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Policy and Cultural Resources Updates. Environmental Update Meeting 12 December 2013. Manuals . Public Involvement Manual CE Manual Section 4(f) Manual EJ Guidance Secondary and Cumulative Effects Manual. Section 6(f) MOA . ODOT, FHWA, ODNR, and NPS Working on MOA
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Policy and Cultural Resources Updates Environmental Update Meeting 12 December 2013
Manuals • Public Involvement Manual • CE Manual • Section 4(f) Manual • EJ Guidance • Secondary and Cumulative Effects Manual
Section 6(f) MOA • ODOT, FHWA, ODNR, and NPS • Working on MOA • Streamlined process will include: • No external agency coordination for maintenance activities • ODNR approves Temporary Non-Conforming Use • One form to cover both 4(f) and 6(f) • Our environmental document process replaces Part B of the PD/ESF form for ODOT projects • Working on streamlining the appraisal process
Compliance Review Trends 2013 • Overall compliance reviews went really well this year! • A few trends: • Environmental Justice • Looks good since new guidance released • Public Involvement • Make sure that comments receive responses • Make sure level of PI is commensurate with project/impacts • Maintenance of Traffic/Community Impacts • Coordination with public services (fire, police, etc.) must begin during NEPA.
Compliance Review Trends 2013 • A few trends: • Environmental Commitments • Make sure commitments are carried through to the commitment box • Purpose and Need • Generally looked good • Don’t include solutions in P&N • Goals and Objectives are optional (only use if needed)
Section 106 Request for Review • Not being used as we originally meant it • Meant to be simple and easy for districts to submit to OES as a scoping tool • Two things have become apparent: • Misunderstanding as to what we need (secondary source review with photo log) • Misunderstanding as to what it is for (clear projects using the Section 106 PA or scope additional cultural activities)
Section 106 Request for Review • Districts need to know what questions they want to have answered with the RFR: • Do you have enough information for us to clear a project or provide a scope? (original intent) • Are you still very early in the process and just need some guidance? • We are revising the Cultural Resources Manual to better explain RFRs • We have discussed at a recent District Environmental Coordinator Meeting as well
Section 106 Request for Review • As consultants: • Make sure you have an accurate project description • Use RFR checklist • Communicate with your prime, LPA, and/or district—ask questions and provide guidance if needed • OES does not need long narratives. However, if something requires explanation, a brief paragraph can be included • Use common sense
Trainings Don’t forget! The grace period for retaking environmental trainings is June 2014! Currently registration is closed for all classes as we update the way we maintain registration data. An email will be sent out on the OES listserve as soon as registration reopens (approximately January 2, 2014)