Safety and NEPA: Case Studies and Noteworthy Practices

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Themes featured in this case study:

Considering Safety Prior to NEPA

Stakeholder and Public Engagement

Safety and Environmental Justice

Safety and Environmental Stewardship

Future Opportunities for Complete Streets

FHWA-SA-22-045

Second Street 

Corridor (US 60)

Complete Street and Road Diet Project 

Frankfort, Kentucky

Introduction 

The City of Frankfort, Kentucky’s Second Street Corridor 

project is an example of how local governments and State

departments of transportation (DOTs) can address safety 

needs during the National Environmental Policy Act (NEPA) 

process (figure 1). The City of Frankfort received 

Transportation Investment Generating Economic Recovery 

(TIGER) funds in 2018 to implement Complete Streets 

elements and a Road Diet along the Second Street Corridor 

(U.S. 60). The project’s objective was to create a safer travel 

experience for all users, boost economic development in a 

distressed neighborhood, and allow for placemaking 

opportunities. 

This case study explains how safety was considered prior to, 

and incorporated into, the NEPA process. The scope of the 

project in this case study demonstrates that improving safety 

performance can also advance environmental stewardship and 

elevate communities where environmental justice (EJ) 

considerations are a motivating factor for transportation 

investments (City of Frankfort, 2017). 

Figure 1. Graphic. Steps of the NEPA process covered by this case study.

Source: FHWA.
Safety and NEPA: Case Studies and Noteworthy Practices

 

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Project Background

Second Street runs east to west along the south side of Frankfort. The corridor is physically separated from

downtown by the Kentucky River; it is connected to downtown by only two bridges crossing the river. In 

2012, Frankfort applied for technical assistance to develop a plan to revitalize, reimagine, and enhance the 

Second Street Corridor through the US Environmental Protection Agency’s (EPA’s) Greening America’s 

Capitals (GAC) Program. The grant allowed the City to develop a Greening America’s Capitals: Second Street 

Corridor (Plan), to improve the corridor by producing a “high quality public realm that promotes healthy civic 

interactions” (Graham, 2012). This Plan resulted in six distinct areas suggested for improvement (figure 2). 

The City received funding in 2018 through the United States Department of Transportation (USDOT) TIGER 

Discretionary Grant Program to implement the Second Street Corridor Complete Street and Road Diet

project. According to the grant application, nearly 25 percent of residents in this neighborhood live in poverty, 

20 percent live with a disability, and nearly 15 percent do not have access to a motor vehicle (City of 

Frankfort, 2017). The corridor’s existing conditions—high vehicle speeds, long crossing lengths, and limited 

multimodal facilities along the corridor—caused safety concerns for pedestrians, bicyclists, and transit users. 

The Complete Street and Road Diet project would improve safety by:

» Implementing new pedestrian, bicyclist, and transit facilities. 

» Increasing access for seniors and persons with disabilities. 

» Reducing the roadway width, creating shorter crossing lengths, and adding space to install multimodal 

facilities.

Figure 2. Graphic. Second Street corridor GAP study areas. 

Source: OSC, 2013. 
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The final project limits included four of the six areas recommended in the 2012 Plan: 

» Second Street School area.

» Second Street between Steele and Shelby Streets.

» Capital Avenue at Second Street.

» Capital Avenue at Main Street.

Each area had specific needs, but the project aimed to create a coherent, connected network that is safe for 

all road users. The other two identified areas in the original 2012 plan, Dolly Graham Park and the Riverfront 

area, are both key elements to potential economic redevelopment and encouraging active lifestyles. However, 

they are not directly related to the street network improvements. The four selected areas noted above

translate into a project study area focused on three segments: Second Street, Capital Avenue, and Main Street 

(figure 3). Improvements to these segments would result in a safer travel network for the residents of the 

corridor area, providing accessibility benefits to all users in the community.

Figure 3. Photograph. Second Street Corridor project limits. 

Source: KYTC, 2019. 
Safety and NEPA: Case Studies and Noteworthy Practices

 

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Project Timeline

The project schedule included a series of key milestones in accordance with the NEPA process and overall 

project delivery (figure 4).

Project Summary

Safety has been a core component of the Second Street Corridor Complete Street and Road Diet project 

since its inception in 2012. The City documented the need to create a safer environment for users

consistently in the GAC grant and subsequent corridor study. The following sections document how the City 

incorporated safety throughout project development and in multiple stages of the NEPA process, including 

pre-NEPA activities: 

» Project Planning and Scoping. 

» Purpose and Need. 

» Alternatives Analysis. 

Safety in Project Planning and Scoping

Through technical assistance provided as part of the 2012 GAC grant program, Frankfort’s corridor study 

process included a public workshop that engaged the community and gathered feedback for creating safer 

facilities and a more comfortable pedestrian and 

bicyclist experience. Public engagement was a key 

element early in the project development process, 

including the visioning exercises associated with the 

2012 corridor study. During a multi-day public 

workshop, citizens voiced their concerns about the 

study area and helped establish project goals (figure 5). 

The workshop established improved user safety as a top 

priority goal. While there was an evaluation of historical 

crash data, the anecdotal input from daily users of the 

corridor helped to solidify the justification of 

implementing a safer corridor solution.

The City continued engaging with the public during the 

NEPA process to maintain support for the project from a diverse stakeholder group. The City held a public 

Figure 4. Graphic. Second Street Corridor project development process. 

Source: FHWA. 

Figure 5. Photograph. Public workshop. 

Source: OSC, 2013. 
Safety and NEPA: Case Studies and Noteworthy Practices

 

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meeting in May 2019 and received 18 written comments from 54 attendees. Many of these comments 

mentioned the importance of safety as part of future improvements. The City’s project team also held a series 

of 23 stakeholder meetings, including meetings with:

» Residents. 

» Property owners. 

» Business owners. 

» Frankfort City Commissioners. 

» Representatives of the Frankfort/Franklin

County Tourist Commission. 

» Downtown Frankfort, Inc. 

» City of Frankfort. 

» Franklin County Arts Council. 

» Kentucky Heritage Council. 

» Kentucky Transportation Cabinet. 

» Kentucky Division of Water. 

» Kentucky River Authority. 

» Frankfort Independent Schools. 

» Walk Bike Frankfort.

The public engagement process included the following groups, which represent underserved communities: 

» South Frankfort Neighborhood Association (the community is 30 percent minority, 24 percent of 

residents live in poverty, 17 percent of residents are age 65 and older, 14 percent do not have access 

to a motor vehicle, and nearly 20 percent of the population is disabled; table 1). 

» Kentucky State University (a historically black university located in Frankfort). 

» Frankfort Independent School Board (school district includes South Frankfort and downtown 

neighborhoods and Second Street Elementary School is located adjacent to the project). 

» Frankfort Housing Authority (representing lower income, ethnically diverse residents living in the 

Southern Apartments which is located adjacent to the project). 

» Elected City Commissioners and County Magistrates who represent a socioeconomically and ethnically 

diverse constituency in and around the project area.

Table 1. Comparison of the South Frankfort community to regional and national characteristics (City of Frankfort, 2017). 

Characteristic South Frankfort City of Frankfort Kentucky United States

Median Household Income $38,582 $41,101 $43,740 $53,889

Poverty 23.9% 19.1% 18.9% 15.5%

Renters 71.6% 50.2% 32.8% 36.1%

No Vehicle Access 13.7% 7.5% 7.8% 9.1%

School Age (5-17) 13.8% 14.6% 16.8% 17.0%

Age 65 and Older 16.8% 15.0% 14.4% 14.1%
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Keeping safety as a priority project goal was a consistent theme throughout all public engagement activities. 

The City has maintained a robust email listserv throughout the project’s duration, sending out over 40 project 

updates to date in order to actively communicate with all stakeholders. City staff also provided project 

updates on social media platforms through their “Track the TIGER” campaign. 

Safety in Project Purpose and Need

The project’s environmental documentation consisted of a Level 1 Categorical Exclusion (CE) as allowed by a 

2018 Programmatic Agreement between the Kentucky Transportation Cabinet (KYTC) and the Federal 

Highway Administration (FHWA). Pursuant to the TIGER application, the project “qualifies as a Categorically 

Excluded activity as it consists of reconstruction of existing public facilities without any significant increase in 

size or capacity” (City of Frankfort, 2017). The City documented the need for an improved streetscape that 

safely accommodated bicyclists and pedestrians and reduced the impact of vehicle traffic on the community. 

Although the word “safety” is not included in the purpose and need statement, the statement still noted how 

pre-NEPA planning and observational data can be used to achieve a safer transportation system. As stated in 

the CE, 

“The purpose of the project is to improve pedestrian and bicycle accommodations in historical downtown 

Frankfort. Along with improving sidewalks and bike lanes, streetscape enhancements will be added, and 

the combined sanitary and stormwater sewer system will be separated to reduce overflows. 

The need for the project was identified through a study of existing conditions of the sidewalks, roadway, 

and combined sewer system. Existing conditions revealed that the Second Street transportation corridor 

exhibits many challenges for pedestrians and bicyclists. Sewer improvements are needed to prevent 

overflows from releasing raw sewage into the Kentucky River during heavy rainfall.” (KYTC, 2019)

The corridor had several known safety concerns:

» High speeds. 

» Narrow sidewalks. 

» Wide roadway.

» Long crosswalks. 

» Illegal left turns. 

» Lack of accessibility for all users and limited compliance with accessibility standards such as Americans 

with Disabilities Act (ADA). 

» Limited bike accommodations. 

» Existing crash history. 

The corridor averaged 17 crashes per year during the 7-year study period (2010 to 2016; City of Frankfort, 

2017). The City decided to implement a Road Diet to accommodate all road users’ needs along Second Street. 

Road Diets are an FHWA Proven Safety Countermeasure. These treatments help slow down drivers, shorten 

pedestrian crossings, and ultimately improve safety and mobility for all users. Road Diets can include wider 

sidewalks, reduced crosswalk lengths, improved lighting, additional transit stops, and enhanced bicycle 

accommodations (FHWA, 2022). The project also included general street repairs to crosswalks and sidewalks 

to reduce impediments to pedestrians and persons with disabilities and damage to vehicles reported along the 

corridor, including deployed airbags, popped tires, and damage to vehicle struts.
Safety and NEPA: Case Studies and Noteworthy Practices

 

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The purpose and need statement also underscored how safety and environmental stewardship can both be 

addressed during the NEPA process. The City documented the need to improve the sewer system along 

Second Street to prevent overflows and releasing raw sewage into the Kentucky River during heavy rainfall. 

The TIGER grant application documents how stormwater improvements and safer bicycle and pedestrian 

accommodations can complement each other: 

» Repaving on-street parking using more porous materials. 

» Planting street trees and rain gardens as part of streetscape enhancements. 

» Constructing linear landscaping buffers along the entire project.

» Separating the combined stormwater and sanitary sewer system to reduce the frequency of overflows 

into the Kentucky River.

In addition to stormwater treatments, this project is located along a corridor that was once known as 

“Gasoline Alley” due to the number of gas stations situated on it. Many of those businesses had closed prior 

to project implementation, but they left behind numerous underground storage tanks (USTs). As 

redevelopment occurs as a result of this project, there is an opportunity to remove these USTs and remediate

potential contamination. As continued development occurs along the corridor, the City plans to apply for 

funding for this work through the Brownfield Assessment Grant program through the US EPA. 

Safety in Alternatives Analysis

The project team based their design process on the concepts of Complete Streets and Road Diets during the 

alternatives development phase of the NEPA process (FHWA, n.d.). These design approaches prioritize safety, 

comfort, and connectivity for all users of the roadway, but they also have environmental benefits associated 

with reduced greenhouse gas emissions. By including bicycle, pedestrian, and transit facilities and Proven Safety 

Countermeasures associated with a Complete Streets design model, contextual designs can incorporate safety 

elements without compromising environmental considerations. 

The City of Frankfort worked through multiple iterations of design options for three distinct project segments

(figure 6): 

1. Second Street – combination of Second Street School Area and Second Street between Steele and 

Shelby Streets Area from the GAP study. 

2. Capital Avenue – Capital Avenue at Second Street from the GAP study.

3. Main Street – Capital Avenue at Main Street from the GAP study.
Safety and NEPA: Case Studies and Noteworthy Practices

 

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The City ultimately selected the following designs for each segment. 

Second Street from Taylor Avenue to Capital Avenue (1)

The proposed safety-related improvements for this segment include: 

» Realignment of cross-streets to address geometric issues. 

» Placement of a median at the school entrance to restrict left turns and provide traffic calming effects. 

» Reestablishment of concrete sidewalk/entrance in front of several buildings to provide a demarcation

between the pedestrian space and the private parking area. 

» Conversion of the Steele and Shelby Street intersections from signalized control to all-way stops. 

» Improved lighting (energy efficient LEDs), crosswalks, and transit accommodations.

The two alternatives developed for Second Street proposed different ways to implement bicycle facilities. 

Alternative 1 included traditional bike lanes, while Alternative 2 included a two-way bicycle facility separated 

from vehicular traffic on Second Street. The City selected Alternative 2 due to the safety benefits associated 

with the separated facility on the section from Bridge Street to Shelby Street. 

» Second Street (from Taylor Avenue to Bridge Street):

o One 12-13-ft travel lane in each direction, with turn lanes as needed.

o 10-16-ft of mixed-use path on the north side of the street (combining pedestrians and 

bicyclists).

o 6-8-ft of sidewalk on the south side of the street.

» Second Street (from Bridge Street to Shelby Street; figure 7):

o One 13-ft travel lane in each direction, with no exclusive turn lanes. 

o 6-ft of sidewalk on the south side of the street.

o 8-12-ft of sidewalk on the north side of the street with adjacent 8-ft, two-way bike lane.

o Curb extensions at intersections.

Figure 6. Graphic. Second Street corridor project limits. 

Source: KYTC, 2019. 
Safety and NEPA: Case Studies and Noteworthy Practices

 

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o On-street parking in westbound direction.

Capital Avenue from Second Street to the Capital Avenue Bridge (2)

The two alternatives developed for Capital Avenue proposed 

different lane configurations to accommodate southbound Capital 

Avenue traffic (figure 8). Alternative 1 provided a dedicated right-turn 

lane, a through lane, and a short, dedicated left-turn lane; Alternative 

2 provided a shared right-through lane and a shared left-through lane. 

However, both alternatives included a multi-use path to provide 

connectivity to the future river trail.

The City recommended Alternative 1 due to the need for the 

dedicated left-turn lane for traffic operations. This demonstrates an 

example of balancing project needs across various parameters while 

still improving safety over the existing condition. Design specifics for 

this alternative include:

» Capital Avenue (from Second Street to the Bridge): 

o One 11-ft travel lane in each direction.

o One 12-ft dedicated southbound right-turn lane and 

one 11-ft dedicated southbound left-turn lane at Second Street.

o 8-10-ft sidewalks on both sides of the street.

o Curb extensions at Second Street intersection.

Figure 8. Graphic. Capital Avenue 

improvement alternative. 

Source: KYTC, 2019.

Alternative 1

Figure 7. Graphic. Second Street typical section, Bridge Street to Shelby Street. 

Source: KYTC, 2019. 
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Main Street – High Street to Broadway Street (3)

The two alternatives developed for Main Street proposed different 

options for the existing eastbound dedicated right-turn lane and 

sidewalk (figure 9). Alternative 1 removed the dedicated eastbound 

right-turn lane and widened the southern sidewalk in front of the 

stone buildings between High Street and Capital Avenue. This 

additional space allowed for improved walking conditions and the 

ability to build a two-tiered sidewalk on the south side to remove 

the existing stair barriers to accessibility for pedestrians with 

disabilities. Alternative 2 maintained the dedicated right-turn lane 

but requires pedestrians not able to use stairs on the south side to 

cross over to the north side. The existing 12-ft sidewalk area on the 

south side in front of the stone buildings would be two-tiered to 

provide both an accessible pedestrian route and an accessible 

entrance to a stone building. The City recommended Alternative 2 

due to the need for the dedicated right-turn lane for traffic 

operations. Design specifics for this alternative include:

» Main Street at Capital Avenue and High Street Intersections:

o Curb extensions at both intersections.

o 10-13-ft sidewalks along the north side of Main 

Street and 6-ft sidewalks on the south side of Main Street.

Project Themes

The Second Street Corridor Complete Street and Road Diet project touches on several themes noted in 

FHWA’s Integrating Road Safety into NEPA Analysis: A Practitioner’s Primer guidance (FHWA, 2011). 

Considering Safety Prior to NEPA 

The NEPA process is structured to produce a thorough review of potential environmental impacts of a 

project, including those to the human environment. However, the grant writing process, along with feasibility 

studies, existing conditions reviews, and stakeholder engagement leading up to the NEPA process can identify 

project needs, safety being just one example. The City’s project planning and pre-NEPA work established 

safety as a priority goal of the community that was used to inform the purpose and need. During the NEPA 

process, there was an opportunity to document project decisions and create a path for safety elements to be 

included in the project.

Safety and Environmental Justice

The project will provide benefits to many of the affected neighborhood residents by providing safe, accessible 

routes along Second Street and across the river into downtown Frankfort. The Second Street Corridor has a 

considerably high low-income population who lack of access to a motor vehicle (table 1). By engaging multiple 

public groups and agencies that advocate for underserved communities (as previously detailed), the project 

team was able to engage these communities and build consensus through the environmental review, design, 

and implementation of the project.

Figure 9. Graphic. Main Street Improvement 

Alternative. 

Source: KYTC, 2019.

Alternative 2
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Safety and Environmental Stewardship

The combination of an improved multimodal environment (i.e., safe, comfortable, and connected network for 

all road users) and environmental remediation (i.e., stormwater improvements, reduced emissions, etc.) 

demonstrate a key point in the USDOT’s National Roadway Safety Strategy (NRSS): 

“The climate, health, and other co-benefits of safety improvements on our roadways and in the 

surrounding environment are substantial, and further support the benefits of a focused roadway safety

effort.” (USDOT, 2022; p. 9)

Future Opportunities for Complete Streets and the NEPA Process

A project like the Second Street Corridor Complete Street and Road Diet project opens the door for future 

opportunities to plan, develop, and operate equitable streets and networks that prioritize safety and 

connectivity to destinations for all people who use the street network. The City hopes to implement various 

forms of public art (murals, sculptures, granite sidewalk inserts) in the future to encourage community 

ownership of the corridor. The positive momentum around this project has also helped the City secure a 

Rebuilding American Infrastructure with Sustainability and Equity (RAISE) grant for a nearby two-mile corridor 

that will also implement Complete Streets concepts, furthering the mission of a safe and connected City 

network.
Safety and NEPA: Case Studies and Noteworthy Practices

 

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References & Additional Information

» City of Frankfort, Kentucky. (2017). TIGER Application: Complete Street and Road Diet on Second Street 

Corridor. Available online: http://www.frankfort.ky.gov/DocumentCenter/View/1593/Frankfort-TIGERApplication---Complete-Street-and-Road-Diet-on-Second-Street-Corridor. 

» Federal Highway Administration. (n.d.). Complete Streets. Available online: 

https://highways.dot.gov/complete-streets 

» Federal Highway Administration. (2011). Integrating Road Safety into NEPA Analysis: A Primer for Safety 

and Environmental Professionals, Report No. FHWA-SA-11-036, Washington D.C. Available online:

https://rosap.ntl.bts.gov/view/dot/42549. 

» Federal Highway Administration. (2022). Proven Safety Countermeasures. Available online: 

https://highways.dot.gov/safety/proven-safety-countermeasures. 

» Graham, H. (2012). Proposal to the U.S. Environmental Protection Agency for the Greening America’s Capitals 

Program [Letter]. Frankfort, Kentucky. 

» Kentucky Transportation Cabinet. (2019). Categorical Exclusion Environmental Determination Checklist. 

Item #: 5-565.00. Franklin County, Kentucky. 

» Office of Sustainable Communities. (2013). Greening America’s Capitals: Second Street Corridor. Frankfort, 

Kentucky. Available online: https://archive.epa.gov/epa/sites/production/files/2014-

02/documents/greening-americas-frankfort_0.pdf.

» Phone Interview on January 28, 2022, with Rebecca Hall (City of Frankfort, KY), Chuck Knowles (City 

of Frankfort, KY), and Andrew Seth (Sustainable Strategies DC).

» United States Department of Transportation. (2022, January). National Roadway Safety 

Strategy. Available online: https://www.transportation.gov/sites/dot.gov/files/2022-02/USDOT-NationalRoadway-Safety-Strategy.pdf.

Project Contact

Rebecca Hall

City of Frankfort

(502) 352-2076 

rhall@frankfort.ky.gov