This guidance details how to write a Project Description for the Kentucky Transportation Cabinet (KYTC) Highway Plan to:

• Provide consistency in Project Descriptions presented in the Highway Plan
• Comply with the National Environmental Policy Act (NEPA) and Code of Federal Regulations (CFR), including that all reasonable alternatives are evaluated prior to the selection of a specific alternative
• Improve quality in the decision making in the development of transportation solutions
• Align solutions with the Cabinet’s strategic goals such as improving safety
• Comply with the The Enacted Highway Plan, or Six Year Plan (SYP), is law – legal issues may arise if a project does not adhere to the wording of the Project Description

The Purpose and Need Statement Guidance for KYTC Projects states

“The Purpose and Need provides the foundation for successful decision-making and the basis for the evaluation and comparison of reasonable alternatives.”

The guidance concludes with

“The Project Description listed in the Cabinet’s Six-Year Plan is not the purpose and need for the project. The project description serves as a placeholder for programming and budgetary planning purposes but should be revised (as needed) once the purpose and need is better defined.”

The court system has found the Project Description to be legally binding and has sided with plaintiffs when the project limits or descriptions have conflicted with the work actually done. Therefore using a purpose statement that describes the goals and objectives of a project without being overly detailed or prescriptive allows for maximum flexibility in the evaluation of alternatives while preventing scope creep.

The Project Description should be

• a full sentence that contains an imperative verb and object (Improve safety, reduce congestion, etc.)
• concise and generally not longer than one sentence

Most Project Descriptions will consist of three basic components: the purpose (described in Section 4.1), the location (described in Section 4.2), and the limits (described in Section 4.3).

KYTC addresses a wide variety of transportation system improvement types and not all project descriptions will fit into the format described above. To the extent possible, Project Descriptions should follow the concepts outlined below.

4.1 Purpose

The Project Description focuses on the purpose (as in Purpose and Need) in developing a project and allows for the development and evaluation of project alternatives. To the extent possible, begin the Project Description with a purpose- type statement to address the transportation-related problems or unsatisfactory conditions as shown in the following examples.

Consider a project with the following need sentence:

This project is needed because the capacity of KY 123 (Oak Ave.) between the intersections with KY 456 (Elm St.) and KY 789 (Maple St.) is inadequate to meet current and future traffic volumes, resulting in congestion and reduced mobility on this stretch of highway.

The following is an example of an appropriate, consistent Project Description:

Reduce congestion and improve mobility on KY 123 (Oak Ave.) between the intersections with KY 456 (Elm St.) and KY 789 (Maple St.).

The Project Description must not identify or describe a preferred alternative; or be so narrowly written as to unreasonably limit the consideration of other alternatives that may address the need.

As an example of what not to write, consider the following sentences:

Widen KY 123 (Oak Ave.) from 2 lanes to 4 lanes between KY 456 (Elm St.) and KY 789 (Maple St.) to relieve congestion. Or Install Turning Lanes on KY 123 (Oak Ave.) between KY 456 (Elm St.) and KY 789 (Maple St.).

In the examples, widening or installing turning lanes are not purposes, but rather alternatives for accomplishing the true purpose of relieving congestion and improving mobility. Other alternatives might include implementing access management, or improving signal timing.

It is important to understand that even when a project has progressed through the NEPA process and a preferred alternative has been selected, retaining a purpose-type Project Description focusing on the project goals and objectives will allow for maximum flexibility throughout the project phases. In contrast, a project description that details a specific alternative in the Highway Plan is still law that must be followed even if a more cost- effective alternative presents itself after another alternative has been selected. An example of this can be seen with projects that have apparent clear-cut solutions such as repairing landslides and replacing bridges. If an adjacent project provides a safer access and eliminates the need for the section of roadway with reoccurring landslides or a deteriorated bridge, a Highway Plan Project Description of “Improve connectivity between A and B” still includes the repair/replace alternative. The same Project Description does not exclude the alternative of completely removing the landslide-prone section of roadway or deteriorated bridge.

The Project Description must also not be overly broad, as it is in the following example of what not to write:

Improve mobility in Lexington.

This sentence is overly broad and invites the consideration of a near infinite number of alternatives. In summary, the Project Description must be neither unreasonably narrow nor unreasonably broad, and the sentence must allow for consideration of multiple alternatives.

FHWA’s technical advisories list nine factors that may be helpful in guiding the Project Description purpose statement for a project. The nine factors are not all-inclusive or applicable in every situation and should only be used as a guide. See regulations (40 CFR §§ 1500-1508) and https://www.environment.fhwa.dot.gov/nepa/trans_decisionmaking.aspx.

• Project Status — The Project Status should be used in the Purpose and Need but does not pertain to the Project Description
• Capacity — The capacity of the present facility and its ability to meet present and projected traffic demands. Possible Project Description purposes: reduce congestion, improve mobility, improve travel time reliability, improve operational
• System Linkage — The project provides a “connecting link” in the transportation system. Possible Project Description purposes: improve system connectivity, complete system linkage, improve mobility.
• Transportation Demand — The project’s relationship to the STIP or an MPO’s TIP is used in the Purpose and Need statement but does not pertain to the Project
• Legislation — The project’s relationship to a Federal, state, or local governmental mandates. Possible Project Description purposes: Improve/complete I-69 system connectivity, complete system linkage on US 460 (Mountain Parkway),
• Social Demands or Economic Development — Projects that foster new employment, benefit schools, complement land use plans, improve access to recreation facilities, etc. Possible Project Description purposes: Enhance economic development, improve safety, and improve access. These Project Description purposes must be backed up with data to support the need. This may be through modeling (for example: TREDIS – http://tredis.com/) or through benefit/cost analyses which support the claim.
• Modal Interrelationships — Projects that interface with and serve to complement airports, rail and port facilities, mass transit services, etc. Possible Project Description purposes: Improve intermodal access, improve freight mobility, improve pedestrian safety, improve transit mobility.
• Safety — Projects necessary to correct an existing or potential safety Improve safety, reduce hazards.
• Roadway Deficiencies — Projects necessary to correct existing roadway deficiencies (e.g., substandard geometrics, load limits on structures, inadequate cross-section, high maintenance costs, ). Possible Project Description purposes: Improve geometrics/ safety/ mobility/travel time reliability.

4.2 Location

For consistency and to the extent possible, identify the project location by providing the route prefix and number followed by the route name in parentheses. For example: KY 123 (Oak Avenue).

4.3 Limits

For consistency and to the extent possible, identify the project limits by providing the route prefix and number followed by the route name in parentheses. For example: “…from KY 456 (Elm Street) to KY 789 (Maple Street).”

Avoid using milepoints within the Project Description. The milepoint limits are already specified within the Highway Plan project information and duplication of information in subsequent modifications as alternatives are developed often result in conflicting milepoint limits between the Project Description and the Highway Plan information.

Although it is preferable to describe project limits from one location to another location, it is not always possible with certain project types such as spot improvements. In these cases, it is acceptable to use milepoint designations with the following language: …from approximately Milepoint 1.2 to Milepoint 2.2. In general, keep the milepoints to 1/10th of a mile and use “approximately” or “in proximity” to include all reasonable alternatives.

For bridge projects, include

• the route prefix and number, and the route name in parentheses of the intersecting route or the name of the river of stream the bridge crosses
• and the Bridge ID in parentheses

  For example:

  Address deficiencies of bridge on KY 123 (Oak Ave.) over Little Rock Run (Bridge ID No. 001B00004N)

  Logical termini concepts must be considered in accordance with 23 CFR 771.111(f)

Ensure the additional principles listed below are followed when preparing a Project Description.

• Limit the Project Description to one simple The more focused and concise the statement, the easier it is to compare and evaluate alternatives.
• Do not include non-transportation-related issues or outcomes and goals that are merely desirable, but not essential. This includes discussion of funding methods, earmarks, local matches, designating who will perform the work, and designating the work phase (i.e. scoping, design, preliminary engineering), or specific references to the bike/ped aspects of the Project-specific information is included in other documents that do not limit evaluation of all reasonable alternatives prior to the selection of a specific alternative.
• Bridges: Include the bridge identification numbers on bridge Do not include the bridge sufficiency rating.
• Do not rely exclusively on planning documents, such as the Statewide Transportation Improvement Program (STIP), to justify the It is not sufficient to merely state that the project is called for by the STIP or the Metropolitan Planning Organization’s (MPO’s) plans, as this does not explain the purpose of the project.
• Do not discuss any alternatives in the Project Description. Project alternatives are discussed and evaluated in other documents such as the Continuous Highway Analysis Framework (CHAF, formerly Project Identification Forms or PIFs), Data Needs Analyses (DNAs) or Design Executive Summaries (DESs).

The following table shows the revision history for this guidance document.