Chapter 2: Advanced Planning and Environmental DocumentationAnchor: #CFAEAGJD
Section 1: OverviewAnchor: #i1002448
The following goals should be accomplished during the advanced planning and environmental documentation stages of project development:
- assessment of hazardous material concerns in the early planning stage of project development
- consideration of hazardous material concerns in alignment selection
- determination of any additional investigation, consideration and/or coordination required for subsequent stages of project development because of the known or possible presence of hazardous materials
- coordination of assessment and/or investigation findings, decisions, considerations and commitments with affected parties, entities, district functional areas, divisions and agencies
- documentation of the hazardous materials assessment, alignment selection decisions regarding hazardous materials, and preliminary commitments due to the known or possible presence of hazardous materials.
Although this manual focuses primarily on transportation projects, other types of right of way or property acquisition efforts may benefit from the information provided. These include, but are not limited to, advanced or hardship acquisition, corridor preservation, maintenance facility acquisition, enhancement projects and transit projects.
Hazardous material contamination may be encountered on any transportation project during construction. Contamination sources can be found in existing, adjacent and proposed right of way. The potential for contamination should be assessed as early as possible when developing transportation plans or during project programming and development. Often, if the danger is identified early, more options are available to avoid or minimize impact to the project and to implement a cost-effective approach for handling the hazardous material contamination. The findings of site assessments and investigations should be well documented.
During advanced planning, early participation is needed from the following:
- local entities such as city, county or metropolitan planning organizations
- other affected district functional areas, such as planning and programming, advanced project development, environmental, right-of-way, design and construction staff
- TxDOT divisions such as Environmental Affairs Division (ENV), Right of Way Division (ROW), Design Division (DES) and Construction Division (CST)
- the Federal Highway Administration (FHWA).
Information obtained during site assessments and investigations must be communicated from one functional area to another within districts and divisions, either in writing or orally (such as in project design concept meetings).
Known or possible hazardous materials concerns, including cost considerations, should be integrated into the project coordination, alignment selection and decision-making processes. The decision-making process requires experience and knowledge of procedures in hazardous materials, right-of-way negotiation and acquisition, property management, design and construction. Additional discussions and meetings may be required to determine the most cost-effective approach to handling known or potential hazardous material contamination. The financial impact of pursuing further investigation and/or preventive action should also be considered. Other environmental issues, health and safety concerns, design feasibility, liability and costs must be considered when rendering the decision to avoid, minimize redesign or properly handle the concern prior to or during construction.
Early coordination with potentially responsible parties (PRPs) and regulatory agencies is recommended. Preliminary or required commitments should be identified or outlined during advanced planning, prior to finalizing environmental documentation and the project decision-making process. Affected parties, entities, district functional areas, divisions and FHWA, as appropriate, must agree to commitments for further investigation, site closure, preventive action and/or waste management.
The documentation for state and federal environmental approvals or clearances should provide full and open disclosure of any environmental consequences that may result from the proposed project. The assessment and investigation findings, decisions, considerations and coordination should be documented in the project files and summarized in any required environmental documentation. Required permits, approvals and coordination should be specifically identified in the environmental document.
In addition to the environmental document, information about known or possible hazardous material contamination must be tracked in the Environmental Tracking System Database (ETS); through this database, the information can be incorporated into cover memos for environmental documentation, approvals or clearance letters, and preliminary design schematics. This information should be forwarded to the appropriate planning, advanced project development, environmental, right-of-way, design and construction staff to facilitate communication. Commitments will require continued coordination in all stages of project development to ensure that any concerns are properly handled prior to or during construction. Design changes should be reassessed for possible hazardous material concerns. In some cases, there may be property management requirements to consider during post-construction maintenance activities. Assessing the risks of hazardous material early on, and communicating any resulting concerns to the appropriate district and division personnel throughout the various stages of project development, will help to avoid surprises and reduce costs.