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Purpose & Need Class How to Write a Better Statement

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1 Purpose & Need Class How to Write a Better Statement
Purpose & Need Class How to Write a Better Statement Presented by: FHWA-Ohio Division ODOT Office of Environmental Services

2 Agenda Introductions/Course Objectives
Administrative & Regulatory Process Developing P&N Putting It All Together Course Wrap-Up Test

3 Introductions Name Company Environmental Experience Class Expectations

4 Course Objectives Understand Federal Requirements
Understand the foundation of an approved NEPA Document is the P&N Understand P&N relationship with Alternative Analysis, Section 4(f), Wetland Findings, Logical Termini, etc.

5 Course Objectives Write and review P&N Statements that:
Focus on transportation problems Advance a project efficiently Provide a clear basis for evaluating alternatives Are legally defensible As the cartoon suggests, the process of developing P&N is not as simple as “point and click”. It may involve going back to the chalk board and ensuring everything has been included

6 Regulations Policy & Procedures

7 Federal Law & Regulations
National Environmental Policy Act of 1969 Regulations CEQ (40 CFR 1502) FHWA (23 CFR 771) I will discuss very briefly the laws and regulations to give you some of the background, and then we will get into the policy and guidance.

8 Policy & Guidance FHWA Technical Advisory (T6640.8a)
10/3/87 Purpose & Need in Environmental Documents 9/18/1990 FHWA/FTA Joint Guidance on Purpose & Need 7/23/2003 Development of Logical Termini 11/5/1993 FHWA Guidance-Linking Planning and NEPA 2/22/2005 CEQ 40 Most Asked Questions ceq.hss.doe.gov/nepa/regs/40/40p3.htm

9 Federal Law & Regulations
National Environmental Policy Act of 1969 The purpose of this Act are: To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation Established a systematic, interdisciplinary approach for decision-making Study, develop, and describe appropriate alternatives to recommended courses of action NEPA requires us to communicate with other agencies and the public. It also requires us to look at alternatives to our proposed actions. It is not a good idea to attempt either of these without a good idea of the purpose and need for the project. You can lose credibility with the public and other agencies if are not able to answer questions about why the project is needed. You can’t determine if an alternative will work if you don’t understand the problem that you are trying to solve

10 CEQ Regulations 40 CFR 1500.1 (c) - Purpose
Ultimately…it is not better documents but better decisions that count. NEPA’s purpose is not to generate paperwork - even excellent paperwork - but to foster excellent action. 40 CFR Purpose and Need The statement shall briefly specify the underlying purpose and need to which the agency is responding in proposing the alternatives including the proposed action The Council on Environmental Quality was established with passage of NEPA. The CEQ is the agency responsible for administering NEPA. The CEQ regs say: it is not better documents but better decisions that count. NEPA's purpose is not to generate paperwork--even excellent paperwork--but to foster excellent action. An understanding of the purpose and need is essential for good decision-making.

11 CEQ Regulations 40 CFR 1502.14 - Alternatives
Heart of the environmental document Agencies shall: “…evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.” CEQ call the alternatives section the heart of the EIS.

12 FHWA Regulations 23 CFR 771.111(f)
…the action evaluated in each EIS or finding of no significant impact (FONSI) shall: Connect logical termini Have independent utility Not restrict consideration of alternatives for other reasonably foreseeable transportation improvements Guidance and Policy for preparation of P&N based upon 40 CFR 1500 and 23 CFR 771

13 FHWA Definition Purpose Need
States concisely and clearly why the undertaking is being proposed Articulates intended positive outcomes Need Transportation problem(s) to be addressed Defines causes of existing problems Factual, quantifiable data

14 FHWA Technical Advisory (T6640.8A)
FHWA Guidance FHWA Technical Advisory (T6640.8A) (10/30/1987) Guidance for Preparing and Processing Environmental and Section 4(f) Documents Section II - Part B Purpose & Need for Action Describe location, length, termini, proposed improvements, etc. Identify and describe the transportation or other needs which the proposed action is intended to satisfy (e.g., provide system continuity, alleviate traffic congestion, and correct safety or roadway deficiencies) The FHWA guidance (Technical Advisory) also touches on link between the purpose and need statement and the alternatives. It will form the basis for the "no action" discussion in the "Alternatives" section, and assist with the identification of reasonable alternatives and the selection of the preferred alternative.

15 FHWA Technical Advisory (T6640.8A)
FHWA Guidance FHWA Technical Advisory (T6640.8A) Section V - Part D Clearly demonstrate that a "need" exists and define the "need" in terms understandable to the public Forms the basis for the “No Build" discussion in the Alternatives section and assist with the identification of reasonable alternatives and selection of the preferred The FHWA guidance (Technical Advisory) also touches on link between the purpose and need statement and the alternatives. It will form the basis for the "no action" discussion in the "Alternatives" section, and assist with the identification of reasonable alternatives and the selection of the preferred alternative.

16 FHWA Technical Advisory (T6640.8A)
FHWA Guidance FHWA Technical Advisory (T6640.8A) On projects where a law, Executive Order, or regulation mandates an evaluation of avoidance alternatives, explanation of the project need should be more specific so that avoidance alternatives that do not meet the stated project need can be readily dismissed

17 Purpose & Need in Environmental Documents
FHWA Guidance Purpose & Need in Environmental Documents (9/18/1990) In many ways, P&N is the most important section of an environmental document Establishes why the agency is proposing to spend public funds, while at the same time causing significant environmental impacts

18 Purpose & Need in Environmental Documents
FHWA Guidance Purpose & Need in Environmental Documents A clear and well-justified P&N explains to the public and decision-makers why expenditure of funds is necessary and worthwhile Priority being given to the action relative to other needed highway projects is warranted Although significant environmental impacts may be expected, P&N should justify why impacts are acceptable Brief discussion of applicability of EIS regulations to other Nepa Docs

19 FHWA/FTA Joint Guidance on P&N
FHWA Guidance FHWA/FTA Joint Guidance on P&N (7/23/2003) Lead agency has the authority and responsibility to define 'purpose and need' for NEPA analysis For Federal-Aid (FHWA Title 23 US Code funded) projects, lead federal agency is FHWA The FHWA also has guidance specifically on Purpose and Need. Copy is in your packet. This guidance is relatively recent and came about due the difficulties that we were having when other agencies did not agree with our purpose and need. This guidance is based on an exchange of letters between the Secretary of Transportation and the Chairman of the Council on Environmental Quality. The secretary asked the chairman to answer two questions: First, what is the role of the lead agency under NEPA in determining "purpose and need?" Second, what is the appropriate role of cooperating agencies in reviewing the "purpose and need" for a project?

20 FHWA Guidance Joint-lead or cooperating agencies should afford substantial deference to the lead agency's articulation of a project’s P&N P&N is the cornerstone for the alternatives analysis, but should not discuss solutions Care should be taken to ensure P&N is not so narrow as to unreasonably point to a single solution

21 FHWA Guidance Logical Termini
Rational end points for a transportation improvement Rational end points for review of environmental impacts

22 Guidance on the Development of Logical Project Termini
FHWA Guidance Guidance on the Development of Logical Project Termini (11/5/1993) In developing a project which can be advanced through stages of planning, environmental, design, and construction, the project sponsor needs to consider a “whole” or integrated project Should satisfy an identified need and consider the context of the local area’s socioeconomics and topography, future travel demand, and other planned infrastructure improvements Explain logical termini and purpose and need relates to it

23 FHWA Guidance Proposed improvements may miss the mark by only peripherally satisfying the need or by causing unexpected side effects which require additional corrective action “Segmentation" may occur where a transportation need extends throughout an entire corridor but environmental issues and needs are discussed for only a segment of the corridor

24 FHWA Guidance Three general principles at 23 CFR (f) used to frame a highway project: Logical termini connection should be of sufficient length to address environmental matters on a broad scope Independent utility or significance Reasonable expenditure even if no additional transportation improvements in the area are made Consideration of alternatives for other reasonably foreseeable transportation improvements is not restricted

25 LINKING PLANNING & NEPA
FHWA Guidance LINKING PLANNING & NEPA (2/22/2005) A sound transportation planning process is the primary source of an undertaking’s P&N P&N is where planning and NEPA intersect Where do projects come from? Where do you get the data?

26 LINKING PLANNING & NEPA
FHWA Guidance LINKING PLANNING & NEPA The following information from planning studies can be used in the P&N: Goals and objectives from the transportation planning process Results of analyses from management systems (e.g., congestion, pavement, bridge, and/or safety)

27 LINKING PLANNING & NEPA
FHWA Guidance LINKING PLANNING & NEPA With proper documentation and public involvement, a P&N derived from the planning process can legitimately narrow the alternatives analyzed for NEPA

28 LINKING PLANNING & NEPA
FHWA Guidance LINKING PLANNING & NEPA Alternatives eliminated during the planning process because they do not meet P&N, can be omitted from the detailed analysis of alternatives in the NEPA document Explain the rationale for elimination of alternatives in the NEPA document

29 FHWA Guidance A statement of the transportation problem
Not solution-based Based on articulated planning factors and developed through a certified planning process

30 FHWA Guidance Specific enough so range of alternatives developed offer solutions to the transportation problem Not so specific as to "reverse engineer” a solution May reflect other priorities and limitations in the area (i.e. environmental resources, growth management, land use, and economic development)

31 Purpose & Need and ODOT’s PDP

32 ODOT’s PDP

33 ODOT’s PDP

34 ODOT’s PDP Revised PDP being used on all new projects
No more Major, Minor, Minimal Replaced with five paths that are based on project type and complexity Five phases of project development: Planning Preliminary Engineering Environmental Engineering Final Engineering Construction

35 ODOT’s PDP Path 1 projects typically Exempt or CE Level 1
No documentation required for Exempt projects Anything above Exempt requires a P&N For projects that are not CE Exempt and those in Paths 2-5, P&N should be prepared in Task 1.3.G of the Planning Phase Complete P&N before identifying alternatives

36 ODOT’s PDP District’s Role Research and prepare
May hire consultant to prepare Locals and consultants must send P&N to district for review and approval For local projects, districts can no longer prepare CE 2 documents or higher Seek local stakeholder concurrence Ensure consistent quality control

37 DO NOT WAIT - involve OES early
ODOT’s PDP ODOT-OES will advise and assist with: Finalizing P&N for all projects during NEPA Any questions you may have P&N for CE Level 3 projects and above must be sent into OES for concurrence OES submits draft P&N for CE Level 4s and higher to FHWA for concurrence DO NOT WAIT - involve OES early

38 ODOT’s PDP OES submits draft to FHWA for concurrence that the P&N:
Defines the existing transportation problem(s) and need(s) to the level independent utility can be established Establishes logical termini and any intermediate control points to address environmental matters Is adequate to evaluate, eliminate or advance planning level conceptual alternatives Does not restrict consideration of alternatives for other foreseeable transportation improvements

39 ODOT’s PDP P&N refined throughout the Planning, Preliminary Engineering, and Environmental Engineering Phases (the Planning and Environmental stages of a project) Draft P&N until approved in the NEPA document FHWA Ohio Division has delegated authority to ODOT to review and approve P&Ns for CE Level 1-3 projects Based on acceptance of the PDP Based on implementation of the Programmatic CE Agreement

40 Save this template as a presentation (.ppt file) on your computer.
Using this PowerPoint break timer This PowerPoint slide uses images, custom animation, and timing to provide a countdown timer that you can use in any presentation. When you open the template, you’ll notice that the timer is set at 00:00. However, when you start the slide show, the timer will start at the correct time and count down by 1-minute intervals until it gets to 1 minute. At that point, it will count down in two 30-seconds intervals to 00:00. To insert this slide into your presentation Save this template as a presentation (.ppt file) on your computer. Open the presentation that will contain the timer. On the Slides tab, place your insertion point after the slide that will precede the timer. (Make sure you don't select a slide. Your insertion point should be between the slides.) On the Insert menu, click Slides from Files. In the Slide Finder dialog box, click the Find Presentation tab. Click Browse, locate and select the timer presentation, and then click Open. In the Slides from Files dialog box, select the timer slide. Select the Keep source formatting check box. If you do not select this check box, the copied slide will inherit the design of the slide that precedes it in the presentation. Click Insert. Click Close.

41 Developing Purpose & Need

42 Importance of P&N P&N is used to:
Communicate and coordinate effectively with stakeholders and the public Evaluate alternatives Justify impacts Establish logical termini/independent utility Manage controversy

43 Importance of P&N A well-written P&N will:
Describe how the project was developed Present a shared understanding of the transportation problems and objectives Assist in defining project scope Guide the development and evaluation of alternatives Avoid developing an ill-conceived project Ensure decisions are legally defensible

44 Basic Structure Project History Purpose Statement Need Elements
Goals and Objectives - optional Summary Logical Termini/Independent Utility

45 CE OnLine

46 CE OnLine

47 Project History Brief discussion of the context for the project
Provide background on existing facility Describe actions taken to date Funding status, schedule, etc. Prior Investigations Traffic Studies Safety Studies Planning Studies

48 Project History Land Use/Visioning or Planning Documents MPO TIP/STIP
Local Comprehensive Plans Local Community Mission Statements

49 Project History Legislative Intent
Federal, State or Local government mandate Consider congressional and/or state directives Congressional Earmarks Conference Report (if one exists) helpful in clarifying intent associated with legislation

50 Project History Legislative Intent
Consider if the following is identified as part of specific legislation: Particular facility design Particular termini Particular mode of travel

51 Purpose Statement Clearly and concisely states primary objectives to be attained A range of potential purposes can exist i.e. Mobility, Safety, Access Articulates the intended positive outcomes An alternative that does not achieve primary purposes would be eliminated 1-2 sentences in length

52 Transportation Needs Quantified data obtained through analyses will determine if a well-defined and well-supported need exists Do not include any reference to solutions Need Elements Defines existing and future conditions Desired conditions Determined by analyses 1-2 well defined needs vs. several poorly supported needs 1-2 paragraphs per need element

53 Transportation Needs Mobility Congestion Facility Deficiencies Safety
System Linkage Modal Inter-relationship Access Emergency Evacuation

54 Transportation Needs Non-Traditional Economic Development/Growth
Environmental Protection National Defense

55 Transportation Needs Mobility Movement of people and goods
Identified and addressed during planning with respect to all modes Transit, rail, aviation, pedestrian and bicycle Ability to meet traffic demands Can be considered a primary need or goal

56 Transportation Needs Mobility Identify source(s) to support
Possible sources might include: MPO Metropolitan Transportation Plan Community Comprehensive Plan State Transportation Plans County and/or municipal visioning documents Land Development Plans

57 Transportation Needs Congestion First step is to define congestion
Determine desired performance level Range of measures can be used: Levels of service (LOS) Volume-to-capacity (V/C) ratios Vehicle hours of delay

58 Transportation Needs Congestion
MPO planning documents (Plans and TIPs) are source, within urban counties Same set of measures may not apply to every project

59 Transportation Needs Congestion
The Travel Demand Model (TDM) is used in the Transportation Planning process and its data can be used to define congestion Provides sufficient data to establish a congestion-related need Includes capacity for a particular transportation facility Estimates the demand for that facility

60 Transportation Needs Congestion
Highway Capacity Manual (HCM) software is another analysis tool

61 Facility Deficiencies
Transportation Needs Facility Deficiencies Poor pavement conditions Poor bridge conditions Substandard geometrics Substantiate need with data “Facility deficiencies” are physical characteristics of a facility that are below the desired performance. Examples include:

62 Facility Deficiencies
Transportation Needs Facility Deficiencies Data can come from various sources: Pavement Management System Bridge Management System Maintenance Management System Roadway Design Manuals and Guidelines Structure Standards – federal, state, local

63 Transportation Needs Safety
Transportation improvements often produce safety benefits Crash data will help support existing and future conditions Often considered purpose of a project, but can be a need as well Completing the project may yield reductions in crash numbers, rates, types and/or severity.

64 Transportation Needs Safety
Only include if data indicates high crash rate and the project will likely address the need

65 Transportation Needs Safety Based on accepted engineering practices
Not relevant without documented crash data Does not increase justification of an undertaking Consider unintended negative consequences

66 Transportation Needs System Linkage Defined as:
Linking two or more existing transportation facilities A new link between two interstates Linking different types of modal facilities Establishing an intermodal facility Linking two or more geographic areas A rail link between Norfolk and Columbus

67 Transportation Needs System Linkage
Linking two or more regional traffic generators and/or geographic areas Mall, regional sports complex, etc. Linking an existing transportation network to a geographic area that currently is not connected

68 Transportation Needs System Linkage Can be a primary need or goal
Rare to have system linkage as a primary need

69 Modal Inter-relationship
Transportation Needs Modal Inter-relationship Appropriate to include intermodal connectivity Define modes to be included Explain in quantifiable terms Define how proposed facility will interface with and serve to complement airports, rail and port facilities, mass transit, etc. An FHWA / FTA project that would provide connectivity between highway users, bikes, pedestrians and transit for example

70 Transportation Needs Access
More than likely a purpose of an undertaking Related to another transportation problem Congestion on nearby facilities Desire to promote economic development

71 Transportation Needs Emergency Evacuation
In Ohio, only applies to nuclear power plant evacuation routes A documented need must exist State or local policy and/or evacuation study Proposed undertaking must be located on a designated evacuation route

72 Economic Development/Growth
Non-Traditional Need Economic Development/Growth New employment, schools, land use plans, etc. Land use changes indicate need to improve or add to highway capacity Some communities have a vision for how they to evolve and prosper A desirable outcome of a transportation undertaking Transportation facilities rarely the sole factor

73 Economic Development/Growth
Non-Traditional Need Economic Development/Growth Transportation infrastructure and other public infrastructure collectively help determine community growth Transportation infrastructure can facilitate the changing of land uses and lead to growth Job creation is not a transportation need Transportation infrastructure, other public infrastructure (e.g. water, sewer, schools) and other considerations (e.g. tax rates, available workforce, available land and/or buildings, real estate values) collectively help determine how and where a community will grow. Provision of transportation infrastructure can facilitate the changing of land uses (e.g. paving an existing dirt road can make the adjacent properties more likely to support greater densities and/or intensities of use) which can lead to community growth/economic development.

74 Economic Development/Growth
Non-Traditional Need Economic Development/Growth Purpose statement should not be written: “ The purpose is to promote growth/economic development” P&N is grounded in transportation: “ The purpose is to provide transportation infrastructure to support community growth/development as identified in [a plan].”

75 Economic Development/Growth
Non-Traditional Need Economic Development/Growth Identify source(s) to support Possible sources include: MPO Metropolitan Transportation Plan Comprehensive Transportation Plan County and/or municipal visioning documents Land Development Plans

76 Economic Development/Growth
Non-Traditional Need Economic Development/Growth Resolutions or other forms of support: Individual Developments Non-governmental Entities Downtown Development Commissions Chambers of Commerce Capital Improvement Programs

77 Economic Development/Growth
Non-Traditional Need Economic Development/Growth Should not be discussed if not substantiated Focusing on existing transportation problems avoids defining a broad purpose that requires consideration of a vast range of non-transportation alternatives for promoting growth/economic development

78 Environmental Protection
Non-Traditional Need Environmental Protection Often incorporate elements that help protect the environment Rarely a transportation need Focus on the underlying reasons for proposing the action based on a transportation need Mitigation projects should reference main project Sometimes the elements can be prescriptive (e.g. compensatory mitigation pursuant to Section 404 of the Clean Water Act). Other times, environmental protection elements can be voluntary.

79 Non-Traditional Need National Defense
Transportation systems considered vital to our national defense/security Critical surface transportation modal systems that transportation professionals should be aware of: Strategic Highway Network (STRAHNET) Railroads for National Defense (RND) Ports for National Defense (PND)

80 Non-Traditional Need National Defense FHWA Perspective:
Identify minimum highway infrastructure needed to fulfill the mission of USDOD Integrate public highway needs into civil policies, plans, and programs Ensure defense readiness of highway infrastructure Establish policy on how DOD uses highway system Pt. there are very specific places for this…proper context

81 Non-Traditional Need National Defense
For inclusion as a primary need, there must be an identified need from a military perspective If project is located on STRAHNET (network), but underlying needs are defined by local community, this element could be a goal

82

83 Goals & Objectives Optional and discretionary - come from planning
Community perspective rather than a transportation perspective Consistent with and follows local plan Aids in the development of context sensitive solutions

84 Goals & Objectives Secondary elements/other desirable outcomes
Is not a core purpose of the undertaking Goals are not a basis for eliminating alternatives in the screening stage May be a factor in the selection of a preferred alternative

85 Goals & Objectives Context Sensitive Solutions Complete Streets
Connection to bike/pedestrian facilities Integrating transit stops, shelters, lanes Burying utilities underground Sidewalks/medians to improve safety

86 Summary Restate Purpose Statement
Briefly summarize Needs discussed above

87 Logical Termini Transportation problem begins and ends
Federal Actions shall not be segmented Does not preclude phasing of construction under a single NEPA action State/Municipal boundaries are not end points

88 Independent Utility Establishes independent significance
May be implied by logical termini May need to be specifically addressed Distinct from project construction phasing Demonstrates that the project is not dependent on any other action

89 Length Recommendations
Level of detail needed can vary Quantified discussion for CE’s should be brief 1 or 2 paragraphs per need element 1-2 pages of text overall An EA/EIS typically involves complex environmental and engineering decisions that may require a more detailed quantified discussion 3-5 pages of text When length recommendations are exceeded, contact OES to initiate consultation with FHWA

90 Points to Remember Must provide tangible, quantifiable data to support the need Comprehensive, specific, and concise Include appropriate maps, illustrations, photos, charts, graphs, spreadsheets, etc., in appendices Re-examine and update P&N as appropriate throughout project development

91 Points to Remember Eliminate “FLUFF” Avoid subjective words
“Just the Facts” Opinions do not count Avoid subjective words May, Maybe, Likely, Could Avoid words with legal interpretations Significant, Segment, and Hazardous

92 Points to Remember Define existing transportation problem(s)
Identify and quantify needs to the level that independent utility can be established Establish logical termini Adequately evaluates, eliminates or advances alternatives

93 Time For Lunch!

94 Case Study

95 Putting it All Together
You will be assigned the task of writing a real life P&N based on handouts You will be given a set of facts and mapping for a transportation problem After completion you will exchange with your neighbor for peer review Class discussion of results

96 Putting it All Together
Format: Project History Purpose Statement Need Elements Goals & Objectives Summary Logical Termini & Independent Utility

97

98 Save this template as a presentation (.ppt file) on your computer.
Using this PowerPoint break timer This PowerPoint slide uses images, custom animation, and timing to provide a countdown timer that you can use in any presentation. When you open the template, you’ll notice that the timer is set at 00:00. However, when you start the slide show, the timer will start at the correct time and count down by 1-minute intervals until it gets to 1 minute. At that point, it will count down in two 30-seconds intervals to 00:00. To insert this slide into your presentation Save this template as a presentation (.ppt file) on your computer. Open the presentation that will contain the timer. On the Slides tab, place your insertion point after the slide that will precede the timer. (Make sure you don't select a slide. Your insertion point should be between the slides.) On the Insert menu, click Slides from Files. In the Slide Finder dialog box, click the Find Presentation tab. Click Browse, locate and select the timer presentation, and then click Open. In the Slides from Files dialog box, select the timer slide. Select the Keep source formatting check box. If you do not select this check box, the copied slide will inherit the design of the slide that precedes it in the presentation. Click Insert. Click Close.

99 Group Discussion

100 Wise You Are

101 Course Summary NEPA’s purpose is to document better decision-making, not better documents Quantified discussion in CE’s should be brief 1 or 2 paragraphs per need element Overall, 1-2 pages of text Quantified discussion in EA/EIS more detailed 3-5 pages of text When length recommendations exceeded, contact ODOT-OES

102 Course Summary Provide a clear, concise and well justified P&N Statement The P&N is a legally defensible document The P&N serves as the foundation for evaluating alternatives, but DOES NOT include a discussion of solutions Does not restrict consideration of other alternatives

103 Consultants should always contact ODOT District Environmental Staff
ODOT Contacts Major New Projects Larry Hoffman - Districts 3, 4, 8, 12 Carmen Stemen - Districts 1, 2, 5, 6, 7, 9, 10, 11 Non Major New Projects Kevin Davis - Policy Supervisor Amber Hewitt - Districts 3, 4, 6, 7, 9, 11 Doug App - Districts 1, 2, 5, 8, 10, 12 Consultants should always contact ODOT District Environmental Staff

104 Questions

105 Test Open Book You have one hour A passing score of 75% is required

106 Thank You!


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