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Tennessee Environmental Procedures Manual

Chapter 2: Project Identification and Development

2.2 Context Sensitive Solutions (CSS)

FHWA promotes Context Sensitive Solutions (CSS) as an integral part of its efforts to advance environmental streamlining and environmental stewardship. In 2006, TDOT developed a CSS Statement of Commitment that outlines its CSS approach. In summary, TDOT's CSS Statement of Commitment defines CSS as:

". . . a process to plan, design, construct, maintain and operate its transportation system in order to establish and achieve transportation, community and environmental goals. Context Sensitive Solutions balances safety and mobility and the preservation of scenic, aesthetic, historic, environmental and other community values. CSS is a philosophy of doing business that impacts both the project development process and project outcomes."

There are four core CSS principles and they apply to transportation processes, outcomes, and decision-making (AASHTO/FHWA March 2007):

  • Strive towards a shared stakeholder vision to provide a basis for decisions;
  • Demonstrate a comprehensive understanding of contexts;
  • Foster continuing communication and collaboration to achieve consensus; and
  • Exercise flexibility and creativity to shape effective transportation solutions, while preserving and enhancing community and natural environments.

The CSS approach is integrated throughout the project development process. It begins in the planning phase, even before the NEPA process is initiated, and continues through the environmental evaluation, design, construction, and maintenance and operations phases of a project (Figure 2.1). CSS is the responsibility of all TDOT divisions, in collaboration with stakeholders, including partner agencies, local governments and the public. Key elements of the CSS process are shown below:

Figure 2.1 CSS Project Development "Bridge Graphic"

Thumbnail - Project Matrix

EnlargeClick image to open a larger version of Figure 2.1 in a new window [pdf 583 kb]

  • Interdisciplinary Project Teams
    An interdisciplinary project team should be established at the beginning of the project development process. Team members should represent all project phases and need to be engaged throughout the entire project development process. Not all technical disciplines may be needed for all projects. It is the responsibility of each team member to provide input throughout the process; work with each other to identify potential problems and issues early in the process; help to develop solutions; and make sure that project concerns are adequately and appropriately addressed.
  • Involvement of a Full Range of Stakeholders
    Involving a full range of stakeholders helps to ensure that issues and concerns of members of the community, agencies and others are all heard. It aids with the development of a project solution that will best fit the context of the community and meet the purpose and need of the project. This element of CSS integrates with the process requirements of SAFETEA-LU Section 6002 for providing participating agencies and the public with an opportunity to provide meaningful input in the development of the purpose and need for a project and the range of alternatives to be studied.
  • Early, Open, and Continuous Communication with all Stakeholders
    Early, open and continuous communication with all stakeholders, including project team members helps to insure that issues and concerns are identified early and helps to streamline the project development process.
  • Consensus Among Stakeholders
    TDOT seeks to achieve consensus with a full range of stakeholders at key project development milestones, including problem identification, development of a project vision, development and assessment of project alternatives, through construction and maintenance. Developing consensus at key project milestones is critical for streamlining the project development process in general and the environmental review process in particular.

The way in which CSS principles are met may vary from project to project. The public involvement and outreach efforts are scaled to the size and nature of the project. For example, large, complex projects and controversial projects may utilize citizen resource teams or focus groups. A citizen resource team is comprised of a representative group of project stakeholders familiar with the project area. The team members serve in an advisory role to TDOT and are responsible for providing input to TDOT about project issues and concerns as well as providing accurate project information to their community members. The use of citizen resource teams is one of the enhanced public involvement activities described in TDOT's Public Involvement Plan.

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Involving a full range of stakeholders; early, open, and continuous communication with all stakeholders; and the development of a project that satisfies the purpose and need for the project are CSS principles that also correlate with NEPA requirements. Early and on-going coordination with the public and resource agencies should be summarized in the environmental document. The document should include a description of how the public was involved in the development of the purpose and need and the potential alternatives. This information should be summarized in the chapters on purpose and need and development of alternatives. A more detailed discussion of the public involvement that has been conducted throughout the project development process should be included in the chapter on agency coordination and public involvement.

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