Click here to return to Second Nature
Click here to read the press release
Click here to read the executive summary

In response to directives in TEA-21, the Oregon Department of Transportation (ODOT) has implemented a coordinated review process for highway construction projects. The process, the Collaborative Environmental and Transportation Agreement on Streamlining (CETAS), establishes a working relationship between ODOT and ten state and federal transportation, natural resource, cultural resource, and land-use planning agencies. The agencies include Oregon’s Department of Land Conservation and Development (DLCD), EPA, FHWA, National Marine Fisheries Service (NMFS), Oregon Department of Environmental Quality (ODEQ), Oregon Department of Fish and Wildlife (ODFW), Oregon State Historic Preservation Office, Oregon Division of State Lands (ODSL), Army Corps of Engineers, and U.S. Fish and Wildlife Service (USFWS). ODOT intends to use the CETAS process for all environmental impact statements and environmental assessments that are prepared for projects that impact natural resources.³ The ultimate goal of CETAS, according to ODOT Environmental Services Manager Lori Sundstrom, is to “produce transportation projects that are as environmentally benign as possible.”

CETAS identifies six “pillars” that support efficient project delivery without sacrificing environmental quality:

1. Environmental Management System (EMS). Not yet established within ODOT, EMS is intended to address the life cycle impacts of ODOT’s activities, products, and services on the environment. In addition to ensuring that ODOT meets its environmental stewardship obligations in the most efficient manner possible an EMS would provide ODOT with routine feedback on its environmental performance.

2. Habitat Mitigation Program. This program, initiated by ODOT but open to participation by other state, regional, and local governments, was established to purchase or create wildlife habitat in anticipation of impacts from future transportation projects. ODOT plans to develop its own wetland mitigation bank under the initiative.

3. Natural and Cultural Resource Mapping Program. Once fully implemented, this program will use a geographic information system (GIS) to map sensitive natural and cultural resources. It will also gather data from a variety of agencies and relate it to the state highway system. This will provide comprehensive views of resources in or near planned project areas, and support collective decision making regarding the actions necessary to sustain and improve critical habitat. The goal is to develop future transportation projects in such a way that whenever possible they avoid impacts to critical natural and cultural resources.

4. Expanded Programmatic Approvals. This element seeks to increase the kinds of construction and maintenance activities covered by programmatic agreements or permits and includes joint or parallel programmatic biological opinions from National Marine Fisheries Services/NOAA Fisheries and the U.S. Fish and Wildlife Service, developing regional general permits with the U.S. Army Corps of Engineers as well as maximizing use of Nationwide Permits, and highway-specific General Authorization permit from the Oregon Division of State Lands. ODOT and its CETAS partners are exploring a permitting approach founded on desired environmental outcomes that consider the temporary disruption from construction as well as the on-going impacts of the finished project.

5. Seamless Performance by Local Governments and Contractors. Under this element, ODOT will improve its training of consultants, contractors and the local governments that receive federal funds that pass through ODOT to ensure the quality of their environmental management practices.

6. Expanding CETAS Partnerships. The final pillar involves extending an invitation to federal land managers, such as the U.S. Forest Service and the Bureau of Land Management, and other local, regional, state or federal governments or agencies to join CETAS on either a permanent or ad hoc basis.⁴

Before ODOT established CETAS, the first opportunity for natural and cultural resource agencies to provide input on an ODOT project was during the project development and final design stage. Such a process, common to most states, means that critical input from resource agencies is unavailable at key decision points in the project development and design process. This often leads to conflicts between resource and transportation agencies and to delays during environmental review while resource agency concerns are addressed and the project is potentially redesigned. Worse, by not providing opportunity for involvement early in the design process, transportation agencies may lose the opportunity to avoid environmental impacts, and instead may be forced to undertake costly and less environmentally beneficial mitigation measures.

Under CETAS, resource agencies are involved in the early planning stage of major projects, and that involvement continues throughout project development. ODOT seeks concurrence from the agencies at four key decision points in project development: purpose and need, range of alternatives to be studied, criteria for selection of a preferred alternative, and selection of the preferred alternative. Concurrence does not replace or supplant official agency actions or approvals required by law, but it is intended to represent a good faith indication of each agency’s acceptance of the project at those points in time. CETAS meets monthly to accomplish project reviews and to work on the various improvement initiatives described above. This also serves to keep all parties informed of potential future conflicts. By tapping into the expertise of natural and cultural resource agencies, ODOT is better able to avoid environmental impacts, assess how to minimize those impacts, and receive valuable advice on selecting optimal mitigation strategies. CETAS members believe that because potential environmental or cultural impacts should be kept to a minimum, the environmental review process, while still exhaustive, should be less controversial, less costly, and less time consuming, and therefore proceed more quickly.

To further improve the environmental review process, ODOT is funding several positions at resource agencies. Using federally-reimbursable funds, ODOT is funding one position at the U.S. Fish and Wildlife Service (FWS), two positions at the Oregon Division of State Lands (ODSL), and three positions at the Oregon Fish and Wildlife Department. ODOT has detailed three ODOT biologists to NMFS/NOAA Fisheries to supplement their staff because of a staffing cap at that agency. ODOT is also evaluating the benefits of funding one position at the State Historic Preservation Office (SHPO). These employees work exclusively to evaluate the environmental impact of ODOT projects, and provide technical assistance to ODOT staff, and so are not forced to choose between their regular work obligations and requests for assistance with environment reviews.⁶

While it’s still too early to formally evaluate CETAS’s effectiveness, (ODOT has begun, but not yet completed, a thorough review process), participants in the program are optimistic about its potential to simultaneously expedite project delivery and improve environmental protection.⁷ An early review of the first three major transportation projects to utilize the CETAS process found concurrence on each aspect of the projects for all participating resource agencies.⁸ (See Appendix D for the CETAS memorandum of understanding.)

Endnotes

3. Oregon Dept. of Transportation. CETAS: A Vision for Joint Environmental and Transportation System Stewardship in Oregon.

4. Oregon Dept. of Transportation. CETAS: A Vision for Joint Environmental and Transportation System Stewardship in Oregon.

5. Northwest Environmental Streamlining and Transportation Forum. Meeting Minutes. May 10, 2001.

6. Personal communication. Lori Sundstrom, Environmental Services Manager, ODOT, December 16, 2002.

7. Personal communication. Lori Sundstrom, Environmental Services Manager, ODOT, December 16, 2002.

8. Oregon Dept. of Transportation. CETAS: A Vision for Joint Environmental and Transportation System Stewardship in Oregon.