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Integrating and Aligning Planning and Permitting
Next Steps
The Transportation Permit Efficiency and
Accountability Committee (TPEAC) helped to frame and
develop a model approach for more effective
environmental decision-making on a watershed scale.
Many efforts are underway across the state to
realize the benefits of integrating watershed,
landscape, and jurisdictional planning with
project-based permitting, mitigation, and
environmental decision-making. Innovation,
creativity, and multi-stakeholder collaboration are
occurring at all levels. Transportation project
teams are working with resource and regulatory
agency staff to align natural and cultural resource
protection with transportation project review and
permitting.
TPEAC and its subcommittees have approached the
concept of integrated and aligning planning and
permitting from many different directions, and at
many different levels. The
Planning
Subcommittee,
Watershed-Based Mitigation Subcommittee, and
Local
Government Task Force are among the key groups
that worked to advance this overall approach. For
this reason, as well the fact that there are many
broad and diverse stakeholders, issues, and next
step opportunities (spanning from early planning on
through project permitting and decision-making), the
task of defining discrete next steps for this TPEAC
approach area is not simple.
TPEAC believes the Governor's Office of Regulatory
Assistance (ORA) and the Governor’s Regulatory
Improvement Program are uniquely positioned to offer
continuing leadership and the attention necessary to
further advance integration of planning and
decision-making on watershed, landscape, and
jurisdictional scales. TPEAC also recognizes that in
Washington State, no entity or authority has sole
responsibility for integrating and aligning all
planning, design, and decision-making.
Likewise, no entity has sole responsibility for sustaining
a healthy environment. This is evidenced by
the array of different planning processes occurring
in Washington's watersheds (see Table 1
below). Collective and individual
agency efforts on several fronts are suggested.
TPEAC therefore offers the following for further
consideration:
- Continue to Refine and Advance Efforts Stemming
from the TPEAC Experience:
Examples include:
- Important Near-Term Next Steps to Pursue:
- ORA can offer a significant point of
leadership to facilitate and focus the energy
necessary to continue to advance more coherent,
integrated, and effective approaches to
planning, design, and decision-making. ORA
should consider:
- Continuing to identify and promote best
practices and spotlight success stories (e.g.,
early interaction between project managers and
permitting staff to identify, avoid, and
minimize impacts, use of local plans and local
knowledge to identify potential mitigation
solutions, etc.);
- Convening and developing common understanding
to assist multi-agency efforts; and
- Improving coordination and communication among
key groups.
- The Washington State Department of
Transportation (WSDOT) should continue to work with WSDOT
transportation planners, metropolitan and
regional planning entities to use information
developed in TPEAC as they begin to implement SAFETEA-LU requirements.
- WSDOT and the resource agencies should revise
the Signatory Agency Committee to be compliant
with SAFETEA-LU 6002 and incorporate
opportunities to planning linkages in this
interagency process.
- WSDOT should clarify how to identify
environmental issues in transportation plans
(per TPEAC's Planning Subcommittee Draft Report), and add
guidance to planning and environmental
procedures manual.
- Unfinished Business (i.e., Areas for Further Consideration):
The Planning Subcommittee Draft report suggests five possible actions, as well as dozens more issues that they were not able to analyze in sufficient detail to make final recommendations. This report is a valuable resource for future individual agency and collaborative efforts.
A few example recommendations include:
- Develop statewide or regional environmental plans;
- Involve resource agencies in land use and transportation planning.
- Consider SEPA non-project analysis for planning level
- Improve analysis of cumulative effects – what level of detail or methods might work at a planning level or regional level?
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Table 1: Planning Efforts in Walla
Walla - Watershed Resource Inventory Area (WRIA)
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History/Background Information
As mentioned, TPEAC and its subcommittees
approached the concept of integrating and
aligning planning and permitting from many
different directions, and at many different
scales. This was done largely through the
efforts and activities of TPEAC’s Planning
Subcommittee, Watershed Subcommittee, and Local
Government Task Force as follows:
- TPEAC’s
Planning
Subcommittee undertook an effort to review
the transportation planning process and make
recommendations on environmental information and
processes that would promote early issue
identification in the planning phase and in
preparation for National Environmental Policy
Act (NEPA), State Environmental Policy Act (SEPA),
and permitting, mitigation, and decision-making.
- Why isn’t it easy to integrate
planning and permitting? -- Under the
Growth Management Act, local governments
determine strategies to address population
growth, land use and protection of the
environment. WSDOT works with local
governments and metropolitan and rural
planning entities to set long-range plans.
The legislature approves project lists.
Transportation projects support GMA and help
implement local and statewide plans – but
the environmental review of those projects
is the primary venue for consideration of
environmental impacts, ESA compliance etc.
- The Subcommittee’s vision was to: “Coordinate
transportation planning with environmental
and land use planning processes at all
levels of government so that transportation
projects avoid, minimize, or otherwise
mitigate impacts on the environment in order
to reduce conflict and project delay, and
help to ensure that subsequent permitting
decisions are made in a more coordinated,
streamlined manner.”
- The Subcommittee produced a
final
draft report summarizing planning issues
and their effect on transportation schedules
and suggesting possible actions, and
identifying the following problem statement:
“It is traditionally at the project level
that the natural resource agencies raise
issues, concerns and questions regarding
cumulative and secondary impacts, indirect
effects, modal choice and range of
alternatives. These issues and concerns are
required to be addressed under NEPA and ESA
but are often difficult to address at the
project level because they relate to
decisions and work that are more effectively
done during the earlier planning stages of
transportation development.”
- Because transportation planning is so
integrally linked with land use planning and
vice versa, numerous state and local
stakeholders need to ultimately be involved
in the formation of solutions to the
problem. [Note: The work led by the
Association of Washington Cities (AWC) and
the Washington State Association of Counties
(WSAC) to integrate watershed planning into
permitting decisions is an example of a
promising direction stemming from the TPEAC
experience that can serve as a foundation
for further action and efforts.]
- The
Watershed Mitigation Subcommittee included
efforts designed to help integrate TPEAC
products with the watershed and land use
planning tools currently being developed by
local governments. See
Implementing Watershed-Based Mitigation Tools
and Strategies for relevant next steps
looking forward.
- The
Local Government Task Force was convened in
2003 to identify issues facing WSDOT when
interacting with local governments. The
Task Force's Final
Report to TPEAC found that WSDOT interaction
with local planning offices (early and often) is
key to timely project delivery.
Ongoing/Related Efforts
Many efforts and improvement activities are
occurring at different points along the continuum of
early-planning through project permitting and
decision-making. Recognizing the challenge of fully
capturing and enumerating all such activities, the
following are presented instead as illustrative
examples of activities relevant to the larger
improvement direction of integrated and aligning
planning and permitting to achieve better outcomes
and more efficient permitting:
- Linking Planning and NEPA for
Transportation (Long-Range Planning Scale):
- Workshop for Linking Planning and NEPA
(August 3-6, 2004) -- This workshop was
hosted by FHWA as part of a federal
initiative. Taking the TPEAC Planning
Subcommittee work as the launching point,
this workshop began with a day-long
executive session; and then a three-day
manager and staff level brainstorm session
to craft an action plan and various
proposals to improve the links. Updated
information, state’s progress reports will
soon be posted on
FHWA’s website.
- SAFETEA-LU -- State DOTs and federal
highway and transit officials must implement
the Safe, Accountable, Flexible, Efficient
Transportation Equity Act: A Legacy for
Users (see
SAFETEA-LU). The law (signed August
2005) includes a number of significant
changes that will affect how transportation
agencies carry out environmental reviews for
their projects (see
http://environment.transportation.org/global/new_on_website.aspx).
- Comprehensive Wildlife Conservation
Strategy -- Comprehensive plans for wildlife
conservation that states have submitted to
federal wildlife officials are an ideal
source to help transportation planners
comply with new mandates of federal
transportation law (see
http://wdfw.wa.gov/wlm/cwcs).
- Tribal TTPOs -- In 2005, WSDOT provided
funds to assist tribes in Washington State
to form Tribal Transportation Planning
Organizations and improve their abilities to
get projects into the statewide planning
process (see
http://www.wsdot.wa.gov/tribal/).
-
Growth Management and Environmental
Permitting Website – Through TPEAC,
WSDOT contracted with CTED to develop a
website for transportation planners and
environmental staff. The site clarifies
confusing elements of GMA and its
relationship to transportation project
environmental analysis, and includes
recommendations for ways WSDOT can use
locally generated information to assist with
NEPA and ESA compliance and permitting
applications.
- Watershed Models and Tools to Help Align
Environmental Information for Better Outcomes
(Short-Range Planning Scale): Over the last
several years many promising directions related to
short range planning and land use decisions have
been identified by various agencies and groups. A
few examples listed below illustrate: (1) the
breadth of interest associated with moving the
planning, permitting, mitigation, and
decision-making system toward a watershed or
landscape-based model; and (2) serve as a foundation
for an effective mitigation approach furthering the
Governor’s goals for regulatory improvement:
- Washington State Association of Counties and
Association of Washington Cities -- In response
to
TPEAC, the AWC and WSAC have initiated:
- development of a “road map” for local
pilots for watershed mitigation;
- establishment of a model for better
integration and alignment of permitting
and planning (e.g., as was demonstrated
through TPEAC field trip to
SR
12, Walla Walla); and
- development of a prototype website to make
it easier for permitters to find
potential mitigation projects that might
meet permitting and watershed planning
objectives [Note: During TPEAC several
permit process and mitigation screening
tools were developed as prototypes.
Clark County and the City of Vancouver
and Lewis County and Cities of Chehalis
and Centralia have been identified as
sites for testing operating versions of
these systems. The screening tools will
utilize GIS systems to integrate data
from watershed, salmon restoration, land
use, and other plans. One of the
objectives of the demonstration is to
make it easier to identify mitigation
sites that meet regulatory requirements
and at the same time implement watershed
and salmon restoration plans. Another
objective is to build a database of
information about potential mitigation
sites by retaining site assessments
performed for individual projects in a
single system where they can be accessed
for use by others seeking potential
mitigation projects.]
- Washington Department of Fish and
Wildlife Mitigation Optimization Report --
Click here to access -- http://epermitting.org/Portals/_JarpaResourceCenter/Documents/MO%20Report%20041505.doc.
[Note: This effort has evolved and matured
along with Ecology as part of an ORA-driven
interest in alternative mitigation as a
regulatory improvement option.
- Washington Department of Ecology’s
Leadership Plan and Action Plan (***link
soon coming****) to develop a more effective
approach to habitat mitigation by advancing
and building on previous mitigation reforms
to achieve greater environmental protection
and more efficient permitting, e.g.,
- Wetlands banking through WSDOT and
as part of Ecology's pilot banking
program;
- Alternative stormwater flow
management. Des Moines Creek Basin Plan
provides an example of a
multi-jurisdictional plan that used
basin-specific analysis to develop a
cost-saving strategy for managing
stormwater and stream flows protective
of fish and water quality (see
http://dnr.metrokc.gov/dnrp/press/2005/0616DesMoinesCreek.htm).
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