Additional Guidance on Local Initiation of Alternatives Analysis Planning Studies
This memorandum provides enhanced guidance to local transit operators, metropolitan planning organizations, state Departments of Transportation, and other local transportation and public agencies on the procedures for initiating a corridor-level planning study that includes the consideration of fixed guideway transit alternatives (and which may require 49 USC Section 5309 New Starts funding). This memorandum supplements guidance previously issued by the Federal Transit Administration (FTA) on Advancing Major Transit Investments through Planning and Project Development (Version 1.1) by specifying the basic information that local study sponsors should submit to FTA at the outset of their alternatives analysis study. FTA requests this information in order for it to better understand the nature of the corridor problems and the conceptual alternatives the local alternatives analysis study intends to address.
Alternatives analysis has been a key part of FTA’s process for advancing local fixed guideway transit projects for over 25 years. 49 USC 5309(e)(1)(A) requires that projects seeking New Starts funding be based upon the results of an alternatives analysis (and later, preliminary engineering). More importantly, an alternatives analysis has been a part of established transportation planning practice for several decades. At its core, alternatives analysis is about serving local decisionmaking. An effective alternatives analysis answers the questions: What are the problems in a corridor? What are their underlying causes? What are viable options for addressing these problems? What are their costs? What are their benefits?
Alternatives analysis is a locally managed study process that relies to a large extent on the information on regional travel patterns, problems, and needs generated as part of the metropolitan transportation planning process, as specified by 23 CFR Part 450 FTA/Federal Highway Administration (FHWA) Joint Final Rule on Metropolitan and Statewide Planning. Local agencies participating in an alternatives analysis have broad latitude in how the study is to be performed, including the choice of whether to conduct the analysis under the review process established by the National Environmental Policy Act of 1969 (NEPA). For studies initiated under NEPA, FTA plays an early and active role in the alternatives analysis, as specified by 23 CFR 771 FTA/FHWA Joint Final Rule on Environmental Impact and Related Procedures.
FTA strongly desires to play such an early and active role in all alternatives analysis studies, including studies initiated outside the NEPA process. FTA has found that such involvement in local alternatives analysis studies yields the greatest benefits. Specifically, FTA’s early, active involvement in local alternatives analysis studies is intended to:
- Assist local agencies in addressing technical and procedural issues early in the study process, rather than at the end when it may be too late to solve them efficiently;
- Ensure that project information required for FTA’s evaluation is developed consistent with good planning practice and FTA guidance;
- Allow FTA to gain sufficient understanding of the resulting project to support FTA's decision later to advance it into preliminary engineering and, ultimately, final design.
If the alternatives analysis is done outside of NEPA, FTA’s participation is further intended to help ensure that study results, including any elimination of alternatives from further consideration, are adequately supported and will likely "stand up" when NEPA review is initiated.
FTA therefore requests that local agencies that have recently initiated, or intend to initiate, an alternatives analysis that may result in the selection of a transit fixed guideway project proposed for funding under the Section 5309 New Starts program to notify their FTA Regional Office in writing of such studies. Prior to formally initiating the study (or as soon as possible for studies that have already been initiated), FTA requests the opportunity to review the following information:
Description of Study Area, Transportation Problems, and Needs. No two alternatives analyses studies are completely alike, because the analysis must respond to the unique conditions of the corridor under review. Because of its inherent national perspective, FTA cannot fully appreciate the context of any alternatives analysis study absent at least a basic understanding of the local study area and the specific problems and needs to be addressed in the study.
A well-specified statement of the problem for which alternative solutions are being analyzed is a key early step of the corridor planning process. When undertaken as part of the NEPA process, a study "purpose and need" establishes the problems that must be addressed in the analysis; serves as the basis for the development of project goals, objectives, and evaluation measures; and provides a framework for determining which alternatives should be considered as reasonable options in a given corridor. More fundamentally, the statement of purpose and need serves to articulate – and justify - why an agency is proposing to spend potentially large amounts of taxpayer’s money to study and implement a project that may cause significant environmental impacts, and why these impacts are acceptable.
For studies performed outside of NEPA, the same type of information should be generated. Like the purpose and need statement, this information provides the context for performing the analysis and for identifying the measures against which alternatives strategies will be evaluated. It also serves as an introduction for decisionmakers (like FTA, but also local and state agencies), stakeholders, and the general public to the study area and its transportation problems and needs.
Study Goals, Objectives, and Preliminary Evaluation Measures. The establishment of study goals and objectives articulates the desired "end-state" of whatever transportation investment results from the alternatives analysis. It also drives the definition of the evaluation measures to be used in the study. Typically, evaluation measures are selected to assess how well (or poorly) each alternative meets the goals and objectives defined for a transportation improvement in the corridor.
Common categories of goals, objectives, and (therefore) measures include:
- Effectiveness - the extent to which alternatives solve the stated transportation problems in the corridor;
- Impacts - the extent to which the alternatives impact --- positively or negatively - nearby natural resources and neighborhoods, air quality, the adjacent transportation network and facilities, land use, the local economy, etc.;
- Cost effectiveness – the extent to which the costs of the alternatives are commensurate with their benefits;
- Financial feasibility – the extent that funds required to build and operate the alternatives are likely to be available; and
- Equity – that is, the costs and benefits of the alternatives are distributed fairly across different population groups.
FTA notes that the development of at least a preliminary set of evaluation criteria at the beginning of the alternatives analysis helps ensure that the study generates the kinds of information that policymakers need to select a locally preferred alternative, while at the same time limiting the data collection and analysis effort to only that information that will be used to support decisionmaking.
Description of Conceptual Alternatives. The development of alternatives to be considered in the alternatives analysis study closely follows the explanation of the corridor problem and definition of study goals and objectives. Properly developed alternatives help ensure that the study produces the full set of information needed by decisionmakers. Naturally, the alternatives should address the study’s problem statement and goals and objectives. In addition, the alternatives should be structured to isolate the differences among potential solutions to the transportation problem and to highlight the trade-offs inherent in the selection of a preferred alternative.
The development and definition of alternatives is typically an iterative process. The first step in this process is the conceptual definition of a broad range of strategies for improving conditions in the corridor. These conceptual alternatives are ideally produced in system planning and then reviewed at the earliest stages of the alternatives analysis study. For each alternative, the conceptual definition includes the preliminary identification of candidate alignments and operating strategies. Defined operating strategies – as distinct from detailed operating plans developed as planning and project development proceeds – give general ideas of overall bus service levels, service standards, and guideway service options. These definitions are sufficient to address such general concerns as ranges of costs, ridership potential and financial feasibility. More basically, they provide the information necessary for decisionmakers and other stakeholders to confirm that no reasonable alternative (in terms of meeting corridor needs) is being excluded from the analysis, as well as understand the magnitude of the costs and benefits associated with the various options for improving conditions in the corridor.
Subsequent evaluation and screening of these conceptual alternatives will narrow the range of viable alternatives to a manageable number to carry forward into a detailed analysis. This analysis includes the development of more detailed definition of alternatives, including an adequate transportation system management alternative likely to serve as the project’s Baseline Alternative for New Starts reporting purposes.
FTA notes that the information it is requesting is not intended to require any additional work on behalf of the study sponsor, but rather draw upon previous planning studies and the routine preparatory work necessary to initiate any comprehensive multimodal planning analysis. Furthermore, if the information specified in this guidance has not already been disseminated (in whatever format) to local study stakeholders, it is suggested that the information submitted to FTA also be made available to these parties to enhance their understanding of the study and the context within which it is being performed.
There is no specific format for the preparation and submission of this information. FTA anticipates that a memorandum or similar document of no more than 10 to 15 pages would satisfy its information needs.
FTA does not "approve" this submission, but will review it and may provide suggestions intended to enhance the alternatives analysis study, and better prepare the study sponsor for developing the information required to support a later request to advance a locally preferred alternative into preliminary engineering.
This information should be sent to the FTA Regional Administrator for the area being studied. The Regional Administrator will then forward the information to the FTA Office of Planning and Environment, which will review and provide comments. FTA may further initiate a conference call with the study sponsor to discuss the submitted materials and outline "next steps" in the conduct of the alternatives analysis study.