# Presentation: 503270

## Improving Environmental Documents

- _The Federal Perspective_
- Comments and Suggestions
- from FHWA (Arizona Division)
- ADOT Quarterly On-Call Meeting
- October 22, 2003

## Before We Get Critical ...

- We need to say that we really
- do appreciate all that you do!
- Collectively, _you in this room_ play a
- very _**significant**_ role in The delivery
- of the Federal-aid Highway Program
- We thank you!

## Coordination - the Recurring Problem @#**!!

**The “engineers” arrive at the “solution”**
**before the environmental review and **
**public involvement process even begins**!
-   Creates instant public credibility problem
-    Produces a reluctance to truly consider or
-           fully develop alternatives – including
-           those suggested by public
-    Often introduces severe time pressures
-    Complicates, compromises and _delays_ the
-           entire process – _and quality suffers!_

## Coordination

- _Involve the engineers!_
-   Demand their active participation – never
-         allow the engineers to sit on the
-         sidelines
-   Do not allow them to proceed ahead of
-         or without the environmental review
-         process
-   Insist that all viable alternatives receive
-         thorough engineering evaluation

## Coordination – a solution

- _Desirably_ – the engineering scoping process
- (PA’s and/or DCR’s) and the environmental
- review/public involvement process should be
- _coordinated and concurrent_.

- _RECOMMENDATION_ – ADOT consider
- initiating the public involvement process
- during (rather than after) the Project
- Assessment and/or Design Concept Study process

## Language

- _WRITE  FOR  CLARITY_
-   Clear and concise
-   Avoid duplication and/or repetition
-   Avoid long and complex sentences
-   Avoid sentences with long lists of similar
-        things – use bullets or numbered lists
-        instead
-   Avoid long paragraphs
-   Use abbreviations – _but carefully_

## Abbreviations & Acronyms

-   Generally desirable to avoid excessive text
-   Always define at first use
-   Avoid excessive use – overuse can cause
-         confusion
-   Don’t use or define if they are needed only
-         once – just spell out the word or name
-   Highly desirable to provide list of
-         abbreviations – UP FRONT!

- _RECOMMENDATION_ – Create a standard
- list of abbreviations and acronyms to use in
- all documents

## Acronyms 

-   Use agency acronyms preferred by that
-         agency (example – FHA vs FHWA)
-   Avoid using multiple acronyms to describe
-         a single agency:
-   BurRec vs BOR
-   USFS vs FS
-   COE vs CofE vs USACOE vs Corps
-   DOT vs USDOT

-   Do not use in List of Mitigation
-         Committments

## Too Many Acronyms?

- Alternate B(3)a-1.5 for the TI connecting SR-101L
- to I-17 and US-60 e/o the BNSF RR and the SRP
- CAP, and RID canals requires coordination with
- MAG, COP, MCDOT, SHPO, USFS, FCDMC, ADEQ,
- USF&WS,AGFD, BLM, BOR, and FHWA due to the
- 4(f) and 6(f) use, and may elevate the NEPA
- document from a CE-2 to an EA or possible an
- EIS, particularly if a new SPUI is used with CIP
- PCC box girders rather than AASHTO Type 4
- girders.  And E I E I O...

## Technical Terms or Jargon

-   Avoid whenever possible
-   Explain fully and clearly when use of
-          technical terms is absolutely necessary
-   Use graphics, maps or diagrams to
-            further clarify explanations
- Remember that we are writing for the
- general public – not engineers or “ologists”!

## Too Many Technical terms!

- Alternate A-D-H-N-R provides a single-point
- urban interchange to avoid four-phase
- overlap signal timing and uses a cast-in-place
- post-tension reinforced Portland cement
- concrete box girder structure type with
- cantilevered abutments and a center straddle
- bent, all on a slightly elevated grade line with
- tangent approaches on a slightly skewed
- alignment.   Huh?

## Language

- _WRITE  IN  A  PERSUASIVE STYLE_
-   Attempt to convince
-   _Use active tense_ – avoid passive tense
-           whenever possible
-   _Draw and express conclusions_ – even
-           preliminary conclusions
-   Provide supporting reasons
-   Make or express comparisons
-   Express professional judgments

## Draw Conclusions!

- Each discussion should end _with a conclusion_
-   If the impacts of an environmental consideration
-          are minor - say so!
-   If the impacts of an environmental consideration
-          are substantial – say so!
-   If an environmental consideration is not
-          involved - say so!
-   If one alternative has less (or more) impacts than
-          another – say so!
-   If one alternative has essentially the same
-          impacts as another alternative – say so!

## Quality Control

-   PROOF READ – always and often!
-   Use “Spell-Check”
-   Check punctuation
-   Check sentence structure – make
-         sure sentences are complete
-   Check and recheck references
-   Check facts – make sure text is
-         consistent throughout (and that
-         text is consistent with tables,
-         and other graphics)

## Quality Contorl – con’t

- _Correct errors as you find them_ – don’t
- leave them for subsequent proofreaders
- or reviewers to catch.
- It is difficult for reviewers to review
- draft documents for content if they
- constantly encounter basic language
- errors – and it greatly delays the process

## Graphics

- _Highly Desirable_ – easier to show complex
-   information and avoids excessive text
-   Maps
-   Graphs
-   Tables & Charts
-   Photos
-   Photo montages

## Maps – an essential tool

-   Should be of good quality – clarity is important
-   Avoid a copy of a copy of a copy of a copy
-   Always show a North arrow – normally, north
-         should be up (towards the top)
-   Label _all_ prominent features – make sure labels
-         and place names are consistent with the text
-   Use correct symbols for route numbers
-   Interstate Highways
-   US Highways
-   State Highways
-   County Highways
-   Reservation Roads

## Graphs – a very good tool

-  Use line, bar or pie graphs to help readers
-        visualize major points and comparisons quickly
-        easily, and accurately
-  Make sure the visual characteristics of graphs
-        reflect the magnitude and importance of the
-        data
-  Provide a title – and add a caption to identify
-        the purpose of the graph
-  Place foot notes & source information
-        below the graph
-  Color vs black & white – color often helps

## Tables and Charts

-  Excellent tools for presenting large
-    amounts of information clearly, concisely
-    and effectively
-  Outstanding tools for presenting
-     comparative information – like relative
-     attributes of alternatives

## Pictures are worth a 1,000 wordsEnough Said!

- But we will elaborate - pictures include:
-   Drawings
-   Diagrams
-   Photographs
-   Aerial photography
-   Photo-montages and other state-
-        of-the-art illustrative techniques

## Pictures – con’t

-   Obviously, pictures do reduce text
-   Pictures also help orient the readers
-   Pictures help readers understand and
-         comprehend important concepts,
-         issues and alternatives
- Pictures may be an under-utilized tool!

## Other Language Issues

- _Will vs Would_
-  “Will” implies that a decision has been
-            made (or a commitment is being
-            made)
-   “Would” is more appropriate for Draft
-            documents describing what would
-            happen if a particular alternate
-            were selected

## Other Language Issues

- _SIGNIFICANT_ – This word has special
- meaning when used in NEPA documents
-   Use with extreme care.
-   Do not use unless you really mean
-         significant – particularly if you are
-         describing impacts
-   Generally, use only in EIS’s
-   Use alternative words – substantial,
-         adverse, major, severe, etc.

## Preliminary Submittals

-   Avoid submitting incomplete documents –
-         multiple submittals and reviews _really slow_
-         the process down
-   Double space
-   _Use Line Numbers_ – this makes it much easier
-         to express and locate comments and
-         corrections (but please begin the line
-         numbers anew on each page – we do not
-         want to deal with Line 10,355)
-   Do not bind (loose leaf is an advantage during
-          reviews)

## Purpose and Need

- _This is the most important part of any _
- _environmental effort_.  Make the purpose &
- need a full and honest explanation of why the
- agency is considering an action.
-   Explain _who_ wants to do _what_ – and _where_ and
-         _why_ they want to do it.
-   Makes the case for doing anything –_ be convincing_
-   Make use of past planning studies
-   Describe what happens if nothing is done (i.e, the
-         “Do Nothing” Alternative)
-   Be specific – use facts and figures

## Alternatives

- Mention, describe and discuss _all alternatives_
- _considered to date_ – even those in considered
- and discarded in early planning studies
-   Show all alternatives graphically
-   Do not forget the “Do Nothing” Alternative

- _Recommendation_ – Use elongated paper (11” x 17” foldout) – with graphic on the left and descriptive text on the right

## Alternatives – con’t

-   If an alternative was discarded in earlier
-         studies – explain why!
-   If an alternative is not worthy of further
-         study now – explain why!
-   Carry all viable alternatives forward - at least to
-         the point where they can be clearly shown to
-         be inferior to other viable alternatives
-   Avoid the temptation to discard alternatives
-         simply to reduce the number considered to a
-         smaller, more manageable or pre-set number
- _BOTTOM LINE_ - THERE MUST BE _**COMPELLING**_
- REASONS TO DISCARD ANY ALTERNATIVES

## Naming Alternatives

-  Use already established names – whenever
-        possible and appropriate - avoid
-        creating new names for old alternatives
-  Avoid long complex names – use short and
-        simple names
-  Use Letters or Numbers to avoid long
-        complex names – such as Alt 1, 2, 3 or
-        Alt A, B, C – _however_, avoid complicated
-        combinations letters or numbers – such
-        as Alt A-G-M-R or Alt B-D-M-T for
-        arrays of braided alternates

## Issue / Resource

-  What is the current condition?
-  What will the project do to it – what
-        are the impacts?
-  What mitigation measures (if any)
-        can be used to offset the impacts
-  Conclusion*
- *  Remember to carry any mitigation measures
- offered as commitments forward to the List of
- Mitigation Commitments at the beginning of the
- document.

## Appendices

- In order to keep the issue/resource discussion
- concise and on point, make use of appendices
-   Place executive summaries of technical
-         reports in appendices
-   Limit the discussion to an executive summary
-         of the Executive Summary of Technical
-         Reports
-   Refer to Technical Reports - but do not
-         include them – either in the document or
-         in the appendices

## Logos

- _Please_ – no company logos in our environmental
- documents
- We realize you are proud of your organizations
- and desire to advertise your involvement and
- contributions, but –
- It is simply not appropriate to place such
- logos in FHWA documents distributed to
- the public – we ask your cooperation.

## In Closing ...

- We again want to reiterate our sincere
- appreciation for your collective efforts
- in accomplishing the difficult and
- challenging task of conducting the
- environmental reviews and preparing the
- environmental documents necessary to
- deliver Federal-aid Projects ... and for
- dealing with the public - conducting the
- necessary public meetings, hearings and
- other public coordination activities.

## Questions?

- Steve Thomas
- (602) 379-3645 ext 117
- _[Steve.thomas@fhwa.dot.gov](mailto:Steve.thomas@fhwa.dot.gov)_
- Ken Davis
- (602) 379-3645 ext 120
- _[Ken.davis@fhwa.dot.gov](mailto:Ken.davis@fhwa.dot.gov)_

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