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Purpose and Need. Mary Ann Rondinella FHWA Resource Center. Where Does P/N Come From?. NEPA and Section 404 of the Clean Water Act specifically address P/N. Section 404: USACE must define the purpose of the project.
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Purpose and Need Mary Ann Rondinella FHWA Resource Center
Where Does P/N Come From? • NEPA and Section 404 of the Clean Water Act specifically address P/N. • Section 404: USACE must define the purpose of the project. • Applies to permits for discharge of dredged or fill material into waters of the U.S. (33 CFR 325).
Where P/N Comes From (continued) • P/N, however, is crucial to compliance with many other laws and E.O.’s. • Example: Section 4(f). • An alternative that does not meet purpose and need is NOT FEASIBLE AND PRUDENT.
Practical Guidance • P/N statements should be concise. • No more than one or two paragraphs. • Purpose: why the project is being proposed (note “why”, not “what”.) • Need: describes the problem to be addressed.
Sample Structure • Introduction/Background • Purpose • Need • Other Goals and Objectives
Practical Guidance on Preparing P/N • P/N statement should not discuss alternatives. • That is, it shouldn’t say, “The purpose of this project is to build a six lane expressway on the current alignment of Main Street from Avenue A to Avenue D.”
Where Do Data for P/N Statements Come From? • Ideally, from the transportation planning process. • In reality, the planning process varies greatly across the U.S. • Some MPOs are including short P/N statements in their TIPs.
Economic development sometimes seems like an indigestible problem.
The Challenge • We need P/N statements that are understandable to the lay public. • “The LRTP calls for a Class A facility with peak hour LOS D or better.” • “The V/C ratio is 1.1, indicating unstable flow.” • “To provide needed throughput, BRT will need to operate at 15 minute headways.” • Huh?
Summary • Need clear, concise P/N statements • Move supporting data to reports, appendices • Use transportation and other plan information • Others?