Companion Guide to Video August 2012

www.fhwa.dot.gov/federal-aidessentials

Environment

NEPA Regulatory Framework and Process

Purpose & Need, and Alternatives

The National Environmental Policy Act, also 

known as NEPA, is an environmental law that 

established the decision-making process that 

agencies must follow prior to the design and 

construction of transportation projects using 

Federal funding or requiring Federal approval. 

Following the right process - or class of action –

is important and is determined by the 

significance of the impacts your project is likely 

to have on the human and natural environment. 

The significance of its impact, not its size or 

cost, will direct you to the appropriate class of 

action and will help you identify the requirements 

for other essential elements, such as 

documentation, public involvement, and 

coordination. 

Transportation projects are intended to meet an 

important purpose and need. Therefore, 

decision-makers on your Federal-aid project 

require justification to support both the 

expenditure of tax payers’ money and the 

environmental impacts involved. 

Your project’s well-reasoned Statement of 

Purpose and Need explains to the decisionmakers, the public, and the stakeholders why 

the proposed project should be implemented. 

Here we will explore what constitutes a good 

purpose and need statement, along with the 

range of alternatives and the appropriate 

amount of analysis required for your project. 

Simply put, the purpose element of the 

statement explains the problem the project is 

intended to address. The need element includes 

the data substantiating that a problem currently 

exists or is likely to occur. 

The 

purpose and need is the starting point for 

developing any necessary alternatives.

When developing alternatives, you should strive 

to include a reasonable and representational 

range of options, including the no-build option. 

Alternatives are not just for highway 

improvement options; they can include demand 

management or alternative modes, such as 

transit, or a combination of all these. 

Agencies are required to explain why a proposed project should be 

implemented
Federal-aid Essentials for Local Public Agencies

For each potential alternative, ask yourself: 

• Does it have logical termini, or logical 

end points? 

• Is it a usable facility in and of itself even 

if no further improvement were built?

For NEPA purposes, the level of analysis 

corresponds to the level of potential 

environmental effects. A project that is 

processed as a categorical exclusion, or CE, will 

generally require less detailed analysis than 

those processed as either an environmental 

assessment or an environmental impact 

statement, referred to as an EIS. 

As an example, let’s walk through the purpose, 

need and alternatives for a pavement 

rehabilitation project that is typically a CE. The 

purpose of the project is to address the 

deficiencies of a roadway with pavement 

deemed less than desirable. 

The need comes from the fact that the pavement 

is cracking and may soon be unusable, as

evidenced through photographs. An alternative 

analysis for this project is not required as is 

typical of projects processed as CEs.

Let’s compare this relatively simple CE with a 

project in which an EIS is necessary. In this 

case, traffic has become congested and is 

predicted to worsen. 

The purpose of the project is to alleviate current 

and predicted congestion on a two-lane 

highway, which will reduce delays and crashes, 

provide improved access to the center of town 

and better accommodate through traffic. 

The need for the project is supported by crash 

data and a traffic analysis. In addition to the nobuild alternative, three others are being 

considered. 

Alternative one involves widening the existing 

highway from two lanes to four lanes. The 

logical termini, or end points, are defined by the 

intersection with County Route 34 and an 

interchange with Interstate 50. The usable 

facility is 12 miles of four-lane highway through 

town. 

Alternative two involves upgrading existing 

county roads on the south side of town. The 

logical termini are the same, but the resulting 

usable facility is a four-lane roadway with safety 

shoulders and turning lanes. 

Alternative three is a new roadway to the north 

of town. The resulting usable facility is a 12 mile, 

divided four-lane highway. 

From this example, we see that the alternatives 

address the project’s purpose and need and that 

the variety is appropriate for any potential 

environmental effects. Traffic demand 

modifications or transit do not meet the need for 

providing adequate through traffic capacity. 

The documents from your planning processes 

are an excellent source of information for 

establishing purpose, need and alternatives. 

Your State department of transportation (State 

DOT) has considerable knowledge and 

expertise in all areas of NEPA compliance. The 

people there can help you ensure the adequacy 

and validity of your Statement of Purpose and 

Need along with any necessary alternatives. 

The FHWA is the final authority when 

determining whether a project’s purpose and 

need as well as its alternatives analysis are 

adequate to meet regulatory requirements. 

Therefore, it’s essential that you engage the 

State DOT and, when appropriate, FHWA early 

and throughout your project’s entire process.
Federal-aid Essentials for Local Public Agencies

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• FHWA guidance on project purpose and need

http://www.environment.fhwa.dot.gov/projdev/tdmelements.asp

• FHWA guidance on developing and evaluating project alternatives

http://www.environment.fhwa.dot.gov/projdev/tdmalts.asp

• AASHTO’s Practitioner's Handbook 07 covering purpose and need 

statement and range of project alternatives

http://www.environment.transportation.org/pdf/programs/PG07.pdf