What is Planning and Environmental Linkage (PEL)?
Planning-Environment Linkage (PEL) is an approach to performing planning studies that allows decisions made in planning to be carried forward into the National Environmental Policy Act (NEPA) process. Without PEL, these decisions usually need to be revisited in order to be valid in NEPA. This results in a repetition of efforts which translates into additional project development time and expense. PEL generally requires that decisions made during planning receive public involvement and resource agency coordination in order to be brought into NEPA. PEL can be used by any planning agency, including state DOTs, MPOs and LPAs.
INDOT has created a PEL Committee to screen proposed PEL studies for appropriateness as PEL pilots. The Committee consists of one expert each from INDOT’s planning, environmental, and traffic engineering divisions. The MPOs and LPAs are encouraged to incorporate PEL elements into their planning studies. PEL may provide local transportation planners with analytical tools and funding options that are not otherwise available.
When is it appropriate to use PEL?
It is appropriate to use PEL when…
- Large geographic scale and/or regionally significant proposal could result in multiple programmable projects with independent utility and logical termini
- Known or anticipated public controversy about scope, need, purpose, and/or potential alternatives
- Complex community impacts or complex environmental constraints
- Need and purpose is unclear, unstable, or requires additional definition
- Too many possible alternatives for an efficient NEPA process
- High cost and/or construction funding not programmed
- Even with a lot of initial work, NEPA process will not meet EA (1 year) or EIS (2 year) time limits
INDOT’s Approach to PEL
Within all planning studies, the location description and deficiency analysis should identify the NEPA concepts of logical termini, independent utility, purpose and need, and no build alternative. Red flag investigations (RFIs) should identify known features in the human and natural environment that may be impacted and may also identify likely locations of concern and environmental obstacles. The RFI follows all current guidelines as they would for an RFI in a NEPA document. Those guidelines can be found in the INDOT Site Assessment and Management webpage. These elements provide the groundwork for NEPA documents for the proposed capital program projects, if any, that result from the planning study. Incorporating the NEPA elements will mainly require statements in the text of the planning document, and the red flag investigation will use existing information and existing INDOT guidance.
The Federal Highway Administration (FHWA) will not certify these elements for inclusion in NEPA because they have not received public involvement and resource agency coordination, but the elements would be formulated and ready for such coordination when NEPA is initiated. Information from the RFI would be available to inform analysis of possible remedies for identified deficiencies.
INDOT has prepared a brochure about PEL that provides basic information about the benefits of PEL and INDOT’s implementation of PEL.
It’s available for viewing and download here: PEL Brochure
Technical information on INDOT’s implementation of PEL is available here: PEL Implementation
For additional information from FHWA regarding PEL, please follow these links.
The PEL questionnaire is available at:
https://www.environment.fhwa.dot.gov/env_initiatives/pel/pel_quest.aspx
The Federal Highway Administration Environmental Review Toolkit Planning and Environment Linkages link:
https://www.environment.fhwa.dot.gov/env_initiatives/PEL.aspx
Contacts
Corey Webb
Environmental Policy Leader
INDOT Environmental Services
CoWebb@indot.in.gov
Jay Mitchell
Technical Planning Supervisor
INDOT Technical Planning and Programming
Jaymitchell@indot.in.gov