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Tennessee Environmental Procedures Manual

Chapter 2: Project Identification and Development

2.4 Development and Consideration of Alternatives

Once the purpose and need for a project has been identified and the study area has been defined, alternative ways in which the transportation problem(s) can be solved must be explored.

Under the CEQ regulations 40 CFR 1500.2, federal agencies are directed to:

(e) Use the NEPA process to identify and assess the reasonable alternatives to proposed actions that would avoid or minimize adverse effects of these actions upon the quality of the human environment.

FHWA, in providing guidance for the implementation of SAFETEA-LU, explains that the development of the range of alternatives should be a collaborative process in which the lead agencies must provide opportunities for the involvement of the public and participating agencies, and the lead agencies must consider the input provided by these groups. After considering the input, TDOT, in consultation with, FHWA, is responsible for deciding the range of alternatives to be considered in the NEPA document. The form and timing of the public and participating agency involvement is flexible, but the opportunity must be provided prior to FHWA's final decision regarding the reasonable range of alternatives. SAFETEA-LU's Section 6002 provisions are mandatory for EIS documents and optional for other levels of documentation.

The second TESA concurrence point (see Section 4.5 of this manual) occurs during this stage, when cooperating and participating agencies are asked to review and concur with the range of alternatives to be carried forward in the environmental document.

The identification, consideration and analysis of all reasonable alternatives or the reasonable range of alternatives is essential to the NEPA process and the goal of objective decision-making. A "reasonable" alternative meets the purpose and need of the project or does not have unacceptable consequences. Other criteria for defining reasonableness may apply to individual projects.

The following sections discuss how the initial set of alternatives is developed and how they may be refined during the NEPA process.

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2.4.1 Preliminary Alternatives Development and Refinement

During the early phases of project development, a set of preliminary alternatives or options are identified or may be confirmed from earlier studies, including MPO Long Range Transportation Plans and Transportation Planning Reports. The number of preliminary alternatives considered depends upon the type of project and its size and complexity. For example, an intersection improvement is likely to have few alternatives, while a new roadway on new location would be expected to have a fairly large number of possible alignments that will ultimately be screened to a reasonable and representative range.

During the development of the preliminary alternatives, and throughout the project planning process, some of the alternatives may be revised and modified, while others may be dropped from further consideration because they are determined to be impracticable or not feasible, may have severe adverse impacts or do not meet the project's purpose and need. New alternatives may also come to light as the process moves forward. Affected agencies and the public will be given opportunities to provide input into the development of alternatives that are considered.

As stated in 40 CFR 1502.14 (a), the CEQ specifically requires that when an EIS is being prepared, "all reasonable alternatives" must be explored. CEQ also requires that those alternatives that were initially considered but eliminated from more detailed study be discussed in the EIS, with the reasons for removing these alternatives from further consideration also explained. CEQ regulations and the Federal Highway Administration (FHWA) regulations and Technical Advisory provide no guidance regarding the consideration of all reasonable alternatives for projects where the documentation is an Environmental Assessment (EA) or a Categorical Exclusion (CE). Although not specified in the Technical Advisory, TDOT generally discusses in the EA the alternatives that were initially considered but dropped from further study after they were determined to be unreasonable.

Beyond the CEQ requirements to evaluate alternatives to avoid or minimize impacts to the environment, there are other regulations that require consideration of "avoidance" alternatives. Specifically, Section 4(f) of the Department of Transportation Act of 1966, the Executive Orders on Wetlands (E.O. 11990), Floodplains (E.O. 11988), and Environmental Justice (E.O. 12898), and the US Army Corps of Engineers' Section 404 (b)(1) guidelines, require agencies to develop alternatives that would avoid or minimize impacts. These regulations are summarized in Appendix C [pdf 67 kb], and discussed in the appropriate sections of Chapter 5, Impact Analysis.

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