIP, and/or STIP. 12

o The total project cost significantly exceeds that provided in the MTP, TIP, and/or 13

STIP (by more than 50 percent). 14

• A project is not included in the STIP or TIP but is found earlier in the planning 15

documents such as the MTP. 16

• In areas subject to transportation conformity (i.e., nonattainment and maintenance 17

areas), the project completion year is not consistent with the MTP and/or TIP regional 18

emissions analysis years for conformity determination. 19

In general, if a project does not meet the federal project consistency requirements, the 20 FHWA will not take action on the project. When federal action cannot be taken due to project 21 inconsistency, delays occur, and those delays put TxDOT at financial risk. More importantly, 22 without these federal actions, TxDOT cannot be reimbursed with federal funds for eligible 23 project costs. Figure 5 summarizes the potential consequences of a project inconsistency. 24

25

2 2014–2023 Cash Forecast. TxDOT. August 2013.

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1 Figure 5. Consequences of Project Inconsistency. 2

3

Project Consistency Responsibility 4 DOTs and MPOs are the major partners responsible for keeping projects consistent with 5

planning documents. Project managers play a central role in maintaining project consistency. 6 It is important for Districts and MPOs to identify the staff responsible for key 7

consistency-related steps/activities during the project development process, both inside their own 8 agency and their partner agency. Figure 6 lists the most common steps/activities that can be used 9 for this purpose along with the most appropriate staff member. Responsibilities should be clearly 10 explained and assigned to staff, and an effort should be made to ensure that they know the 11 responsible party for the other activities. 12

13

•Internal Communication and Coordination •Tracking and internal coordination of changes made to projects •As project moves through the PD process, checks environmental documents for any inconsistencies

District Project Managers

•Oversee and Coordinate Environmental Process •Compiles environmental documents for projects, and checks for any inconsistencies with the planning documents (MTP, TIP, STIP, UTP)

District Environmental

Coordinator

•External Communication and Coordination •Communicating changes to/from MPOs and headquarter staff •Ultimately responsible for maintaing project consistency and coordinating with the MPO and TxDOT Divisions

District TP&D Director

•Review of Submitted Environmental Documents and Project Scope ENV

Project Delivery Manager

Unnecessary Delays to the Project

Consequences of Project Inconsistency

Failure of Project-Level Conformity

Withholding of Federal Funding

Potential Failure of MTP and/or TIP Conformity

Potential Need for MTP and/or TIP Conformity Reevaluation

NA

&

Mai

nten

ance

Al

l Ar

eas

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Figure 6. Example of Helpful Activities for Maintaining Project Consistency. 1

Maintaining Project Consistency 2 Maintaining project consistency, or Project Consistency Management, is an ongoing 3

process and covers all phases of project development. It becomes critical during the last four 4 years of the project development process (i.e., when projects are listed in the TIP and STIP). 5

The scoping document is a collection of the first set of information on a project. A robust 6 scoping coupled with early coordination ensures that the project is set up by various stakeholders 7 in a consistent and timely manner. This early consistency has been indicated to greatly help the 8 stakeholders to maintain the consistency of information in the later stages of the project 9 development. 10

The project should be consistent with all applicable planning documents throughout the 11 project development process and into the preparation of the environmental review document. 12 The main mechanism through which TxDOT and FHWA/FTA check for project consistency is 13 the environmental review document and applicable planning documents (i.e., MTP, TIP, STIP). 14 If the project design concept or scope changes significantly after the project is environmentally 15 cleared, a reevaluation will be required and planning documents will likely need to be updated. 16

The basic principle of project consistency management is a seemingly simple task that 17 becomes a challenge in practice because at any given time, there are multiple teams working on 18 different aspects of a project and each use different tools and data resources. That is why project 19 inconsistencies are strongly associated with a breakdown of communication and poor 20 coordination. Establishing a systematic process for this task can greatly help practitioners to 21 simplify the coordination of efforts between different parties. 22

The following proposed steps can help in establishing such a process. The goal of these 23 steps is to establish project inconsistency prevention as a routine part of project development 24 process at the local and regional level. 25

• Step 1: Training – Make sure that all project managers have a general understanding 26

of the: 27

o Project delivery process. 28

o Planning and programming documents. 29

o Environmental process. 30

o Transportation conformity. 31

o Importance of maintaining project consistency. 32

• Step 2: Assign Responsibility – Clear roles assignment is an important factor in 33

establishing an effective PCM process. Ensure that all staff and parties involved in the 34

project inconsistency prevention, specifically project managers, have a clear 35

understanding of their responsibility in the process. 36

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• Step 3: Authority and Tools – To establish an effective PCM process, project 1

managers should be assigned the authority to meet their responsibilities and be 2

equipped with the right tools to accomplish them. 3

• Step 4: Establish a PCM Work Flow – Establishing a workflow helps to clarify the 4

steps necessary for maintaining project consistency. A workflow is a depiction of a 5

sequence of operations and connected steps, which demonstrate the elements and 6

flow of work in a simple form. 7

• Step 5: Systematic Coordination and Communication – Having a set of effective 8

communication and coordination procedures, specifically with MPO staffers, is 9

fundamental to achieve a successful project consistency management process. Many 10

times communication and coordination occur on a personal level. While personal 11

level communication and coordination is necessary and works in many instances, it 12

has a few major flaws that can cause a breakdown of communication: 13

o Risk of discontinuity: Staff turnovers can cause a major breakdown of 14

communication until the new person establishes the working/personal 15

relationship. 16

o No guarantee of a minimum level of communication: It requires a strong personal 17

level relationship of the staff and can become unreliable if a strong 18

working/personal relationship does not exist between the parties. 19

Best Practices 20 The following are examples of best practices based on the research team’s interview with 21

TxDOT and MPO staff with regard to establishing a system of communication and coordination 22 that TxDOT districts have done: 23

24 • Regular Meetings with MPO—The TP&D director and/or environmental coordinators 25

in some districts have monthly or quarterly meetings with MPO staffers. The main 26

purpose of these meetings is to keep MPOs aware of any changes to projects as well as 27

amendments or updates needed in the planning documents. Items such as project scope, 28

costs, and limits are discussed in the meetings. 29

• Regular Internal Project Meetings—Some districts have regular internal meetings 30

between the various district departments working on projects, including design, 31

environmental, and planning. These internal meetings help maintain communication as a 32

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project is developed at the district level. The involved parties are usually the district 1

planners, environmental coordinators, and design engineers. These meeting are held on a 2

regular basis or at critical junctures such as 30 percent, 60 percent, and 90 percent design 3

or environmental analysis completed. 4

Project Consistency Checklist 5 The research team developed a project consistency checklist as a tool for practitioners to 6

use to check for project consistency throughout the project development process. The checklist 7 includes various elements related to conformity, design concept, design scope and project cost. 8 The checklist also includes the planning documents that have to be checked such as NEPA 9 documentation, MTP, TIP/STIP and UTP. The project checklist was developed based on forms 10 that TxDOT currently uses for easy implementation for practitioners. The research team could 11 not provide the checklist because TxDOT has not released the checklist for publication. 12

CONCLUSIONS 13

The research team investigated the various aspects of the project development process 14 with a focus on how to maintain project consistency through the letting stage. Through an 15 extensive literature review and interviews with TxDOT and MPO staff, the researchers gained an 16 understanding of the regulations of transportation planning, project development life cycle, and 17 how they relate to the general and project-level transportation conformity process. This project 18 provides an insight to stakeholders’ involvement in maintaining project consistency and key 19 challenges that hinder project consistency during the project development process. This project 20 also outlines tools and resources that will assist with meeting FHWA’s criteria of maintaining 21 project consistency. 22

The researchers found that the main challenges leading to project inconsistencies are 23 insufficient communication over the changes to the projects’ design concept and scope, cost, and 24 estimated letting date. This research provides a set of tools and recommended practices to assist 25 state DOTs and MPO staff in maintaining project consistency throughout the project 26 development process. The research team developed a project consistency guidebook. The 27 guidebook explains how project planning and development interact with the regional and project 28 level air quality conformity process. 29

ACKNOWLEDGEMENTS 30

The study reported in this paper was funded by the Texas Department of Transportation 31 (TxDOT). The authors would like to thank Julia Ragsdale, Tim Wood and Michelle Conkle of 32 TxDOT for their support on all stages of the study. 33 34

35

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35 10. 40 CFR Part 51. Retrieved from http://www.law.cornell.edu/cfr/text/40/51. Accessed 36

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43 12. California Department of Transportation. (2009). Project Development Procedures 44

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13. Florida Department of Transportation. (2003). Florida Department of Transportation 1 (FDOT) Efficient Transportation Decision-Making (ETDM) Process. AASHTO Center 2 for Environmental Excellence. 3

4 14. Kasich, John R. (2011). Project Development Process. Ohio Department of 5

Transportation. Retrieved from: 6 http://www.dot.state.oh.us/Divisions/Planning/Environment/training/Environmental%207 Update%20Meeting%20Materials%20June%2016%20201/Project_Development_Proces8 s.pdf. 9

(i) Code of Federal Regulations. 40 CFR Part 51. Retrieved from http://www.law.cornell.edu/cfr/text/40/51. Accessed October 2013.

(ii) Texas Administrative Code. Retrieved from http://info.sos.state.tx.us/pls/pub/readtac$ext.TacPage?sl=R&app=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=30&pt=1&ch=114&rl=260. Accessed October 2013.