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Planning and Environmental Linkage (PEL)

What is Planning and Environmental Linkage (PEL)?

Planning-Environment Linkage (PEL) is an approach to performing planning studies that allows decisions made in planning to be carried forward into the National Environmental Policy Act (NEPA) process.  Without PEL, these decisions usually need to be revisited in order to be valid in NEPA.  This results in a repetition of efforts which translates into additional project development time and expense.  PEL generally requires that decisions made during planning receive public involvement and resource agency coordination in order to be brought into NEPA. PEL can be used by any planning agency, including state DOTs, MPOs and LPAs.

INDOT proposes to incorporate basic PEL elements into selected INDOT and Local Planning Agency (LPA) planning studies and to incorporate more complex PEL elements into the planning studies on a pilot basis, consistent with 23 CFR 168.   INDOT has created a PEL Committee to screen PEL planning studies for appropriateness as PEL pilots; it consists of one expert each from INDOT’s planning, environmental, and corridor planning divisions.  The MPOs and LPAs are encouraged to incorporate PEL elements into their own planning studies.  PEL may provide local transportation planners with analytical tools and funding options that are not otherwise available.

When is it appropriate to use PEL?

It is appropriate to use PEL when…

  • A need has been identified and planning funds have been dedicated towards further refinement of the need and range of possible alternative solutions but where no construction funding has been identified or committed.
  • There will be a longer path to develop a stable purpose and need, and
  • The potential project is large in scale with large or complex potential impacts, and a long lead time may be needed for public acceptance.

Please follow this link to INDOT’s Pilot Implementation of Planning Environmental Linkage document:

Pilot PEL Implementation

INDOT’s Approach to PEL

Within all planning studies, the location description and deficiency analysis should identify the NEPA concepts of logical termini, independent utility, purpose and need, and no build alternative.  Red flag investigations (RFIs) should identify known features in the human and natural environment that may be impacted and may also identify likely points of controversy or environmental obstacles. The RFI follows all current guidelines as they would for an RFI in a NEPA document.  Those guidelines can be found in the INDOT Site Assessment and Management (SAM) Manual. These elements provide the groundwork for NEPA documents for the proposed capital program projects that result from the planning study. Incorporating the NEPA elements will mainly require statements in the text of the planning document, and the red flag investigation will use existing information and existing INDOT guidance.

The Federal Highway Administration (FHWA) will not certify these elements for inclusion in NEPA because they have not received public involvement and resource agency coordination, but the elements would be formulated and ready for such coordination when NEPA is initiated. Information from the RFI would be available to inform analysis of possible remedies for identified deficiencies.

INDOT’s  Application of PEL components into planning level studies revolves around two planning study levels.

Level 1 planning studies will incorporate:

  • Location description and deficiency analysis,
  • Logical termini,
  • Independent utility,
  • Purpose and need,
  • Public involvement and,
  • Resource Agency coordination

Level 2 planning studies will take the next step to also incorporate:

  • Alternative development and screening while carrying the no-build alternative forward.

By implementing this PEL approach to the development of corridor planning level studies, FHWA can be asked at the end of the process to certify that level one and two elements are consistent with PEL and can be carried forward into NEPA.

For additional information regarding the PEL, please follow these links:

The PEL questionnaire is available at:
https://www.environment.fhwa.dot.gov/env_initiatives/pel/pel_quest.aspx

The Federal Highway Administration Environmental Review Toolkit Planning and Environment Linkages link: https://www.environment.fhwa.dot.gov/env_initiatives/PEL.aspx

The INDOT Planning and Environmental Linkage Contacts

Brandon Miller
NEPA Team Leader
INDOT Enviromental Services
Bramiller1@indot.in.gov

Jay Mitchell
Technical Planning Supervisor
INDOT Technical Planning and Programming
Jaymitchell@indot.in.gov

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