Navigating Multi-Agency NEPA Processes to Advance Multimodal Transportation Projects (2016)

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A-1 A P P E N D I X A Summary Project Description The Dulles Corridor Metrorail Project is a 23-mile extension of the Washington, D.C., metropolitan area’s heavy rail system from East Falls Church in Fairfax County, VA, to Washington Dulles International Airport and Loudoun County, VA. Key U.S. DOT Agencies • Federal Transit Administration (FTA)—Lead • Federal Aviation Administration (FAA)—Cooperating Key State and Local Agencies • Metropolitan Washington Airports Authority (MWAA)— Project Sponsor • Virginia Department of Rail and Public Transportation (DRPT)—Project Sponsor, 2000–2008 • Washington Metropolitan Area Transit Authority (WMATA) • Fairfax County • Loudoun County Challenges Faced The Dulles Corridor Metrorail Project team faced three of the five common challenges related to multi-agency National Environmental Policy Act (NEPA) activities (see Table A-1). Strategies, Tactics, and Lessons Learned • Conduct NEPA activities within the framework of single lead agency’s requirements, while addressing second U.S. DOT agency requirements separately. • Establish a joint project office. • In cases where more than one U.S. DOT agency has a major action, consider having one agency lead preparation of the environmental documentation, with the other agencies adopting it. • Combine NEPA processes and select a single lead agency. • For phased multimodal projects, engage all federal agen- cies in every phase, even if their interests are not directly affected by all phases. • Align the NEPA and New Starts processes. Case Study Detail Introduction The Dulles Corridor Metrorail Project is a 23-mile exten- sion of the existing WMATA Metrorail system. The project will serve Virginia’s two largest employment centers—Tysons Corner and the Reston/Herndon area—and will provide a one-seat ride from Washington Dulles International Air- port (Dulles Airport) to downtown Washington, D.C. The alignment will be primarily at-grade within the medians of the Dulles International Airport Access Highway (DIAAH)/ Dulles Toll Road and the Dulles Greenway. MWAA is managing construction of the new heavy rail line in two phases. The first phase extends 11.7 miles from west of the East Falls Church Station on the Metrorail Orange Line, adding four new stations within Tysons Corner, and termi- nating at the Wiehle Avenue Station in Reston. The second phase completes the remaining 11.5 miles from Wiehle Ave- nue in Fairfax County to the Route 772 station just west of Ashburn in Loudoun County, adding five stations, including one at Dulles Airport (see Figure A-1). The project includes construction of a new rail yard on Dulles Airport property and improvements to an existing rail yard at the West Falls Church Station. Phase 1 opened for revenue service in July 2014, and Phase 2 is slated for completion in 2018. Upon completion of Phase 1, MWAA turned over the segment to Case Study—Dulles Corridor Metrorail Project, Northern Virginia

A-2 Unique agency- specific program requirements under the NEPA umbrella Differing agency interpretations of NEPA requirements Anticipating which agencies will have a major federal action Efficient coordination among agencies Securing funding for multimodal NEPA studies Table A-1. Challenges summary. Figure A-1. Dulles Corridor Metrorail Project map. Source: Dulles Corridor Metrorail Project, Project Overview, March 2012, Version 2

A-3 WMATA to own and operate as part of the existing Metrorail system as the “Silver Line.” Phase 2 will similarly be owned and operated by WMATA upon completion. Lead, Cooperating, and Participating Agencies FTA served as the lead federal agency for NEPA activities. FTA also provided federal funding for NEPA, covering approx- imately 80 percent of the cost. FAA served as a cooperating agency, as construction of the project requires use of the air- port property and FAA’s approval of the change in the Airport Layout Plan, per FAA Order 5050.4b, “NEPA Implementing Instructions for Airport Actions.” The Virginia DRPT was the project sponsor from NEPA ini- tiation in 2000 through 2008, when ownership of the project was transferred to MWAA. The transfer was part of a larger agree- ment between the Commonwealth of Virginia and MWAA, under which MWAA assumed responsibility for operating the Dulles Toll Road and building the Dulles Corridor Metrorail Project, using a portion of the revenues generated by the Dulles Toll Road toward financing construction of the Metrorail proj- ect. After transfer of project ownership, DRPT continued to provide oversight and remained a funding partner. WMATA was a participating agency for the duration of NEPA activities. WMATA served as the technical manager for the NEPA process because the agency is assuming ownership and operation of the line upon construction of each phase. WMATA hired and managed the consultants that supported the NEPA process. WMATA also served as the FTA grantee for most of the NEPA process, until grantee status was trans- ferred to MWAA. The project involved numerous other par- ticipating agencies at the state and local levels, most notably Fairfax County and Loudoun County. Although the coun- ties did not play large roles in preparing or reviewing NEPA documents—other than to confirm that the assumptions (e.g., population and employment forecasts) were consistent with their long-range plans—they did conduct land use planning for Tysons Corner and other station areas, and Fairfax County established benefit assessment districts to help fund the project. The regional Metropolitan Planning Organization, the Trans- portation Planning Board at the Metropolitan Washington Council of Governments, worked closely with the project team during ridership forecasting. Coordination was fostered by a joint project office that housed WMATA staff, WMATA’s consultant, and DRPT. As ownership of the line transferred upon completion of each phase, DRPT shifted its role and responsibilities in the joint project office, including its staff, to MWAA. During most of the NEPA process, the project team coordinated directly with FTA headquarters in nearby Washington, D.C. The Final Environmental Impact Statement (FEIS) was initiated in 2010 and was subject to a new FTA process for NEPA coordination, which required the D.C. metropolitan field office—a subset of FTA Region 3—to take a direct role in day-to-day activities. This new approach added layers to FTA coordination efforts as FTA headquarters was still kept informed and involved in key decisions. The joint project office coordinated with the FTA D.C. metropolitan field office, which coordinated with the FTA Region 3 office, which com- municated with FTA headquarters. Decisions and informa- tion from FTA headquarters then flowed in reverse to the joint project office. Before MWAA assumed the role of project sponsor, the joint project office conducted most FAA coordination through MWAA, as its staff had working relationships with FAA. NEPA Process/Approach Studies for transit alternatives in the Dulles Corridor date back to the planning of Dulles Airport in the 1950s. The origi- nal adopted regional plan for the Metrorail system excluded the Dulles Airport connection because the level of develop- ment in the corridor at the time did not warrant heavy rail service. However, a transit connection to the airport remained a local and regional goal. Formal consideration of alternatives continued in the 1990s, with the Dulles Corridor Transportation Study (1997) and the Supplement to the Dulles Corridor Trans­ portation Study (1999). These studies, which addressed FTA New Start program requirements for an analysis of mode and alignment alternatives, recommended a rail line between the Metrorail Orange Line and Route 772, primarily using the median of the Dulles International Airport Access Highway and leaving the highway to directly serve Tysons Corner and Dulles Airport. The formal NEPA process began with issuance of a Notice of Intent to prepare an Environmental Impact Statement (EIS) in June 2000, followed by scoping meetings in July 2000. Two years later, FTA, DRPT, and WMATA, in cooperation with FAA, published the Dulles Corridor Rapid Transit Proj­ ect Draft Environmental Impact Statement and Section 4(f) Evaluation (DEIS), which considered five alternatives: No Build, BRT, Metrorail, combined BRT/Metrorail, and Phased Implementation (the recommendation that emerged from pre- vious studies). The DEIS identified an extension of the existing Metrorail Orange Line from just east of the West Falls Church Metrorail station to Route 772 as the locally preferred alter- native (LPA). This alternative included 11 new stations and ancillary facilities. Subsequently, FTA recommended that the project be imple- mented in phases due to concerns about FTA’s ability to fund the full LPA—which had an estimated capital cost of $2.9 bil- lion to $3.1 billion in year-of-expenditure dollars—through

A-4 the Section 5309 New Starts program. Prior to undertaking the FEIS, the project team conducted additional environmental review to address phasing. The October 2003 Dulles Corridor Rapid Transit Project Supplemental Draft Environmental Impact Statement and Section 4(f) Evaluation (Supplemental DEIS) identified the Metrorail alternative terminating at Wiehle Avenue with express bus service running to the western end of the Dulles Corridor as the Phase 1 LPA. FTA determined that the Phase 1 LPA had independent utility and would be con- sidered for federal funding as a standalone project. Phase 2 was defined as an extension of heavy rail west from Wiehle Avenue to Dulles Airport and Route 772. The Dulles Corridor Rapid Transit Project Final Environmental Impact Statement and Section 4(f) Evaluation (FEIS), issued in December 2004, evaluated three alternatives: the No Build Alternative, the Wiehle Avenue Extension (Phase 1 LPA), and the full 23-mile LPA. The FEIS confirmed that the Wiehle Avenue Extension would perform similarly to the full LPA and met the criteria for FTA Section 5309 New Starts funding. FTA and FAA issued separate Records of Decision (RODs). FTA issued its ROD in March 2005, signifying completion of the NEPA process for the full LPA and the Phase 1 LPA. FAA issued a ROD for the full LPA in April 2005, then retracted it and issued a second ROD in July 2005 in order to distinguish its federal actions and findings for Phase 1 and Phase 2 of the project. FAA’s ROD signified FAA environmental approval of Phase 1 and generally left many of the findings for Phase 2 open for review at a later time. Most significantly, FAA’s July 2005 ROD specified that a “written re-evaluation of the continued adequacy, accuracy, and validity of the FEIS will be required prior to commencement of Phase II actions . . .” FAA added this clause because Phase 2 of the project was planned for con- struction more than three years after approval of the FEIS and included the portion of the alignment through airport prop- erty. The reissuance of FAA’s ROD did not have a material effect on the NEPA schedule and was ultimately beneficial to the project overall, as distinguishing between the two phases of the project allowed the first phase to proceed more rapidly. Preliminary engineering for the Phase 1 LPA yielded design changes that triggered additional NEPA review. Among the proposed design refinements were a shift in the project align- ment and reconfiguration of the roadway travel lanes within Tysons Corner, alternative station designs, simplified aerial guideway structures and architectural treatments, and a revised connection with the existing Metrorail Orange Line. An Envi- ronmental Assessment (EA) was completed in February 2006 and FTA determined that the design refinements would not result in new significant impacts or significant changes to the impacts evaluated in the FEIS. FTA issued an Amended ROD adopting the preliminary engineering refinements in Novem- ber 2006. The refinements did not trigger FAA action and thus did not require amending the FAA ROD. A New Starts Full Funding Grant Agreement for Phase 1 of the project was signed in March 2009 and construction commenced that month. The project opened in July 2014. Similar to Phase 1, several refinements to the Phase 2 design emerged during preliminary engineering that required addi- tional environmental review. Most significantly, the refined design replaced the tunnel and underground station at Dulles Airport with an elevated guideway and aerial station. Alter- natives considered in the Dulles Corridor Metrorail Project, Phase 2 Preliminary Engineering Design Refinements Environ­ mental Assessment (April 2012) were limited to the full LPA and a refined LPA. The EA did not evaluate a No Action Alter- native, as doing so would override the decision made in FTA’s Amended ROD; this is consistent with FTA policies and regulations in that changes of limited scope do not necessitate reconsideration of the entire project. The Phase 2 EA also responded to the condition in FAA’s 2005 ROD that Phase 2 undergo written re-evaluation prior to construction. FAA remained a cooperating rather than lead agency, but as the EA progressed FAA took a more active role. Prior to the Phase 2 EA, FAA’s role was largely to review and verify that assumptions and findings were consistent with the airport’s long-term plans. In 2012, however, FAA began a nationwide initiative to clarify existing and establish new requirements related to the protection of Runway Protection Zones (RPZ). The RPZ is a two-dimensional trapezoidal area at ground level at either end of a runway to enhance the safety and protection of people and property on the ground. While it is preferred to keep this area clear of all objects, certain uses are permissible; FAA maintains strict guidelines. A portion of the project alignment is located in the median of DIAAH, which runs along the northern edge of the RPZ of Runway 1R/19L. Under the Refined LPA, the alignment would encroach into the RPZ as shown in Figure A-2. While protecting the RPZ was not a new requirement, FAA had issued more stringent guidance in 2012 that clarified per- missible land uses in RPZs and outlined an evaluation process for FAA approval of land uses not expressly permitted. Further, as noted previously, the refined Phase 2 alignment on airport property (including Dulles Airport Station) would be aerial rather than below grade. The Dulles alignment was found to be an incompatible land use for the RPZ per FAA guidelines and was thus subject to the revised requirements and review process. As a result, the Phase 2 EA evaluated three mitigation alternatives that focused on shifting the RPZ south of the Dulles Metrorail track layout to eliminate the conflict. FAA deemed all three mitigation alternatives viable. MWAA is responsible for selection and implementation of the mitigation alternative separate from, but concurrent with, the Phase 2 project and coordinating with FAA to conduct separate environmental review of the preferred mitigation alternative per NEPA and Council on Environmental Quality (CEQ) regulations as well

A-5 as FAA Orders. FTA issued a Finding of No Significant Impact (FONSI) for Phase 2 in December 2012 as an attachment to FTA’s 2006 Amended ROD for the full project. The FONSI sat- isfied the environmental requirements for a loan under the U.S. DOT’s Transportation Infrastructure Finance and Innovation Act (TIFIA) program. Subsequent to the issuance of the Phase 2 EA, FAA inde- pendently evaluated the document for compliance with FAA requirements and later certified its agreement with the find- ings and mitigation strategies in a combined FONSI/ROD that was signed in January 2013, just over one year after the FTA ROD was issued. The January 2013 FONSI/ROD for Phase 2, along with FAA’s July 2005 ROD, is FAA’s approval of the revision of the Airport Layout Plan and Airport Prop- erty Map to depict the Phase 2 design refinements. It also is the determination that the EA prerequisites associated with any future applications for Passenger Facility Charge Program or Airport Improvement Program funding have been fulfilled (the Passenger Facility Charge Program and Airport Improve- ment Program are federal grant programs for planning and development projects for public-use airports that are included in the National Plan of Integrated Airport Systems). FAA’s FONSI/ROD issuance concluded the NEPA process for the Dulles Metrorail Project. As of November 2014, Phase 2 had begun early construction activities, with a scheduled opening in 2018. Agency Requirements Applied to NEPA FTA NEPA requirements are detailed in 23 CFR Part 771, “Environmental Impacts and Related Procedures.” FAA NEPA requirements are outlined in FAA Order 1050.1E, “Environmental Impacts: Policies and Procedures” and FAA Order 5050.4B, “NEPA Implementing Instructions for Airport Actions.” FAA Order 1050.1E sets agency-wide environmen- tal protocol while FAA Order 5050.4B provides instructions for federal actions that support airport development proj- ects. Both agencies’ requirements respond to the statutory requirements of NEPA, the Council on Environmental Qual- ity’s “Regulations for Implementing the Procedural Provi- sions of NEPA” (40 CFR 1500-1508), and U.S. DOT’s Order 5610.C, “Policies for Considering Environmental Impacts.” The two agencies’ NEPA requirements address the same topic areas and were not found to be incompatible during the NEPA process for the Dulles Corridor Metrorail Project. FTA overlaid New Starts program requirements on the NEPA process. Most significant was the recommendation that the project be phased following completion of the DEIS because the full LPA was too costly for a single New Starts full funding grant agreement. FTA’s requirement that New Starts projects meet certain cost-effectiveness thresholds heavily influenced alignment decisions in the Tysons Corner area. FTA allowed the full LPA as well as the Phase 1 LPA to be incorporated into both the DEIS and FEIS, as well as the 2005 ROD, even though only Phase 1 was being advanced for FTA New Starts funding. This allowed engineering on Phase 2 to proceed while the project sponsors addressed funding. Prior to the Phase 2 EA, FTA revised its project management procedures and protocols for day-to-day oversight activities and coordination with the joint project office to make them consistent with other FTA regions. Rather than coordinating directly with FTA headquarters, the joint project office was directed to coordinate with FTA’s Metropolitan Field Office in Washington and its Region 3 office in Philadelphia. FAA largely exercised its statutory authority to adopt another agency’s environmental documentation, per the CEQ and FAA regulations listed above. Over the course of the NEPA process, FAA provided input and direction to FTA and the joint proj- ect office as needed. Its RODs acknowledged responsibility for the scope and content that specifically address FAA actions. One example relates to compliance with RPZ protection under FAA’s Advisory Circular 150/5300-13A, “Airport Design” (Sep- tember 28, 2012) and “Interim Guidance on Land Uses within Source: Dulles Corridor Metrorail Project, Phase 2, PE Design Refinements, Environmental Assessment, April 2012 Figure A-2. Dulles Metrorail alignment in RPZ.

A-6 a Runway Protection Zone” (September 27, 2012). Operating rail lines are considered “places of public assembly,” which are prohibited in an RPZ. Given that the median of DIAAH was deemed the only viable alignment through the airport property, the RPZ, not the project alignment, would have to be shifted in order for the project to proceed. At FAA’s direction, mitigation alternatives were evaluated as part of the Phase 2 EA. In other instances, where compliance with FAA regula- tions could not be addressed within the framework of FTA’s NEPA process, FAA conducted the requisite supplemental evaluation separately. For example, prior to FAA’s approval of the proposed change to the Airport Layout Plan for the Dulles Project, FAA undertook an additional evaluation sep- arate from the analysis conducted for the FTA’s EA. Impact of These Requirements The Dulles Corridor Metrorail project completed a DEIS, Supplemental DEIS, and FEIS for a 23-mile project within four years. The ROD for Phase 1 of the project was received within five years. This relatively rapid progress was partially due to strong political and public support for the high-profile project and regional commitment to advancing the project as expeditiously as possible to receive a New Starts Full Funding Grant Agreement. Overlaying FTA New Starts requirements added to the analy- sis and documentation required for the project, and played a large role in the ultimate phasing and alignment of the proj- ect. FTA’s decision to phase the project, for funding purposes, following the DEIS, led to a need for additional NEPA review of the phased project. To reduce costs and meet FTA’s cost- effectiveness thresholds for New Starts, the alignment through Tysons Corner had to be mostly elevated, rather than below grade as originally proposed. The change in FTA’s project management procedures and protocols for coordinating with the joint project office affected the schedule for the Phase 2 EA. After FTA’s metro politan office was given project oversight responsibilities, FTA became more involved in day-to-day coordination. Rather than following MWAA’s typical approach of coordinating directly with FAA, the FAA’s concerns regarding protection of the RPZ were addressed within the context of the FTA’s EA. FTA also took a lead role in resource agency coordination. For example, up until the Phase 2 EA, the project office conducted Section 106 coordination directly with environmental resource agencies. After FTA’s project management procedures changed, all coor- dination was handled through FTA. This ultimately slowed progress because FTA had limited staff available to devote to this project. In addition, the new protocol resulted in a tiered review structure that delayed the flow of information between FTA headquarters and the joint project office. Even so, the project proceeded relatively smoothly overall. Compliance with FAA’s aviation rules, particularly as related to RPZ protection, had the most substantial impact on the project schedule. FAA’s greater level of input in the Phase 2 EA increased the time it took for the EA document to be issued, and FAA’s subsequent independent evaluation of the EA and FTA’s findings added time to the project schedule. Challenges to Multimodal NEPA Studies Relevant to the Project Unique Agency-Specific Program Requirements Under the NEPA Umbrella: FAA’s nationwide initiative to clarify existing and establish new requirements related to protecting the RPZ added time to the project schedule. The Phase 2 EA contemplated alternatives for shifting the northern boundary of the affected RPZ, although this was an FAA action com- pletely separate from the project scope. The New Starts process resulted in additional work over the course of NEPA, including completion of a Supplemental DEIS for project phasing and incorporation of preliminary New Starts criteria evaluations in the environmental documents. The FTA’s cost-effectiveness criterion and thresholds for New Starts played a large role in the alternatives studied and alignment decisions within Tysons Corner. Differing Agency Interpretations of NEPA Require- ments: One difference related to the role of the NEPA pro- cess in federal agency decision-making. For FTA, the NEPA process is part of the project development process and the project evolves incrementally during NEPA. For FAA, projects are subjected to NEPA review after they are developed. Anticipating Which Agencies Will Have a Major Federal Action: From the start of the NEPA process, it was clear that the project would require the involvement of both FTA and FAA, as the project was envisioned to be an extension of the Washington, D.C., Metrorail system that would use airport right-of-way for a portion of its alignment and be funded partially through the FTA’s New Starts program. Efficient Coordination among Agencies: The Dulles Corridor Metrorail Project had a large group of stakeholders, including two U.S. DOT agencies. Working through the joint project office for coordination with participating agencies helped to expedite the project. The project office included staff familiar with FTA policies and procedures, and MWAA served as a liaison with FAA to help resolve airport-related issues. Securing Funding for Multimodal NEPA Studies: NEPA activities were funded through a combination of federal and state sources, with a federal share of 80 percent and the remain- ing 20 percent contributed by the Commonwealth of Virginia and Fairfax County. Securing this funding was not a challenge.

A-7 Strategies/Tactics Used to Overcome Challenges Having a single agency in a strong lead role helped to address challenges related to agency-specific requirements and differing agency interpretations of NEPA requirements. It was agreed from the start that FTA and FAA were the agen- cies that would have a federal action. FTA served as the lead because the region was seeking FTA funding for the project. The original 1964 Master Plan for the airport included transit access. In the 1985 Master Plan Update, FAA recommended that the median of the DIAAH—a dedicated access road to the airport from Washington, D.C.—continue to be reserved for a future Metrorail extension to the airport. Use of airport property required FAA to approve the modification to the Dulles Airport Layout Plan, which was FAA’s major federal action for the project. Much of the NEPA work was conducted within the frame- work of FTA’s requirements, with FAA providing input as needed. In general, if additional FAA analysis was required, FAA conducted the work separately. FAA ultimately adopted FTA’s environmental documentation, acknowledging in its RODs responsibility for the scope and content that specifi- cally address FAA actions. This approach limited the potential for delays due to differences in agency requirements or inter- ests. Conducting coordination through the joint project office helped keep both FTA and FAA informed over the course of the project. The project team noted that having adequate funding to complete the NEPA process was key. In total, the costs for NEPA activities are estimated to have been more than $30 mil- lion. Much of the work was completed at an 80/20 split between federal and local funding; funding NEPA activities would have been challenging without substantial federal involvement. The local match was provided by the Commonwealth of Virginia and Fairfax County. Lessons Learned Combine NEPA processes and select a single lead agency. FAA adopted FTA’s environmental documentation throughout the NEPA process, ultimately saving time and resources. Federal agency roles shifted some in Phase 2, as FAA undertook a separate evaluation for changes to the Air- port Layout Plan. While this added time to the project sched- ule, overall the project progressed relatively smoothly because FTA served in a clear lead role and FAA focused its review on aviation-related issues. For phased multimodal projects, engage all federal agen- cies in every phase, even if their interests are not directly affected by all phases. The project team noted that it was helpful having FAA at the table for the entire project, even though their role was minimal in the first phase of NEPA. It was more efficient to structure the Dulles project as one NEPA process rather than having to do sequential NEPA pro- cesses because all agencies were not involved from the outset. Align the NEPA and New Starts processes. While the phased approach has ultimately proven successful, FTA didn’t suggest phasing the project until after completion of the DEIS, leading to the need for a Supplemental DEIS. FTA’s evolving policies and criteria for New Starts funding also played a signif- icant role in alignment decisions in Tysons Corner. Alignment options meeting the criteria had to be considered within the NEPA process and documents. Bibliography Federal Aviation Administration. July 2005. “Record of Decision, Dulles Corridor Metrorail Project.” Federal Aviation Administration. January 8, 2013. “Finding of No Sig- nificant Impact/Record of Decision, Dulles Corridor Metrorail Project, Phase 2.” Federal Transit Administration. November 17, 2006. “Amended Record of Decision, Dulles Corridor Metrorail Project.” Federal Transit Administration. December 17, 2012. “Finding of No Significant Impact, Dulles Corridor Metrorail Project, Phase 2 Pre- liminary Engineering Design Refinements.” Federal Transit Administration, Metropolitan Washington Airports Authority, and Washington Metropolitan Area Transit Authority. April 2012. Dulles Corridor Metrorail Project, Phase 2 Preliminary Engineering Design Refinements Environmental Assessment. Federal Transit Administration, Virginia Department of Rail and Pub- lic Transportation, and Washington Area Metropolitan Transit Authority. June 2002. Dulles Corridor Rapid Transit Project Draft Environmental Impact Statement and Section 4(f) Evaluation. Federal Transit Administration, Virginia Department of Rail and Pub- lic Transportation, and Washington Area Metropolitan Transit Authority. October 2003. Dulles Corridor Rapid Transit Project Sup­ plemental Draft Environmental Impact Statement and Section 4(f) Evaluation. Federal Transit Administration, Virginia Department of Rail and Pub- lic Transportation, and Washington Area Metropolitan Transit Authority. December 2004. Dulles Corridor Rapid Transit Project Final Environ mental Impact Statement and Section 4(f) Evaluation.