Environmental Document-NEPA

When a City or County locally manages a project through the TDOT Local Programs Office, the very first “NOTICE TO PROCEED” will be for the Preliminary Engineering Phase-NEPA (PE-NEPA). I just want to take some time and explain what this is, and how it works.

“NEPA” stands for National Environmental Protection Act. An “approved NEPA document” looks like this: Sample NEPA

So what is this about and why should you care? It is simple:

No completed and approved NEPA document = No Federal funds for Construction

From the local government perspective it is pretty simple. The Notice to Proceed for PE-NEPA is your green light to put your TDOT pre-qualified engineering firm to work. We will do what it takes to get the approved document through TDOT.

The TDOT point of contact for all things Environmental and who your consultant will be working with is Joe Matlock (615) 741-5365 Joe.Matlock@tn.gov  Joe is a really nice guy to work with and really knows his stuff. If he follows through on recent threats to retire (which he can at any time) we are all in trouble, because there is nobody else who does what he does at TDOT. You will notice on the NEPA document front page that Joe’s signature is written across the top in a big John Hancock sort of way. If Joe’s signature is not on it, then it is not an approved NEPA document.

Here is one issue for local government officials and staff to understand: The NEPA document must cover the project that you want to have constructed. Lets say you get to the end of the process and you want to go “just one more street down” and bid that out as part of the project. If that is not covered under the NEPA document that you have for the project then you are out of luck. Now there are other concerns and issues like the contract with TDOT and all the certifications and approvals covering up to that next street. Just know that adding one more thing/termini/section onto a NEPA document is pretty much the equivalent of starting all over from square one.

So, my recommendation is to make your NEPA document like a big umbrella that covers not just the very limited project that you know that you have funds for today, but anything else that you might get funding for. Just because it is in the NEPA document does not mean that you have to do it. But not having it covered under the NEPA document pretty much takes if off the table.

As long as the activities that you are doing are pretty much the same kind of work (resurfacing, signals, sidewalks, curb and gutter) and these are activities that are considered a “Categorical Exclusion” (a whole other discussion for another post) then having more locations covered under the same NEPA is not much more time or expense. Having a NEPA document cover twenty locations costs only slightly more, takes just slightly more effort, and takes the same amount of time for TDOT approval as five locations. By having these extra locations covered, you can have options latter on down the line that you wouldn’t have otherwise.

As of this writing NEPA documents are good for two years from final approval before they expire. As long as nothing has changed (termini, or type of work) then it is not a big deal (about 2 weeks) for Joe Matlock to update it for another two years. I know that TDOT and the FHWA are reviewing their NEPA process and procedures to make smaller projects easier to get processed through. I will be keeping an eye on these developments and will let you know as these changes come out.

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About arran375

I work for Askew, Hargraves, Harcourt and Associates, Inc. here in Nashville, Tennessee. The short version of what I do is that we help local governments spend the Federal funds they get from TDOT on road, and bridge projects.
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