C. Avoidance & Compensation Interviews, continued

4. Avoidance During Project Planning

When it comes to avoiding habitat fragmentation at the project level, nearly all of the states interviewed relied on a strong working relationship and open communication with resource and regulatory agencies to help them identify potential impacts to habitat resulting from highway projects.

Arkansas State Highway and Transportation Department (AHTD) makes an effort to avoid impacts to habitat during the "cursory review" phase where personnel determine if proposed project corridors may potentially impact listed or sensitive species or habitats based on known occurrences. AHTD relies on comments received from USFWS and other natural resource/regulatory agencies following initial review of the NEPA document with regards to habitat fragmentation and/or connectivity.

For Indiana DOT, the earliest stage at which habitat is considered is during the NEPA process at the step that they refer to as "red flag" step, which occurs after scoping/field visits and before meetings with regulatory agencies. Red Flag issues are put into a commitments database, along with recommendations from regulatory agencies and responses. Habitat fragmentation is not generally considered unless it is specifically received as an official written concern from an agency.

Maryland SHA develops preliminary alternatives using their GI Tool and looks at connectivity in the project area, determining what alternatives would have the biggest impact and highlighting more viable alternatives. If impacts cannot be avoided, then efforts are made towards stewardship. The GI Tool is also used at the project planning level, and can be tailored to individual projects, particularly major capital and high visibility projects. This approach involves intense data collection and analysis of project study area watersheds, and the use of an optimization model for stewardship and/or mitigation opportunities. Maryland SHA also has Concurrence Points in their project development process as well as monthly project review meetings with the resource agencies during which they may express concerns about habitat fragmentation at any time. There are also new MD Department of Environmental Protection (DEP) rules for stormwater management during Environmental Site Design. The rules encourage a move away from ponds and towards more linear designs which will reduce the project footprint and minimize impacts to habitat.

At the project level, NHDOT uses the GRANIT system to help identify natural resources and avoid impacting habitat. Letters are sent out as soon as a project is proposed to agencies and town officials to inquire about the area in which the project may be located to determine if they know of any issues associated with the project area. If a critical issue is identified, a meeting will be held. Natural resource agencies may express concerns about habitat fragmentation at monthly meetings involving the state and federal agencies. When a project comes up, and there are issues regarding natural resources or habitat, it will be presented at these monthly meeting to obtain comments. Meetings may occur several times during the course of design and alignment options may be altered based on comments.

New York State DOT has not had many large projects requiring an alternatives analysis and as a result, have not yet developed a standard procedure to identify potential wildlife habitat fragmentation impacts at this time. However, agencies may express their concerns about habitat fragmentation during the NEPA process or during design phase meetings.

For large-scale planning and projects requiring an Environmental Impact Statement (EIS), Oregon DOT conducts interagency statewide multi-agency forums. Decision points in the process allow for resource agency input. ODOT is also one of the few states interviewed that does include impacts to wildlife resulting from proposed roadway-generated noise in the impact analysis, but only when listed species are involved (e.g., northern spotted owl, bald eagle, etc.).

When it comes to avoiding habitat fragmentation during project planning, TxDOT has found that it is more effective to have all agencies and stakeholders involved as early in the project development process as possible so that they can think about avoidance and compensation in the early stages even if the project design is only 0-20% complete. The issue of fragmentation is discussed during alternatives analysis and is addressed in environmental documents as part of impacts and indirect and cumulative impacts analysis. TxDOT looks for, and expects to see a discussion of fragmentation in these documents. In terms of stormwater management, TxDOT is currently studying things like Permeable Friction Course which is a permeable roadway that allows the roadway to act as a filter. This type of technology can reduce the size of stormwater facilities and associated impacts. TxDOT has always included impacts to wildlife resulting from proposed roadway-generated noise in the impact analysis because they consider impacts at the landscape scale with an eye towards the future.

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