Integrating Freight into NEPA Analysis 

Integrating Freight into NEPA Analysis

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Table of Contents

PREFACE ...............................................................................................1

INTRODUCTION ........................................................................................2

1. PUBLIC/STAKEHOLDER INVOLVEMENT ................................................4

OVERVIEW OF CHALLENGES .............................................................4

WHAT TO LOOK FOR ......................................................................4

WHO TO TALK TO ..........................................................................5

WHAT TO ASK ...............................................................................6

2. SCOPING ......................................................................................7

FREIGHT-FOCUSED.........................................................................7

FREIGHT-RELATED .........................................................................8

FREIGHT IMPACT ANALYSIS ..............................................................8

3. PURPOSE AND NEED ......................................................................8

FREIGHT-FOCUSED PROJECTS .........................................................9

FREIGHT-RELATED PROJECTS ........................................................10

DATA SOURCES ...........................................................................11

4. ALTERNATIVES ANALYSIS...............................................................12

FREIGHT-FOCUSED PROJECTS .......................................................13

FREIGHT-RELATED PROJECTS ........................................................15

5. AFFECTED ENVIRONMENT ..............................................................17

6. ENVIRONMENTAL CONSEQUENCES ...................................................17

FREIGHT-FOCUSED AND FREIGHT-RELATED PROJECTS .......................18

ENERGY, AIR QUALITY, AND NOISE .................................................20

SOCIAL, ECONOMIC, AND ENVIRONMENTAL JUSTICE ...........................20

INDIRECT AND CUMULATIVE IMPACTS ................................................21

FREIGHT IMPACT ANALYSIS ............................................................22

7. MITIGATION .................................................................................24

FREIGHT-FOCUSED AND FREIGHT-RELATED PROJECTS .......................24

FREIGHT IMPACT ANALYSIS/MITIGATION ............................................25

CONCLUSION ........................................................................................26

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Integrating Freight into NEPA Analysis

List of Tables

TABLE 1. FREIGHT STAKEHOLDER OUTREACH ..........................................5

TABLE 2. DESCRIPTION OF FREIGHT DATA ...............................................9

TABLE 3. FREIGHT DATA SOURCES ......................................................11

TABLE 4. EXAMPLES OF FREIGHT SOLUTIONS ........................................13

TABLE 5. PERFORMANCE METRICS EXAMPLES .......................................15

TABLE 6. IMPACTS OF FREIGHT-FOCUSED AND FREIGHT-RELATED

PROJECTS ON ENVIRONMENTAL RESOURCES AND FEATURES ......19

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Integrating Freight into NEPA Analysis

List of Figures

FIGURE 1. INTEGRATING FREIGHT INTO THE TRANSPORTATION PLANNING AND

PROJECT DEVELOPMENT PROCESS ...........................................1

FIGURE 2. OVERVIEW OF NEPA PROCESS ...............................................3

FIGURE 3. ALAMEDA CORRIDOR RAIL LINE ............................................27

Appendix

A. LIST OF RELEVANT FHWA TRAINING MATERIALS

B. REFERENCES FOR NEPA LEGISLATION, REGULATIONS, AND GUIDANCE

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Integrating Freight into NEPA Analysis

Integrating Freight into 

NEPA Analysis

PREFACE

The effi ciency and effectiveness of freight transportation in the United 

States is critical to national, regional, and local goals and objectives related 

to: 1) economic growth and development; 2) ensuring livable communities; and 3) creating a sustainable environment (human and natural). 

In order to satisfy these goals and objectives it is increasingly important 

to integrate freight transportation issues and solutions throughout the 

transportation planning and project development process (Figure 1).

Figure 1. Integrating Freight into the 

Transportation Planning and Project 

Development Process
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Integrating Freight into NEPA Analysis

This handbook is designed to provide information on freight transportation to: 1) professionals responsible for advancing transportation projects 

through the National Environmental Policy Act (NEPA) process analysis; 

and 2) those freight stakeholders (public and private sector) interested in 

advancing freight transportation projects utilizing public sector highway 

funds that require NEPA analysis.

There are a number of resources available to those who desire a more 

in-depth understanding of NEPA and various characteristics specifi c to 

freight transportation. Some of these resources are listed in Appendix 

A and others are referred to in the text. Appendix B lists key legislation, 

regulations, and guidance to environmental planning.

INTRODUCTION

The National Environmental Policy Act (NEPA) requires analysis of the 

impacts of proposed Federal activities on the natural and human environments. Therefore, the use of Federal-aid highway funds to implement a 

transportation project requires that the project be advanced through the 

NEPA process as defi ned in law and regulation (23 CFR 771, etc.). The 

consideration of freight transportation within this process can be viewed 

from two perspectives: 1) the project itself is designed to resolve a freight 

transportation issue or need; and 2) there are freight-related features (warehousing, access to intermodal facilities, loading docks, etc.) that could be 

affected by the design and location of any transportation project in a given 

area. In the fi rst case the project could be either solely focused on solving a 

freight transportation issue or the freight transportation issue could be one 

of several issues to be resolved. The second perspective requires analysis 

of impacts of a proposed transportation project on activities, facilities, and/

or features associated with the movement of freight (warehouses, industry, 

retail stores, roads, ports, railroads, etc.). There is a need to understand how 

a project could change freight transportation activity; and how the changes 

in freight transportation activity could impact the environment.

Projects that may require the integration of freight considerations include 

the broad range of projects that can be funded through the Federal-aid highway funding as defi ned in Title 23 USC. These include but are not limited to: 

intersection improvements, reconstruction and rehabilitation of roadways, 

bridge replacements and/or rehabilitation, repaving, building highway on 

new location, expanding highway corridors, interchange improvements, 

additions of interchanges, roadway widening, access to intermodal facilities, accommodating rail expansion with roadway improvements, safety 

improvements, and many others.

Ideally, freight transportation considerations will have been included 

in the transportation planning process, which precedes NEPA, and that 

information will help to frame the NEPA analysis.
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Integrating Freight into NEPA Analysis

The purpose of this handbook is to provide information on how to integrate freight considerations into the NEPA process and analysis. This 

handbook is one of a series of informational documents developed to 

improve the consideration of freight in the transportation planning and 

project development process (Figure 1).

This handbook is designed for NEPA practitioners as well as those 

interested in advancing freight projects and the guidance in this 

handbook will apply to Environmental Impact Statements (EIS), 

Environmental Assessments (EA), and projects categorically excluded 

(CEs) from the necessity to prepare an EIS.1

 Each of the seven steps 

described in this handbook and illustrated in Figure 2 are covered 

in greater detail in the National Highway Institute (NHI) Courses on 

planning and the environment as shown in Appendix A.

The NEPA regulations upon which the information in this handbook is 

based include the CEQ National Environmental Policy regulations (40 

CFR 1500-1508) and FHWA NEPA regulations (23 CFR 771). FHWA 

technical guidance and documents are based on these regulations.

Figure 2. Overview of NEPA Process

1

 This will likely include CEs authorized by 23 CFR 771.117(d), and which are 

sometimes known as “documented CEs” or “Type 2 CEs.” Please refer to 

procedures under agreement between your state DOT and the FHWA Division.
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Integrating Freight into NEPA Analysis

1. PUBLIC/STAKEHOLDER INVOLVEMENT

An effective public involvement process for any transportation project 

requires the identifi cation of the appropriate stakeholders to engage with 

in developing a project. This identifi cation should include the consideration of freight transportation interests from both the public and private 

sectors. Additional information on developing and conducting public 

involvement can be found in Appendix A.

OVERVIEW OF CHALLENGES

Outreach to freight transportation stakeholders can be challenging. It 

is often diffi cult to identify all of the relevant freight stakeholders. For 

those stakeholders that are identifi ed, it is sometimes diffi cult to achieve 

a meaningful dialogue. The demands of operating a freight-related 

company do not easily lend themselves to participation in the transportation project development process. Additionally, freight stakeholders 

can be reluctant to disclose operational information that they deem to be 

proprietary and could benefi t their competitors.

WHAT TO LOOK FOR

The degree of freight stakeholder inclusion specifi ed in state DOT public 

involvement processes varies by state. Existing transportation planning 

process regulations require states (and MPOs) to consider freight in the 

development of Transportation Improvement Programs (TIP), Statewide 

Transportation Improvement Programs (STIP), and Long-Range 

Transportation Planning (LRTP) efforts. These involvement opportunities begun in planning should be folded into the NEPA process for a 

given project. A fi rst step is to conduct a review of the planning studies to determine to what extent freight was considered. When evaluating 

information gathered through freight stakeholder involvement during the 

planning process, some key questions to ask are:

• Did the sponsoring agency reach out to freight stakeholders and are 

there other stakeholders that were not involved that should be?

• Did the outreach produce meaningful comments from freight 

stakeholders?

• Was there specifi c data collected from or verifi ed by freight 

stakeholders?

• Were the freight stakeholder comments and data considered and 

included in the planning analysis and documents?

Freight Stakeholder Involvement 

can add a new dimension to typical public involvement processes. 

For the 2005 Detroit Intermodal 

Terminal Facility EIS, the study’s 

outreach list included:

• U.S. Department of 

Agriculture;

• U.S. Department of 

Commerce;

• U.S. Department of 

Transportation;

• U.S. Department of Energy;

• Federal Aviation 

Administration;

• Federal Railroad 

Administration;

• Michigan Department of 

Agriculture;

• Michigan Department 

of Labor and Economic 

Growth;

• CSX;

• Canadian National 

Railroad;

• Canadian Pacifi c Railway;

• Norfolk Southern Railroad;

• Ford Motor Company;

• DaimlerChrysler;

• General Motors; and

• Detroit Intermodal Freight 

Terminal Local Advisory 

Committee Members.
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Integrating Freight into NEPA Analysis

• How will you fold freight stakeholder outreach into the public 

involvement process during the NEPA analysis given what already 

has been done?

The information from the planning process will help frame the public 

involvement approach during the NEPA analysis for a specifi c project. 

Benefi ts will include but are not limited to identifying the freight stakeholders to engage with and how to engage with them.

WHO TO TALK TO

There are several types of freight interests to consider. Table 1 provides a 

list of potential freight stakeholder types and recommended methods for 

engaging with each.

Table 1. Freight Stakeholder Outreach

Freight Stakeholder Type Recommended Method of Outreach

Trucking Firms State and regional trucking association, owner-operator trucking associations – dispatchers 

among others.

Individual trucking fi rms.

The state DOT truck permitting section may have useful information.

Railroads For Class I railroads, contact public affairs department at HQ location.

For short line railroads, contact directly or through state-level short line railroad association.

The state DOT rail division will be a valuable resource for contacts and information.

Marine Ports Major ports have transportation planners that are typically accessible through state and city DOTs 

or MPO planning organizations.

American Association of Port Authorities.

Intermodal Association of North America.

In-person visits are recommended for marine ports.

The state may have a port offi ce that could be a valuable resource for contacts and information.

Port Terminal Operator Contact through marine port.

Warehouse/Distribution 

Center Operator

In-person visit, some states and regions maintain freight facility databases which is a potential 

source of this information.

Truck Stop Operator On-line trucking information web sites provide a list of truck stops around the country. Once 

identifi ed, an in-person visit is recommended.

Major Shippers Chamber of Commerce, local economic development agency, referral from other freight stakeholders 

(carriers and others).

The state Department of Commerce (or equivalent) could be a valuable resource).

Air Cargo Companies Contact through airport staff that manages air cargo operations.

The state DOT may have an Aviation section/department that could be a valuable resource.

Pipelines Work with state Department of Energy and U.S. DOT Pipeline and Hazardous Materials Safety 

Administration for specifi c contacts.

Federal Agencies (Federal Motor Carrier 

Safety Administration, Federal Railroad 

Administration, Federal Maritime 

Administration)

Contact state representatives for each relevant agency.

Note: For a detailed discussion on freight stakeholder participation refer to the FHWA workshop course “Engaging the Private Sector in Freight 

Planning.” Information on this course can be found at: http://www.ops.fhwa.dot.gov/freight/FPD/Docs/fpd_fl yer0606.pdf.
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Integrating Freight into NEPA Analysis

A particular challenge for involving freight stakeholders is identifying 

a stakeholder whose facilities are located outside the defined project 

study area. For example, a trucking firm may be a frequent user of a 

rural interstate facility, even though their truck terminals are located 

in urban locations 50 miles or more from the study area. In these 

circumstances, statewide and regional associations will be important 

sources of information. This would include state trucking associations, 

state and local chambers of commerce, and state and local economic 

development agencies.

WHAT TO ASK

There are four types of input that should be received from freight 

stakeholders. First, what are their current uses of the facility being 

studied? These uses can be considered in terms of operations and trip 

characteristics of freight in the study area and include:

• The freight mode used;

• Origin-destination combinations served;

• Time of day of shipments;

• Number and types of trucks (or other vehicles) used;

• Vehicle routing; and

• The sensitivity of the shipments to the project alternatives being considered (time sensitivity of deliveries, ease of access to facilities, etc.).

Second, freight stakeholders should be provided with an opportunity to 

comment on the accuracy of freight forecasts used in the scoping process. 

Any assumed changes in the trip characteristics described above should be 

discussed with freight stakeholders. Third, freight stakeholders should be 

a source of input for identifying alternatives, particularly given their fi rsthand knowledge of the study area. Fourth, freight stakeholders should 

comment on the impact of project alternatives on their operations and trip 

characteristics. These types of input will be a recurring theme for each of 

the components of the NEPA process as discussed in the following sections.
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Integrating Freight into NEPA Analysis

2. SCOPING

Freight considerations should be integrated into the scoping process 

for environmental studies. Additional information on the scoping process can be found in NHI Course 142005 NEPA and the Transportation 

Decision-Making Process, Lesson No. 6. A link to this course can be found 

in the Appendix A.

As provided in the CEQ NEPA regulations at 40 CFR 1501.7, scoping is “an 

early and open process” designed to “identify the signifi cant issues related 

to a proposed action.” FHWA’s technical guidance provides detailed 

information on the preparation of the Notice of Intent (NOI) to prepare an 

EIS and includes reference to conducting public scoping meetings.

Consideration of freight transportation in the scoping step begins with 

understanding the nature of the freight issue or issues to be considered. 

Is there a freight transportation problem to be solved and/or are their 

freight facilities and features in a study area that could be affected by a 

project? These perspectives are described as follows:

• “Freight-focused” projects are projects that address a specifi c freight 

transportation problem or need. Examples include: construction of 

truck-only lanes, highway capacity improvements due to increased 

truck volumes, highway reconstruction/paving due to increased volumes of trucks, interchange construction/reconstruction to provide 

or improve truck access, rail relocation, and developing an access 

road to a container port, rail yard, or pipeline/truck depot.

• “Freight-related” projects are projects in which freight is one of a number of transportation problems which are being addressed. Other 

problems or needs may include, but are not limited to: safety, capacity for all vehicles, access, and design to name a few.

• “Freight impact analysis” is the analysis of the impacts to freight activities, and facilities (distribution centers, loading docks, intermodal 

facilities, industry access, and access in and out of ports, truck access 

and fl ows on roadways (for example) of any project alternatives.

FREIGHT-FOCUSED

For freight-focused projects, a thorough examination and understanding 

of freight transportation problems in an area will be required to develop 

alternatives and assess the impacts of these alternatives on the full spectrum of environmental resources. This analysis will eventually focus 

on the specifi c issues that are relevant. This understanding also will be 

important to developing mitigation measures if needed.

“Freight-Focused Problem”

Freight-focused projects will have 

problems that are specifi c to freight 

which need to be addressed. This 

can include: road access to an 

intermodal facility, high numbers 

of truck-involved crashes, or delay 

on a key freight route (e.g., between 

port and nearby urban area).
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Integrating Freight into NEPA Analysis

FREIGHT-RELATED

For freight-related projects, the scoping phase is critical to defi ning the 

freight problems to be resolved in concert with other problems and setting the study boundaries. For example, a major freight facility such as an 

intermodal rail yard or big box retail distribution center may need to be 

identifi ed within the study area boundary, a multimodal corridor under 

study could have trucks as 30 percent of the total vehicular traffi c contributing to the defi ned problems, and/or truck-related accidents could 

be one of a number of issues that need to be addressed. This will ensure 

that freight transportation problems are addressed as appropriate while 

avoiding a comprehensive freight review which is needed for a freightfocused project.

FREIGHT IMPACT ANALYSIS

The freight impact analysis will include, but may not be limited to the 

potential impacts that project alternatives have on freight operations 

(movement) and freight facilities. The analysis of impacts to freight 

facilities and freight operations could be folded in with the “social and 

economic” impact analysis for a given project or considered separately. 

Information on freight impact analysis will be folded into the Affected 

Environment section as well as the Environmental Consequences and 

Mitigation sections.

If there are confl icts between freight and the local community regarding 

the proposed project, confl ict resolution opportunities should be identifi ed as part of the project study (early in the process). The project sponsor 

must strive to be an honest broker of the facts and not aligned with either 

confl icting interest.

3. PURPOSE AND NEED

Freight transportation issues should be considered in the development of 

Purpose and Need Statements for any project. Additional information on 

developing Purpose and Need Statements can be found in NHI Course 

142005 NEPA and the Transportation Decision-Making Process, Lesson No. 4.

A link to this course can be found in Appendix A.

CEQ NEPA regulations are brief in the description of Purpose and Need: 

“The statement shall briefl y specify the underlying Purpose and Need to 

which the agency is responding in proposing the alternatives, including 

the proposed action.” (40 CFR 1502.13). FHWA technical guidance states 

that the Purpose and Need statement will:

“Identify and describe the proposed action and the transportation 

problem(s) or other needs which it is intended to address (40 CFR 
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Integrating Freight into NEPA Analysis

1502.13). This section should clearly demonstrate that a ‘need’ exists 

and should defi ne the ‘need’ in terms understandable to the general 

public. This discussion should clearly describe the problems which the 

proposed action is to correct. It will form the basis for the ‘no action’ discussion in the ‘Alternatives’ section, and assist with the identifi cation of 

reasonable alternatives and the selection of the preferred alternative.”2

FREIGHT-FOCUSED PROJECTS

For freight-focused projects, the Purpose and Need should articulate the 

freight transportation problems to be resolved and the nature of freight 

activity in the study area. The problem(s) to be resolved should be 

defi ned in detail. Ideally, much of the information related to the Purpose 

and Need for freight-focused projects should be found in previous planning documents of the project. The types of information that should be 

included in the Purpose and Need Statement are found in Table 2.

Table 2. Description of Freight Data

2

 FHWA Technical Advisory T 6640.8A.

Freight Element Types of Information to Consider for Inclusion

Freight Facility Information Map indicating the location and type of freight facilities in the study area.

For projects involving freight rail, a map showing rail facilities, rail lines, and at-grade rail crossings in the study 

area is needed.

Square footage of each facility in the study area.

Number of employees at each facility in the study area.

Number of vehicles (trucks, trains, ships, planes) per day or year in and out of each facility in the study area.

Types and amount of commodities in and out of each facility.

Volume Data Hourly classifi cation counts to separately identify truck volume peaks and auto volume peaks.

On- and off-ramp classifi cation counts to better understand specifi c destinations of trucks on corridors.

Level of Service Data (LOS) Separate LOS estimates for morning, midday, and afternoon periods for highway corridors.

Identifi cation of congested freight rail lines, where relevant.

Freight Forecasts Growth of freight traffi c should be developed from freight-specifi c sources. See section on sources of freight 

data for more information.

Safety Data For highway corridors, report accident rates separately for truck-only accidents, truck-auto accidents, and autoonly accidents. Also report fatality rates separately by vehicle class, where relevant.

For rail corridors, report accidents separately for passenger transit and freight rail.

When relevant, report accidents at at-grade highway-rail crossings.

Road Geometry Identify locations of steep grades, sharp curves, short weaves, and reduced vertical clearances that impact 

truck operations.

Pavement Condition Describe pavement condition using information from state DOT road network database, FHWA HPMS data, 

stakeholder input, and/or fi eld observation.

Origin-Destination Data Identify split between through traffi c versus traffi c destined into and out of the study area. Identify routing 

information and determine potential for diversion to other routes and modes.

Economy Describe the freight component of the study area’s economy, including the number of employees and output by 

dollar or tonnage for specifi c industries.

Land Use Land use data, including the existing and future location of facilities that generate or attract freight shipments 

should be collected to provide as much industry detail as possible because truck, rail, and port trip generation 

characteristics vary substantially by industry.
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Integrating Freight into NEPA Analysis

FREIGHT-RELATED PROJECTS

The Purpose and Need for freight-related projects should include a defi -

nition of the freight transportation problem(s) to be resolved (as with the 

freight-focused project) along with any other transportation issues. The 

problem(s) should be clearly defi ned. Information that can be of use in 

defi ning the freight problem(s) could include but is not limited to:

1. Truck volume percentages may be high on one segment of a corridor 

and low on other segments indicating that freight analysis should be 

focused in one area.

2. A specifi c interchange or intersection could have a high level of truckinvolved accidents indicating that truck-focused safety improvements 

should be targeted at that location.

3. Traffi c has a high percentage of trucks (e.g., 20 percent or more). In 

this case, it will be important to describe the nature of those truck 

fl ows (commodity distribution, origin-destination pairs, truck types, 

etc.) to determine if there are problems related to these volumes and 

to focus where solutions will need to be considered.

4. Traffi c volumes through a small town may have reached a level that 

is a problem for the town. Forecasts may show this traffi c (including 

trucks) increasing in the future. The truck portion of this problem 

needs to be accurately defi ned (origin and destination, volumes, etc.) 

so that the appropriate solutions that are balanced between vehicle 

types can be developed. For example, solutions appropriate for 

increasing car volumes may be possible within the confi nes of the 

town on existing roadways but could result in substantial displacements (residents and businesses) if designed to accommodate truck 

volumes and movements.

After the nature of the problem(s) has been established, Table 2 should 

be reviewed to determine which of the freight elements are relevant for 

the Purpose and Need. The problem defi nition will drive the rest of the 

environmental and alternatives analysis.

Hourly Classifi cation Counts

A typical freight scenario has 

truck volumes which peak in the 

middle of the day, while auto 

volumes typically peak during 

the morning and afternoon commute periods. Therefore, hourly 

classifi cation counts are the best 

means to identify truck and auto 

peak-volume periods. Similarly, 

LOS estimates should be provided 

by time periods to ensure that the 

congestion for the typical truck 

and auto periods is estimated.
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Integrating Freight into NEPA Analysis

DATA SOURCES

A key component of the Purpose and Need is the presentation of available 

data for freight elements in the study area (Table 2). Some freight data 

should be available from preceding planning studies, but it may need to 

be supplemented or updated to complete the environmental analysis. A 

list of key freight data types and potential sources of related data is shown 

in Table 3. The NHI Courses listed in Appendix A also include several 

specifi c freight data sources.

Table 3. Freight Data Sources

Type of Freight Data Potential Sources of Data

Truck Counts State DOTs, MPOs, special counts collected as part of previous planning studies. May need to update truck 

counts for a specifi c project.

Truck Volume Estimates Truck components of travel demand models, estimated truck percentages applied to total volume data.

Origin-Destination Data Roadside truck surveys, state-level O-D data from freight fl ow databases (e.g., FAF), input from freight 

stakeholders.

Freight Flow Data FHWA Freight Analysis Framework database, Bureau of Transportation Statistics Commodity Flow Survey 

Data, proprietary commodity fl ow databases (e.g., TRANSEARCH).

Freight Forecasts Extrapolation from historical truck counts and rail volumes, FHWA FAF data, extrapolations of employment 

forecasts, interviews of freight stakeholders, and proprietary TRANSEARCH database.

Freight Shipment Characteristics Roadside truck surveys, input from freight stakeholders.

Freight Facility Databases Land use databases, previous planning studies, visual observation of study area.

Freight Safety Data State accident databases for highway safety data, FRA for rail safety data.

Economic Data The U.S. Economic Census contains county-level economic data (some data is suppressed due to 

confi dentiality concerns), state Departments of Labor maintain county-level industry-specifi c employment 

databases and often can provide 10- to 15-year forecasts, Proprietary sources such as Dun & Bradstreet 

provide zip code-level employment information by industry, socioeconomic data also can be found in state 

and regional travel demand model databases.
12

Integrating Freight into NEPA Analysis

4. ALTERNATIVES ANALYSIS

Freight considerations should be integrated into the Alternatives Analysis 

process for environmental studies. Additional information on Alternatives 

Analysis can be found in NHI Course 142005 NEPA and the Transportation 

Decision-Making Process, Lesson No. 7. A link to this course can be found 

in Appendix A.

CEQ NEPA regulations describe the importance of the alternatives 

analysis:

“This section is the heart of the environmental impact statement. Based 

on the information and analysis presented in the sections on the Affected 

Environment (Sec. 1502.15) and the Environmental Consequences 

(Sec. 1502.16), it should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defi ning 

the issues and providing a clear basis for choice among options by the 

decision-maker and the public.”

FHWA guidance recommends that the Alternatives Analysis section of 

environmental documents begin with a concise discussion of how and 

why the “reasonable alternatives” were developed for detailed study and 

explain why other alternatives were eliminated.3

 The development and 

analysis of alternatives for freight-focused projects will differ somewhat 

from the process used for freight-related projects as described in the following sections. However, one subject that is relevant for both types of 

projects is freight diversion.

The two types of diversion to consider are modal diversion and route diversion. Typically, modal diversion occurs between the truck mode and the 

intermodal rail mode as the total logistics costs associated with shipping 

goods on one or both modes changes. However, truck-rail modal diversion is limited to only certain types of commodities of distances roughly 

500 miles or more. Route diversion occurs most frequently by trucks 

using alternative highways. Route diversion also can occur between rail 

lines if signifi cant operational changes are expected for the rail network.

It is important that the alternatives analysis examines whether the road 

network and freight origin-destination combinations are conducive to 

diversion for each of the alternatives. If freight diversion is possible for 

any of the alternatives, it is important that the analytical tools utilized 

for the study are capable of generating diversion estimates. A detailed 

discussion of estimating techniques for modal diversion can be found in 

3

 FHWA Technical Advisory T 6640.8.

Proprietary Freight Data

Private sector fi rms can also be 

good sources of freight data. In the 

case of proprietary freight data, 

it is important to work directly 

with the providers of this data to 

determine what components of 

the data can be published in formal reports and what components 

must remain private. Methods 

of protecting proprietary data 

include removing company names 

from freight fl ow data, providing 

a data range rather than a specifi c 

value and aggregating data across 

large geographic areas to include 

several companies in a single geographic unit.
13

Integrating Freight into NEPA Analysis

the FHWA NHI Course Multimodal Freight Forecasting in Transportation 

Planning. A link to this course can be found in Appendix A.

FREIGHT-FOCUSED PROJECTS

Identifying Alternatives. For freight-focused projects, all alternatives 

developed should focus on solving freight transportation problems. 

Reasonable alternatives should be developed in consultation with government agencies, the general public, private sector freight stakeholders, 

as well as any other organizations and interest groups that could have 

an interest. It is very important to keep track of all comments on alternatives whether developed during the planning or NEPA phases of a project 

so that responses can be folded into the modifi cations of alternatives to 

improve the overall project outcome. Private sector freight stakeholders 

often have the expertise to substantially affect the development of alternatives. Additional efforts may be needed during the NEPA process to 

reach out to freight stakeholders if their comments were not solicited or 

are not well documented from the planning phase.

Alternatives should be considered across three solution categories: 

1) infrastructure solutions; 2) operations solutions; and 3) policy solutions. 

Examples of each of the types of solutions are shown in Table 4.

Table 4. Examples of Freight Solutions

Solution Category Examples

Infrastructure New alignments, adding lanes, improving roadway geometry, access to intermodal facilities, highway reconstruction, 

intersection design, truck climbing lanes, Interstate access, truck parking, use of alternative routes, etc.

Operational Improved traffi c signalization, changing mixed-fl ow lanes to managed lanes, system integration, variable message 

signs, accident response management, systemwide management for truck parking, real-time traffi c information, webbased port schedules (for pick up and delivery), weigh-in-motion, rationalizing cross-town movements (reducing number 

of truck trips), E-ZPass, urban truck parking management, etc.

Policy Defi ning the National Network, Regional Truck Size and Weight permitting, adopting weigh-in-motion (also Operations), 

routing for hazardous materials, city management of loading zones, overall land use and zoning approaches, facilitating 

diversion from one mode to another, etc.

Freight Diversion – Key Analytical 

Considerations:

• Commodity type – e.g., 

high-value versus lowvalue, function in overall 

supply chain;

• Distance shipped;

• Shipper/receiver delivery 

requirements – e.g., small, 

frequent shipments versus 

large, infrequent shipments;

• Availability of modal 

options; and

• Operational characteristics 

of modal options.
14

Integrating Freight into NEPA Analysis

Screening Alternatives. Robust freight data and analytical tools are keys 

to analyzing alternatives for freight-focused projects as well as the potential for environmental impacts. The most common analytical tool utilized 

for estimating truck traffi c is the travel demand model. When utilizing 

a travel demand model for a freight-focused project, it is important to 

fi rst understand the level of accuracy of the model relative to trucks in 

the study area. It is not uncommon for travel demand models to be validated on the basis of total vehicle volumes across regional screenlines. 

While this may be suffi cient for regional or statewide planning purposes, 

it may not provide a suffi cient level of accuracy for developing alternatives for a specifi c project and location during the NEPA and Preliminary 

Design phases. It may be particularly problematic when estimating 

truck volumes for specifi c projects. To verify the accuracy of the travel 

demand model, truck volumes need to be checked with model outputs 

at multiple locations in the study area. If the model and the volume data 

are substantially different, then either the model will need to be recalibrated or off-model techniques will be needed to estimate the impacts 

of alternatives. Forecasted truck volumes along a roadway also should 

be evaluated for reasonableness by checking growth rates with sources 

such as FHWA’s Freight Analysis Framework (FAF) forecasts, employment forecasts, and private sector freight stakeholders. When modeling/

forecasting it is important to remember that trucks are not just big cars. 

They are on the road for different reasons and they behave differently 

(schedules, turning radii, etc.).

It is important to identify the potential environmental impacts of each 

alternative so that the nature and magnitude of the impacts are included 

as a factor in determining which alternatives (that meet the project purpose and need) should be advanced through the NEPA analysis and 

selection process. The emphasis on selecting reasonable alternatives to 

advance begins with: 1) consideration of alternatives that avoid impacts 

while meeting the purpose and need; 2) then the alternatives that minimize impacts; and 3) fi nally consideration of the potential mitigation of 

impacts of each alternative.

Identifying appropriate screening criteria for freight-focused projects also 

is an important step. A comprehensive stakeholder involvement process 

is likely to generate a number of alternatives that will need to be reduced 

to a set of reasonable alternatives for detailed analysis. A fi rst level of 

evaluation can be conducted to eliminate alternatives that clearly do not 

meet the Purpose and Need of the project. Further screening may include: 

1) the degree to which the alternative solves the problem; 2) whether or 

not the alternative is based on a proven technology; 3) compatibility with 

existing or planned transportation systems; 4) compatibility with local 

and/or community goals and objectives; and 5) an appropriate balance 
15

Integrating Freight into NEPA Analysis

of environmental avoidance and/or impacts by alternative. A second 

level of screening can then be conducted with more detailed analysis of 

freight activity including performance metrics as shown in Table 5 and 

specifi c environmental impacts. These criteria should fl ow directly from 

the Purpose and Need Statement for the project as illustrated in Table 5.

FREIGHT-RELATED PROJECTS

Identifying Alternatives. As discussed in the Public/Stakeholder 

Involvement Section identifying alternatives for freight-related projects will require consultation with: 1) relevant government agencies; 2) 

the general public; and 3) private sector freight stakeholders. It is just 

as important to ensure that outreach extends to the private sector freight 

stakeholders for freight-related projects as for freight-focused projects. 

The list of participating government agencies should be checked to 

confi rm that appropriate freight-interested government agencies are consulted in developing alternatives (Army Corps of Engineers Port Division, 

state freight rail offi ce, state economic development agency, etc.).

Alternatives should be considered across the same three categories as for 

freight-focused projects: 1) infrastructure; 2) operational; and 3) policy. 

The relationship between the project and freight which was established in 

the Purpose and Need Statement should be used to generate alternatives 

that address freight needs as well as the other identifi ed transportation 

needs for the project. The same alternatives that would be considered for 

a freight-focused project also may be relevant for freight-related projects. 

The difference is that the development of alternatives will have to balance 

the degree to which they can satisfy all of the identifi ed transportation 

problems not just freight issues.

Sample Problem Described

in Purpose and Need Statement

Corresponding Performance Metric(s) 

Estimated in Alternatives Analysis

Congestion between a port terminal and nearby warehouse region. Estimated travel-time savings between the port and the warehouse

location, and reduction in the number of truck trips.

High truck accident location. Estimated reduction in truck-involved accident rate and accidents and 

severity of accidents.

Trucks traveling through towns/urban areas causing travel-time 

delays, community disruption, property, and economic impacts.

Number of or percentage of trucks diverted from through town movement, 

travel-time differential.

Port access schedule resulting in long truck lines at specifi c times 

of the day contributing to poor air quality in nonattainment areas, 

congestion, and ineffi cient freight movement.

Number of trucks that shift port access to off-peak times, travel-time 

improvements for port access.

Table 5. Performance Metrics Examples
16

Integrating Freight into NEPA Analysis

Screening Alternatives. It is expected that some alternatives will 

improve freight movement while others may make freight movement 

more challenging. In many instances, the improvement of freight movements on a transportation project also will provide improvements for the 

movements of passenger vehicles. In screening freight-related projects, 

it is critical to have metrics that estimate both freight and other types 

of transportation improvements. Examples of metrics may include, but 

are not limited to: truck travel times, auto travel times, truck-involved 

accidents, auto-involved accidents, and percent truck and/or auto diversions. Developing alternatives to address multiple problems can be 

complicated and may require a balancing of benefi ts. Analytical tools 

that are capable of addressing diverse issues will need to be used and the 

applicability of travel demand models (or other analytical tools) to both 

passenger vehicle and freight vehicle traffi c in the project’s study area 

will need to be examined carefully.

Confl icts in developing alternatives may occur so the screening of alternatives will need to incorporate a number of perspectives. For example: 

problems for a specifi c project may be defi ned as congestion and safety 

on an urban roadway and intersection affecting both truck and automobile movements. One solution might be to narrow the lane widths to add 

a lane so more cars and trucks can move through the intersection or to 

improve a turning movement. While benefi ting autos this could increase 

the severity of the problem for the trucks traveling through the area as 

the lanes might not be wide enough for their safe passage causing further 

problems (property damage, traffi c jams, crashes, etc.).

A number of approaches to screening alternatives may need to be considered that will be sensitive to the variety of problems identifi ed in the 

Purpose and Need and the potential impacts of those alternatives on the 

natural and human environment. One concept that may be considered if 

used in concert with other approaches is to monetize performance metrics. This involves estimating a dollar value for performance metrics 

such as truck delay, auto delay, truck-involved accidents, auto-only accidents, fatalities, and emissions similar to what is done for benefi t/cost 

analyses. This allows for an unbiased process (from one perspective) 

to be used to compare alternatives that benefi t freight relative to alternatives that benefi t passenger vehicles to alternatives that benefi t both. 

The FHWA Highway Economic Requirements System4

 is a good source 

for factors to convert travel time and accidents into dollar amounts for 

both passenger vehicles and trucks. This method would have to be 

balanced with other screening approaches to reach the best solution(s) 

which includes consideration of the No-Build alternative.

4

 Highway Economic Requirement System for State Use, FHWA, 2008.
17

Integrating Freight into NEPA Analysis

5. AFFECTED ENVIRONMENT

Defi ning the affected environment in a project study area provides the 

foundation upon which alternatives can be developed, the environmental 

consequences of alternatives can be evaluated, and measures to avoid, minimize, and/or or mitigate impacts can be developed. The existing condition 

of the affected environment can be used as a baseline for comparison of any 

build alternative against the No-Build. Both quantitative and qualitative 

descriptions are needed. Examples include but are not limited to: identifying the location, size, and quality of wetlands; describing and mapping 

signifi cant historic properties, and mapping neighborhoods, towns, communities, schools, hospitals, businesses, and parks. Mapping the resources 

and features that make up the affected environment, should include identifi cation of freight transportation-related activities, features and facilities 

such as: truck volumes on roadways in the study area, noting highways 

with high truck volumes, the location of freight distribution centers, manufacturing locations, intermodal facilities (including pipeline/truck depots), 

marine ports, retail centers, air cargo facilities, border crossings, rail lines 

and rail yards, as well as other locations requiring freight transportation 

services. These types of facilities could be incorporated into descriptions of 

existing social and economic factors for a project study area or stand alone 

if warranted.

The information on the affected environment is critical to developing 

alternatives for freight-focused and freight-related projects that limit 

the nature and extent of environmental impacts while solving the problems. This information also is important to accurately assessing the 

impacts that freight-focused and freight-related projects have on the 

environment and determining how to avoid, minimize, and/or mitigate those impacts. Finally, the defi nition of the affected environment, 

including freight features and facilities (highways, rail, distribution 

centers, ports, intermodal yards, etc.), provides critical information 

for consideration when developing alternatives for any transportation 

improvement project.

6. ENVIRONMENTAL CONSEQUENCES

The environmental consequences step represents the core of the environmental impact analysis for a project. This section includes information on 

how freight-focused and freight-related projects should be evaluated with 

respect to their environmental impacts and folds in the analysis of any 

transportation project on freight features and facilities. Additional information on Environmental Consequences can be found in NHI Course 

142005 NEPA and the Transportation Decision-Making Process, Lesson No. 6. 
18

Integrating Freight into NEPA Analysis

A link to this course can be found in Appendix A.

The CEQ regulations at 40 CFR 1508.8 defi ne “effects” as follows:

Effects includes ecological (such as the effects on natural resources and 

on the components, structures, and functioning of affected ecosystems), 

aesthetic, historic, cultural, economic, social, or health, whether direct, 

indirect, or cumulative. Effects also may include those resulting from 

actions which may have both benefi cial and detrimental effects, even if on 

balance the agency believes that the effect will be benefi cial.

FHWA technical guidance regarding environmental consequences recommends that this section includes the probable benefi cial and adverse social, 

economic, and environmental effects of alternatives under consideration 

and describes the measures proposed to mitigate adverse impacts. The 

information should have suffi cient scientifi c and analytical substance to 

provide a basis for evaluating the comparative merits of the alternatives.5

FREIGHT-FOCUSED AND FREIGHT-RELATED PROJECTS

For both freight-focused and freight-related projects, there could be 

direct, indirect, and cumulative environmental impacts. Direct impacts 

may include but are not limited to the impacts related to freight-focused 

or freight-related projects that may introduce more freight transportation (trucks, trains, etc.) into a project study area, and the impacts of 

building a freight-focused or freight-related transportation facility on all 

environmental resources and features. These impacts may in turn create 

additional indirect impacts that need to be considered.

Table 6 provides examples of types of impacts to the various environmental resources and features that could occur with the development and 

construction of freight-focused and freight-related projects.

Ultimately, freight-focused and freight-related projects are no different 

than any other transportation projects with respect to their potential to 

have impacts on a variety of environmental resources and features. Each 

project will need to have a carefully crafted Purpose and Need Statement 

and be scoped to defi ne the areas of focus that will be needed in the environmental analysis. Creating a comprehensive defi nition of the affected 

environment, including mapping and quantitative as well as qualitative 

data, will be just as important for these types of projects as for any transportation project and should be done early in the process to support the 

development of alternatives as well as the impact analysis.

5

 FHWA Technical Advisory T 6640.8A.
19

Integrating Freight into NEPA Analysis

The following sections provide examples for consideration in developing 

the impact analysis for freight-focused and freight-related projects.

Resource or Features Description of Potential Impacts and Effects

Economic There could be an increase in employment and output as freight activity increases.

Increased freight traffi c may be detrimental for nonfreight-focused industries (e.g., tourism, recreation).

Improvements of freight access could result in desired economic development.

Add to the tax base.

Energy Fuel effi ciency for trains is better on a ton-per-mile basis relative to trucks. Fuel effi ciency for trucks is better on a 

miles-per-gallon basis relative to autos. Reliable travel speeds improves effi ciency for all modes.

Social/Environmental Justice Industrial areas that require truck and other modal access are often surrounded by residential neighborhoods that 

can be low-income and minority in composition.

Improving freight access into and out of a community may benefi t to businesses as well as residents.

Freight projects may generate jobs to improve economically disadvantaged regions.

Alternatives may cause severing of community and neighborhood ties.

Air Quality Freight vehicles are typically powered by diesel engines which have particular emissions characteristics. Increasing 

the volume of these vehicles into an area can result in impacts that will need to be mitigated and innovative 

approaches may need to be used.

Decreasing freight congestion improving travel time may decrease the amount of total pollutants emitted.

Idling may be decreased at intersections or at an intermodal facility gate also providing AQ benefi ts.

Greenhouse gas analysis is also included here.

Noise One truck is the equivalent of 32 cars in terms of noise generated. Freight trains are even louder.

Visual Trucks, trains, and cargo ships are typically considered to be eyesores by local residents and tourists alike.

Bicycle and Pedestrian Bicycle and pedestrian paths can be negatively impacted by alternatives that introduce more freight traffi c or that are 

located in the vicinity of pedestrian/bicycle path.

Land Use Freight projects may generate a variety of freight-related land uses that may or may not be compatible with an 

area’s established planning and zoning policies.

Expanding a port facility may create confl icts within a municipality that would like to develop high-end residential 

properties instead.

Farmland/Rural Character Freight projects may preserve or increase viability of prime, unique, or important farmland by providing additional 

access to markets for these goods.

Signifi cant Historic 

Properties (Archaeology, 

Buildings, Landscapes, etc.)

A Freight facility that is being modifi ed (improve capacity and/or function) may be a signifi cant historic property.

Expansion of existing facilities or building new facilities may impact one or more types of historic properties directly, 

indirectly, and/or cumulatively.

Wetlands As with all transportation projects freight-focused and freight-related projects can impact wetlands in a variety of 

ways that will need to be evaluated carefully.

Section 4(f) Properties and 

Resources (Public Parks, 

Historic Properties, Wildlife 

Refuges, etc.)

A freight facility may be identifi ed as a Section 4(f) resource (signifi cant historic property) or may be in or near a 

Section 4(f) resource, with the potential to impact that resource.

Alternatives such as a highway on new location benefi ting freight transportation could result in a “taking” from a 

Section 4(f) property (park, recreation, area, historic property).

Coastal Zone, Water Quality, 

T&E Species, Floodplain

Freight-focused and freight-related projects may have direct, indirect, and/or cumulative impacts on these resources.

Table 6. Impacts of Freight-Focused and Freight-Related Projects on 

Environmental Resources and Features
20

Integrating Freight into NEPA Analysis

ENERGY, AIR QUALITY, AND NOISE

Trucks and trains have vastly different operating characteristics relative 

to autos. Therefore, changes in freight movement also could have notable 

impacts on energy consumption, air quality, and noise. These changes 

must be explored for both freight-focused and freight-related projects. These can be described as performance metrics in the Alternatives 

Analysis to enable comparisons between alternatives with vastly different 

performance characteristics. More information on these environmental impacts can be found in the FHWA NHI Course Integrating Freight 

into the Transportation Planning Process Session on Freight Impacts. 

This course also includes reference material that can be used to estimate 

energy, air quality and noise impacts from changes in freight activity.

SOCIAL, ECONOMIC, AND ENVIRONMENTAL JUSTICE

In terms of social impacts, FHWA recommends that freight be incorporated 

into the consideration of changes in an area that can affect populations in 

various ways, including, but not limited to, neighborhoods and communities. These changes may be benefi cial or adverse, and may include, but 

are not limited to: splitting neighborhoods, improving access to goods 

and services, introducing more job opportunities, affecting the cost of 

goods, isolating a portion of a neighborhood or an ethnic group, generating new development, affecting property values, or separating residents 

from community facilities, and improving safety. Other aspects to consider include changes in travel patterns and accessibility (e.g., vehicular, 

commuter, bicycle, or pedestrian) along with impacts on school districts, 

recreation areas, churches, businesses, tax base, police, and fi re protection. 

This should include both the direct impacts and the indirect impacts to a 

population. Analysis of the social impacts of freight-focused and freightrelated projects is both qualitative and quantitative, and it does require 

having good data on the traffi c impacts of various alternatives.

Freight-focused and freight-related projects may be located in areas that 

are populated by low-income and minority people. As stated in Executive 

Order 12898:

“[E]ach Federal agency shall make achieving environmental justice part 

of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of 

its programs, policies, and activities on minority populations and lowincome populations...”
21

Integrating Freight into NEPA Analysis

Historically, residential housing in the vicinity of heavy or light industry 

historically housed the people that worked at those facilities (factories, 

docks, and rail yards). This housing tends to be less expensive then other 

areas and may be home to minority and/or low-income populations that 

may or may not work at these facilities. Therefore, issues of Environment 

Justice (EJ) will need to be addressed as would be the case with expanding major arterial, highways, and Interstates. In addition a project may 

affect access to jobs for low-income and minority populations and this 

impact should also be taken into consideration. FHWA conducts an 

EJ analysis as part of the NEPA analysis of impacts on all communities 

affected by a project.

The quantitative aspect of this analysis involves overlaying changes in 

freight activity with socioeconomic data. Where travel demand model 

outputs are available, a map should be generated that shows changes 

in the volumes of trucks and trains and how that overlaps with various 

neighborhoods, income groups, ethnic groups, as well as businesses. 

Off-model estimation techniques can be utilized for circumstances 

where travel demand models are not available. In addition the population and business travel patterns and transportation needs can be 

quantified and mapped.

The qualitative aspect of this analysis involves stakeholder involvement. 

The outreach must involve the freight community to determine how alternatives could impact their operations. The outreach also must include, 

but is not limited to, the general public, neighborhood and community 

groups, businesses, schools, and community facilities to determine the 

impacts of alternatives on an area.

INDIRECT AND CUMULATIVE IMPACTS

Indirect effects are effects that are caused by a proposed action, but are 

later in time (although reasonably foreseeable) or farther removed geographically. Indirect effects may include growth-inducing effects and 

other effects related to induced changes in the pattern of land use, location 

of freight facilities, and related effects on air and water and other natural 

resources. For example, a road project may shift existing and anticipated 

industrial growth to a different area of a region and this will in turn change 

the pattern of freight movement in the region. The growth already may 

have been happening, but the road project “indirectly” infl uenced where 

it took place. Another example of indirect affects could be that a road 

project on new location may infl uence the location of freight distribution 

centers in the future resulting in development and changes in traffi c and 

specifi cally truck access into and out of an area. Indirect effects, while diffi cult to quantify and assess, must be linked to a discernable direct effect 

due to the project.
22

Integrating Freight into NEPA Analysis

Cumulative effects are defi ned6 as:

“The impact on the environment which results from the incremental 

impact of the action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency or person undertakes 

such other actions.”7

Analyzing cumulative effects differs from the traditional environmental impact assessment because the analysis must consider expanding 

the geographic area of study beyond that of the proposed project and 

expanding the temporal limits to consider past, present, and future 

actions that may affect the resource elements of concern. For freightfocused and freight-related projects, this means that the entire supply 

chain of goods movement must be considered in the overall analysis, 

including those elements of the supply chain that occur outside of the 

study area boundaries. Cumulative effects can be positive as well as 

negative depending on the resource element being evaluated.

FREIGHT IMPACT ANALYSIS

This section addresses the analysis of the impact of any transportation 

project on freight activities, facilities, features, and operations in a project 

study area. This will ensure that as alternatives are developed for transportation projects, freight is taken into consideration when determining 

the impacts and the balancing of those impacts with other environmental (human and natural) resources and features. From this perspective 

freight transportation may be considered an element or subset within the 

context of social and economic resources or features. A project alternative that has a negative impact on access to an intermodal freight facility, 

warehousing, expansion of a port facility, access to industrial sites, or 

precludes the effi cient development of these types of facilities may have a 

detrimental impact on the economy in the area, including, but not limited 

to jobs, community viability, and the tax base. While general (people and 

transit) access to a community may be the objective of a particular project 

access by freight carriers also may need to be considered. Viability of that 

community could be negatively affected if freight access into and within 

the community is impeded (access to: hospitals to deliver life saving 

product, delivery to stores of food, and to gas stations to deliver fuel for 

example). Some examples of impacts to freight facilities and operations 

that may need to be considered include but are not limited to:

6

 Per the Council on Environmental Quality’s (CEQ) regulations implementing 

the procedural provisions of the National Environmental Policy Act (NEPA).

7

 40 CFR 1508.7.

The Lackawanna Valley Industrial Highway Project

Analysis of both indirect and 

cumulative impacts was included 

in the NEPA analysis for this 

highway project on new location 

in Northeast Pennsylvania. The 

location of the new interchanges 

linking the surrounding towns 

and cities to the new highway 

were anticipated to affect the location of future freight distribution 

centers and warehousing that 

would serve the broader region. 

This in turn would affect traffi c 

patterns in the study area and 

future development. There would 

be a resulting cumulative effect 

with respect to developed versus 

undeveloped land and loss of some 

types of habitat. Mitigation for 

the potential indirect and cumulative impacts included additional 

funding for local transportation 

plans and environmental analysis 

and mitigation recommendations 

for parcels subject to development.
23

Integrating Freight into NEPA Analysis

1. Changing access to warehousing areas: can create safety and access 

problems for trucks; the possibility of increasing truck traffi c through 

communities creating safety, air quality, and noise issues for residents; and increases in costs to transport freight resulting in increased 

costs of products to consumers, etc.).

2. Changing design of highways to narrow lane widths to increase the 

number of lanes on a highway in a high-volume truck corridor can 

result in unsafe conditions for trucks and autos due to the size of 

trucks (width and length).

3. Application of tolling to an existing or new limited access freeway can 

cause trucks to leave the freeway to avoid tolls thus increasing trucks 

on parallel roads that are not necessarily designed to handle high volumes of truck traffi c. This could result in safety problems (increased 

crashes), as well as accelerating the deterioration of pavements and 

bridges due to truck weights and loading factors and an increase of 

trucks through towns and cities negatively affecting traffi c fl ow and 

safety of autos, pedestrians, and bicycles.

4. The design and placement of roundabouts to deal with traffi c congestion and fl ow could result in trucks not being able to maneuver through 

intersections resulting in safety problems and increased congestion.

5. Poor signal timing that restricts the number of trucks that can pass 

through an intersection in areas with large volumes of trucks can 

exacerbate congestion and increase the potential for crashes.
24

Integrating Freight into NEPA Analysis

7. MITIGATION

FREIGHT-FOCUSED AND FREIGHT-RELATED PROJECTS

The impacts of increased freight activity in the study area will need to 

be fully evaluated so that measures to mitigate impacts can be developed. There are examples where improved freight transportation has 

resulted in positive mitigation measures for a community (Alameda 

Corridor). Considerations may include, but are not limited to: 

mitigating the impacts of more trains on a local rail line, more trucks on 

major and minor roadways, or changing truck traffi c patterns into and 

out of a community to access intermodal facilities. Mitigation examples 

for freight-focused projects include:

1. Mitigation measures that directly address the increased freight transportation activity, such as developing sound or visual barriers that 

reduce the intrusion of freight transportation noise and visual impacts 

on local neighborhoods;

2. Alterations in local transportation networks, such as rerouting truck 

traffi c, and building rail/road or road/road grade separations to minimize the interaction between trucks/trains and autos/pedestrians/

bicycles; and

3. Improving pedestrian and bicycle access, improving the local network of roads by repaving and repairing, and improve transportation 

safety within the community may be considered.

Two examples of potential mitigation measures to consider for freightfocused projects include the following:

Example 1: An increasingly popular method to mitigate the air quality 

impacts of increased truck activity is to accompany freight improvement 

projects with truck parking locations that have idle emissions reduction 

technology. Trucks in commercial truck stops or rest areas typically 

leave their engines running to maintain power in the truck cab while the 

truck is parked. However, newer technology allows truck drivers to plug 

into a power source to maintain power to truck systems while turning 

off the engine. The alternatives generally save fuel and reduce emissions 

compared to idling the main engine.8

8

 For a listing of current idle reduction technologies, please visit EPA’s 

web site at http://www.epa.gov/smartway/transport/what-smartway/

idling-reduction-available-tech.htm.

Mitigation in the Alameda Corridor

The Alameda Corridor (Figure 3) 

EIS developed several mitigation 

actions, including:

1. The placement of noise barriers 

and the potential use of 

building insulation at specifi c 

locations to mitigate noise 

impacts.

2. Potentially signifi cant safety 

impacts involve possible 

train derailments and cargo 

spills. Specifi c mitigations 

include signalization, and 

centralized traffi c control. In 

addition, ACTA will prepare 

an emergency response plan 

in consultation with other 

agencies.

Potentially signifi cant traffi c impacts 

involve reducing pedestrian and 

vehicular access at certain locations, traffi c detours, and general 

inconveniences during construction. Mitigations include the 

development of a construction 

management plan to target specifi c 

areas, restriction of constructionrelated parking, hauling, excavation, 

and staging activities, and maintained access to businesses, schools 

and residences.
25

Integrating Freight into NEPA Analysis

Example 2: Barrier walls are another common mitigation concept for 

freight-related projects because of their multipurpose functionality. 

They can be used during the construction process to minimize noise due 

to construction and, later, freight facility operations. They also can be 

used as a security feature to inhibit theft both during construction and 

facility operations. It is important to develop a barrier wall concept that 

is consistent with the natural surroundings of the project. The Detroit 

Intermodal Facility Terminal Final EIS provided a specifi c example of the 

use of barrier walls for a freight project.

FREIGHT IMPACT ANALYSIS/MITIGATION

Mitigating the impacts of a transportation project on freight facilities and 

operations will require coordination with the freight stakeholders and 

the public in some cases. This coordination is important while impact 

analysis is performed and alternatives are considered, and later when 

appropriate mitigation is developed. The freight stakeholders have specifi c knowledge that could be the key to selecting appropriate mitigation 

measures for each alternative developed. Mitigation of impacts on freight 

facilities and operations should be tailored to the nature of the impact and 

the resource. Working with freight stakeholders during the identifi cation 

of mitigation options is critical to the success of a project. Examples of 

mitigation for impacts to freight facilities and operations could include 

but are not limited to:

1. Mitigation of impacts to truck operations during construction or 

reconstruction of a highway could include but are not limited to: 

a) advance notice of construction schedules to trucking companies 

that use the corridor; b) posting notices/schedules on corridors 

removed from the project location but that provide access for truckers to the project corridor (truckers can then plan alternative routing); 

and c) ensuring that work zone safety measures take into account 

truck volumes in the corridor.

2. The impacts of changing access for trucks into and out of an intermodal facility may require mitigation measures that ensure the continued 

safe and effi cient access for trucks, including geometric design (lane 

widths and turning radii), pavement design and materials (pavement 

needs to hold up to truck weights for the long term), potential grade 

separations, and effi cient routing that avoids rerouting trucks through 

residential communities.

3. Changing the traffi c patterns (including creation of bike lanes and 

other livable amenities) into, out of, and within a community may 

impact truck access to industry; loading docks for hospitals; delivery 
26

Integrating Freight into NEPA Analysis

to stores, etc. Mitigation considerations should be developed among 

the affected parties and could include but are not limited to: rerouting 

trucks within the community effi ciently to maintain access to facilities; providing areas for loading and unloading trucks on streets (top 

of the street or bottom of the street) for deliveries to stores, restaurants, and offi ces; and balancing the location and design of pedestrian 

and bicycle facilities in corridors that also require truck access.

CONCLUSION

FHWA has adopted the policy of managing the NEPA project development and decision-making process as an “umbrella,” under which all 

applicable environmental laws, executive orders, and regulations are 

considered and addressed prior to the fi nal project decision and document approval. Freight considerations are a vital component in this 

process. Conclusion of the NEPA process results in a decision that 

addresses multiple concerns and requirements, including freight. The 

FHWA NEPA process enables transportation offi cials to make project 

decisions that balance engineering, freight, and transportation needs 

with social, economic, and natural environmental factors. During the 

process a wide range of partners, including the public, businesses, interest groups, and agencies at all levels of government, provide input into 

project and environmental decisions.
27

Integrating Freight into NEPA Analysis

Figure 3. Alameda Corridor Rail Line

Source: American Society of Civil Engineers.

A-1

Integrating Freight into NEPA Analysis

Appendix A

List of Relevant FHWA 

Training Materials

FHWA NATIONAL HIGHWAY INSTITUTE COURSES

• FHWA-NHI 139001 – Integrating Freight in the Transportation 

Planning Process

• FHWA-NHI 139002 – Uses of Multimodal Forecasting in Freight 

Planning

• FHWA-NHI 139003 – Advanced Freight Planning

• FHWA-NHI 139005 – Linking Freight to Planning and the Environment

• FHWA-NHI 139006 – Integrating Freight in the Transportation 

Planning Process – Web-Based Standard Version

• FHWA-NHI 142005 – NEPA and Transportation Decision-Making

• FHWA-NHI 142036 – Public Involvement Techniques for 

Transportation Decision-Making

• FHWA-NHI 142052 – Introduction to NEPA and Transportation 

Decision-Making – Web-Based

See the following URL for details on these courses: 

http://www.nhi.fhwa.dot.gov/training/nhistore.aspx.

FHWA WORKSHOP

• Engaging the Private Sector in Freight Planning

See the following URL for details on this workshop: 

http://www.ops.fhwa.dot.gov/freight/FPD/Docs/fpd_fl yer0606.pdf.

B-1

Integrating Freight into NEPA Analysis

Appendix B

References for NEPA 

Legislation, Regulations, and 

Guidance

LEGISLATION

• Federal-Aid Highways, Title 23, United States Code, “Highways,”

National Environmental Policy Act of 1969, as amended (NEPA), plus 

numerous other related statutes and orders.

http://environment.fhwa.dot.gov/projdev/tdmpdo.asp.

REGULATIONS

• “Regulations for Implementing the Procedural Provisions of the 

National Environmental Policy Act” – 40 CFR Parts 1500-1508, 

November 29, 1978 (Council on Environmental Quality – CEQ).

• “Environmental Impact and Related Procedures” 23 CFR 771, August 

28, 1987 (FHWA).

http://environment.fhwa.dot.gov/projdev/tdmpdo.asp.

FEDERAL HIGHWAY ADMINISTRATION (FHWA) 

GUIDANCE

• “Guidance for Preparing and Processing Environmental and Section 

4(f) Documents” – FHWA Technical Advisory T6640.8A, October 30, 

1987.

http://environment.fhwa.dot.gov/projdev/tdmpdo.asp.

• FHWA Technical Advisory T6640.8.

http://www.environment.fhwa.dot.gov/projdev/impTA6640.asp.
B-2

Integrating Freight into NEPA Analysis

OTHER GUIDANCE

• Questions and Answers about NEPA Regulations, Council on 

Environmental Quality (CEQ) Memorandum, March 16, 1981.

• The RED BOOK – Applying the Section 404 Permit Process to Federal-Aid 

Highway Projects, FHWA, et al., September 1988.

• FHWA Environmental Guidebook (primarily an internal document) – 

An all-inclusive compendium of environmental guidance information 

which includes the following:

– Section 4(f) Policy Paper, October 5, 1987 as updated June 7, 1989;

– Transportation Enhancement Activities, FHWA Memorandum, 

April 24, 1992;

– Cooperating Agencies, FHWA Memorandum, March 19, 1992; and

– Purpose and Need, FHWA Memorandum, September 18, 1990.

• NEPA and Transportation Decision-Making – Project 

Development and Documentation Overview, August 21, 1992, 

http://environment.fhwa.dot.gov/projdev/tdmpdo.asp.
1. Report No.

FHWA-HOP-10-033

2. Government Accession No.

 

3. Recipient’s Catalog No.

 

4. Title and Subtitle

Integrating Freight into NEPA Analysis

5. Report Date

September 2010

6. Performing Organization Code

 

7. Author(s)

Dike Ahanotu

8. Performing Organization Report No.

9. Performing Organization Name and Address

Cambridge Systematics, Inc.

100 CambridgePark Drive, Suite 400

Cambridge, MA 02140

10. Work Unit No.

 

11. Contract or Grant No.

DTFH61-06-D-00004

12. Sponsoring Agency Name and Address

U.S. Department of Transportation

Federal Highway Administration

Offi ce of Operations (HOP)

1200 New Jersey Avenue, SE

Washington, DC 20590

13. Type of Report and Period Covered

Final Report

August 2008-December 2010

14. Sponsoring Agency Code

HOFM

15. Supplementary Notes

FHWA COTM: Kate Quinn, Offi ce of Freight Management and Operations, and Neel Vanikar, Offi ce of 

Project Development and Environmental Review

16. Abstract

The effi ciency and effectiveness of freight transportation is critical for economic growth and development, 

ensuring livable communities, and creating a sustainable human and natural environment. It is increasingly important to integrate freight transportation issues and solutions throughout the transportation planning 

and project development process.

This handbook is designed to provide information on freight transportation to: 1) professionals responsible for advancing transportation projects through the National Environmental Policy Act (NEPA) process 

analysis; and 2) public and private sector freight stakeholders interested in advancing freight transportation 

projects utilizing public sector highway funds that require NEPA analysis.

NEPA requires analysis of the impacts of proposed Federal activities on the natural and human environments. Therefore, the use of Federal-aid highway funds to implement a transportation project requires 

that the project be advanced through the NEPA process as defi ned in law and regulation. This handbook 

considers freight transportation from two perspectives: 1) a project that itself is designed to resolve a freight 

transportation issue or need; and 2) a project in which freight-related features (warehousing, access to intermodal facilities, loading docks, etc.) could be affected by the project’s design and location. 

 

17. Key Words

freight, NEPA, EIS, intermodal, goods movement, 

environmental review, project development

18. Distribution Statement

No restrictions. 

19. Security Classif. (of this report)

unclassifi ed

20. Security Classif. (of this page)

unclassifi ed

21. No of Pages

44

22. Price

NA

Technical Report Documentation Page

Form DOT F 1700.7 (8-72) Reproduction of completed pages authorized


Integrating Freight into NEPA Analysis