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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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
Part 2 – Supporting Facts and/or Data
The “need” sentence cannot be conclusory – must be
supported by facts or data
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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
Examples of types of supporting facts and/or data
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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Developing a Good Purpose and Need
Examples of types of supporting facts and/or data
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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Developing a Good Purpose and Need
Examples of types of supporting facts and/or data
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
More tips
Do not break the purpose and need statement into
“primary,” “secondary,” and “tertiary” needs and
purposes – too complicated
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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
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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Developing a Good Purpose and Need
Patrick.Lee@txdot.gov
(512) 416-2358
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