developing a good purpose and need...developing a good purpose and need example of a “need”...

DEVELOPING A GOOD PURPOSE AND NEEDPatrick Lee

TxDOT Environmental Affairs Division

Developing a Good Purpose and Need

“Efforts and courage are not enough

without purpose and direction.” JFK

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TxDOT ENV Guidance

“Preparing a Purpose and Need Statement”

TxDOT.gov

Inside TxDOT

Divisions

Environmental Affairs

Environmental Compliance Toolkits

NEPA and Project Development

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Why is a Purpose and Need Statement Important?

Provides basis for development and evaluation of

project alternatives

Each alternative must be analyzed in terms of the

extent to which it will or will not satisfy the purpose and

need

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Where does the Purpose and Need Statement go?

Has its own heading within EA or EIS

Near the beginning of the document, before discussion

of alternatives

In TxDOT’s EA Outline, the Purpose and Need

Statement is Section 3.0

Generally no longer than one or two paragraphs (more

on that later)

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Three parts to a Purpose and Need Statement

1. Need (single sentence)

2. Supporting Facts and/or Data

3. Purpose (single sentence)

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Part 1 – The “need” sentence

Identifies the transportation-related problems or

unsatisfactory conditions the project is needed to

address

Can be a single transportation-related problem or

unsatisfactory condition – no need to bolster with

further justifications

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Example of a “need” sentence

“The project is needed because FM 1234 between the intersections with Elm St. and Maple St. is:

(a) inadequate to meet current and future traffic volumes, resulting in congestion, reduced mobility, and a Level of Service of ‘F’ on this stretch of highway; and

(b) does not meet current design standards as the travel lanes are too narrow and there are no shoulders.”

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Part 2 – Supporting Facts and/or Data

The “need” sentence cannot be conclusory – must be

supported by facts or data

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Examples of types of supporting facts and/or data

Safety

–Describe the crash history, relating the history to

similar roadways, as appropriate

– Identify design or operational issues leading to safety

problems, such as vehicles have to make

unprotected left turns

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Congestion and/or mobility

–Discuss the capacity of the existing facility and its

ability to meet current and future traffic volumes

–Provide historical, present, and protected traffic

volumes and levels of service

–Describe any trends in land use and population

leading to congestion

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Failure to meet current design standards

–Explain how the existing roadway does not meet

current design standards, such as load limit,

geometrics, or lack of turning lanes

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System connectivity

–Explain how the existing transportation system within

the project area interfaces and connects with other

facilities, and identify any connectivity problems

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Do I need to do a separate

“Purpose and Need Technical Report?”

In most cases, no -- the entire purpose and need

statement can be included in the body of the EA or EIS

However, in rare cases where there is a substantial

amount of supporting facts and/or data that needs

technical explanation, it may be appropriate to do a

separate Purpose and Need Technical Report

Talk to your ENV core team member before doing this

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Part 3 – The “purpose” sentence

Again, just a single sentence

The “need” sentence describes a problem, the

“purpose” sentence states the intention to solve that

problem

Must be 100% consistent with the “need” sentence

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Example of a “purpose” sentence:

Need:

–“This project is needed because the capacity of FM 1234 between the intersection with Elm St. and Maple St. is inadequate to meet current and future traffic volumes, resulting in congestion and reduced mobility on this stretch of highway.”

Purpose

–“The purpose of the project is to reduce congestion and improve mobility on FM 1234 between the intersections with Elm St. and Maple St.”

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Bad “purpose” sentences

Do not identify or describe the preferred alternative, or

be so narrowly written as to unreasonably limit the

consideration of alternatives to address the need, or

leave construction of the preferred alternative as the

only alternative that could possibly fulfill the purpose.

“The purpose of the project is to widen the two-lane

road to four lanes to relieve congestion.” – No!

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Bad “purpose” sentences

Likewise, the purpose sentence must not be overly

broad, such that it invites the consideration of a near

infinite number of alternatives.

“The purpose of the project is to improve traffic

mobility in Austin.” – No!

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More tips

In writing the “need” statement, limit it to problems or

unsatisfactory conditions for which a solution is truly

needed – the more concise and focused the need

statement, the easier it will be to later compare and

evaluate alternatives

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More tips

Do not include non-transportation-related issues or

outcomes and goals that are merely desirable, but not

essential

For example, do not include “minimization of

environmental impacts,” as this is not a transportation-

related problem or unsatisfactory condition. We can

still take into consideration without it being a project

“need.”

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More tips

Do not break the purpose and need statement into

“primary,” “secondary,” and “tertiary” needs and

purposes – too complicated

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More tips

Do not rely exclusively on planning or programming

documents, like the STIP, to justify the project.

It’s not sufficient to just say, “this project is called-for

by the STIP,” as this does not convey the true,

underlying need and purpose of the project

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More tips

Do not discuss alternatives in the purpose and need

statement

Alternatives are discussed and evaluated in the

Alternatives Section of the EA or EIS (Section 4.0 in

ENV’s EA outline)

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[email protected]

(512) 416-2358

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