FHWA Audits Utah DOT National Environmental Policy Act Compliance

Utah highway by Getty Images

Consistent communication between managers and staff members could benefit the Utah Department of Transportation as it executes National Environmental Policy Act responsibilities, according to a recent federal audit.

The Federal Highway Administration published its first of four audits regarding UDOT’s compliance with environmental review practices in the Federal Register on April 13.

Utah participates in the Surface Transportation Project Delivery Program, which allows a state to assume FHWA’s responsibilities outlined in NEPA. The program requires FHWA to audit the state every year for the first four years of the state’s participation.

---

---

Among UDOT’s responsibilities are the preparation of environmental assessments and environmental impact statements. Although FHWA’s report states that UDOT has successfully added these project review responsibilities, the federal agency found that UDOT could communicate policy matters to staff members more efficiently.

“Most [subject matter experts] and regional environmental staff were not aware of the latest policies and procedures regarding the NEPA Assignment Program,” the audit states. “Some regional staff said they expect to hear about changes from their managers in the regional office, but they often feel they do not receive all necessary information.”

Another observation listed in the audit was inconsistent file management systems. UDOT primarily relies on ProjectWise, a document management software system, to store all of its documents, according to Brandon Weston, environmental services director at UDOT. The system was not created specifically to handle environmental documents, and Weston explained that the agency had no set policy for how to deal with draft documents.

Audit by Transport Topics on Scribd

Carissa Watanabe, environmental performance manager at UDOT, said that the agency has issued file management guidance that creates a “uniformed structure of subfolders” within ProjectWise geared specifically toward environmental assessments and environmental impact statements.

Weston said FHWA’s examination of UDOT’s internal document processing system offered a valuable third-party perspective.

“It don’t think it was a difference of opinion. It was just one organization trying to understand the inner workings of another,” Weston said. “It was good for us because we get that independent look to see if there are ways to improve it. Not having the inside perspective was a good thing because they really helped us understand how somebody that doesn’t know our system as well as we do could better understand it.”

UDOT assumed federal NEPA responsibilities in January 2017. The audit took place June 2017 and involved 18 on-site interviews with UDOT staff over the course of several days. FHWA’s audit team consisted of NEPA experts from Utah, California, the District of Columbia, Georgia and Texas.

Besides an on-site visit, the team of auditors reviewed UDOT’s response to FHWA’s pre-audit information request, its NEPA project files and its self-assessment of its NEPA program.

While Weston agreed with the observations in the audit, he noted that the audit took place while UDOT was in the nascent stages of assuming its federal responsibilities.

“It always takes a long time to get change implemented fully. There was also a concern on UDOT’s side that, because of the newness of the assignment program, we didn’t necessarily have the right people in the room for the audit,” Weston said. “That’s my opinion, but also I agree with FHWA’s observation that it’s important that everyone in our department have an understanding of what the program is and what the responsibilities are.”

The Federal Register notice solicits public comments on the audit report, which must be submitted before May 14.

Weston said he thought the audit was an overall success because it did not list any measures that were left unmet in terms of legal competency. He said UDOT and FHWA likely will start planning the next audit soon.

“[It’s] an opportunity to get outside perspective on how we can improve,” UDOT spokesman John Gleason said. “We’re always looking to take that next step, and if there are suggestions, we’re always open to hearing those.”