Report to Congressional Requesters

United States General Accounting Office 

GAO

May 2004 TRANSPORTATION 

PLANNING 

State and 

Metropolitan Planning 

Agencies Report Using 

Varied Methods to 

Consider Ecosystem 

Conservation 

GAO-04-536 
www.gao.gov/cgi-bin/getrpt? GAO-04-536.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Katherine 

Siggerud, (202) 512-2834, 

siggerudk@gao.gov. 

Highlights of GAO-04-536, a report to

congressional requesters 

May 2004

TRANSPORTATION PLANNING 

State and Metropolitan Planning 

Agencies Report Using Varied Methods to 

Consider Ecosystem Conservation 

Of the 36 transportation planning agencies that GAO contacted, 31 

considered ecosystem conservation in transportation planning, using a 

variety of methods. For example, Colorado conducts studies that 

incorporate ecosystem issues to guide future transportation decisions, uses 

advance planning to avoid or reduce impacts, and actively involves 

stakeholders. New Mexico uses planning studies to identify locations where 

wildlife are likely to cross highways and design underpasses to allow safe 

crossings. In the absence of specific requirements, federal agencies 

encourage ecosystem consideration in planning. 

Planners and state resource agency officials most frequently reported 

reduced ecosystem impacts and improved cost and schedule estimates as 

positive effects. For example, planners in New York changed a planned fivelane highway to a lower-impact two-lane boulevard after weighing the area’s 

mobility needs and the project’s impact on the surrounding habitat. In 

Massachusetts, resource agency officials said that addressing ecological 

requirements in planning improved schedule certainty during the federally 

required environmental review. Furthermore, planners and resource agency 

officials reported that working together has improved relationships between 

their agencies, thereby allowing ecosystem concerns to be resolved in a 

more timely and predictable manner. Officials also listed negative effects, 

such as higher project costs and more work for resource agencies. 

Most Frequently Reported Benefits from Considering Ecosystem Conservation 

Constituent support from agency staff, political appointees, or the public 

was the most frequently reported factor (27 instances) that encouraged 

planners to consider ecosystem conservation. For example, New Mexico’s 

“pro-environment” culture reportedly encourages planners to consider 

ecosystem conservation. The cost in time and resources of considering 

ecosystem conservation was most often cited as a discouraging factor (23 

instances). For example, Colorado planners cited the significant amount of 

time needed to collect and maintain access to ecosystem data.

The nation’s roads, highways, and 

bridges are essential to mobility 

but can have negative effects on 

plants, animals, and the habitats 

that support them (collectively 

called ecosystems in this report). 

Federally funded transportation 

projects progress through three 

planning phases: long range (20 or 

more years), short range (3 to 5 

years), and early project 

development, (collectively defined 

as planning in this report) before 

undergoing environmental review 

(which includes assessing air and 

water quality, ecosystems, and 

other impacts) required under the 

National Environmental Policy Act. 

Federal law requires planners to 

consider protecting and enhancing 

the environment in the first two 

phases, but does not specify how 

and does not require such 

consideration in the third phase. 

GAO reported on (1) the extent to 

which transportation planners 

consider ecosystem conservation 

in planning, (2) the effects of such 

consideration, and (3) the factors 

that encourage or discourage such 

consideration. GAO contacted 36 

planning agencies (24 states and 12 

of approximately 380 metropolitan 

planning organizations), as well as 

officials in 22 resource agencies 

that maintain ecological data and 

administer environmental laws. 

The Department of Transportation 

and U.S. Army Corps of Engineers 

had no comments on a draft of this 

report. The Department of the 

Interior generally agreed with the 

contents of our draft report. 
Page i GAO-04-536 Ecosystem Conservation in Transportation Planning 

Letter 1

Results in Brief 3

Background 7

Most Planners Contacted Reported Considering Ecosystem 

Conservation during Transportation Planning 9

Planners and Resource Agency Officials Reported Mainly Positive 

Effects of Considering Ecosystem Conservation 20

Support from Constituents and Transportation Agency Personnel 

Most Often Encouraged Consideration of Ecosystem 

Conservation 23

Agency Comments and Our Evaluation 28

Appendix I Telephone Interview Questions for State and 

Metropolitan Area Planners 30 

Long-Range Transportation Planning 30

State Transportation Improvement Program Planning 32

Pre-NEPA Planning 33

Appendix II Telephone Interview Questions for Resource 

Agency Officials 35 

State Transportation Planning 35

Metropolitan Planning Organization Transportation Planning 35

General Questions 35

Appendix III Scope and Methodology 37 

Appendix IV Methods Used by Twenty-Two Agencies to 

Consider Ecosystem Conservation 43 

Appendix V Department of the Interior Comments GAO’s 

Mission 44 

Contents 
Page ii GAO-04-536 Ecosystem Conservation in Transportation Planning 

Tables 

Table 1: Phases During Which Transportation Planning Agencies 

Consider Ecosystem Conservation 11

Table 2: Factors that Reportedly Encourage Consideration of 

Ecosystem Conservation in Transportation Planning 24

Table 3: Factors that Reportedly Discourage Consideration of 

Ecosystem Conservation in Transportation Planning 26

Figures 

Figure 1: State and Metropolitan Planning Agencies Surveyed, and 

Whether They Reported Considering Ecosystem 

Conservation in Transportation Planning 5

Figure 2: Reported Consideration of Ecosystem Conservation 

during Transportation Planning for 36 Planning Agencies 10

Figure 3: Example of an Underpass Created to Allow Bears to 

Cross Highway Right-of-way without Danger of Collisions 

with Vehicles 14

Figure 4: Effects of Considering Ecosystem Conservation in 

Transportation Planning Reported by Planners and 

Resource Agency Officials 21

Abbreviation 

NEPA National Environmental Policy Act

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permission from GAO. However, because this work may contain copyrighted images or 

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Page 1 GAO-04-536 Ecosystem Conservation in Transportation Planning 

May 17, 2004 

Congressional Requesters 

The nation’s vast network of roads, highways, and bridges is essential to 

interstate commerce, economic growth, national defense, and leisure 

mobility. Yet the construction, improvement, rehabilitation, and even 

maintenance of the tens of thousands of miles of this transportation 

infrastructure each year can cause permanent environmental change by 

disturbing plant and animal habitats, creating barriers to animal 

movement, and producing other impacts. By one estimate, roads 

ecologically affect about one-fifth of the U.S. land mass.1

Although federal agencies must assess the environmental impact of 

proposed federally funded transportation projects under the National 

Environmental Policy Act (NEPA), state and metropolitan planners have 

the opportunity to consider these issues earlier during three planning 

phases: (1) as they develop long-range (20 or more years) plans; (2) as they 

develop short-range (3-5 years) plans known as transportation 

improvement programs; and (3) as they conduct early project planning.2

The Transportation Equity Act for the 21st Century requires that planners 

develop these long-range plans and short-range programs and that the 

plans consider projects and strategies that will, among other things, 

protect and enhance the environment. However, the act provides no 

guidance on how planners should meet this requirement. 

You requested that we identify the extent to which planners consider the 

conservation of plants, animals, and the habitats that support them 

 1

R.T. Forman, “Estimate of the Area Affected Ecologically by the Road System in the 

United States,” Conservation Biology (2000) 14(1):31-35, cited in Natasha C. Kline, The 

Effects of Roads on Natural Resources: A Primer Prepared for the Sonoran Desert 

Conservation Plan, (Tucson, Arizona: January 2002). 

2

Approximately 380 metropolitan planning organizations perform transportation planning 

for areas having populations of 50,000 or more. State departments of transportation 

develop and implement statewide transportation plans and generally implement projects 

listed in metropolitan area plans. The National Environmental Policy Act requires that 

federal agencies assess the environmental impact of proposed actions that would 

significantly affect the environment. For a detailed description of how the act affects 

highway planning, design, and construction, see U.S. General Accounting Office, Highway 

Infrastructure: Stakeholders’ Views on Time to Conduct Environmental Reviews of 

Highway Projects, GAO-03-534 (Washington, D.C.: May 23, 2003). 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-536 Ecosystem Conservation in Transportation Planning 

(collectively called “ecosystems” in this report) in transportation 

planning.3

 In response, we asked transportation planners and others to 

identify (1) the extent to which state and metropolitan area transportation 

planners consider ecosystem conservation and how federal agencies are 

involved; (2) the effects, if any, of considering ecosystem conservation 

during transportation planning; and (3) the factors that encourage or 

discourage transportation planners from considering ecosystem 

conservation. 

To carry out this work, we reviewed laws and regulations relating to 

transportation planning and ecosystem conservation and spoke with 

officials of federal transportation agencies, resource agencies (those 

having responsibility for maintaining ecological data and administering 

federal environmental laws) and transportation and environmental 

conservation associations. We also selected a nonprobability sample of 24 

states and 12 metropolitan planning organizations, primarily on the basis 

of geographic diversity, to reflect a variety of ecosystems.4

 We spoke with 

officials in each of our sample states’ departments of transportation and 

metropolitan planning organizations to ascertain (1) the extent to which, if 

at all, they consider ecosystem conservation during state and metropolitan 

area transportation planning before they are required to consider the 

proposed project’s environmental impact under NEPA; (2) anticipated and 

observed effects of considering ecosystems during transportation 

planning; and (3) factors that may encourage or discourage planners from 

considering ecosystems during transportation planning. To gain an 

understanding of the breadth and depth of each sample states’ and 

metropolitan planning organizations’ consideration of ecosystem 

conservation in transportation planning, we asked a variety of questions 

about how planners implement this approach, whether and how they 

involve stakeholders, what types and sources of data they consider, what 

positive and negative effects they have observed or expect to observe, and 

what factors encourage and discourage them from these efforts. (See app. 

I for a complete listing of these questions.) To obtain an additional 

perspective on the information that planning agencies reported, we 

contacted officials in resource agencies in 22 of our sample states.5

 We 

 3

Because federal law already requires that states and local governments meet air and water 

quality standards, we did not include air and water issues in our review. 

4

A nonprobability sample is a sample not produced by a random process. 

5

We attempted to obtain resource agency perspectives in each of the 24 states in our 

sample, but were unable to contact two of these agencies. 
Page 3 GAO-04-536 Ecosystem Conservation in Transportation Planning 

asked these officials how they are involved in transportation planning, 

whether they collect ecological data and make these data available to 

transportation planners, what they believe are the effects of considering 

ecosystem conservation in transportation planning, and what factors 

encourage and discourage them from participating in transportation 

planning. (See app. II for a complete listing of these questions.) Finally, we 

reviewed transportation plans that were available from the state 

departments of transportation and metropolitan planning organizations in 

our sample. Although we requested planners’ and resource agency 

officials’ observations about the effects of considering ecosystem 

conservation in transportation planning, we did not evaluate the 

effectiveness of their efforts, or determine whether one agency’s efforts 

were more effective than another’s. We did not verify the statements of 

state and metropolitan transportation planners or resource agency 

officials because it was not practical to do so. The results of our work 

cannot be projected to all states and metropolitan planning organizations. 

In order to make reliable generalizations, we would have needed to 

randomly select a larger sample of states and metropolitan planning 

organizations than time allowed. We conducted our work from May 2003 

through April 2004 in accordance with generally accepted government 

auditing standards. (See app. III for additional information on our scope 

and methodology.) 

The majority of the state and metropolitan planners that we contacted 

reported considering ecosystem conservation in transportation planning, 

and federal agencies encourage them to do so. (See fig. 1.) Planners in 31 

of the 36 agencies (86 percent) described considering ecosystem 

conservation at varying points in transportation planning using a variety of 

methods. Planners in four statesOregon, South Dakota, Colorado, and 

North Carolinadescribed extensively considering ecosystem 

conservation during planning through methods such as studies that 

incorporate ecosystem issues to guide future transportation decisions, 

advance planning to avoid or reduce ecosystem impacts, and active 

stakeholder participation. Twenty-two of the 31 said they conduct corridor 

studies or use project screening, among other methods, to consider 

ecosystem conservation.6

 For example, New Mexico used corridor studies 

 6

A corridor is a broad geographic band that follows a general directional flow connecting 

major sources of trips that may contain a number of street, highway, and transit route 

alignments. 

Results in Brief 
Page 4 GAO-04-536 Ecosystem Conservation in Transportation Planning 

to plan for, among other things, where bear and deer were likely to cross 

highways, and designed underpasses for them at these locations to help 

prevent vehicle collisions with wildlife. Planners in two agencies 

described focusing most of their ecosystem conservation efforts on 

ecological resources within areas of specific interest to their region, such 

as wetlands. Finally, planners in three agencies reported using mainly 

resource agency data and input from other stakeholders to determine 

whether their transportation plans could affect ecosystems, or 

incorporated in their transportation plans locally developed plans that 

consider ecosystem conservation. Planners in five agencies said they do 

not consider ecosystem conservation in transportation planning before 

projects are subject to federal environmental review because, among other 

things, these agencies lack the time and resources or guidance on how to 

do so. Officials we contacted in state wildlife conservation or natural 

resource departments, as well as similar resource agencies, generally 

agreed that they assist transportation planners in considering ecosystem 

conservation during transportation planning. However, 11 of the state 

resource agency officials said they would like to be more involved in 

transportation planning or commented that communication with their 

state departments of transportation could be improved. Although federal 

law does not specifically require planners to consider ecosystem 

conservation in transportation plans, the Federal Highway Administration 

and the U.S. Fish and Wildlife Service encourage state transportation 

planners to do so. The U.S. Fish and Wildlife Service and the Army Corps 

of Engineers often assist planners by providing ecosystem data or 

comments on transportation plans. 
Page 5 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Figure 1: State and Metropolitan Planning Agencies Surveyed, and Whether They Reported Considering Ecosystem 

Conservation in Transportation Planning 

The effects of considering ecosystem conservation in transportation 

planning were mostly positive, according to the planners and state 

resource agency officials we interviewed. Specifically, planners in 29 of 

the 31 agencies that consider ecosystem conservation in transportation 

planning, and 16 of the 19 state resource agency officials that we 

interviewed in the states that consider ecosystem conservation, described 

one or more positive effects on the environment. These positive effects 

include conserving habitat, reducing habitat fragmentation, or scheduling 

construction times to reduce impacts on breeding of certain species. For 

example, metropolitan planners in New York told us that they changed 

plans for a five-lane highway to a lower-impact two-lane boulevard after 

finding that the wider highway would significantly affect the surrounding 

habitat and that, according to an updated traffic study, the wider highway 

was not needed to ensure mobility. In addition, 12 planners and three state 
Page 6 GAO-04-536 Ecosystem Conservation in Transportation Planning 

resource agency officials reported that considering ecosystem 

conservation in transportation planning leads to more certain project costs 

and schedules. In Massachusetts, for example, resource agency officials 

told us that addressing ecosystem conservation in planning improves 

schedule certainty as the project progresses through federally required 

environmental reviews. In 13 instances, transportation planners and state 

resource agencies reported that working together to address ecosystem 

issues in transportation planning had improved relationships between 

their agencies, which allowed environmental issues to be resolved in a 

timely and predictable manner. Officials also reported other positive 

effects, including better relationships with the public and a heightened 

awareness of ecosystem issues among transportation planning staff. On 

the other hand, eight transportation planners and one state resource 

agency official reported that addressing ecosystem issues during project 

planning resulted in negative effects, such as higher project costs and 

workload increases for resource agencies. 

Support from constituents and transportation agency personnel was the 

key factor that reportedly encouraged transportation planners to consider 

ecosystem conservation, while the cost in time and resources was the key 

discouraging factor identified. Of the 31 planners we interviewed who said 

they considered ecosystem conservation in transportation planning, 27 

cited support from staff in their own agencies, political appointees, or the 

public as an encouraging factor. For example, planners in Oregon and New 

Mexico told us that the state’s pro-environment culture and citizens’ 

concerns about protecting ecological resources encourage them to 

consider ecosystem conservation. Planners mentioned other encouraging 

factors that are similar to the positive effects they identified, such as more 

certain cost estimates and project implementation schedules and fewer 

adverse effects on ecological resources. The most frequently cited 

discouraging factor, identified by 23 of the planners we interviewed, was 

the time and resources required to consider ecosystem conservation. For 

example, transportation planners in Colorado and North Carolina told us 

that collecting and maintaining access to the data needed to consider 

ecosystem conservation in transportation planning, while beneficial, 

required significant time and resources. The time and resources required 

were also a factor that discouraged three of the five agencies that do not 

consider ecosystem conservation in transportation planning. Other 

planners reported discouraging factors such as difficulty in obtaining 

stakeholders’ involvement and pressure from proponents of development 

to move forward with projects without considering ecosystem 

conservation. 
Page 7 GAO-04-536 Ecosystem Conservation in Transportation Planning 

The Department of Transportation and U.S. Army Corps of Engineers had 

no comments on a draft of this report. The Department of the Interior 

generally agreed with the contents of our draft report and provided 

technical clarifications, which we incorporated as appropriate. 

Federally funded highway projects are typically completed in four phases: 

• Planning: State departments of transportation and metropolitan planning 

organizations begin with a vision and a set of long-term goals for their 

future transportation system, and translate these into long-range 

transportation plans and short-range plans known as transportation 

improvement programs. Although not required by federal law, a state 

department of transportation may perform additional planning once a 

project is started, such as consulting with resource agencies to determine 

the project’s potential ecosystem impacts. We refer to this final phase of 

planning as “pre-NEPA planning” in this report. 

• Preliminary design and environmental review: State departments of 

transportation identify a project’s cost, level of service, and construction 

location; assess the potential effects on environmental resources as 

required by NEPA; and select the preferred alternative. 

• Final design and right-of-way acquisition: State departments of 

transportation finalize design plans, acquire property, and relocate 

utilities. 

• Construction: State departments of transportation award construction 

contracts, oversee construction, and accept the completed project. 

The Transportation Equity Act for the 21st Century lays out general 

requirements for transportation planning and consideration of the 

environment. The act requires that state and metropolitan area long-range 

plans consider projects and strategies that will, among other things, 

protect and enhance the environment. It also requires states and 

metropolitan planning offices to provide the public with an opportunity to 

comment on the transportation improvement programs. Governors review 

and approve metropolitan transportation improvement programs within 

their respective states. 

However, the Transportation Equity Act for the 21st Century does not 

specifically address how ecosystem conservation should be considered in 

transportation planning. The act does not require that long-range 

transportation plans contain projects and strategies that protect and 

Background 
Page 8 GAO-04-536 Ecosystem Conservation in Transportation Planning 

enhance the environment, and provides no guidance on how planners are 

to consider ecosystem conservation. Although the Federal Highway 

Administration reviews and approves each state’s transportation 

improvement program to, among other things, ensure that the plans meet 

the requirements of the act, failure to meet these requirements is not 

reviewable in court. 

Congress is considering the 6-year surface transportation reauthorization 

bill. Separate bills have passed in each chamber.7

 The House bill leaves in 

place the existing legislation’s framework of requiring planners to consider 

the protection and enhancement of the environment in their plans. The 

Senate bill provides more explicit language on environmental 

considerations and new consultation requirements for planners. 

Specifically, it indicates that protecting and enhancing the environment 

includes “the protection of habitat, water quality, and agricultural and 

forest land while minimizing invasive species.” Additionally, the Senate bill 

requires that long-range transportation plans include a discussion of (1) 

the types of potential habitat mitigation activities that may assist in 

compensating for habitat loss and (2) the areas that may have the greatest 

potential to restore and maintain habitat types affected by the plan. 

Further, the bill requires planning agencies to consult with state and local 

agencies responsible for protecting natural resources. 

In addition to meeting the planning requirements of the Transportation 

Equity Act for the 21st Century and NEPA, planning agencies must adhere 

to a number of other federal laws pertaining to transportation and the 

environment before construction can begin on federally funded projects, 

including: 

• The Endangered Species Act of 1973 is intended to conserve threatened 

and endangered species and the ecosystems on which they depend. 

Section 7 of the act requires federal agencies to ensure that projects they 

authorize, fund, or carry out, including transportation projects, are not 

likely to jeopardize the continued existence of any threatened or 

endangered species (including fish, wildlife, and plants) or result in the 

destruction or adverse modification of designated critical habitat for these 

species. The U.S. Fish and Wildlife Service and the National Marine 

Fisheries Service administer and enforce this law. 

 7

Safe, Accountable, and Efficient Transportation Equity Act of 2004, S.1072, 108th Cong. 

Title I(E) (Feb. 26, 2004), and Transportation Equity Act: A Legacy for Users, H.R. 3550, 

108th Cong. Title VI (Apr. 2, 2004). 
Page 9 GAO-04-536 Ecosystem Conservation in Transportation Planning 

• The Clean Water Act of 1977 is intended to restore and maintain the 

chemical, physical, and biological integrity of the nation’s waters through 

the prevention and elimination of pollution. Section 404 of the act pertains 

to wetland development.8

 Under this section, the Army Corps of Engineers 

provides permits to transportation agencies whose projects affect 

wetlands. To obtain permits, applicants must first attempt to avoid adverse 

impacts to wetlands or, if this is not possible, to minimize the impacts to 

the extent practicable and compensate for any unavoidable impacts 

through mitigation. 

To comply with these and other laws, transportation planners may 

coordinate with a variety of state and federal agencies. They do so to 

obtain ecological data, such as information on threatened and endangered 

species and wetlands; advice on how to address adverse impacts of 

transportation projects; or both. 

Of the 36 transportation planners we interviewed, a total of 31 (21 out of 

24 in state departments of transportation and 10 out of 12 in metropolitan 

planning organizations) reported using various methods to consider 

ecosystem conservation during transportation planning. Some of these 31 

planning agencies begin considering ecosystem conservation in 

transportation planning as they develop their long-range plans while 

others begin considering ecosystems conservation just prior to starting the 

federally required environmental review under NEPA. Four of these 

agencies reported using multiple approaches to consider ecosystem 

conservation, 22 stressed their use of corridor studies or project screening, 

2 emphasized their consideration of the ecological resources of specific 

interest in the surrounding area, and 3 reported using methods similar to 

other agencies but do not use corridor studies or project screening or 

focus on specific resources. (See fig. 2.) Planners in 5 agencies said they 

do not consider ecosystem conservation during transportation planning. In 

the absence of specific federal requirements to consider ecosystem 

conservation in transportation planning, federal agencies encourage state 

and metropolitan area planners to do so and they provide technical 

assistance. 

 8

Wetlands are generally defined as transitional areas such as swamps, marshes, bogs, and 

similar areas between open waters and dry land. 

Most Planners 

Contacted Reported 

Considering 

Ecosystem 

Conservation during 

Transportation 

Planning 
Page 10 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Figure 2: Reported Consideration of Ecosystem Conservation during 

Transportation Planning for 36 Planning Agencies 

Note: Other methods do not include corridor studies, project screening, or focus on specific ecological 

resources. 

Of the 31 planning agencies that consider ecosystem conservation in 

transportation planning, 21 (68 percent) first do so as they develop their 

long-range plans. (See table 1.) Four agencies (13 percent) begin 

considering ecosystem conservation as they develop transportation 

improvement programs. The remaining six agencies (19 percent) begin just 

before starting the federally required environmental review under NEPA 

(pre-NEPA planning). Twenty of 31 agencies reported considering 

ecosystem conservation at more than one point, and 14 reported 

considering ecosystem conservation during corridor studies that begin at 

varying times during planning. 

Planning Agencies Vary on 

How Early They Consider 

Ecosystem Conservation 
Page 11 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Table 1: Phases During Which Transportation Planning Agencies Consider Ecosystem Conservation 

Planning agency Long-range plan

Transportation 

improvement program Pre-NEPA

State planning agencies 

• Alabama x

• Alaska x x

• Colorado x x

• Delaware x xx

• Georgia x x

• Idaho x x

• Indiana x x

• Iowa x

• Louisiana x x

• Massachusetts x

• Mississippi x

• Nebraska x

• Nevada x x

• New Mexico x

• New York x

• North Carolina x xx

• North Dakota x x

• Oklahoma x x

• Oregon x xx

• South Dakota x xx

• Utah x

Metropolitan planning organizations 

• Benton-Franklin Council of Governments, Washington x x

• Butte County Association of Governments, California x x

• Capital District Transportation Commission, New York x x

• Central Virginia Metropolitan Planning Organization, Virginia x x

• Flagstaff Metropolitan Planning Organization, Arizona x x

• Greensboro Transportation Advisory Committee, North Carolina x

• Madison Athens-Clarke Oconee Regional Transportation Study, 

Georgia x xx

• Merrimack Valley Planning Commission, Massachusetts x x

• Waco Metropolitan Planning Organization, Texas x

• Yellowstone County/Billings Metropolitan Planning x

Source: GAO analysis of interview responses. 
Page 12 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Oregon, South Dakota, Colorado, and North Carolina reported extensively 

considering ecosystem conservation in transportation planning using 

several approaches. The Oregon Department of Transportation has 

included a policy in its long-range plan to, among other things, maintain or 

improve the natural and built environment, including fish passage and 

habitat, wildlife habitat and migration routes, vegetation, and wetlands. 

The long-range transportation plans of Colorado and North Carolina each 

contain specific references to goals or policies to conserve ecosystems, 

while South Dakota’s plan contains a less specific goal aimed at protecting 

the environment. 

Oregon planners said they meet monthly with state and federal resource 

agencies and with the Federal Highway Administration to discuss project 

proposals before beginning to address NEPA requirements. To plan for 

each project’s potential impact, the planners said they obtain data from a 

variety of sources, such as field studies led by biologists, the Oregon 

Natural Heritage Data System, the National Wetlands Inventory, and the 

state department of transportation’s ecological survey of all the roads in 

the state.9

 The planners then use these data and a set of criteria developed 

by stakeholders to screen projects before programming them for 

construction. 

The South Dakota Department of Transportation becomes increasingly 

involved with federal and state resource agency stakeholders—including 

the U.S. Fish and Wildlife Service; Army Corp of Engineers; U.S. Forest 

Service; South Dakota Game, Fish, and Parks; and the South Dakota 

Department of Natural Resources—as a project evolves from a conceptual 

plan through final design. Initially, the department works with state 

resource agency stakeholders to obtain ecological data in geographic 

information system or paper formats that identify ecological resources 

located within the study boundaries and uses these data to avoid sensitive 

habitat.10 The department then develops plans to avoid, minimize, or 

mitigate the project’s impact. Later, when more specific project design 

plans become available, the department works with resource agency 

 9

The Oregon Natural Heritage Data System is the state’s most comprehensive database of 

rare, threatened, and endangered species. It includes site-specific information on the 

occurrences, biology, and status of more than 2,000 species throughout the state. 

10A geographic information system is a system of computer software, hardware, and data 

used to manipulate, analyze, and graphically present a potentially wide array of information 

associated with geographic locations. 

Four State Planning 

Agencies Consider 

Ecosystem Conservation 

Using Several Approaches 
Page 13 GAO-04-536 Ecosystem Conservation in Transportation Planning 

stakeholders to determine habitat locations, adjust project alignments to 

avoid habitat, or consider other design changes to minimize the project’s 

impact before beginning the environmental review required under NEPA. 

The Colorado Department of Transportation has assigned one of its 

employees to work with the U.S. Fish and Wildlife Service to focus on 

transportation issues, according to state transportation planners. The 

planners said that numerous stakeholders from federal, state, and 

nongovernmental agencies assist the department in determining species 

and habitat locations throughout the state and in focusing efforts on 

conservation and mitigation planning. The planners reported that the 

department is conducting advance planning to integrate ecosystem issues 

into corridor studies that they expect to develop over the life of the longrange plan. They also said that Colorado has established a revolving fund 

to acquire habitat for mitigation before specific projects are actually 

developed. 

Finally, the North Carolina Department of Transportation considers 

ecosystem conservation in transportation planning by making extensive 

use of resource agency personnel and geographic information system data. 

According to state planners, the department funds 33 resource agency 

positions to help identify and resolve ecosystem issues early in project 

development. The planners told us they use the geographic information 

system data to identify where ecosystems may conflict with transportation 

plans and determine the potential cost of addressing the conflicts. They 

said that the department, in partnership with the Army Corps of Engineers, 

also identifies and acquires property for future mitigation. Finally, the 

planners said that the department assists small metropolitan planning 

organizations and localities in broad-based ecosystem screening on all 

projects to identify any ecological issues and potential costs associated 

with those issues. 

Twenty-two of the 31 planners who consider ecosystem conservation 

during transportation planning conduct corridor studies or screen projects 

for ecosystem impact. These planners survey ecosystems in the corridor 

and take steps to avoid or mitigate ecological impacts. For example, 

planners in New Mexico, with data from their Department of Game and 

Fish, used corridor studies to identify areas of high potential for animalvehicle crashes. Planners described how such planning studies led to the 

construction of underpasses that allow bear and deer to pass beneath 

highways in the state. (See fig. 3.) Nebraska reviews ecological databases 

to identify potential impacts of planned transportation projects; considers 

avoidance strategies; and, if avoidance is not possible, documents the 

Most Planners Said They 

Considered Ecosystem 

Conservation in 

Transportation Planning 

When Conducting Corridor 

Studies or Screening 

Projects 
Page 14 GAO-04-536 Ecosystem Conservation in Transportation Planning 

conflict so that project designers can develop mitigation measures, 

according to state transportation planners. 

Figure 3: Example of an Underpass Created to Allow Bears to Cross Highway Rightof-way without Danger of Collisions with Vehicles 

Some planning agencies screen out projects from their plans that would 

have undesirable ecosystem impacts. For example, metropolitan planners 

for the Merrimack Valley area in Massachusetts told us that they use data 

from a geographic information system in planning to identify ecological 

resources in the path of proposed projects. Using this information, 

together with public comments on the project, they determine whether the 

ecological impacts require that the project be redesigned or terminated 

prior to beginning the environmental review required under NEPA. 

Nearly all planning agencies that develop corridor studies or use 

ecosystem impacts to screen projects involve stakeholders in developing 

their plans. For example, Alaska invites federal agenciesincluding the 

U.S. Fish and Wildlife Service, Army Corps of Engineers, National Park 

Service, Bureau of Land Management, and National Marine Fisheries 

Serviceand its Departments of Fish and Game, and Natural Resources to 
Page 15 GAO-04-536 Ecosystem Conservation in Transportation Planning 

meetings to provide input for transportation plans. After a meeting, each 

agency has the opportunity to write a letter of concern about specific 

resources or areas. Metropolitan planning organizations, local 

governments, municipal officials, tribes, elected officials, and anyone else 

who has expressed interest in Alaska’s transportation planning are also 

invited to review and comment on transportation plans. 

Of the 22 planning agencies that consider ecosystems by conducting 

corridor studies or project screening, 12 include ecosystem conservation 

as a policy or goal in their long-range transportation plans. For example, 

the Central Virginia Metropolitan Planning Organization’s long-range 

transportation plan calls for an assessment of the social and 

environmental impacts of the transportation plan’s recommendations, and 

establishes the policy of removing projects with unacceptably high 

environmental or community impacts from planning consideration. 

In addition to considering ecosystem conservation in transportation 

planning through corridor studies or as a means to screen potential 

projects, these 22 planning agencies reported using one or more of the 

following common methods either in addition to or in combination with 

corridor studies or screening: 

• using resource agencies as stakeholders in developing transportation 

plans; 

• considering the views of environmental interest groups in developing 

transportation plans; 

• using resource agency data to determine mitigation requirements, develop 

alternative locations, or to avoid planning projects with unacceptably high 

ecosystem impact; 

• using geographic information systems to determine ecological resource 

locations; 

• providing funding for ecological impact studies; 

• having planning agency or resource agency personnel conduct site visits to 

determine or confirm the location of ecological resources; and 
Page 16 GAO-04-536 Ecosystem Conservation in Transportation Planning 

• incorporating in transportation plans local plans that have considered 

ecosystem conservation.11

Six of these agencies reported using at least 4 of the methods listed above. 

The remaining 16 used 3 or fewer methods. Because we did not evaluate 

the effectiveness of these methods, the number of methods used by a 

planning agency does not necessarily indicate effectiveness. (See table 4 in 

app. IV for a summary of the specific methods that each agency reported 

using.) 

Transportation planners in Georgia told us they focus on preserving the 

state’s wetlands through mitigation banking.12 The state department of 

transportation has established funding accounts to purchase land for 

wetland mitigation banking and to pay for consultants to design wetland 

mitigation banks, according to planners in Georgia. They told us that the 

department has also entered into a memorandum of agreement with a 

state resource agency for the long-term maintenance of these mitigation 

banks. These planners said that nongovernmental organizations, including 

The Nature Conservancy, Georgia Trust for Public Land, and Georgia 

Conservancy, help identify properties for sale and conduct on-site reviews 

of potential sites for wetland mitigation banks. Federal resource agencies 

assist by reviewing proposed land acquisitions to determine if the land is 

suitable for use as a wetland mitigation bank, according to the planners. 

They added that, when transportation projects are at the conceptual 

design stage, state resource agencies identify wetlands, streams, and 

endangered species habitats that could be adversely affected by the 

project and point out avoidance or mitigation opportunities. 

Planners in Montana’s Yellowstone County/Billings metropolitan area told 

us that their focus is on the natural resources of the Yellowstone River 

corridor and the Rim Rocks. These planners said they consider ecosystem 

conservation in planning transportation projects that would affect these 

natural resources, primarily through consultations with stakeholders such 

as the Yellowstone River Parks Association, Bike Net, local government 

 11This list includes only those methods reported by at least 2 of the 22 agencies. 

12A mitigation bank is a site where wetlands, other aquatic resources, or both are restored, 

created, enhanced, or, in exceptional circumstances, preserved expressly for the purpose 

of providing compensatory mitigation in advance of authorized impacts to similar 

resources. 

Two Agencies Focus on 

One or More Specific 

Ecological Concerns in the 

Area 
Page 17 GAO-04-536 Ecosystem Conservation in Transportation Planning 

representatives, planning boards, and neighborhood task forces. The 

planners said these planning boards and neighborhood task forces are 

involved throughout transportation planning. 

The Delaware Department of Transportation, Butte County Association of 

Governments, California, and Madison Athens-Clarke Oconee Regional 

Transportation Study (the metropolitan planning organization in Athens, 

Georgia) reported considering ecosystem conservation in transportation 

planning by using some of the same methods used by other agencies but 

do not use corridor studies, project screening, or focus on a specific 

ecological resource. Each of these agencies includes ecosystem 

conservation as a policy or goal in its long-range transportation plan. 

Delaware Department of Transportation planners said they consider input 

from resource agencies and environmental interest groups and use 

geographic information system data to determine transportation projects’ 

potential impact on ecological resources and develop alternatives as 

needed. Planners at the Butte County Association of Governments told us 

they receive input from resource agencies to determine mitigation 

requirements and use geographic information system data to determine 

ecological resource locations. Finally, the Madison Athens-Clarke Oconee 

Regional Transportation Study planners said that local land use plans 

consider ecosystem conservation as it relates to transportation and they 

incorporate the local plans in the metropolitan area’s transportation plans. 

Planners in the Arizona, New Hampshire, and Illinois departments of 

transportation, as well as metropolitan planners in Great Falls City, 

Montana, and Montachussett, Massachusetts, said they do not consider 

ecosystem conservation in transportation planning and instead rely on 

compliance with NEPA to address ecological issues. The reported factors 

that discouraged these agencies from considering ecosystem conservation 

in transportation planning include a lack of time and resources required or 

guidance on how to do so. These factors are discussed in more detail in 

the final section of this report. 

Three Agencies Consider 

Ecosystem Conservation 

in Transportation Planning 

Through Other Methods 

Five Agencies Do Not 

Consider Ecosystem 

Conservation in 

Transportation Planning 
Page 18 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Resource agency officials in 19 of the 21 states that consider ecosystem 

conservation in transportation planning generally agreed that they assist 

transportation planners in doing so. (We were not able to contact resource 

agency officials in the two remaining states.13) However, over half (11) of 

these resource agency officials said that they would like to be more 

involved in transportation planning or that communication with their 

state’s department of transportation could be improved. For example, 

officials of the Oklahoma Department of Wildlife Conservation explained 

that they need to be involved early in transportation planning because the 

pressure from supporters of transportation projects often results in 

concerns about ecosystems surfacing as afterthoughts. Similarly, officials 

in Utah’s Division of Wildlife Resources said that they are involved too late 

in planning because the project design is already set and budgeting for 

necessary mitigation sometimes has been inadequate. 

Although federal law does not specifically require planners to consider 

ecosystem conservation in transportation plans, the Federal Highway 

Administration encourages state and metropolitan planners to do so by 

identifying and promoting exemplary initiatives that are unique, 

innovative, attain a high-level environmental standard, or are recognized 

as particularly valuable from an environmental perspective, according to 

the agency’s fiscal year 2004 performance plan. These could be planning or 

project-level initiatives that involve, for example, designing mitigation 

projects that support wildlife movement and habitat connectivity, 

developing watershed-based environmental assessment and mitigation 

approaches, or using wetland banking. The agency has identified eight 

such initiatives and plans to identify and promote at least 30 initiatives by 

September 30, 2007. 

North Carolina’s Ecosystem Enhancement Program is one of the eight 

exemplary initiatives that the Federal Highway Administration has 

identified. In view of a rapidly expanding transportation program with a 

high volume of projects affecting an estimated 5,000 acres of wetlands and 

900,000 feet of streams over 7 years, North Carolina plans to consider and 

mitigate the potential impacts of many planned projects in a 

comprehensive manner by assessing, restoring, enhancing, and preserving 

 13We asked transportation planners in each state in our sample to provide the name of the 

resource agency official that they most frequently contacted. Nevada planners did not 

provide a resource agency contact. We were unable to arrange an interview with the New 

York resource agency contact. 

State Resource Agency 

Officials Generally Agreed 

That They Are Involved in 

Transportation Planning 

but Would Like More 

Involvement 

Federal Agencies 

Encourage Consideration 

of Ecosystem 

Conservation in 

Transportation Planning 
Page 19 GAO-04-536 Ecosystem Conservation in Transportation Planning 

ecosystem functions and compensating for impacts at the watershed level. 

This approach to ecosystem conservation aims to decouple ecosystem 

mitigation from individual project reviews. 

Federal Highway Administration officials believe that such integrated 

approaches help break down organizational barriers between state 

departments of transportation and state resource agencies. They added 

that publicizing exemplary initiatives helps show that addressing 

ecosystem conservation in transportation planning improves working 

relationships between these agencies and facilitates interagency 

cooperation in the future. As noted in the next section of this report, many 

planners and resource agency officials that we interviewed cited improved 

interagency relationships as a positive effect of considering ecosystem 

conservation in transportation planning. 

The U.S. Fish and Wildlife Service also encourages state departments of 

transportation and state resource agencies to share project planning and 

ecosystem information to incorporate more forethought to wildlife 

habitats, before project designs are set and while flexibility still exists, 

according to agency officials. To this end, the Service, in cooperation with 

the International Association of Fish and Wildlife Agencies, has conducted 

several regional workshops on state wildlife conservation plans. Officials 

told us that during these workshops they discussed how the plans could 

be used to provide transportation planners with important information 

that they could consider in transportation planning.14

The U.S. Fish and Wildlife Service and other federal resource agencies also 

administer and enforce environmental laws and generally help state 

planners consider ecosystem conservation by responding to requests for 

data and providing comments on transportation plans. The federal 

agencies most frequently consulted by the transportation planners we 

interviewed were the Fish and Wildlife Service and the Army Corps of 

Engineers. Transportation planners said they often ask these resource 

agencies to provide ecological data from geographic information systems 

or ecological maps to help identify and evaluate a project’s impact. Many 

planners also said these federal resource agencies provide technical 

expertise or actively participate in transportation planning. For example, a 

 14States are required to submit, or commit to develop, wildlife conservation plans by 

October 1, 2005, to be eligible for wildlife conservation grants under the State Wildlife 

Grant Program. According to U.S. Fish and Wildlife Service officials, all states have 

committed to develop these plans. 
Page 20 GAO-04-536 Ecosystem Conservation in Transportation Planning 

New York Department of Transportation planner told us that the Fish and 

Wildlife Service and the Army Corps of Engineers provide technical 

expertise on the long-term impacts of transportation projects on 

ecosystems. 

Regardless of the ways planning agencies consider ecosystem 

conservation in transportation planning, 29 of the 31 transportation 

planners and 16 of 19 resource agency officials we interviewed reported 

one or more positive effects of doing so.15 These officials listed fewer 

negative effects. 

Twenty-eight planners and resource agency officials reported that 

considering ecosystem conservation in transportation planning enabled 

them to avoid or reduce adverse impacts on ecological resources—the 

most frequently reported positive effect. (See fig. 4.) For example, 

planners and state resource agency officials reported 

• preventing irreparable habitat damage in New York by changing planning 

from a five-lane highway to planning for a lower-impact two-lane 

boulevard after a study revealed that the original project would be 

detrimental to the surrounding habitat, and updated traffic studies 

indicated that the wider highway was not needed to ensure mobility; 

• decreasing habitat fragmentation in North Carolina by using geographic 

information system data on state ecological resources during project 

planning to avoid or mitigate unacceptable potential impacts on habitat; 

and 

• working with the state resource agency in Nebraska to identify preferred 

times for construction in order to reduce impacts on the breeding of 

certain species. 

 15This section reflects the results of 50 interviews out of a possible 60 (24 state and 12 

metropolitan planners, and 24 state resource agency officials). It does not include any 

views on ecosystem conservation that may have been expressed by the transportation 

planners and resource agency officials that we interviewed in the three states that do not 

consider ecosystem conservation, nor does it include the views of transportation planners 

in the two metropolitan planning organizations that do not consider ecosystem 

conservation in transportation planning. Finally, we did not interview resource agency 

officials in Nevada and New York for reasons previously stated. 

Planners and 

Resource Agency 

Officials Reported 

Mainly Positive 

Effects of Considering 

Ecosystem 

Conservation 
Page 21 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Figure 4: Effects of Considering Ecosystem Conservation in Transportation 

Planning Reported by Planners and Resource Agency Officials 

Fifteen transportation planners and state resource agency officials 

reported that considering ecosystem conservation improves a project’s 

cost and schedule estimates. For example, planners and state resource 

agencies reported 
Page 22 GAO-04-536 Ecosystem Conservation in Transportation Planning 

• better project cost estimating in Colorado because planners become aware 

of, and can plan to avoid, unacceptable adverse impacts on ecological 

resources; 

• improved schedule certainty in Massachusetts, because addressing state 

resource agency requirements during planning provides more certainty 

that projects will not need to be redesigned to meet these requirements 

later, during federally required environmental reviews; and 

• improved preparedness to address ecological issues during the 

development of a project in California by identifying those issues early in 

planning. 

In 13 instances, transportation planners and state resource agency officials 

reported improved relationships between departments of transportation 

and state resource agencies. For example, improved relationships through 

partnership and coordination among stakeholders can help resolve 

environmental issues in a timely and predictable manner. Additional 

positive effects that planners and state resource agency officials cited 

include an increased awareness of ecosystem conservation among the 

transportation planning agency’s staff, an improved public image of the 

department of transportation, and a stimulus to consider transportation 

alternatives such as transit. 

Compared with the number of positive effects attributed to considering 

ecosystem conservation in transportation planning, planners and resource 

agency officials reported relatively few negative effects. Planners in South 

Dakota and at the Benton-Franklin Council of Governments, Washington, 

told us that considering ecosystem conservation in transportation 

planning requires additional cost and time. A resource agency official in 

Iowa said that working with planners to determine project impacts and 

select mitigation sites adds to the agency’s workload. Finally, planners in 

Louisiana noted that the general public, as well as elected officials who 

support specific projects, become dissatisfied with the state department of 

transportation when environmental issues affect a project’s delivery. 
Page 23 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Support from constituents and transportation agency personnel was the 

most often reported factor that encouraged planners to consider 

ecosystem conservation in transportation planning. The cost in staff time 

and money was the most often reported discouraging factor for agencies 

that reported considering ecosystem conservation. Planners at three of the 

five agencies, who said they do not consider ecosystem conservation in 

transportation planning, also cited the cost in time and resources, while 

the remaining two listed other discouraging factors. 

Twenty-seven of the 31 transportation planners we interviewed, who said 

they consider ecosystem conservation in transportation planning, cited 

support from within their own agencies, from political appointees, or from 

external constituents as a factor that motivated them to do so. (See table 

2.) For example, transportation planners in Mississippi told us that their 

agency is committed to being environmentally aware, and that this culture 

has encouraged them to consider ecosystem conservation in planning. 

Metropolitan planners in Albany, New York, noted that their corporate 

culture provides a strong foundation to consider ecosystem conservation 

as they develop transportation plans. Similarly, metropolitan planners in 

central Virginia said that the planning commission’s staff are concerned 

about being good stewards and maintaining a balance between 

transportation and other concerns. 

Support from 

Constituents and 

Transportation 

Agency Personnel 

Most Often 

Encouraged 

Consideration of 

Ecosystem 

Conservation 

Planners Identified 

Support from Constituents 

and Transportation Agency 

Personnel and Other 

Encouraging Factors 
Page 24 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Table 2: Factors that Reportedly Encourage Consideration of Ecosystem 

Conservation in Transportation Planning 

Encouraging factor 

Number of planners 

reporting

Constituent support and support from transportation agency 

personnel 27

More certain cost estimates/schedules for project 

implementation 18

Fewer adverse impacts on ecological resources 7

Improvement in the public’s perception of the transportation 

agency 6

Improved relations with resource agencies 5

Other (each was mentioned only once) 4

Source: GAO analysis of interview responses. 

Note: We asked planners to list the three most important factors. This table includes responses from 

planners in the 31 agencies that consider ecosystem conservation during transportation planning. 

The views of elected officials and agency heads were another facet of 

constituent support. For example, the governor of New York has strongly 

encouraged planners there to improve their environmental performance, 

and the governor of New Mexico has initiated a new program that 

explores several environmental issues, according to planners in those 

states. This support from elected officials has influenced planners in these 

states to consider ecosystem conservation during transportation planning. 

Finally, planners in Delaware and Oregon emphasized the importance of 

their agency leaders’ support for ecosystem conservation. 

In addition, the general public’s attitude toward ecosystem conservation 

motivated planners to consider ecosystem conservation during 

transportation planning. Planners in Oregon and New Mexico attributed 

their consideration of ecosystem conservation partly to the proenvironment culture in their states. They told us, for example, that citizens 

are concerned about wildlife protection and view the natural environment 

as a major asset to the state. Metropolitan planners in Albany, New York, 

told us that citizens are concerned about excessive land consumption 

which is one factor that encourages them to consider ecosystem 

conservation during transportation planning. 

Transportation planners also listed encouraging factors that were similar 

to the positive effects that were discussed earlier in this report. For 

example, 18 planners said that they were encouraged to consider 

ecosystem conservation in transportation planning by expectations of 
Page 25 GAO-04-536 Ecosystem Conservation in Transportation Planning 

more certain cost estimates and construction schedules. Nine of these 

planners also listed positive effects that centered on developing more 

accurate cost estimates and determining more predictable project delivery 

dates. Similarly, seven planners listed having fewer adverse effects on 

ecological resources as an encouraging factor, while five of these planners 

also listed this as a positive effect. Planners also listed improved 

relationships with the state resource agencies as an encouraging factor as 

well as a positive effect of considering ecosystem conservation in 

transportation planning. 

Although most of the planners we interviewed reported that considering 

ecosystem conservation in transportation planning was beneficial, doing 

so presented challenges. Chief among these challenges was the staff time 

and money required to consider ecosystem conservation in transportation 

planning, reported by 23 planners, including those in Arizona, New 

Hampshire, and Montachusett, Massachusetts, who do not consider 

ecosystem conservation in transportation planning. (See table 3.) An 

Arizona planner said that state reductions in funding and staffing have 

discouraged the department from considering ecosystem conservation 

during transportation planning, adding that the planning department staff 

has been reduced by 75 percent since the mid-1990s. New Hampshire 

planners said they do not have sufficient funds to enter into long-range 

studies. Therefore, there is pressure to wait until NEPA, which requires, 

among other things, an assessment of the impact of proposed 

transportation projects on the natural and human environment. 

Planners Identified Time 

and Resource 

Requirements and Other 

Discouraging Factors 
Page 26 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Table 3: Factors that Reportedly Discourage Consideration of Ecosystem 

Conservation in Transportation Planning 

Discouraging factor 

Number of planners 

reporting

Time and monetary/staffing resources required 23

Difficulty obtaining stakeholder involvement/guidance 15

Political/proponent pressure to move ahead/lack of political 

support 11

Inappropriate to do so during long-range planning 9

Negative public response/public expectations 6

It is not required 2

Other (each was mentioned only once) 6

Source: GAO analysis of interview responses. 

Note: We asked planners to list the three most important factors. This table includes responses from 

planners in all 36 agencies that we contacted. 

The staff time and money required was also the major discouraging factor 

for those planning agencies that do consider ecosystem conservation in 

transportation planning. For example, planners in Colorado and North 

Carolina told us that, while beneficial, it takes a significant amount of time 

and effort to develop, maintain, and provide access to the data required to 

consider ecosystem conservation during transportation planning. 

Additionally, some metropolitan area planners told us that small planning 

agencies are particularly hard-pressed, because of their small size, to 

consider ecosystem conservation. For example, a metropolitan planner in 

central Virginia noted that the limited funding his agency receives for longrange transportation planning precludes more focused activities to 

address environmental factors, even though the agency would like to do 

so. Similarly, metropolitan area planners in Athens, Georgia, told us their 

ability to conduct detailed ecological analyses during planning is very 

limited because they do not have enough staff. 

Difficulties in obtaining involvement or guidance from stakeholders was 

the second most often cited discouraging factor, according to the planners 

we interviewed. This was the chief discouraging factor mentioned by a 

planner in Montachusett, Massachusetts, a metropolitan planning 

organization that does not consider ecosystem conservation before project 

developers prepare environmental impact assessments under NEPA. The 

planner stated that the planning organization lacks guidance from the state 

or federal agencies on the priority of ecosystem conservation. The planner 

noted that the planning organization addresses all federal requirements in 
Page 27 GAO-04-536 Ecosystem Conservation in Transportation Planning 

transportation planning, as well as those issues the state emphasizes, but 

ecosystem consideration has not been one of them. Planners in Utah, a 

state that does consider ecosystem conservation in transportation 

planning, told us that resource agencies prefer to comment on projects 

that are better defined than is typically the case when they appear in 

transportation planning documents. On the other hand, a Utah resource 

agency official told us that his agency would like to be involved in these 

earlier planning phases, but the state department of transportation does 

not notify it early enough in planning.16

In addition, some planners told us that they lacked guidance from 

stakeholders, namely state resource agencies, on how to consider 

ecosystem conservation in transportation planning. They noted that longterm or comprehensive plans for managing the state’s ecological resources 

would help them make decisions about what resources to consider during 

planning; however, their state resource agencies had not completed such 

plans. A few of the state and federal resource agencies we interviewed 

noted, though, that some states are developing wildlife conservation plans 

as part of a new federal program or other habitat management plans that 

they believe will be useful to state departments of transportation. 

Third, pressure from political leaders or project proponents to move 

forward in spite of ecological concerns, or because of competing 

priorities, also discouraged planners from considering ecosystem 

conservation in transportation planning. For example, planners in North 

Carolina told us that developers give little credence to environmental 

concerns. Economic development in Iowa takes precedence over 

ecosystem concerns, according to a planner there. A state resource agency 

official in Oregon echoed these sentiments, stating that, in some instances, 

regional transportation planners and the state department of 

transportation value improving economic development over conserving 

ecological resources. 

A few other planners cited additional discouraging factors. Local 

expectations that a project will be built, regardless of ecosystem concerns, 

is a discouraging factor, according to a transportation planner in North 

Carolina. Also, planners in three jurisdictions noted that circumstances 

might change between early planning for a project and its implementation. 

 16We did not attempt to reconcile the differences between the statements of Utah planners 

and resource agency officials. 
Page 28 GAO-04-536 Ecosystem Conservation in Transportation Planning 

This was the chief discouraging factor for Illinois, where planners do not 

consider ecosystem conservation before NEPA. Finally, planners in Great 

Falls City-County, Montana, a jurisdiction that does not consider 

ecosystem conservation in transportation planning, stated that their 

existing policy is to rely on NEPA to assess the ecosystem and other 

environmental impacts of proposed transportation projects. 

The Department of Transportation and U.S. Army Corps of Engineers had 

no comments on a draft of this report. The Department of the Interior 

generally agreed with the information in a draft copy of this report and 

provided technical clarifications, which we incorporated as appropriate. 

See appendix V for a copy of the Department of Interior’s comments. 

As arranged with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after the 

date of this letter. At that time we will send copies of this report to 

congressional committees with responsibilities for highway and 

environmental issues; the Secretary of Transportation; the Secretary of the 

Interior; the Administrator, Federal Highway Administration; the Director, 

U.S. Fish and Wildlife Service; the Commander, U.S. Army Corps of 

Engineers; and the Director, Office of Management and Budget. We will 

also make copies available to others upon request. This report will be 

available at no charge on our home page at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

either James Ratzenberger at ratzenbergerj@gao.gov or me at 

siggerudk@gao.gov. Alternatively, we may be reached at (202) 512-2834. 

Key contributors to this report were Jaelith Hall-Rivera, Rebecca Hooper, 

Jessica Lucas-Judy, Edmond Menoche, James Ratzenberger, and Michelle 

K. Treistman. 

Katherine Siggerud 

Director, Physical Infrastructure 

Agency Comments 

and Our Evaluation 
Page 29 GAO-04-536 Ecosystem Conservation in Transportation Planning 

List of Congressional Requesters 

The Honorable Thomas R. Carper 

United States Senate 

The Honorable Jon S. Corzine 

United States Senate 

The Honorable John F. Kerry 

United States Senate 

The Honorable Carl Levin 

United States Senate 

The Honorable Ron Wyden 

United States Senate 

The Honorable Earl Blumenauer 

House of Representatives 

The Honorable Rosa L. DeLauro 

House of Representatives 

The Honorable Wayne T. Gilchrest 

House of Representatives 

The Honorable James L. Oberstar 

House of Representatives 
Appendix I: Telephone Interview Questions 

for State and Metropolitan Area Planners 

Page 30 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Before each telephone interview with officials at state departments of 

transportation and metropolitan planning organizations, we provided 

participants with the following questions and encouraged them to review 

the questions and to invite others as appropriate to participate in the 

interview in order to provide as accurate and complete answers as 

possible. Question numbers preceded by “SLR” are those referring to the 

development of the long-range transportation plan. Questions preceded by 

“ST” are those referring to the development of the state transportation 

improvement program. Finally, questions preceded by “SPN” refer to a 

phase of project planning that immediately precedes NEPA, which we 

termed “pre-NEPA planning.” Questions for metropolitan area planners 

were similarly numbered except that they began with the letter “M” to 

easily differentiate between the state and metropolitan planners’ questions 

and responses.1

1) Please answer a, b and c, and follow the instructions as applicable. 

a) Does your state consider ecosystem conservation during the creation 

of the long-range transportation plan? Yes or No. If yes, answer all SLR 

questions. If no, answer SLR 7 and SLR 8. In either case, please also 

answer b and c below. 

b) Does your state consider ecosystem conservation during the creation 

of the state transportation improvement program? Yes or No. If yes, 

answer all ST questions. If no, answer only ST 8 and ST 9. In either 

case, please also answer a and c. 

c) Does your state consider ecosystem conservation during the pre-NEPA 

phase, or at any other time other than during and after NEPA? Yes or 

No. If yes, answer all SPN questions. If no, answer only SPN 7 and SPN 

8. In either case, please also answer a and b. 

(Answer if applicable.) 

SLR1) How does your state consider ecosystem conservation during the 

creation of the long-range transportation plan? 

 1

Questions asked of metropolitan area planners were identical except where noted. 

Appendix I: Telephone Interview Questions 

for State and Metropolitan Area Planners 

Long-Range 

Transportation 

Planning 
Appendix I: Telephone Interview Questions 

for State and Metropolitan Area Planners 

Page 31 GAO-04-536 Ecosystem Conservation in Transportation Planning 

SLR2) What stakeholders, if any, are involved in helping you consider 

ecosystem conservation in the long-range transportation plan (federal or 

state agencies, non-government organizations, other)? 

SLR3) How are these stakeholders involved in helping you consider 

ecosystem conservation in the long-range transportation plan? 

SLR4) What type of ecosystem data, if any, do you include in the 

development of the long-range transportation plan? 

SLR5) Please provide any other ways, not discussed above, that your state 

considers ecosystem conservation when developing the long-range 

transportation plan. 

We would now like to discuss the effects of considering ecosystem 

conservation in developing the long-range transportation plan. 

SLR6) Please describe any anticipated or observed effects, positive or 

negative, that you can attribute to the consideration of ecosystem 

conservation in the long-range transportation plan. 

We would like to know about factors that encourage or discourage 

consideration of ecosystem conservation in long-range transportation 

planning. 

SLR7) Please list the three factors that have been the most important in 

encouraging your state to consider ecosystem conservation as the longrange transportation plan is developed. 

SLR8) Similarly, please list the three factors that have been the most 

important in discouraging your state to consider ecosystem conservation 

as the long-range transportation plan is developed. 
Appendix I: Telephone Interview Questions 

for State and Metropolitan Area Planners 

Page 32 GAO-04-536 Ecosystem Conservation in Transportation Planning 

We would like to learn about how your state considers ecosystem 

conservation as it develops the state transportation improvement 

program.2

(Answer if applicable) 

ST1) How does your state consider ecosystem conservation during the 

creation of the state transportation improvement program? 

ST2) What stakeholders, if any, are involved in helping you consider 

ecosystem conservation in the state transportation improvement program 

(federal or state agencies, non-government organizations, other)? 

ST3) How are these stakeholders involved in helping you consider 

ecosystem conservation in the state transportation improvement program? 

ST4) What type of ecosystem data, if any, do you include in the 

development of the state transportation improvement program? 

ST5) Do you use project criteria that incorporate ecosystem conservation 

when determining which projects will be placed on the state 

transportation improvement program? 

ST6) Please provide any other ways, not discussed above, that your state 

considers ecosystem conservation when developing the state 

transportation improvement program. 

We would now like to discuss the effects of considering ecosystem 

conservation in developing the state transportation improvement 

program. 

ST7) Please describe any anticipated or observed effects, positive or 

negative, that you can attribute to the consideration of ecosystem 

conservation in the state transportation improvement program. 

We would like to know about factors that encourage or discourage 

consideration of ecosystem conservation in the creation of the state 

transportation improvement program. 

 2

In the metropolitan planning organization interviews, we asked the same questions but 

about the transportation improvement program. 

State Transportation 

Improvement 

Program Planning 
Appendix I: Telephone Interview Questions 

for State and Metropolitan Area Planners 

Page 33 GAO-04-536 Ecosystem Conservation in Transportation Planning 

ST8) Please list the three factors that have been the most important in 

encouraging your state to consider ecosystem conservation as the state 

transportation improvement program is developed. 

ST9) Similarly, please list the three factors that have been the most 

important in discouraging your state to consider ecosystem conservation 

as the state transportation improvement program is developed. 

We would like to learn about how your state considers ecosystem 

conservation as it begins project development—after the project has been 

listed on the state transportation improvement program, but before the 

NEPA process begins. As previously discussed, we call this phase the 

“pre-NEPA” phase. 

(Answer if applicable) 

SPN1) How does your state consider ecosystem conservation during the 

pre-NEPA phase? 

SPN2) What stakeholders, if any, are involved in helping you consider 

ecosystem conservation during the pre-NEPA phase (federal or state 

agencies, non-government organizations, other)? 

SPN3) How are these stakeholders involved in helping you consider 

ecosystem conservation during the pre-NEPA phase? 

SPN4) What type of ecosystem data, if any, do you include in the preNEPA phase? 

SPN5) Please provide any other ways, not discussed above, that your state 

considers ecosystem conservation in the pre-NEPA phase. 

We would now like to discuss the effects of considering ecosystem 

conservation in the pre-NEPA phase. 

SPN6) Please describe any anticipated or observed effects, positive or 

negative, that you can attribute to the consideration of ecosystem 

conservation in the pre-NEPA phase. 

We would like to know about factors that encourage or discourage 

consideration of ecosystem conservation in the pre-NEPA phase. 

Pre-NEPA Planning 
Appendix I: Telephone Interview Questions 

for State and Metropolitan Area Planners 

Page 34 GAO-04-536 Ecosystem Conservation in Transportation Planning 

SPN7) Please list the three factors that have been the most important in 

encouraging your state to consider ecosystem conservation during the preNEPA phase. 

SPN8) Similarly, please list the three factors that have been the most 

important in discouraging your state to consider ecosystem conservation 

during the pre-NEPA phase. 

Is there anything else that you would like to tell us about considering 

ecosystem conservation in transportation planning? 

We would like to contact someone in the state resource agency 

(Department of Natural Resources, Department of Environmental 

Protection, etc.) that is most involved with your agency in considering 

ecosystem conservation during the transportation planning process. 

Please provide the name, official title, and contact information. 
Appendix II: Telephone Interview Questions 

for Resource Agency Officials 

Page 35 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Prior to each interview with officials at state resource agencies, we 

provided participants with the following questions and encouraged them 

to review the questions and to invite others as appropriate to participate in 

the interview in order to provide as accurate and complete answers as 

possible. “RA” precedes all question numbers so that we could easily 

distinguish questions and responses as those pertaining to resource 

agencies. 

RA1) The _____________ state department of transportation told us that 

your agency is involved in transportation planning. Please describe your 

involvement. 

RA2) How did your agency become involved in state transportation 

planning? 

RA3) Is your agency involved with metropolitan planning organizations in 

considering ecosystem conservation in the transportation planning 

process? If yes, please continue. If no, please skip to RA7. 

RA4) In what ways is your agency involved with metropolitan planning 

organizations in considering ecosystem conservation in transportation 

planning? 

RA5) What metropolitan planning organizations are you involved with? (If 

you do not know the names of the metropolitan planning organizations, 

simply list the number that you are involved with.) 

RA6) How did your agency become involved in metropolitan planning 

organization transportation planning? 

RA7) Does your agency collect or generate ecosystem data? Yes or No. 

If yes: 

Is it available to state departments of transportation? 

Is it available to metropolitan planning organizations? 

We would now like to discuss the effects of considering ecosystem 

conservation in any phase of transportation planning. 

Appendix II: Telephone Interview Questions 

for Resource Agency Officials 

State Transportation 

Planning 

Metropolitan Planning 

Organization 

Transportation 

Planning 

General Questions 
Appendix II: Telephone Interview Questions 

for Resource Agency Officials 

Page 36 GAO-04-536 Ecosystem Conservation in Transportation Planning 

RA8) Please describe any anticipated or observed effects, positive or 

negative, that you can attribute to the consideration of ecosystem 

conservation in transportation planning prior to NEPA. 

We would now like to ask you about factors that encourage or discourage 

your participation in the consideration of ecosystem conservation in 

transportation planning. 

RA9) Please list the three factors that you consider to be the most 

important in encouraging your agency to participate in consideration of 

ecosystem conservation in transportation planning. 

RA10) Please list the three factors that you consider the most important in 

discouraging your agency from participating in consideration of ecosystem 

conservation in transportation planning. 

RA11) Is there anything else you would like to tell us about considering 

ecosystem conservation in transportation planning? 

Thank you. 
Appendix III: Scope and Methodology 

Page 37 GAO-04-536 Ecosystem Conservation in Transportation Planning 

To obtain a basic understanding of how transportation planners consider 

ecosystem conservation in transportation planning and how federal 

agencies are involved, we discussed transportation laws, regulations, and 

planning procedures with officials in the following agencies: 

• Federal Highway Administration in headquarters and Phoenix, Arizona; 

U.S. Fish and Wildlife Service in headquarters, Phoenix and Tucson, 

Arizona, and Denver, Colorado; and Army Corps of Engineers in 

headquarters, Baltimore, Maryland, and Phoenix, Arizona. 

• State departments of transportation, resource agencies, and metropolitan 

planning organizations in Virginia, Massachusetts, Wisconsin, Mississippi, 

and Colorado; the metropolitan planning organizations for the 

Washington, D.C., area and Pima County, Arizona; and state departments 

of transportation and resource agencies in Florida and Maryland. 

• The American Association of State Highway Transportation Officials, 

Association of Metropolitan Planning Organizations, The Nature 

Conservancy, International Association of Fish and Wildlife Agencies, and 

Defenders of Wildlife. 

At each of these locations, we also obtained and reviewed transportation 

planning documents. We defined ecosystems as plants and animals and the 

habitats that support them. We defined planning as activities associated 

with developing the federally required long-range transportation plan, 

short-range transportation improvement program, and the nonfederally 

required project planning that some jurisdictions perform just prior to 

beginning the environmental review required by the National 

Environmental Policy Act (NEPA), as well as any activities, such as 

corridor studies, that are performed concurrently with, but independently 

of, federally mandated transportation planning activities. Because federal 

law already requires that states and local governments meet air and water 

quality standards, our inquiry did not include identifying whether state 

departments of transportation and metropolitan planning organizations 

were considering these issues in transportation planning. 

To identify (1) how state and metropolitan area transportation planners 

consider ecosystem conservation and how federal agencies are involved, 

(2) the effects these planners have seen from this consideration, and (3) 

the factors that encourage or discourage them from doing so, we 

developed a set of questions to ask transportation planners selected 

through a nonprobability sample of 24 states and 12 metropolitan planning 

Appendix III: Scope and Methodology 
Appendix III: Scope and Methodology 

Page 38 GAO-04-536 Ecosystem Conservation in Transportation Planning 

organizations. We divided the nation into eight geographic zones 

containing a roughly equal number of states to ensure that our sample was 

geographically and ecologically diverse. To ensure that our sample 

included states with a variety of population sizes, we used census data to 

divide states in each zone into three subgroups according to population—

high, low, and medium. We then randomly selected 1 state from each of 

the 24 subgroups to obtain a 24-state sample, which included the following 

states: 

• Alabama 

• Alaska 

• Arizona 

• Colorado 

• Delaware 

• Georgia 

• Idaho 

• Illinois 

• Indiana 

• Iowa 

• Louisiana 

• Massachusetts 

• Mississippi 

• Nebraska 

• Nevada 

• New Hampshire 

• New Mexico 
Appendix III: Scope and Methodology 

Page 39 GAO-04-536 Ecosystem Conservation in Transportation Planning 

• New York 

• North Carolina 

• North Dakota 

• Oklahoma 

• Oregon 

• South Dakota 

• Utah 

To ensure ecosystem diversity among the 12 metropolitan planning 

organizations in our sample, we divided the nation into quadrants 

containing a roughly equal number of states. Then, to ensure that our 

sample would reflect the varying extent to which metropolitan planning 

organizations consider ecosystem conservation in transportation planning, 

we used the results from our 2002 survey of all metropolitan planning 

organizations. The survey asked how much consideration, if any, they give 

to the impact of transportation projects on environmentally sensitive 

lands, such as wetlands, when they develop their transportation plans.1

According to their answers, we divided the metropolitan planning 

organizations in each quadrant into three subgroups: (1) those that 

indicated little or no, or some consideration; (2) those that indicated 

moderate consideration; and (3) those that indicated great or very great 

consideration. We then randomly selected one metropolitan planning 

organization from each of the 12 subgroups, resulting in the following 

sample: 

• Benton-Franklin Council of Governments, Washington; 

• Butte County Association of Governments, California; 

• Capital District Transportation Commission, New York; 

• Central Virginia Metropolitan Planning Organization, Virginia; 

 1

U.S. General Accounting Office, Environmental Protection: Federal Incentives Could 

Help Promote Land Use That Protects Air and Water Quality, GAO-02-12 (Washington, 

D.C.: Oct. 31, 2001). 
Appendix III: Scope and Methodology 

Page 40 GAO-04-536 Ecosystem Conservation in Transportation Planning 

• Flagstaff Metropolitan Planning Organization, Arizona; 

• Great Falls City-County Planning, Montana; 

• Greensboro Transportation Advisory Committee, North Carolina; 

• Madison Athens-Clarke Oconee Regional Transportation Study, Georgia; 

• Merrimack Valley Planning Commission, Massachusetts; 

• Montachusett Regional Planning Commission, Massachusetts; 

• Waco Metropolitan Planning Organization, Texas; and 

• Yellowstone County/Billings Metropolitan Planning Organization, 

Montana. 

To gain an understanding of the breadth and depth of each sample state’s 

and metropolitan planning organization’s consideration of ecosystem 

conservation in transportation planning, we developed a variety of 

questions about how planners implement this consideration, whether and 

how they involve stakeholders, what types and sources of data they 

consider, what positive and negative effects they have observed or expect 

to observe, and what factors encourage and discourage them from these 

efforts. (See app. I for a complete listing of these questions.) Through 

telephone interviews, we asked planners to address these questions for 

each of three phases of transportation planning: (1) as they develop their 

long-range transportation plans, (2) as they develop their short-range 

transportation improvement programs, and (3) in the project planning 

stage that immediately precedes the environmental review under NEPA.2

Planners reported similar effects of considering ecosystem conservation in 

transportation, planning and similar encouraging and discouraging factors 

across these three phases. Therefore, we did not report answers to these 

questions by phase. Appendix II contains the questions that we asked 

planners who we interviewed in state departments of transportation and 

metropolitan planning organizations. We also reviewed the available longrange transportation plans of each state and metropolitan planning 

organization in our samples to determine whether these plans contained 

goals related to ecosystem conservation. 

 2

We asked all planners the same questions. We did not provide the planners with sets of 

possible responses from which to choose. 
Appendix III: Scope and Methodology 

Page 41 GAO-04-536 Ecosystem Conservation in Transportation Planning 

To obtain the perspectives of state resource agency officials, we asked 

officials at each department of transportation in our sample to identify the 

official at the state resource agency who was most involved with the 

department of transportation during planning.3

 We conducted telephone 

interviews with resource agency officials in 22 of our 24 sample states, 

asking these officials how they participate in considering ecosystem 

conservation in transportation planning, whether they collect ecological 

data and make these data available to transportation planners, the effects 

that they can attribute to considering ecosystem conservation, and the 

factors that encourage or discourage their participation.4

 See appendix II 

for a complete listing of the questions that we asked resource agency 

officials. 

In analyzing our interview responses, we used content analysis and 

consensus agreement among four analysts to categorize similar responses, 

and grouped state and metropolitan planning organizations accordingly. 

To increase the reliability of our coding of responses, we used consensus 

agreement among the same four analysts. We did not verify the accuracy 

of the information that we obtained in our interviews or determine 

whether or how the consideration of ecosystem conservation that 

planners described affected transportation projects or ecosystems 

because it was not practical to do so. However, the variety of questions 

that we asked of transportation planners, combined with the perspectives 

of resource agency officials, mitigates the potential that our results portray 

more extensive consideration of ecosystem conservation in transportation 

planning than may actually exist. Although we requested planners’ and 

resource agency officials’ observations about the effects of considering 

ecosystem conservation in transportation planning, we did not evaluate 

the effectiveness of their efforts, or determine whether one agency’s 

efforts were more effective than another’s. The results of our work cannot 

be projected to all states and metropolitan planning organizations. In order 

to make reliable generalizations, we would have needed to randomly 

 3

Because state resource agencies are organized in a variety of ways, independently 

identifying the appropriate resource agency contact in each of our 24 sample states was not 

practical. 

4

We asked each resource agency official the same questions. We did not provide these 

officials with sets of possible responses from which to choose. Nevada did not provide a 

state resource agency contact, and the New York state resource agency contact did not 

respond to requests to be interviewed. Because Idaho Department of Transportation 

officials told us that their primary resource agency contact was with the Boise office of the 

U.S. Fish and Wildlife Service, we interviewed an official at that agency, rather than a state 

resource agency official. 
Appendix III: Scope and Methodology 

Page 42 GAO-04-536 Ecosystem Conservation in Transportation Planning 

select a larger sample of states and metropolitan planning organizations 

than time allowed. 
Appendix IV: Methods Used by Twenty-Two 

Agencies to Consider Ecosystem 

Conservation 

Page 43 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Note: The twenty-two agencies included in this appendix are those that employ corridor studies or 

screen projects for ecosystem impact. The list of methods used does not include every method used 

by these agencies. It includes only those methods reported as used by two or more agencies. 

Appendix IV: Methods Used by Twenty-Two 

Agencies to Consider Ecosystem 

Conservation 
Appendix V: Department of the Interior 

Comments GAO’s Mission 

Page 44 GAO-04-536 Ecosystem Conservation in Transportation Planning 

Appendix V: Department of the Interior 

Comments GAO’s Mission 

Note: We included these 

specific comments in this 

final report, where 

appropriate. 

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