Post-Project Evaluation of the Effectiveness of Mitigation and Avoidance Strategies
Research Idea Scope
In February 2010 the Council on Environmental Quality (CEQ) released draft guidance for NEPA Mitigation and Monitoring. The memorandum proposes: “To provide guidance for departments and agencies of the Federal government on the mitigation and monitoring of activities undertaken in a National Environmental Policy Act (NEPA) process. Through guidance CEQ seeks to enable agencies to create successful mitigation planning and implementation procedures with robust public involvement and monitoring programs.”
In preparation of the release of the final CEQ guidance, this research proposal suggests a best practices summary of post-project evaluations that demonstrate effective mitigation and monitoring strategies. This project would focus on the NEPA commitments made in the environmental document and investigate the strategies and measurements that were used to evaluate the effectiveness of the mitigation efforts. As the content of CEQ’s final guidance is largely unknown, this research will provide a much needed resource to the states as they explore effective measurement practices for ensuring promises made during the NEPA process are followed through on.
A comprehensive collection of best practices that address how state DOTs are measuring performance is necessary to prepare for the release of the final guidance. This research project will assist states in measuring their commitments in the environmental document versus the results of the post-project evaluation. Whereas the National Environmental Policy Act (NEPA) requires federal agencies to integrate environmental values and impacts into their decision making process, tracking the effectiveness of their proposals is sometimes loosely managed or only required for specific waterway impacts.
This research can also verify that resources identified for avoidance or minimizations within the NEPA document were indeed in the post project. Acknowledging that alterations and changes occur through the development of a project, this research would highlight effective measurements that can be used to track the progress and effectiveness of the project’s outlined mitigation and avoidance strategies. Such a compilation of best practices would further help DOTs understand and compare the existing and effective measurement tools and procedures that are currently being utilized.
A synthesis of these measurement techniques will provide transportation agencies with the necessary background and resources for evaluating whether the mitigation outcomes met the commitments documented in the NEPA document. By gathering and reviewing this information the wider community of transportation practitioners, natural resource managers, cultural resource specialists and historic preservation advocates will have a much more thorough basis for discerning acceptable and effective mitigation and avoidance strategies.
The research project will have three (3) tasks:
Evaluate state practices for mitigation tracking programs and proven projects that have been successful with post-project mitigation. Out of those states, identify 12 states that represent each of the four AASHTO regions, therefore equally representing a range of geography, natural resources and regulatory oversight. Working with the DOTs identify projects including: mega, mid range and small to review and identify mitigation and avoidance strategies identified in the NEPA document. A range of commitments including, Section 7, Section 404, Section 106, etc, should be reviewed and considered. Research on the effective strategies should consider the mitigation planning and implementation procedures highlighted in CEQ’s draft guidance for NEPA Mitigation and Monitoring.
Review and analyze the range of current practices. Looking at the 12 successful programs determine how the measurement criteria was established, implemented and evaluated.
Prepare a final report that documents the successful practices. The report will document a range of commitments and practices. The final report should take into consideration CEQ’s draft guidance for NEPA Mitigation and Monitoring.
TRB 2006 NEPA Process Workshop Tim Hill, SCOE Environmental Process and Analysis Subcommittee