tips to prevent or reduce negative observations€¦ · unable to locate approved copy of hot-spot...

TIPS TO PREVENT OR REDUCE NEGATIVE OBSERVATIONS

Table of Contents

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9-14

15-19

20-24

25-29

4-8Introduction

Missing or incorrect documentation

Conflict in file documentation/information

ECOS tasks/ activities not completed

EPIC/Coordination not recorded or tracked

Deviation from guidance/ procedural steps

Work done incorrectly

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30-34

35-39

Table of Contents

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45-46

40-44Summary

Q & A

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9

Introduction

Daniel Webster

4

Introduction

AQ – Air Quality

CMP – Congestion Management

Process

CO – Carbon Monoxide

DB – database

ECC – Environmental Coordinators

Conference

ECOS – Environmental Compliance

Oversight System

EPIC - Environmental Permits, Issues

and Commitments

5

Acronyms

HE – Human Environment

ITS – Intelligent Transportation

System

MSAT – Mobile Source Air Toxics

PRT – Project Review Team

Q&A – Questions & Answers

TAQA – Traffic Air Quality Analysis

WPD Tab – Work Plan Development

Tab

Introduction

Goals of this Presentation

Discuss the internal review process

Identify the common Human Environment (HE) related observations

Discuss each type of finding in detail

Identify actions to prevent observations

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Introduction

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Projects are environmentally cleared

PRT reviews project files, inputs observations in DB in groups

HE specialist assigned to review a group of HE observations

HE specialist will determine validity of finding and whether action is

required.

HE specialist will contact Delegate and recommend action

HE specialist will comment on observations in review DB

Delegate action required

No d

ele

ga

te a

ction

requ

ire

d

Internal Review Process

Introduction

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Delegate will not likely be contacted for observations with a low rating.

Delegate will likely have some minor updates to the project file for medium ratings,

usually creating a journal entry and maybe uploading add’l backup documentation

A high rating does not necessarily lead to pulling clearance or conducting a re-

evaluation but certainly could. These would usually be associated to a compliance

requirement not being appropriately addressed for a project.

No Action required to correct

project record.

Minor action required to correct

project record or documentation

required to explain missing or

incorrect information.

Low Medium

Rating Observations

Major action required to correct

project record, potentially

including:

• pulling clearance, or

• conducting re-evaluation.

High

Introduction

Typical HE Observations

1. Missing or incorrect documentation

2. Conflict in file documentation/information

3. ECOS tasks/ activities not completed

4. EPIC/Coordination not recorded or tracked

5. Deviation from guidance/ procedural steps

6. Work done incorrectly

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Missing or incorrect documentation

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Missing or incorrect documentation

Description

This observation is used for project files which are missing information to

support project conclusions, or that do not correctly document information

such that it is not clear where to find applicable supporting information.

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Missing or incorrect documentation

Air Quality Examples

Unable to locate approved copy of Hot-Spot Analysis Decision form

Unable to locate MSAT meeting minutes

Unable to locate finding statement for CO TAQA, MSAT, CMP.

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Missing or Incorrect Documentation

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Noise Examples

Appears project is a Type I project; however unable to locate evidence noise

analysis was performed.

Unable to locate .dat and .idx files.

Unable to locate documentation for Prepare and Send Information to Local

Officials.

See Documentation

Requirements in the traffic

noise handbook and Texas

ECOS User’s Guide for Traffic

Noise Analysis

Missing or incorrect documentation

Community Impacts Example

Project Definition screen of Work Plan Development Tool says “No

Permanent Community Impacts”

– Intended for projects that clearly will have no community impacts

• Seal Coats

• Overlays

• Signals

• ITS

• Most bridge replacements

– Not intended for

• Open-ended D-list CEs

• Median Projects

• Bike/ped improvements

• Projects involving displacements of any kind

• Changing two-way to one-way frontage roads

• Completion of gaps in frontage roads/extension projects

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Missing or Incorrect Documentation

Community Impacts Example

Community Impacts Tech Report states that public involvement

opportunities were, or will be, advertised in a language(s) other

than English, but no documentation is uploaded.

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Missing or incorrect documentation

Prevention

Setup a process to make sure that appropriate documentation is uploaded

into ECOS for any ECOS form created during scoping.

Setup a process to make sure that all transportation elements are either

covered by a negative declaration statement or an analysis.

Be sure to upload all relevant documentation

Make sure your commitments are met

Make sure you understand the work plan development tool questions and

how they connect to other tools in the toolkits

Future process improvements

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Conflict in file documentation/information

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Conflict in file documentation/information

Description

This observation is used when there

is a contradiction in the project file.

This could be a contradiction

between ECOS fields, between ECOS

fields and uploaded documents, or

between multiple uploaded

documents.

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Conflict in file documentation/information

Induced Growth Examples

Work Plan Development Tool says no Induced Growth analysis is warranted,

but project purpose and need or goals state that the project will improve

mobility.

Work Plan Development Tool says an Induced Growth analysis will be

completed, but other documentation states that no induced growth will

occur.

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Conflict in file documentation/information

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AQ Examples

Contradiction in the project file on whether project is exempt from conformity

between WPD screen, project definition, or conformity report form.

Contradiction in the project file on whether project is adding capacity

between the WPD screen, project definition screen, and uploaded technical

reports.

Conflict in file documentation/information

Prevention

Setup a quality control check of data entered during the scoping process.

Verify statements in uploaded documents is consistent with ECOS data fields.

Always explain your decisions

Document all project changes, and check whether they affect previous

determinations

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ECOS tasks/ activities not completed

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ECOS tasks/ activities not completed

Description

This observation is used for project

files which have open or missing ECOS

tasks or forms/activities.

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ECOS tasks/ activities not completed

General Examples

No ECOS tasks relating to required work

– Very common

– Work may have been completed correctly, but not documented correctly

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ECOS tasks/ activities not completed

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Noise Example

Finding: Unable to locate ECOS Form - Noise Assessment.

– Occasional finding

– Form had been broken and was not recommended for usage. Form now is functional.

Texas ECOS User’s Guide for Traffic Noise Analysis

• In the scoping process, if the Work Plan Development Tool determines the need for a noise analysis,

then the Noise Assessment form is recommended for usage.

ECOS tasks/ activities not completed

Prevention

Be sure to enter tasks in ECOS

Be sure to close tasks that are input in ECOS

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EPIC/Coordination not recorded or tracked

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EPIC/ Coordination not recorded or tracked

Description

This observation is used for project files which are missing the applicable ECOS

tracking of a coordination or EPIC. This does not necessarily mean that the

applicable action was not performed.

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EPIC/ Coordination not recorded or tracked

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AQ Example

Unable to locate ECOS Coordination for conformity, hot-spot, or TCEQ MOU

coordination.

EPIC/ Coordination not recorded or tracked

Prevention

Follow the procedures in the ECOS AQ Procedures to determine which

coordinations should be present for air quality documents and forms.

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Deviation from guidance/ procedural steps

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Deviation from guidance/ procedural steps

Description

This observation is used for project files which did not follow applicable

program guidance and procedures to get to the conclusions. This does not

mean that conclusions reached were incorrect, just that they did not do so

through following existing step-by-step procedures.

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Deviation from guidance/ procedural steps

Noise Example

Finding: Unable to locate evidence of a noise analysis

According to Traffic Noise Handbook 10.1:

Document a noise analysis utilizing Traffic Noise Templates:

http://ftp.dot.state.tx.us/pub/txdot-info/env/toolkit/730-01-ds.pdf

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Deviation from guidance/ procedural steps

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AQ Examples

Uploaded documents not identified as “Final” or “Approved”

Unable to locate ECOS form/review for documents uploaded into ECOS

Deviation from guidance/ procedural steps

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Prevention

Make sure that any uploaded documents with a title or watermark of “Draft” also

have a another version uploaded with a title of “Final” or “Approved”.

Use the ECOS AQ Instructions to identify which ECOS forms should be associated to

each uploaded document. If there is no ECOS form for the document to be uploaded,

there probably should be.

Use the ECOS AQ Instructions to identify which reviews should be created for each

uploaded document.

According to the ECOS Noise Instructions, when a noise analysis occurs, a Noise

Assessment Form should be created and the documentation should be loaded to

ECOS. Typically, the Noise Document section is preferred for all noise related

documentation

Work done incorrectly

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Work done incorrectly

Description

This observation is used for project

files where it appears that some

aspect of the work performed for the

environmental clearance was done

incorrectly.

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Work done incorrectly

No examples to date

Keep up the good work!

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Summary

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Summary

Internal review observations are being filtered through the subject

matter experts before being sent to the Delegates.

There are good practices that can be established as preventative

measures.

So far HE review observations have all been rated low to medium.

Actions for medium rated observations would tend to be little more

than journal entries.

Actions for major observations could include unclearing a project, or

performing a re-evaluation.

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Q&A

Any Questions?

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