# \...\...Department of Transportation and Federal Highway Administration, \.....Division

## Final Report Accomplishment of Environmental Commitments Process Review November 2001

 

 

 

 

  -------------------- ------------- ------------------------------ ------
  /s/                  12/7/2001     /s/                             

                       Date          For                            Date

  Chief Engineer                     Division Administrator          
  -------------------- ------------- ------------------------------ ------

### Executive Summary

During the spring of 2001 a joint Federal Highway Administration
(FHWA)/\...\.... Department of Transportation (STA) review of STA\'
process for meeting environmental commitments during construction was
conducted in Districts \....., \...\...\...\...., \...\...\...\...., and
\...\...\...\..... The review was initiated as a result of findings in
construction inspections conducted in late 2000 and through discussions
with the Environmental Coordinators of STA Headquarter Construction and
Environmental Divisions. The review determined that communication,
interpretation of contract documents, and construction knowledge and
experience were in need of improvement. These are summarized in Findings
1 through 4. Development of environmental project aids, creation of an
environmental/construction liaison, improvement of contract documents,
training, and greater involvement of the district Environmental and
Project Managers during construction are among the detailed
recommendations to correct these areas and are set forth in the
report\'s Findings and Recommendations. Existing STA guidance documents
(Environmental Handbook, Project Development Procedures Manual and
Construction Manual) are comprehensive in establishing adequate
procedures. Some districts have also initiated a variety of successful
and innovative measures to meet environmental commitments. Examples of
these are summarized in Findings 5 and 6.

## Summary of Findings:

**Areas Needing Improvement**

1.  Communication between Environmental, Design and Construction.

2.  Knowledge and experience within Design, Construction and
    Environmental.

3.  Transitions between Capital functional units as staff leave
    (transfer of project history information).

4.  Consistent interpretation of permits and agreements.

**Areas of Success and Innovation**

5.  District \...\... demonstrated a system that successfully
    communicated commitments from the environmental document to
    Construction. The system is based on a checklist developed and
    maintained by Environmental for each phase of the project.

6.  District \...\...\.... developed several solutions focused on
    environmental compliance. These solutions in many ways mirror this
    team\'s recommendations. Key elements of the District \... process
    include an Environmental Coordinator who acts as a liaison between
    Environmental and Construction for the environmental process.
    District \...\...\...\.... has a similar liaison position.

### Table of Contents

[Executive
Summary](../../../../../../../../C:/_Webpage/construction/#esummary)

[Introduction](../../../../../../../../C:/_Webpage/construction/#intro)

> [Purpose](../../../../../../../../C:/_Webpage/construction/#purpose)
>
> [Objectives](../../../../../../../../C:/_Webpage/construction/#objectives)
>
> [Scope](../../../../../../../../C:/_Webpage/construction/#scope)

[The Process Review
Team](../../../../../../../../C:/_Webpage/construction/#team)

[Findings and
Recommendations](../../../../../../../../C:/_Webpage/construction/#find)

> [Figure 1: STA District
> Map](../../../../../../../../C:/_Webpage/construction/#1)

Attachments

> [Attachment 1:
> Questionnaire](../../../../../../../../C:/_Webpage/construction/#a1)
>
> [Attachment 2: District \..... Mitigation Monitoring Reporting
> Record](../../../../../../../../C:/_Webpage/construction/#a2)
>
> [Attachment 3: District \...\...
> Checklist](../../../../../../../../C:/_Webpage/construction/#a3)
>
> [Attachment 4: District \...\...\..... Contract Acceptance
> Checklist](../../../../../../../../C:/_Webpage/construction/#a4)

### Introduction

As a result of findings in construction inspections conducted in late
2000 and discussions with Environmental Coordinators of STA Headquarter
Construction and Environmental Divisions, FHWA and STA decided to
partner in a process review of STA\' process of meeting environmental
commitments during construction.

Environmental commitments are those mitigation measures identified in
documents prepared pursuant to the National Environmental Policy Act
(NEPA), the (state) Environmental Quality Act and requirements found in
permits and agreements from regulatory and resource agencies.

Meeting environmental commitments during construction varies in method
as well as complexity depending upon the setting. To ensure a diverse
blend of construction project examples, Districts .., \..., \..., and
\... (Figure 1) were selected for the broad range of environmental
issues found within their geographical boundaries. These districts also
provide a cross-section of rural and urban settings.

The Process Review Team (the Team) focused on identifying the process
implemented by each district to comply with environmental commitments
for the selected projects in the construction phase.

In each district, the Team first met with the Deputy District Directors
for Design, Project Management, Construction and Environmental to review
their internal process. Then the Team conducted a field review with
Resident Engineers and their staff to see how the process transferred to
construction. In general, the Team found that improvement is needed
between the process developed to comply with policy and its
implementation in construction.

A questionnaire was developed to assure that the review was able to
identify the process, whether formal or informal, and to determine the
extent of how the process was being followed. Prior to meeting, a
questionnaire (Attachment 1) was sent to each district. The intent of
disclosing the questions was to enable the districts to prepare their
response and understand areas of interest to the Team. The Team also
requested that each district select two or three projects for field
review. The projects had to be at least 50 percent complete in the
construction phase and have environmental commitments. The intent of
pre-selecting projects was to allow each district an opportunity to
illuminate the success of their processes.

At the completion of the District reviews, the Team compiled its
findings. The Team then worked with a broader group of senior
specialists to develop recommendations. In addition, the Team identified
several innovative processes employed in the different districts.

This report identifies the recommendations and more importantly the
innovative successes brought to light by this review. Overall, the Team
recommends that formal policy and procedure be stressed by Management
and followed through in its implementation during construction.

#### Purpose

The purpose of this effort is to review the processes used within STA to
meet project commitments identified in environmental documents prepared
pursuant to NEPA and (STATE LAW REFERENCED) and related regulatory
permits. NEPA and (State law referenced) are the basic charters for
protection of the environment and the foundation of this review. FHWA,
in conjunction with STA, has the responsibility to meet the intent of
these laws for federal transportation related actions under their
jurisdiction. Therefore, FHWA establishes policy, sets goals, and
provides a means for carrying out the policy to implement NEPA in its
regulations. Furthermore, pursuant to 23 CFR 771.109, STA has
implementation responsibilities. Processes used within STA to meet
environmental commitments fulfill oversight obligations and ensure both
NEPA and (STATE LAW REFERENCED) are implemented in transportation
projects under STA\' jurisdiction.

#### Objectives

The review objectives were to evaluate:

-   Procedures used by STA to ensure that environmental commitments are
    designed into projects.

-   Procedures used by STA to ensure environmental commitments are
    implemented during the construction phase.

-   Procedures used by STA to ensure environmental commitments are
    addressed and transmitted to personnel responsible in the
    maintenance phase.

-   Recommendations that will assist STA in improving existing
    guidelines and procedures to address the above items.

The Team investigated the project delivery process from project
development through construction.

#### Scope

This review was a joint venture between FHWA and STA. The review was
conducted between April and July of 2001. Four districts were selected
for this review out of the \...\... districts which comprise the STA
organization (Figure 1).

### Figure 1

(Figure 1 has been removed to make this a generic report)

### The Process Review Team

The team was sponsored by:

  ----------------------------- -----------------------------------------
  Chief\                        Division Chief\
  Engineering Services\         Construction\
  FHWA \....Division            \....Department of Transportation

  ----------------------------- -----------------------------------------

Five permanent team members were assigned with additional members
invited as the need occurred. The team members were:

  ---------------------------------- ------------------------------------
  Construction Engineer\             Environmental Coordinator\
  FHWA \...\.... Division            Construction Division\
                                     \...\.... Department of
                                     Transportation

  Project Development Coordinator\   Environmental Coordinator\
  Design Division\                   Division of Environmental Analysis\
  \...\.... Department of            \...\.... Department of
  Transportation                     Transportation

  Environmental Branch Chief\         
  \...\.... District\                
  \...\.... Department of            
  Transportation                     
  ---------------------------------- ------------------------------------

### Findings and Recommendations

While none of the districts visited had established a formal
environmental compliance process, the team is aware that certain
districts have implemented informal environmental/construction
processes. These processes are noted in this summary. Recommendations
are provided for the first four Findings. The last two Findings are
examples of success and innovation.

**Finding 1: Poor communication between Environmental, Design and
Construction**.

Based upon the review, the Team found that the construction staff has
difficulties in contacting appropriate design and environmental staff to
get advices for their environmental-related problems. The Team also saw
gaps in how commitment information is passed through to the final plans.

> **Recommendation 1**: Create an Environmental/Construction Liaison
> position for all Districts. Presently Districts 10 and 11 have
> Environmental/Construction Liaisons. The team found that this
> significantly improved the construction of environmental commitments.
> One role of this position is to facilitate communication between
> Construction and Environmental as well as provide Environmental
> technical support during the construction phase.
>
> **Recommendation 2**: Maintain a current phone list/contact list of
> the PDT or the project team members. This list should be attached to
> the checklist identified in Recommendation 2. An example of this list
> is included as Attachment 2 to this report.
>
> **Recommendation 3**: Develop an Environmental Commitments Summary
> Checklist or Guidance to convey environmental requirements. This
> checklist or guidance needs to be reviewed by Design, Construction,
> Environmental and other Project Development Team (PDT) members in
> coordination with the FHWA Transportation Engineer. An example of this
> process can be found in District \....\'s [Environmental Compliance
> Quality Team Report]{.underline}, August 1997. The Mitigation
> Monitoring Reporting Record (MMRR) (Attachment 2) is similar in
> concept. This checklist is developed with the environmental document
> during the Project Report phase. It is to be presented at the project
> pre-job meeting by Environmental staff or the
> Environmental/Construction Liaison.
>
> **Recommendation 4**: Continuity of Environmental staff throughout the
> process is IMPORTANT. Retention in the Environmental units is the key.
> Because this can be accomplished in many ways, recommendations for
> improving this problem should be left to the district\'s management.
>
> **Recommendation 5**: Define and clarify construction engineering
> roles and responsibilities, especially the Project Manager. As with
> the Environmental staff, continuity from project inception through
> completion for the construction engineering is critical to ensure that
> environmental commitments are met. The Project Manager plays a key
> role in that process.
>
> **Recommendation 6**: According to activity 270.50 of the STA Work
> Breakdown Structure Manual (WBS), the Environmental staff needs to
> participate in the development of the ***Certificate of Environmental
> Compliance.*** The team found that in many instances this was not
> happening. The team found that a similar form (Attachment 4) prepared
> by District \..., the statewide form (CEM-6301) used for documenting
> contract acceptance needs to include a certification that all
> environmental commitments were met. This form must be completed and
> signed by the Resident Engineer at the completion of construction. The
> team also feels this recommendation could also be further developed to
> help transfer environmental commitments to Maintenance.
>
> **Recommendation 7**: Environmental commitments should be translated
> to contract bid items similar to Standard Special Provisions (SSPs)
> that were developed for storm water and hazardous waste.
>
> **Recommendation 8**: District Environmental staff must review Plans,
> Specifications and Estimates (PS&E) packages to ensure that
> appropriate special provisions are included and shown on the plans. If
> the Environmental review does not occur, the package would not advance
> from District Office Engineer to HQ Office Engineer.
>
> **Recommendation 9**: Providing guidance to Environmental staff for
> PS&E review will further ensure environmental compliance. This may be
> a job-aid such as a checklist.

**Finding 2: Lack of knowledge and experience within Design,
Construction and Environmental.**

The review revealed that some design staff had little knowledge of
general environmental objectives while the environmental staff had
little knowledge of construction techniques and PS&E process.

> **Recommendation**: Develop the following training for Capital Project
> Delivery staff:

-   provide a short course on meeting environmental commitments

-   joint training effort between STA and FHWA

-   develop training on how to maintain the administrative record

-   develop job-aids for Construction and Environmental staff

-   provide guidance for PS&E review (checklist)

-   provide training to environmental staff on construction procedures
    and techniques

**Finding 3: Poor transition between Capital functional units as staff
leave.**

Based upon the review conducted with the District\'s Management staff,
it was found that the formal process of transmitting environmental
commitment information between the project\'s Capital Functional Unites
was inadequate.

> **Recommendation 1**: Establish standards for maintaining project
> records. FHWA and STA legal staff should review these standards.
>
> **Recommendation 2**: Project management and functional units must
> keep project history file up to date. Establishing procedures for
> project files and providing training to staff will improve
> performance.
>
> **Recommendation 3**: STA should provide staff with direction on how
> and when to document communications with resource and regulatory
> agency staff then, in accordance with Recommendation 1 and 2 above,
> include these documents in the project file.
>
> **Recommendation 4**: Conduct internal spot checks or audits by STA
> staff to improve the quality of project files.
>
> **Recommendation 5**: Develop ~~a~~ statewide guidance for project
> record keeping.

**Finding 4: Incorrect or inconsistent interpretation of environmental
commitments.**

The review team discovered that the environmental commitment
requirements were sometimes inconsistently or incorrectly interpreted by
the staff of different capital functional units. For instance, it was
found that construction activities for the mitigation site on the State
Route \... project in the City of \...\...\.... was taking place at the
wrong time of the year.

> **Recommendation 1**: The Environmental Commitments Summary Checklist
> should be reviewed by the PDT in coordination with the FHWA
> Transportation Engineer (Finding 1, Recommendation 2).
>
> **Recommendation 2**: Provide cross training between functional units
> focusing on best management practices, construction methods and
> contract language consistent with environmental commitments.
>
> **Recommendation 3**: Include all permits in the Contractor\'s Bid
> Package.

-   develop Office Engineer boilerplate for an environmental SSP

-   use electronic contract packages

-   make permits available on the internet

**Finding 5: District \...\... Innovation - \"Environmental Commitment
Checklist\"**

District \.... is constructing a multi-phase project on new alignment.
The project has several complex environmental issues. During the review
of this project, District \... demonstrated a system that successfully
communicated commitments from the environmental document to the
Construction staff. The system is based on a checklist (Attachment 3)
developed and maintained by Environmental staff for each phase of the
project. The checklist presents a summary of commitments found in the
environmental document. Construction staff ensures these commitments are
completed. Regular meetings between Environmental and Construction staff
are held to check progress and to clarify any commitments that might not
be clearly understood.

> **Recommendation**: Use this as a statewide model.

**Finding 6: District \.... Innovation, \"Environmental Compliance
Quality Team\".**

District \.... developed several solutions focused on environmental
compliance. These solutions in many ways mirror the Team\'s
recommendations. Key elements of the District \... report include an
environmental commitments checklist that is used to monitor completion
through construction and a construction liaison who provides
environmental technical support during the construction phase as well as
enhanced communication between Construction and Environmental staff.

> **Recommendation**: Use this as a statewide model.

## ATTACHMENT 1: QUESTIONAIRE

### ACCOMPLISHMENT OF ENVIRONMENTAL COMMITMENTS

**TOPIC AREAS AND QUESTIONS**

A.  **District Project Development**

    1.  What process is followed to insure that recommended mitigation
        measures and permit conditions made during project development
        are incorporated into the project design; contract plans and
        specifications; and finally carried out in Construction?

> What guidance or instructions are available to require documentation
> of environmental commitments and implementation at each stage of a
> project i.e., environmental, design, construction?

2.  Who is assigned to track the recommended mitigation, permit
    requirements, and other environmental commitments throughout to
    ensure that it is incorporated into the design and construction of a
    project?

3.  What measures are taken to insure proper completion of environmental
    mitigation: checklists, computerized databases, other methods? How
    are changes monitored to ensure that commitments continue to be met,
    for example contract addendums or construction change orders

4.  Who is responsible for maintaining mitigation features? For how
    long? What procedures are used?

5.  Are environmental mitigation features being maintained in a manner
    consistent with their continued effectiveness? Is there a
    communication process set up for informing the Maintenance Branch of
    environmental commitments in a specific area? Are maintenance
    problems evident ?

6.  Have commitments been made during the environmental process that
    could not be made in design or during the construction phase? If
    this has occurred, what changes were made, what process was
    followed?

7.  Do you have any suggestions that would improve the existing
    procedures with regards to implementing environmental commitments?

8.  How do you provide feedback to Environmental?

9.  How do your Project Engineers/Project Managers become aware of
    environmental commitments and/or requirements?

10. When do the Project Engineers/Project Managers consult with the
    Environmental Branch? Is there consultation on-going during all
    steps of design?

11. What design reviews are done by the Environmental Branch?

12. Does the Environmental Branch review and concur with the final
    design?

13. How do you ensure that environmental commitments are feasible from a
    design and constructability point of view during the environmental
    process?

14. How do you provide feedback to Environmental?\
     

    a.  How does Environmental convey to Design and the Construction
        Resident Engineer the environmental commitments for a project
        such as mitigation and permit requirements?

    b.  Is a distinction made by Environmental to Design and the
        Construction Resident Engineer between environmental commitments
        (required) and measures to minimize harm (not mandatory but
        desired)?

15. Are you aware that Environmental Certification is identified in the
    WBS and the Construction Manual?

16. Are you using this activity code and providing Environmental
    Certification?

17. How are you implementing the Environmental Certification process?

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B.  **District Construction**

    1.  What type of guidance has been issued to the Construction Office
        concerning the handling and implementation of environmental
        commitments?

    2.  Are the construction field personnel aware of environmental
        commitments of a project? If so, by whom and how is this done?
        Through written correspondence or verbal conversation?

    3.  How do you provide feedback to Environmental?\
         

        a.  How does Environmental convey to Design and the Construction
            Resident Engineer the environmental commitments for a
            project such as mitigation and permit requirements?

        b.  Is a distinction made by Environmental to Design and the
            Construction Resident Engineer between environmental
            commitments (required) and measures to minimize harm (not
            mandatory but desired)?

    4.  During the pre-construction conference, is the contractor made
        aware of any environmental commitments? By whom? Is this
        documented? Are representatives from Environmental invited?

    5.  If changes need to be made, for any reason, to the planned
        environmental commitments, what process is followed and who is
        notified of the changes? Who approves these changes ?

    6.  After completion of the project, are the actions to accomplish
        the environmental commitments documented in contract records
        including any necessary special instructions for future
        maintenance? If so, what happens with the information (i.e., who
        is notified and reviews theses records)?

    7.  Does the commitment involve on-going maintenance activities? If
        so, how is this accomplished? What is the process followed for
        assuring that maintenance activities are accomplished?

    8.  Do you have any suggestions that would improve the existing
        construction procedures with regards to implementing
        environmental commitments?

    9.  Was the commitment accomplished as stated in the Environmental
        Document?

    10. Were there field changes to the scope of the Environmental
        Document? If so, what were these changes? What approval process
        was used? How was concurrence by externals documented?

    11. Briefly describe how you are made aware of Environmental
        Commitments on projects.

    12. Are CCO\'s that involve environmental commitments, directly or
        indirectly, always reviewed by the Environmental Branch?

    13. What is the established process you follow that passes on
        environmental commitments to the Maintenance Branch?

    14. Are you aware of the Construction Manual requirement (2-05-4,
        Environmental Review) that at the completion of construction the
        Environmental Branch with the Resident Engineer is to conduct a
        review to ensure that all environmental commitments were
        completed. In addition, a brief memo giving suggestions for
        improving future projects is to be sent to the appropriate
        District and Headquarters functional units? Is a report written
        on the completion of the project? If so, who receives a copy of
        the report and where are they filed? Does the report include the
        status of completing all the environmental commitments?

    15. Are you aware that a Certificate of Environmental Compliance is
        identified in the WBS and the Construction Manual?

    16. Are you using this activity code and providing Environmental
        Certification?

    17. How are you implementing the Environmental Certification
        process?

## Attachment 2: District \... Mitigation Monitoring Reporting Record

### MITIGATION MONITORING and REPORTING RECORD

Page 1 of 6

  ------------------------------------------------- ---------------------
  Date: November 2, 1994\                           11-Riv-86
  Revision Date:\                                   
  Enviro. Coordinator:                              

  ------------------------------------------------- ---------------------

  --------------------- ---------------- -------------- ---------- ------------- ---------- ------------- ----------------- ----------
  **Task and Brief      **Responsible    **Timing/      **Action   **Task                   **Remarks**   **Environmental   
  Description**         Branch/Staff**   Phase**        Taken to   Completed**                            Compliance**      
                                                        Comply                                                              
                                                        with                                                                
                                                        Task**                                                              

                                                                   **Initial**   **Date**                 **Initial**       **Date**

  DESIGN KICK-OFF       Project Manager  Beginning of 1                                                                      
                                         Phase                                                                              

  PRE-LOG IN REVIEW     Design           80% Plans                                                                           

  ENVIRONMENTAL PS&E    Environmental    District PS&E                                                                       
  REVIEW                Coordinator      Circulation                                                                        

  IN-HOUSE              Project Manager  Contract Award                                                                      
  PRE-CONSTRUCTION                                                                                                          
  MEETING                                                                                                                   

  Transfer Resident     Project Engineer Pre-const                                                                           
  Engineer Book                          Meeting                                                                            

  PRE-JOB MEETING WITH  Construction     Beginning of                                                                        
  CONTRACTOR                             Construction                                                                       

  ENVIRONMENTAL         Construction     Safety Review                                                                       
  COMPLIANCE REVIEW                                                                                                         

  DESIGN FEATURES       Construction /   Post                                                                                
  MEMORANDUM            Design           Construction                                                                       

  SOIL EROSION AND                                                                                                           
  SILTATION (5.0)                                                                                                           

  STA will comply with  Proj.                                                                                                
  measures set forth in Mgmt./Const.                                                                                        
  the National                                                                                                              
  Pollutant Discharge                                                                                                       
  Elimination System                                                                                                        
  (NPDES) permit.                                                                                                           
  (p.14)                                                                                                                    

  WATER QUALITY (5.0)                                                                                                        

  Existing and future   Proj. Mgmt./                                                                                         
  water quality will be Hydraulics                                                                                          
  monitored and                                                                                                             
  controlled through                                                                                                        
  the NPDES permit                                                                                                          
  process. (p.15)                                                                                                           

  Seed the R/W,         Proj. Mgmt./                                                                                         
  including the median  Land. Arch./                                                                                        
  where appropriate,    Const.                                                                                              
  with native plants to                                                                                                     
  establish vegetation                                                                                                      
  (to provide habitat                                                                                                       
  and reduce long term                                                                                                      
  erosion.) (p.19)                                                                                                          

  Rehabilitate          Proj. Mgmt./                                                                                         
  appropriate areas     Land. Arch./                                                                                        
  along the             Biology                                                                                             
  \...\...\.... River                                                                                                       
  by removing invasive                                                                                                      
  plants. (p.15)                                                                                                            

  Proposed construction Proj. Mgmt./                                                                                         
  affecting the         Proj. Dev./ Env.                                                                                    
  \...\...\..... River  Steward.                                                                                            
  will require the                                                                                                          
  application for a 404                                                                                                     
  permit from the ACOE.                                                                                                     
  (p.15)                                                                                                                    

  Proposed construction Proj. Mgmt./                                                                                         
  affecting the         Proj. Dev./ Env.                                                                                    
  \...\...\..... River  Steward.                                                                                            
  and other drainages                                                                                                       
  will require the                                                                                                          
  application for a 401                                                                                                     
  permit from the U.S.                                                                                                      
  EPA and the                                                                                                               
  \...\...\.....                                                                                                            

  LIGHT AND GLARE (5.0)                                                                                                      

  Install high pressure Proj. Mgmt./                                                                                         
  sodium lights at      Proj. Dev.                                                                                          
  intersections to                                                                                                          
  reduce glare. To                                                                                                          
  minimize ambient                                                                                                          
  light, narrowly                                                                                                           
  shielded lights will                                                                                                      
  be considered during                                                                                                      
  design. (p.18)                                                                                                            

  NOISE (5.0)                                                                                                                

  Install earthen noise Proj. Mgmt./                                                                                         
  berms to reduce noise Proj. Dev./ Env.                                                                                    
  levels for several    Analysis \'C\'                                                                                      
  homes. (p.17)                                                                                                             

  Minimize construction Proj. Mgmt./                                                                                         
  noise. Noise berms    Proj. Dev./                                                                                         
  will be constructed   Const.                                                                                              
  as one of the first                                                                                                       
  orders of work.                                                                                                           
  (p.17)                                                                                                                    

  BIOLOGY (5.0)                                                                                                              

  A pre-construction    Proj. Mgmt./                                                                                         
  survey will be done,  Biology/ Const.                                                                                     
  and Burrowing Owls                                                                                                        
  will be excluded from                                                                                                     
  any active burrow                                                                                                         
  immediately prior to                                                                                                      
  construction. (p.19)                                                                                                      

  Seed the right of     Proj. Mgmt./                                                                                         
  way, including the    Land. Arch./                                                                                        
  median where          Const.                                                                                              
  appropriate, with                                                                                                         
  native plants to                                                                                                          
  establish vegetation                                                                                                      
  (to provide habitat                                                                                                       
  and reduce long term                                                                                                      
  erosion),                                                                                                                 
  approximately 100                                                                                                         
  acres will be seeded.                                                                                                     
  (p.19)                                                                                                                    

  Acquire and restore   Proj. Mgmt./                                                                                         
  appropriate lands in  Biology                                                                                             
  the vicinity of the                                                                                                       
  project. Site                                                                                                             
  specifics, including                                                                                                      
  mitigation/impact                                                                                                         
  ratios, will be                                                                                                           
  determined as part of                                                                                                     
  the Section 404                                                                                                           
  permit process. The                                                                                                       
  current plan proposes                                                                                                     
  about 100 acres of                                                                                                        
  restoration. (p.21)                                                                                                       

  A mitigation plan for Proj. Mgmt./                                                                                         
  the alkali sink scrub Biology/ Proj.                                                                                      
  will be prepared in   Dev.                                                                                                
  coordination with the                                                                                                     
  FWS. The plan will                                                                                                        
  then be submitted and                                                                                                     
  approved by FHWA                                                                                                          
  prior to the                                                                                                              
  remaining stages of                                                                                                       
  the project (2 & 3)                                                                                                       
  being advertised.                                                                                                         
  (p.21)                                                                                                                    

  FARMLAND (5.0)                                                                                                             

  Consideration will be Proj. Mgmt./                                                                                         
  given to providing    Proj. Dev.                                                                                          
  access to farmland                                                                                                        
  which has been                                                                                                            
  severed by the                                                                                                            
  project. (p.22)                                                                                                           

  STA intends to offer  Proj. Mgmt./                                                                                         
  for lease, future     Right-of-Way                                                                                        
  interchange right of                                                                                                      
  way for agricultural                                                                                                      
  purposes. (p.22)                                                                                                          

  STA will investigate  Proj. Mgmt./                                                                                         
  placing a             Right-of-Way                                                                                        
  conservation easement                                                                                                     
  on farmland parcels                                                                                                       
  to keep them in                                                                                                           
  agricultural                                                                                                              
  operation (such as                                                                                                        
  excess parcel                                                                                                             
  remainders). (p.22)                                                                                                       

  ENDANGERED SPECIES                                                                                                         
  (5.0)                                                                                                                     

  Utilize diversion     Proj. Mgmt./                                                                                         
  channels during       Biology/ Const.                                                                                     
  construction to                                                                                                           
  prevent impacts to                                                                                                        
  the desert pupfish.                                                                                                       
  (p.22)                                                                                                                    

  Acquire a minimum of  Proj. Mgmt./                                                                                         
  20 acres which        Right-of-Way                                                                                        
  includes suitable                                                                                                         
  pupfish habitat,                                                                                                          
  within 1 year of the                                                                                                      
  start of construction                                                                                                     
  of Stage 3. (p.22)                                                                                                        

  HOUSING AND                                                                                                                
  RELOCATION (5.0)                                                                                                          

  Provide relocation    Proj. Mgmt./                                                                                         
  assistance for        Right-of-Way                                                                                        
  residents of all                                                                                                          
  homes and businesses                                                                                                      
  displaced by the                                                                                                          
  project. Resident                                                                                                         
  displacees will be                                                                                                        
  relocated into                                                                                                            
  comparable decent,                                                                                                        
  safe and sanitary                                                                                                         
  housing. (p.24)                                                                                                           

  CULTURAL RESOURCES                                                                                                         
  (5.0)                                                                                                                     

  Sites adjacent to     Proj. Mgmt./                                                                                         
  project areas were    Archaeology/                                                                                        
  designated \"ESAs\"   Const.                                                                                              
  and declared                                                                                                              
  off-limits to                                                                                                             
  construction                                                                                                              
  activities. (p.27)                                                                                                        

  VISUAL (5.0)                                                                                                               

  Seed the right of way Proj. Mgmt./                                                                                         
  (including medians    Land. Arch.                                                                                         
  where appropriate)                                                                                                        
  with native species,                                                                                                      
  and plant native                                                                                                          
  trees or palms at                                                                                                         
  appropriate                                                                                                               
  locations. (p.28)                                                                                                         

  Incorporate texturing Proj. Mgmt./                                                                                         
  and coloring of       Proj. Dev.                                                                                          
  structures/bridges,                                                                                                       
  where practicable.                                                                                                        
  (p.28)                                                                                                                    

  The two largest       Proj. Mgmt./                                                                                         
  channels (Ave. 68 and Proj. Dev.                                                                                          
  57) will be earth                                                                                                         
  bottomed, allowing                                                                                                        
  plants to establish                                                                                                       
  over time. (p.28)                                                                                                         

  Concrete and          Proj. Mgmt./                                                                                         
  rocks/gabions will be Proj. Dev.                                                                                          
  colored to match                                                                                                          
  surrounding soil,                                                                                                         
  where practicable.                                                                                                        
  (p.28)                                                                                                                    

  Every effort will be  Proj. Mgmt./                                                                                         
  made to save removed  Proj. Dev.                                                                                          
  date palm trees, so                                                                                                       
  that they can be                                                                                                          
  replanted elsewhere                                                                                                       
  in the valley. (p.28)                                                                                                     

  Berms will be         Proj. Mgmt./                                                                                         
  earthen, and          Proj. Dev.                                                                                          
  therefore will blend                                                                                                      
  in better with the                                                                                                        
  environment than                                                                                                          
  would walls. Also                                                                                                         
  they will be rounded                                                                                                      
  and with varying side                                                                                                     
  slopes to provide a                                                                                                       
  more natural                                                                                                              
  appearance. (p.28)                                                                                                        

  CONSTRUCTION                                                                                                               
  ACTIVITIES (5.0)                                                                                                          

  Noise barriers will   Proj. Mgmt./                                                                                         
  be one of the first   Proj. Dev./                                                                                         
  orders of work to     Construction                                                                                        
  help mitigate                                                                                                             
  construction noise.                                                                                                       
  (p.28)                                                                                                                    

  The Construction      Proj. Mgmt./                                                                                         
  Resident Engineer     Proj. Dev./                                                                                         
  will keep residents   Construction                                                                                        
  in the immediate area                                                                                                     
  informed about                                                                                                            
  construction                                                                                                              
  operations. (p.28)                                                                                                        

  Nighttime, weekend    Proj. Mgmt./                                                                                         
  and holiday work near Proj. Dev./                                                                                         
  residences will be    Construction                                                                                        
  limited to 5 types of                                                                                                     
  activities. (p.28)                                                                                                        

  Compliance with STA   Proj. Mgmt./                                                                                         
  Standard              Proj. Dev./                                                                                         
  Specification 7-1.01I Construction                                                                                        
  (July, 1992). (p.28)                                                                                                      
  --------------------- ---------------- -------------- ---------- ------------- ---------- ------------- ----------------- ----------

### ATTACHMENT 3: DISTRICT CHECKLIST

ROUTE MITIGATION MONITORING REPORT

+---------------------------------+---+---------------+--------------------+
| Project/Component:              |   | EA            | K.P.               |
+---------------------------------+---+---------------+--------------------+
| Mitigation Log Number           | P |               |                    |
|                                 | a |               |                    |
|                                 | r |               |                    |
|                                 | t |               |                    |
|                                 | y |               |                    |
|                                 | R |               |                    |
|                                 | e |               |                    |
|                                 | s |               |                    |
|                                 | p |               |                    |
|                                 | o |               |                    |
|                                 | n |               |                    |
|                                 | s |               |                    |
|                                 | i |               |                    |
|                                 | b |               |                    |
|                                 | l |               |                    |
|                                 | e |               |                    |
|                                 | f |               |                    |
|                                 | o |               |                    |
|                                 | r |               |                    |
|                                 | M |               |                    |
|                                 | i |               |                    |
|                                 | t |               |                    |
|                                 | i |               |                    |
|                                 | g |               |                    |
|                                 | a |               |                    |
|                                 | t |               |                    |
|                                 | i |               |                    |
|                                 | o |               |                    |
|                                 | n |               |                    |
|                                 | M |               |                    |
|                                 | o |               |                    |
|                                 | n |               |                    |
|                                 | i |               |                    |
|                                 | t |               |                    |
|                                 | o |               |                    |
|                                 | r |               |                    |
|                                 | i |               |                    |
|                                 | n |               |                    |
|                                 | g |               |                    |
+---------------------------------+---+---------------+--------------------+
| Required Monitoring/Reporting   |   | Implementati  |                    |
| Frequency:                      |   | on/Monitoring |                    |
|                                 |   | Phase:        |                    |
|                                 |   | (circle)\     |                    |
|                                 |   | Design        |                    |
|                                 |   | Construction  |                    |
|                                 |   | Operation     |                    |
+---------------------------------+---+---------------+--------------------+
| Mitigation Measure:             |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
+---------------------------------+---+---------------+--------------------+
| Mitigation Monitoring Action    |   |               |                    |
| Performed:                      |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
+---------------------------------+---+---------------+--------------------+
| Mitigation Complete? Yes \_\_\_ |   |               |                    |
| No \_\_\_\                      |   |               |                    |
| If yes, reference any           |   |               |                    |
| supporting documentation such   |   |               |                    |
| as engineering drawings,        |   |               |                    |
| contract documents, or other    |   |               |                    |
| reports as applicable.\         |   |               |                    |
| If no, itemize outstanding      |   |               |                    |
| mitigation and reasons why      |   |               |                    |
| measures were not implemented.  |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
|                                 |   |               |                    |
+---------------------------------+---+---------------+--------------------+
| In accordance with the          |   |               |                    |
| \...\.... Public Resources Code |   |               |                    |
| Section 21081.1, I hereby       |   |               |                    |
| certify under penalty that the  |   |               |                    |
| information contained herein is |   |               |                    |
| true and correct to the best of |   |               |                    |
| my knowledge.                   |   |               |                    |
+---------------------------------+---+---------------+--------------------+
| Name/Title/Agency of Person     |   |               |                    |
| Completing Report:              |   |               |                    |
+---------------------------------+---+---------------+--------------------+
| Signature:                      |   | Date:         |                    |
+---------------------------------+---+---------------+--------------------+
| Signature of Project Manager:   |   | Date:         |                    |
+---------------------------------+---+---------------+--------------------+

![](media/image1.jpeg){width="5.583333333333333in" height="7.625in"}