Qaqc Plan

April 2019
November 2017
Quality Assurance/Quality Control (QA/QC) Plan
For Federal-aid Highway Projects
ADOT Environmental Planning

Quality Assurance/Quality Control Plan April 2019
TABLE OF CONTENTS
1 INTRODUCTION ............................................................................................................................................ 3
1.1 QUALITY ASSURANCE (QA) ....................................................................................................................................3
1.2 QUALITY CONTROL (QC) .......................................................................................................................................3
2 CE ASSIGNMENT AND NEPA ASSIGNMENT ................................................................................................... 3
2.1 ASSIGNMENT OF FHWA ENVIRONMENTAL REVIEW RESPONSIBILITY ..............................................................................4
2.1.1 CE Assignment - State Assumption of Responsibility for Categorical Exclusions ...................................4
2.1.2 NEPA Assignment - Surface Transportation Project Delivery Program ..................................................4
2.2 INVOLVEMENT WITH FHWA ..................................................................................................................................4
2.3 RESPONSIBILITIES .................................................................................................................................................4
2.4 CE ASSIGNMENT MOU REQUIREMENTS...................................................................................................................5
2.4.1 CE Assignment – Reporting and Annual Self-Assessment ......................................................................5
2.4.2 CE Assignment – FHWA Monitoring.......................................................................................................5
2.5 NEPA ASSIGNMENT MOU REQUIREMENTS ..............................................................................................................7
2.5.1 NEPA Assignment – Self-Assessments....................................................................................................7
2.5.2 NEPA Assignment - Performance Measures ..........................................................................................8
3 QUALITY DOCUMENTS ................................................................................................................................ 11
3.1 TERMINOLOGY ...................................................................................................................................................11
3.1.1 Environmental Document ....................................................................................................................11
3.1.2 NEPA Document(s) ...............................................................................................................................11
3.1.3 Environmental Review Document(s) ....................................................................................................11
3.2 DOCUMENTATION REVIEW ...................................................................................................................................11
3.2.1 Documentation Resources ...................................................................................................................11
3.2.2 Document Readability..........................................................................................................................11
3.3 TYPES OF NEPA DOCUMENTATION........................................................................................................................12
3.3.1 Categorical Exclusions (CE) ..................................................................................................................12
3.3.2 Environmental Assessments ................................................................................................................12
3.3.3 Environmental Impact Statements ......................................................................................................12
3.4 ADMINISTRATIVE RECORD ....................................................................................................................................14
4 DOCUMENTATION REVIEW AND APPROVAL............................................................................................... 15
4.1 QA/QC OF LETTERS ...........................................................................................................................................15
4.2 ENVIRONMENTAL REVIEW DOCUMENTS .................................................................................................................16
4.2.1 Technical Document Review ................................................................................................................16
4.2.2 Review and Approval of CEs .................................................................................................................16
4.2.3 Review and Approval of EAs and EISs ..................................................................................................18
4.3 LEGAL SUFFICIENCY.............................................................................................................................................21
4.3.1 Environmental Document File Preparation Requirements and Considerations ...................................22
4.3.2 Individual Section 4(f) File Preparation Requirements and Considerations .........................................22
4.4 QA/QC RESOURCES ...........................................................................................................................................23
5 SECTION 4(F) DOCUMENTS REVIEW AND APPROVAL .................................................................................. 23
5.1 SECTION 4(F) INVOLVING HISTORIC PROPERTIES.......................................................................................................24
5.1.1 Reviews for exceptions and de minimis impact involving historic properties: .....................................24
5.1.2 Reviews for programmatic and individual Section 4(f) evaluations involving historic properties: ......25
5.2 SECTION 4(F) INVOLVING PARKS, RECREATION AREAS, AND WILDLIFE AND WATERFOWL REFUGES ....................................25
5.2.1 Reviews for exceptions and use with de minimis impact involving parks, recreation areas and wildlife
and waterfowl refuges: ......................................................................................................................................26
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5.2.2 Reviews for programmatic and individual Section 4(f) evaluations involving parks, recreation areas
and wildlife and waterfowl refuges: ..................................................................................................................27
APPENDIX ............................................................................................................................................................ 28
CE QUALITY CONTROL CHECKLIST ..................................................................................................................................29
INDIVIDUAL CE QUALITY CONTROL FORM .......................................................................................................................31
EA QUALITY CONTROL CHECKLIST ..................................................................................................................................32
EA QUALITY CONTROL FORM ........................................................................................................................................34
EIS QUALITY CONTROL CHECKLIST..................................................................................................................................36
EIS QUALITY CONTROL FORM .......................................................................................................................................39
AMENDMENTS TO QAQC PLAN.....................................................................................................................................41
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1 INTRODUCTION
The Arizona Department of Transportation’s (ADOT) vision is to be the standard of excellence for
transportation systems and services. Environmental Planning (ENV – short-hand throughout this
document) is committed to conducting quality environmental reviews and producing the highest quality
environmental documents in compliance with the National Environmental Policy Act (NEPA) and all
related environmental laws affecting transportation project development.
ENV has established this Quality Assurance/Quality Control Plan (QA/QC Plan) to ensure the overall
quality and efficiency of the environmental review process. This QA/QC Plan describes Quality Assurance
and Quality Control procedures and processes, QA/QC review documentation, document review
procedures, quality document production guidance, and the staff responsible for performing activities
and verifying compliance. Templates and tools for successfully implementing this QA/QC Plan are also
included.
ENV project teams will implement this QA/QC Plan during the preparation and review of environmental
documents to meet federal environmental review requirements. This QA/QC Plan is designed to
provide directions to assist project teams in meeting these requirements. Provision of quality products
and quality service are of utmost importance to ADOT and this QA/QC Plan will be used to help develop
quality environmental reviews and documents in delivering ADOT and Local Public Agency (LPA) Federal-
aid Highway Program (FAHP) projects.
1.1 Quality Assurance (QA)

Quality Assurance is a system for ensuring a desired level of quality control in the development,
production, or delivery of products and services. ENV defines QA as preventing problems, process
monitoring, and self-assessment activity on a “program level.” QA is employed at the project level and
the management level to ensure that prudent QC procedures and tools are in place and are being
carried out with the desired quality compliant products provided. Within ENV the Standards and
Training Manager is responsible for overseeing QA. QA includes having the procedures and support
documentation in place to successfully conduct environmental document preparation and review. QA
also includes self-monitoring through self-assessments as required by the CE and NEPA Assignment
MOUs and as described elsewhere in this QA/QC Plan. As part of QA, individual projects and project files
are periodically reviewed to ensure that project-specific quality control measures such as document
checking and technical reviews are being completed. Through this process, QA provides feedback to
those preparing documents and technical studies to ensure continuous improvement.
1.2 Quality Control (QC)

Quality Control is a system for verifying and maintaining a desired level of quality in technical analysis
and documentation through the use of proper checking against standards and verification of products.
ENV defines QC as the day-to-day effort of identifying and correcting deficiencies and errors and the
documentation of those efforts. QC is routinely employed at the production or “project level.”
2 CE ASSIGNMENT AND NEPA ASSIGNMENT
ADOT and the Federal Highway Administration (FHWA) have agreements in place with QA/QC procedure
requirements to help deliver the FAHP. Consequently, this QA/QC Plan will assist ADOT in conforming to
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the stipulations of the FHWA-ADOT Memorandum of Understanding (MOU) for the State Assumption of
Responsibility for Categorical Exclusions under 23 U.S.C 326 (CE Assignment) and the MOU between
FHWA and ADOT for the Surface Transportation Project Delivery Program codified in 23 U.S.C. 327
(NEPA Assignment). This QA/QC Plan ensures that ADOT ENV staff implement the provisions of the
MOUs and outlines ADOT approval authority for Categorical Exclusions (CE) listed under 23 CFR
771.117(c) and (d), individually documented CEs under 23 CFR 771.117(d), Environmental Assessments
(EA)/Finding of No Significant Impact (FONSI), and Environmental Impact Statements (EIS)/Record of
Decision (ROD). A Final EIS is abbreviated as FEIS.
2.1 Assignment of FHWA Environmental Review Responsibility
2.1.1 CE Assignment - State Assumption of Responsibility for Categorical Exclusions

Pursuant to 23 U.S.C. 326, FHWA and ADOT entered into a CE Assignment MOU on January 3, 2018 that
assigned to ADOT FHWA’s environmental review responsibilities for determining whether certain
projects are categorically excluded from the requirement to prepare EAs or EISs. All responsibilities
concerning CE determinations not assigned under the CE Assignment MOU are assigned under the NEPA
Assignment MOU. The CE Assignment MOU is renewable every three years.
2.1.2 NEPA Assignment - Surface Transportation Project Delivery Program

Pursuant to 23 U.S.C. 327, FHWA and ADOT have entered into a NEPA Assignment MOU on April 16,
2019 that assigned FHWA’s environmental review responsibilities to ADOT including the preparation and
approval of EAs and EISs as well as the preparation of CEs not assigned under the CE Assignment MOU.
The NEPA Assignment MOU is renewable every five years.
2.2 Involvement with FHWA

Pursuant to these MOUs, FHWA cannot provide any project-level assistance to ADOT in carrying out any
of the responsibilities assumed under CE Assignment and NEPA Assignment. Project-level assistance is
generally defined as any advice, consultation, or document review associated with a particular highway
project. However, FHWA may provide program-level assistance concerning interpretation of any
applicable law contained in the United States Code, interpretation of any environmental review-related
regulation, interpretation of FHWA policies or formal guidance.
For those projects excluded from NEPA Assignment where FHWA remains the Lead Federal Agency
ADOT will coordinate with FHWA on environmental documentation review and approval.
2.3 Responsibilities
As a consequence of CE Assignment and NEPA Assignment, ADOT is liable for carrying out the USDOT
Secretary's responsibilities it has assumed under Assignment, subject to the limitations of the Eleventh
Amendment waiver of sovereign immunity by ADOT.
In assuming the USDOT Secretary's responsibilities under NEPA Assignment and other agreements,
ADOT is subject to the same procedural and substantive requirements that apply to the USDOT
Secretary in carrying out these responsibilities. Such procedural and substantive requirements include
federal laws, federal regulations, Executive Orders, policy, guidance and interagency agreements such as
programmatic agreements, memoranda of understanding, memoranda of agreement, and other similar
documents that relate to the environmental review process.
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2.4 CE Assignment MOU Requirements

The CE Assignment MOU (326 MOU) established certain requirements related to FHWA oversight and
reporting. Interagency agreements or memoranda may require revision post-assignment.
2.4.1 CE Assignment – Reporting and Annual Self-Assessment

ADOT ENV is committed to continuous improvement; therefore, performance regarding document
quality and delivery is reviewed by supervisors and senior managers.
When monitoring CE quality, ENV will check QC Checklists in the project files for project timeliness and
quality based on comments and number of submittals reviewed. This review process will be conducted
annually by the ENV Standards and Training Manager as part of Quality Assurance requirements of the
326 Assignment MOU. Based on this review, action may be needed to improve QA/QC. Accordingly the
QA/QC Plan will be evaluated and updated and ENV staff will be made aware of the assessment results,
process improvements and any revisions made to this QA/QC Plan.
Notably, certain performance monitoring and quality assurance activities are required by FHWA under
stipulation IV.(F) of the 326 CE MOU. In conformance with these requirements, ADOT performs the
following items:
1. Compile a list of CE determinations and Section 4(f) approvals of use that the state has approved
every 6 months. This is to be completed by the ADOT NEPA Assignment Manager and submitted
to FHWA by the ENV Administrator.
2. Prepare a self-assessment report summarizing ENV performance under the 326 CE MOU. This is
required 30 days prior to a FHWA scheduled monitoring review. This is to be completed by the
ADOT ENV Standards and Training Manager or another delegate at the discretion of the ENV
Administrator.
3. Maintain electronic project records and general administrative records pertaining to the 326 CE
MOU. FHWA may request these project file records which must be provided within five (5)
business days. Project files are to be retained for a minimum of three (3) years from completion
of project construction.
2.4.1.1 CE Assignment Self-Assessment Report Outline

The 326 MOU self-assessment report has the below outline:
1. Background: Legal citations and MOU requirements
2. Purpose: Provide statistical summary of ADOT performance under 326 MOU
3. Statistical Report of CE and 4(f) approvals: Provide report graphics
4. QC Practices and Processes: Discuss application of QA/QC Plan to 326 MOU Requirements
5. Quality Discussion: Discuss Report Data here.
6. Appendices provide copies of internal data reports
2.4.2 CE Assignment – FHWA Monitoring

FHWA will periodically review ADOT’s records and performance under the 326 CE MOU. The CE MOU
provides guidance on performance measures that FHWA will consider when evaluating ADOT’s
performance in the CE Assignment Program. The FHWA-defined quality measures for state performance
are provided below.
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1. CE decisions are appropriately and timely documented.

ADOT will implement the procedures outlined in this QA/QC Plan. These procedures rely on
established ADOT documentation practices developed with FHWA oversight. Such practices are
described in this QA/QC Plan and appendices.
2. CE decisions are factually and legally supportable at the time the decision is made.
ADOT has implemented specific project technical review and decision making practices as
outlined in this QA/QC Plan and its appendices.
3. CE decision-making complies with 23 CFR 771.117 and the CE Assignment MOU processes.
ADOT implements the procedures outlined in this QA/QC Plan to document ENV project related
significant decision points and to note when responsible parties act in accordance with these
procedures. As ADOT gathers experience in implementing MOU requirements, this QA/QC Plan,
and other ADOT guidance and procedures may be improved and refined in accordance with CE
Assignment MOU provisions.
4. The State has met staffing and quality control requirements of the MOU.
ADOT, in the course of expected administrative practice, reviews staff performance, project
workloads, and document quality in accordance with employee Human Resource evaluation
programs and the Governor’s Office of Arizona Management System (AMS) government
streamlining and efficiency programs. Such routine review of staff performance and staffing
levels are conducted to ensure ADOT meets the requirements of the CE Assignment MOU.
5. The State has complied with other Federal and State legal requirements.
ADOT, during the course of project delivery, reviews projects for applicability with other federal
and state programs. Clean Water Act and the Clean Air Act are examples of legal programs ADOT
routinely assesses for applicability and impact analysis during the NEPA process. Such
assessment is documented according to procedures outlined in this QA/QC Plan.
6. The State has complied with record keeping requirements.
ADOT will implement the procedures outlined in this QA/QC Plan. Conformance with project
record keeping requirements will be part of the annual self-assessment.
2.4.2.1 FHWA Monitoring Review Coordination

The NEPA Assignment Manager, working in cooperation with the FHWA Arizona Division, is responsible
for the arranging access to necessary information and for ensuring employees are available for FHWA
interviews or answering questions. FHWA monitoring coordination requires meeting the following
responsibilities:
1. Establish a general schedule in coordination with the FHWA Arizona Division
2. Facilitate monitoring review communication with ENV management, technical teams, and
other ADOT operational staff and management
3. Plan for the monitoring review including coordination of file transfers for remote electronic
reviews
4. Coordinate the audit visit with FHWA and secure meeting rooms
5. Ensure the availability of personnel during the audit visit
6. Facilitate the monitoring report review of the draft report and acceptance of the final report
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2.5 NEPA Assignment MOU Requirements

The NEPA Assignment MOU (327 MOU) established certain requirements related to FHWA oversight and
reporting.
2.5.1 NEPA Assignment – Self-Assessments

FHWA will periodically review ADOT’s records and performance under the 327 MOU in conformance
with stipulation 8.2. Please refer to the 327 MOU for more specific detail regarding FHWA procedures.
The following are specific record keeping requirements worth emphasizing from the 327 MOU.
MOU 8.2.5 ADOT shall perform annual self-assessments of its QA/QC process and performance
to determine if its process is working as intended. If any process areas are identified as needing
improvement, ADOT will take appropriate and timely corrective actions to address such areas.
At least one month prior to the date of a scheduled FHWA audit, ADOT will transmit a summary
of its most recent self-assessment to FHWA Arizona Division Office. The summary will include a
description of the scope of the self-assessment conducted and the areas reviewed, a description
of the process followed in conducting the self-assessment, a list of the areas identified as
needing improvement, any corrective actions that have been or will be implemented and a
statement from ADOT’s ENV Administrator concerning whether the processes are ensuring that
the responsibilities ADOT has assumed under this MOU are being carried out in accordance with
this MOU and all applicable Federal laws and policies, and a summary of ADOT's progress
toward attaining the performance measures listed in Part 10 of this MOU.
MOU 8.2.6 Upon the Effective Date of this MOU, ADOT will maintain a list of approved
individually documented CEs, EAs, EISs and Section 4(f) determinations.
2.5.1.1 NEPA Assignment Self-Assessment Report Outline

The 327 MOU self-assessment report has the general outline below that may be modified based on
individual reporting needs:
1. Executive Summary
2. Results of Self-Assessment
3. Program Consistency
4. Observations
5. General Improvement Opportunities
6. Performance Measures
7. Self-Assessment Scope
8. Previous Self-Assessment Resolution or Follow-up
2.5.1.2 FHWA Audit Coordination

The NEPA Assignment Manager, working in cooperation with the FHWA Arizona Division, is responsible
for arranging access to necessary information and for ensuring employees are available for FHWA
interviews or answering questions. FHWA audit coordination requires ADOT meeting the following
responsibilities:
1. Establish a general audit schedule within 180 days of the effective date or the anniversary
date of the MOU
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2. Facilitate audit planning communication with ENV management, technical teams, and other
ADOT operational staff and management
3. Plan for the audit, including review of FHWA pre-audit questions, and coordination and
scheduling of remote electronic reviews
4. Coordinate the audit visit with FHWA
5. Ensure the availability of files and personnel during the audit visit
6. Review the draft audit report and coordinate with FHWA for the final audit report posting in
the Federal Register
2.5.2 NEPA Assignment - Performance Measures

To evaluate the success of assignment under the 327 MOU, ADOT established a set of performance
measures against which ADOT is evaluated in administering the assigned environmental review
responsibilities. ADOT collects and maintains the necessary and appropriate data related to meeting the
performance measures and monitors progress toward meeting the performance measures. ADOT
reports the results to the FHWA annually. The performance measures contained in the 327 MOU are
outlined below. The bold italicized text and the numbering format match the 327 MOU.
A. Compliance with NEPA, FHWA NEPA regulations, and other Federal environmental statutes
and regulations:
i. Maintain documented compliance with procedures and processes set forth in

this MOU for the environmental responsibilities assumed under the Program.
 Percent of approved environmental documents that have all supporting

technical documentation in the project file supporting analysis for NEPA.
[This is a percentage obtained by number of projects with signed NEPA

determinations (CE/FONSI/ROD) and with supporting technical reports for
Section 4(f), Section 7, Section 106, Clean Air Act, 23 CFR 772 - Noise regulations,
as applicable, divided by the total number of projects approved.]
ii. Maintain documented compliance with requirements of all applicable

Federal statutes and regulations for which responsibility is assumed (e.g.,
Section 106 of the NHPA, Section 7 of the ESA, etc.).
 Percent of approved environmental documents that have approvals for other

applicable laws in the project file supporting decisions for NEPA.
[This is a percentage obtained by number of projects with signed NEPA

determinations (CE/FONSI/ROD) and with supporting approvals for Section 4(f),
Section 7, Section 106, Clean Air Act and 23 CFR 772 - Noise regulations, as
applicable, divided by the total number of projects approved.]
B. QA/QC for NEPA decisions:
i. Maintain and apply internal quality control and assurance measures and
processes, including a record of:
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a.Legal sufficiency determinations made by counsel; this shall include

the legal sufficiency reviews of Notices of Intent and Notices of Final
Agency Action as required by law, policy, or guidance;
 Percent of Federal Register notices reviewed for legal sufficiency prior to

publication
[This is a percentage obtained by total number of Notices of Intent and Notices

of Final Agency Action reviewed for legal sufficiency prior to publication divided
by the total number of notices needing review.]
 Percent of FEIS or FEIS/ROD and individual Section 4(f) evaluations reviewed for
legal sufficiency prior to document approval
[This is a percentage obtained by total number of FEIS, FEIS/ROD and individual

Section 4(f) evaluations reviewed for legal sufficiency prior to approval divided
by the total number of FEIS or FEIS/ROD and individual Section 4(f)
determinations.]
b. Compliance with FHWA's and ADOT's environmental document

content standards and procedures, including those related to QA/QC;
and,
 Percent of individually documented CE’s with a CE Quality Control Checklist and

the draft environmental documents with a completed EA/EIS Quality Control
Checklist in the project file
[Percentage is obtained by total number of projects with documented quality

control checklists in the project file divided by total number of projects with
approved individually documented CEs and draft environmental documents.]
c. Completeness and adequacy of documentation of project records for

projects done under the Program
 Percent of approved final environmental documents with completed CE/EA/EIS

Quality Control Form in the project file
[Percentage is obtained by total number of projects with documented quality

control forms in the project file divided by total number of projects with
approved individually documented CEs and final environmental documents.]
C. Relationships with agencies and the general public:
i. Maintain communication among ADOT, Federal and State resource

agencies, and the public from effective date of assumption of
responsibilities under this MOU.
 Agency and public communication
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[This is a percentage measuring notification. Percentage is obtained by number

of CE/EA/EIS projects with documented agency and public scoping letters sent by
the project divided by the number of projects with letters required to be sent for
the project during the scoping phase.]
ii. Maintain effective responsiveness to substantive comments received from

the public, agencies, and interest groups on NEPA documents and
environmental concerns.
 Rating how well ADOT responds to substantive comments of the public for
publically reviewed EA/EIS projects
[This rating is based upon a number of EA/EIS projects that have summary
reports including complete comment responses in the project file, following the
making of documents available for public comment, divided by the total number
EA/EIS projects with public reivews during the period.]
iii. Maintain effective NEPA conflict resolution processes whenever

appropriate.
 Rating how well NEPA conflict resolution process on CE/EA/EIS projects works
by not needing to formally escalate an issue involving an outside agency [23
U.S.C. 139(h)(6)]
[This rating is based upon the number of CE/EA/EIS projects not needing formal
escalation divided by the total number of ongoing CE/EA/EIS project]
D. Increased efficiency and timeliness in completion of NEPA process:
i. Compare time of completion of environmental document approvals before

and after assumption of responsibilities under this MOU.
 Time of completion of EAs
[Compare actual project EA delivery production time to historical average before

327 MOU Assignment. Percentage is obtained per project by total number of
months to complete EA approvals after NEPA assignment divided by the average
total number of months to complete EA approvals before NEPA assignment.]
ii. Report actual time to completion for key interagency consultations (e.g.
Section 7 biological opinions, Section 106 resolution of adverse effects)
 Actual time to complete key interagency consultations
[Section 7 Biological Opinions (Section 7 initiation letter to Biological Opinion) and

Section 106 resolution of adverse effects (Determination of adverse effect to
agreement on resolution)].
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3 QUALITY DOCUMENTS
3.1 Terminology
3.1.1 Environmental Document

Environmental document is defined in CEQ regulations 40 CFR 1508.10: “Environmental
document includes the documents specified in §1508.9 (environmental assessment), §1508.11
(environmental impact statement), §1508.13 (finding of no significant impact), and §1508.22 (notice of
intent).” 23 CFR 771 defines environmental document as “EAs and EISs” and CEs as a “designation.”
3.1.2 NEPA Document(s)

Historically in 23 CFR 771 “NEPA documents” referred to EAs and EISs. Though historically referring to
EAs and EISs, for convenience and ease of use by staff, ADOT defines “NEPA document” or “NEPA
documentation” to mean: listed CE, individually documented CE, EA/FONSI and EIS/ROD.
3.1.3 Environmental Review Document(s)

23 CFR 771 includes the term “environmental review document” which is used synonymously with
“environmental document.” ADOT defines environmental review document(s) to mean any documents
prepared as part of the environmental review process including technical reports, NEPA documentation
and Section 4(f) evaluations.
3.2 Documentation Review

As the Lead Federal Agency under CE and NEPA Assignment, ADOT is responsible for coordination,
review and approval of environmental review documents. CEs are prepared for the vast majority of
projects. EAs and EISs are completed less frequently and have comprehensive procedures that must be
followed. The procedures outlined in this section of the QA/QC Plan ensure consistent review of
environmental review documents. The detailed guidance in how to prepare environmental review
documents resides elsewhere in specific environmental technical analysis and environmental document
preparation guidelines.
3.2.1 Documentation Resources

There are a multitude of resources on the ADOT Environmental Planning website to support
environmental review documents including the; Categorical Exclusions (CE) Manual, EA/EIS Guidance,
Section 4(f) Manual, etc. as well as guidance in the various technical areas.
3.2.2 Document Readability

Documents prepared or approved by ENV can be made available to the public (exceptions include
documents with confidential cultural resources information). All documents should be written clearly
and concisely with accurate information. Documents should be written in plain English. Technical
documents may contain highly technical terms and wording, for example, the biology document will
identify scientific names of plant and animal species. Environmental documents should contain
summary and conclusions from technical reports. Acronyms should be spelled out with the first use.
Documents should be written using correct grammar, content, and spelling. Consultant and internally
written documents are reviewed for quality and consistency.
The environmental document preparer should strive to follow the requirements of CEQ 40 CFR 1501.7
and §1502.7 regarding excessive paperwork and page limits. CEQ “40 Questions” recommends the
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length of EAs be limited to 10 to 15 pages. The “EA may incorporate by reference background data to
support its concise discussion of the proposal and relevant issues.” ADOT EAs may exceed these limits
but environmental documents should include only enough information from the technical reports to
provide a basis for how a decision was made. CE Checklists are also prepared with CEQ goals in mind
with technical information and consultations prepared separately and residing in the project file.
Environmental documents should be written clearly, concisely and based on facts, not opinion. In short,
the environmental documents should 1) tell the story, 2) keep it brief, and 3) comply with the
regulations.
Document review and approval procedures are outlined under Chapter 4 - Documentation Review and
Approval.
3.3 Types of NEPA Documentation
3.3.1 Categorical Exclusions (CE)

A CE is an action that, based on FHWA’s past experience, normally does not involve significant
environmental impact and therefore does not require the preparation of an EA or EIS. CEs are
documented and approved using the CE Checklist which was developed in conformance with 23 CFR.
771. The detailed guidance for preparing CE Checklists is outlined in ADOT ENV’s Categorical Exclusions
(CE) Manual. The “listed CEs” are prepared and approved by ADOT under the CE Assignment MOU.
Individually documented and approved CEs are approved by ADOT under the NEPA Assignment MOU.
Approval of the CE Checklist by the ENV Administrator documents completion of NEPA requirements for
a federal action. NEPA approval is needed for federal actions (FHWA authorizations) that include federal
funding for design, right-of-way and construction as well as administrative approvals such as a Change in
Access of the Interstate and approval of design exceptions on the National Highway System.
3.3.2 Environmental Assessments

An EA may be prepared for an action that does not appear to involve significant impacts but does not
qualify for a CE. EAs are normally prepared with the expectation that the project will qualify for a FONSI
after the appropriate environmental analysis and public review and comment. The guidance for
preparing an EA is outlined in the ADOT EA/EIS Guidance. EAs are not required to follow the Efficient
Environmental Review process (23 U.S.C. 139); however, agency and public scoping are conducted for
ADOT EAs.
The public review period for an EA is 30 days unless the EA incorporates an individual Section 4(f)
evaluation in which case the Department of Interior (DOI) is given 45 days for review of the document.
The draft EA must be available for public review for 30 days and made available 15 days before a public
hearing. The Environmental Planner, Project Manager and ADOT Communications Public Information
Officer must plan for a public hearing in conformance with the ADOT Public Involvement Plan (PIP).
There should be an understanding of the date the EA will be ready for public review and project team
agreement on a public hearing date before one is committed to. No Federal Register notice is required
for an EA though coordination with Communications is required to provide a public notice.
3.3.3 Environmental Impact Statements

An EIS is prepared for an action that has known significant impacts on the environment. The guidance
for preparing an EIS is outlined in the ADOT EA/EIS Guidance. An EIS is required to follow the Efficient
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Environmental Review process outlined in 23 U.S.C. 139. Though initiated in sequence there are many
steps in the process that will overlap and be conducted in parallel with other steps in the process.
General procedures are depicted as follows but are flexible in order to meet the needs of a particular
project and to implement Executive Order 13807 – One Federal Decision as needed.
EIS Process Flow
Conduct Impact Prepare and

Initiate Project
Analysis Review Draft EIS
Efficient Range of Public Review of

Environmental Alternatives the DEIS
review Process Concurrence
Cooperating and Develop and Notice of

Participating screen Alternatives Availability in the
Agencies Identified Federal Register
Establish Develop Purpose Public Hearing and

Coordination Plan and Need Address
and schedule Comments
Develop Public Conduct Project Prepare FEIS/ROD

Involvement Plan Scoping and Publish
Issue Notice of Initiate Surveys File Limitation of

Intent and Technical Claims Notice
Studies
The general steps are depicted above are a precursor to the document review steps outlined in this
QA/QC Plan. Project development and environmental review documents steps are defined elsewhere.
Similarly, the steps outlined below are to ensure that they happen and do not outline the full
procedures (SOP).
3.3.3.1 USDOT Permitting Dashboard

The Permitting Dashboard is an online tool for Federal agencies, project developers, and interested
members of the public to track the Federal government’s environmental review and authorization
processes for large or complex infrastructure projects, part of a government-wide effort to improve
coordination, transparency, and accountability.
A major function of this Dashboard is to track infrastructure projects designated as Covered Projects
under Title 41 of the Fixing America’s Surface Transportation Act (FAST-41). The Dashboard also
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provides information on certain projects subject to Titles I, IX, and XI of the FAST Act (DOT projects), as
well as other infrastructure projects. The Dashboard projects are those covered under 42 U.S.C. 4370m–
1(c)(1)(A). ADOT is responsible for updating projects on the Dashboard as required of FHWA.
3.3.3.2 Prior Concurrence

Prior concurrence reviews are put in place for FHWA Headquarters reviews of FHWA Division decisions
for projects that are highly controversial or involve issues of national policy or program significance.
With ADOT ENV’s centralized structure this exact model cannot be emulated because EISs are not
approved at a “District level” which would be equivalent to an FHWA “Division level” if ADOT decision
making was decentralized. Regardless, concurrent reviews could possibly be required on occasion that
mirror 23 CFR 771.125(c). ADOT Multimodal Planning Division Director has been selected to conduct any
prior concurrence reviews. MPD would review the Draft EIS concurrently with the NEPA Assignment
Manager and legal pre-review. MPD would also review the FEIS concurrently with the NEPA Assignment
Manager and Legal Sufficiency Review. See FHWA’s Guidance on FHWA Prior Concurrence Procedures for
EISs for more information.
3.3.3.3 EIS Submittal to U.S. EPA

Following the Council on Environmental Quality's NEPA regulations at 40 CFR 1506.9, ADOT is required
to submit all EISs, together with comments and responses, to the U.S. Environmental Protection Agency
(EPA) in California – Region 9. The EPA will prepare a Notice of Availability for publication in the Federal
Register. All submissions to EPA must be made electronically via U.S. EPA's "e-NEPA system." ADOT has
designated staff with access to the e-NEPA system for document submittals. In addition to the e-NEPA
submission, the Environmental Planner will coordinate with the EPA Region 9 Office to determine the
number of hard copies to submit.
3.3.3.4 Federal Register Notices

ADOT does not have the authority to submit documents directly to the Federal Register such as the
Notice of Intent under 23 CFR 771.123(a) and Notice of Final Agency Action under 23 USC 139(l). ADOT
must transmit these documents to FHWA's Arizona Division Office, and the FHWA will then submit these
to the Federal Register on behalf of ADOT. FHWA is required to submit these documents to the Federal
Register in a timely manner upon receipt from ADOT.
For an EIS ADOT must transmit the Draft, Final, or Supplemental EIS to the EPA. EPA will then prepare
the Notice of Availability for publication in the Federal Register.
3.3.3.5 Limitations on Claims

Under 23 CFR 771.139 ADOT can issue a limitation on claims notice in the Federal Register that reduces
the statute of limitations for challenging a federal agency decision for a project from 6 years to 150 days.
ADOT will make use of the 150 day statute of limitations for those projects as deemed necessary by the
Environmental Planning Adminstrator. The NEPA Assignment Manager is responsible for coordinating
the placement of the notice in the Federal Register with the FHWA Arizona Division.
3.4 Administrative Record

40 CFR 1505.1 requires that decisions be made in accordance with the policies and purposes of NEPA
and to demonstrate decisions were not arbitrary and capricious. For all projects the project folder in the
ENV-Drive will serve as the repository of documentation that would be used to create an administrative
14
record if needed. When a legal challenge is filed, ENV will verify (with the advice of legal counsel) that
decisional documents from the Project File be made part of an administrative record. The Environmental
Planner and Technical Specialists are responsible for maintaining the project files that would support an
administrative record.
For an EIS, an Administrative Record organizational framework is created at the start of the project. For
an EA the Environmental Planner should consider creating an Administrative Record organizational
framework at the start of the project. The regular project file may contain drafts and final documents,
various communications, public outreach materials, etc. The Administrative Record generally will
contain project final documents, and those documents memorializing process and decision related
records.
The Administrative Record will be needed if the State is sued for a project environmental decision. The
Administrative Record is what the Court will use in deciding any lawsuits filed. The Arizona Attorney
General’s Office (AGO) may request additional documentation that was not included. Some projects can
take many years to complete and staff may change on the project over time. This is why it is important
to document decisions throughout the project development process.
Creation of the administrative record should be discussed early in the process when beginning the scope
of the work for an EIS and when discussing scope of the consultant tasks. For additional guidance see
the AASHTO Practitioner’s Handbook 01 “Maintaining a Project File and Preparing an Administrative
Record for a NEPA Study” and the FHWA online Toolkit. Though a consultant may set up and maintain an
administrative record the Environmental Planner is the responsible person for the Administrative
Record.
4 DOCUMENTATION REVIEW AND APPROVAL
4.1 QA/QC of Letters

All agency letters for projects that fall under the CE and NEPA Assignment MOUs are reviewed for
quality, substance and suitability. Contact information should be verified before letters are sent.
The following letters should be reviewed as follows:
• Cooperating and Participating agency letters are reviewed by a Senior Planner.
o The Wetland Biologist also reviews letter sent to the Corps. The Biologist reviews
cooperating agency letters sent to the USFWS. Other technical areas review letters to
other agencies as needed.
• Section 106 consultation letters are reviewed by the HPT Team Lead or Cultural Resources
Program Manager
• Section 7 consultation letters are reviewed by the Biology Team Lead or Biology Program
Manager
If an Environmental Planner or technical specialist prepares scoping or agency letters a peer review by
another Planner or supervisor is required. The Environmental Planner or technical specialist performs
this review if letters are prepared by an environmental consultant. Contact lists should be verified by the
consultant. For projects excluded from NEPA Assignment (per the 327 MOU), the FHWA letter format
and protocols for review and approval shall be followed.
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4.2 Environmental Review Documents

Document review and approval procedures are described below.
4.2.1 Technical Document Review

All project technical documents submitted by consultants or local agencies are to be reviewed by the
assigned Technical Specialists. Prior to final approval, all biology documents prepared by ADOT biology
staff will be reviewed by another ENV Staff member. Reviews should verify all project information is
correct and the scope of work is consistent with all NEPA documents.
After the first submittal of a technical report there should be a meeting or phone conversation between
the Technical Specialist and the consultant to discuss any unresolved comments or questions on the
technical reports. No more than two report review submittals are expected. If the Technical Specialist
needs assistance from their supervisor, they may request their supervisor also review the document.
If consultants have submitted technical documents to the Technical Specialists directly, the
Environmental Planner should be notified of the submittal by the Technical Specialist and be included in
comment responses and resolution.
4.2.2 Review and Approval of CEs

Environmental Planner is responsible for overseeing the completion of CE Checklists for all projects. CEs
are developed in accordance with the requirements outlined in ADOT ENV’s Categorical Exclusions (CE)
Manual. ADOT CE and ADOT CE Checklist are synonymous since the approval is included with the
Checklist.
CE Review Process
1. ENV Planner 6. Comment

verifies the project 7. QC Review
Resolution
information
2. Agency and
5. Technical Teams
public scoping (as 8. CE Approved
review CE
needed)
9. CE Validated by
3. Technical studies 4. ENV Planner ENV Planner at
and consultations prepares CE Authorization (as
needed)
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4.2.2.1 CE Review and Approval Process

The following steps are conducted for CE review and approval:
1. Environmental Planner verifies the project scope of work/project description/limits and
confirms programming data as applicable
2. Environmental Planner conducts environmental scoping with agencies and public (as outlined in
CE Scoping Guidelines)
o Scoping letters sent by email
o Additional public scoping (as needed)
3. Technical Teams conduct technical studies and consultations as required
o Technical determinations, and any project specific mitigation measures, are provided to
the Environmental Planner for documenting in the CE
4. Environmental Planner prepares the CE
5. Technical Teams review CE
o Technical specialists review any relevant technical area documented in a CE as well as

project information and any mitigation measures to ensure consistency with technical
documents and consultation.
o Environmental Planner sends a copy of any individually documented CE prepared under

23 CFR 771.117(d) to the ADOT Civil Rights Office concurrently with the Technical
Specialists review
6. Comment resolution (as needed).
o Environmental Planner ensures that technical comments are addressed and ensures
copies of any substantive technical review comments are placed in the Project File
7. Environmental Planner provides the CE to a Senior Planner/peer reviewer for a QC review. The
reviewer completes the CE Quality Control Checklist and provides a copy with any comments on
the CE to the Environmental Planner. A copy of the checklist is placed in the project file.
o A QC Quality Control Checklist is not required for a (c)(1) CE.
o The Environmental Planner prepares the final CE for signature and sends to the
approver.
o Environmental Planner prepares a CE Quality Control Form for any individually

documented CE prepared under 23 CFR 771.117(d). The NEPA Assignment Manager
certifies that the CE is ready for approval. This form is only for CEs completed under the
NEPA Assignment MOU.
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8. ENV Administrator or delegate (NEPA Assignment Manager, Project Delivery Manager or

Environmental Programs Manager) approves the CE.
o The CE Approver verifies the CE determination (type of CE selected) made by the

preparer of the CE is appropriate for the described action
9. The Environmental Planner validates the CE at the time of the request for federal authorization.
There should be no additional review required at this stage of the process. The following
statement is contained in the validation letter:
o “ADOT certifies that NEPA requirements consistent with the scope of work of the
project have been met and the project incorporates all environmental commitments per
23 CFR 771.109(d).”
 Note; a CE re-evaluation, which may need time for additional technical

evaluation, must be identified, discussed with the project team and approved
prior to this final step of validating a CE at the time of the request for FHWA
authorization.
4.2.3 Review and Approval of EAs and EISs

The assigned Environmental Planner is responsible for overseeing the completion of EAs and EISs. EAs
and EISs are developed in accordance with the requirements outlined in the ADOT ENV’s EA/EIS
Guidance and other environmental technical guidance.
Note: “EA/EIS Quality Control Checklist” referenced in this section of the Plan indicates either the “EA
Quality Control Checklist” or the “EIS Quality Control Checklist” as appropriate. The “EA/EIS Quality
Control Form” referenced in this section of the Plan indicates either the “EA Quality Control Form” or
the “EIS Quality Control Form” as appropriate.
Draft EA/EIS Review Process
1. 1st draft 7. Draft environmental

environmental 6. Cooperating Agency
document for signature
document with QC review as applicable
prepared
certification submitted
8. Manager confirms
2. Project Team reviews 5. Draft environmental
environmental
1st draft environmental document reviewed by
document is ready for
document Manager and Legal
signature
3. Planner Completes QC 9. Draft environmental

4. Comment Resolution
Checklist document Approved
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4.2.3.1 Review and Approval of Draft EA and Draft EIS

1. The initial draft environmental document is submitted by the consultant to the Environmental
Planner (or the ADOT Project Manager if so arranged)
a. Environmental Planner ensures that the preceding technical reports that support project
decisions are completed
b. Environmental Planner documents in the EA/EIS Quality Control Form that the
consultant has included a QC statement in the submittal of the draft environmental
document including the names of reviewers
i. Working drafts of documents or sections of documents may be reviewed prior

to receiving the 1st draft environmental document with the consultant’s QC
certification
2. Environmental Planner (or Project Manager) distributes the initial draft environmental
document to the appropriate members of the project team including the Project Manager
(Environmental Planner), ADOT Civil Rights Office, Communications, District and the Technical
Specialists for their concurrent review.
a. The Environmental Planner includes a review due date in the distribution email. Review
timeframes are specified in the Environmental Planning Review Timeframe Guidelines in
the ADOT ENV Project Development Procedures
b. Depending on project complexity the Environmental Planner may also provide a copy of
the first submittal document to their supervisor or to a peer for a concurrent review
(not mandatory)
c. Only one submittal for review and comment by the project team is expected. Complex
projects may require an additional draft(s) or sections of the draft for review and
comment before the NEPA Assignment Manager/legal pre-review.
3. QC Review
a. The Environmental Planner completes the EA/EIS Quality Control Checklist
b. The Environmental Planner documents in the EA/EIS Quality Control Form that the
Technical Specialists and any other reviews as needed have been completed
4. Comment Resolution completed
a. A comment resolution meeting is held to ensure critical comments in need of formal

discussion and resolution will be adequately addressed. This resolution can also take
place by email confirmation if there are no major issues that need discussion.
b. The revised draft submittal goes back to the Technical Specialist or others if the
comments were highly technical within the specific discipline, difficult in nature, or if
requested by the reviewer
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5. Draft environmental document is sent to the NEPA Assignment Manager and the AGO for legal
pre-review
a. A legal pre-review for an EA is optional. A legal pre-review for a draft EIS is required by
ADOT (not a federal regulatory requirement)
b. A second project team review may be necessary depending on the quality of the first
submittal and the successful resolution of all first review comments
c. Comment Resolution for NEPA Assignment Manager and legal comments completed
6. Cooperating Agency review (as needed or agreed upon in a Coordination Plan if applicable)
7. Draft environmental document ready for approval
a. Environmental Planner ensures the NEPA Assignment Manager, legal pre-review and
Cooperating Agency (if applicable) comments are addressed
8. The NEPA Assignment Manager documents the EA/EIS Quality Control Form acknowledging
that the QC review, technical reviews, and legal pre-reviews (if required) have been conducted
and that the draft document is ready for approval by the ENV Administrator
9. Approval of the draft environmental document for Public Review
a. The NEPA Assignment Manager or the Project Delivery Manager can approve a draft EA
in the absence of the ENV Administrator. The approver must be different than the one
who signs the EA/EIS Quality Control Form
b. The State Engineer’s Office approves a Draft EIS in the absence of the ENV Administrator
4.2.3.2 Review and Approval of Final EA/FONSI and Final EIS/ROD

The Environmental Planner is responsible for overseeing the review and approval of final EAs and final
EIS/RODs.
1. In cooperation with ADOT Communications and the Project Manager ensure that all public and
agency comments and responses to substantive comments are accounted for and addressed
a. The approach strategy to respond to the comments should be agreed-upon by the

project team. This strategy would include responding to all comments vs. grouping
comments with generalized responses.
b. Comment resolution is conducted, in cooperation with agencies as needed, for any

outstanding comments or issues
2. The Environmental Planner and project team review the draft final environmental document
and resolve any additional comments as needed
3. Environmental Planner provides the draft final environmental document to the NEPA
Assignment Manager and the AGO for QC and legal sufficiency review (required for an EIS)
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a. A legal sufficiency review may be conducted for an EA but there is no federal legal
sufficiency requirement. The final EA must be sent for legal sufficiency review if it
contains a Section 4(f) evaluation that does not utilize one of the programmatic
evaluations or is a de minimis impact.
4. The NEPA Assignment Manager’s review comments and any legal sufficiency review comments
are sent to the consultant for incorporation into the final environmental document
5. The Environmental Planner ensures the NEPA Assignment Manager and legal sufficiency review
comments are addressed
a. A revised draft final environmental document is sent to the AGO (if necessary).
Individual sections or pages reflecting comment resolution may be sent in lieu of the full
document if acceptable to the AGO.
b. A statement of legal sufficiency from the AGO for an EIS, or an individual Section 4(f)
determination if included with an EA, must be included in the project file
c. Legal sufficiency review procedures are outlined in Section 4.3
6. The NEPA Assignment Manager completes the EA/EIS Quality Control Form acknowledging that
the QC and a legal sufficiency reviews have been conducted and that the document is ready for
approval
7. The ENV Administrator approves the Final EA/FONSI or FEIS/ROD*
a. The NEPA Assignment Manager or the Project Delivery Manager can approve an
EA/FONSI in the absence of the ENV Administrator. The approver must be different than
the one who signs the EA/EIS Quality Control Form
b. State Engineer’s Office approves a FEIS/ROD in the absence of the ENV Administrator
c. *A separate FEIS and ROD would both follow Steps 3 through 5 concurrently as separate
documents
4.3 Legal Sufficiency

The legal sufficiency review of an environmental document is an important element in ADOT’s overall
project development process. The following procedures instruct ENV staff in the preparation of project
files for a legal sufficiency review of a FEIS or a final Section 4(f) evaluation prior to signature approval by
the responsible authority. In other words, all relevant project and environmental files are complete in
final form except for an approval signature on the EIS or individual Section 4(f) at the time of legal
sufficiency review.
Legal sufficiency reviews are conducted by the AGO or by specialized outside environmental counsel
appointed by AGO and funded by ADOT. When conducting a legal sufficiency review, the attorney will
assess the document from the perspective of legal standards, litigation risk and legal defensibility. The
assessment will consider whether the document was properly developed and whether it answers
substantive questions which could be reasonably raised. This assessment will focus on the adequacy of
21
the essential NEPA and/or Section 4(f) elements. Are the decision elements suitably supported? This
review will also document any significant readability concerns of legal import.
Adherence to the procedures and recordkeeping outlined in this section of the QA/QC Plan shall
constitute evidence of the adequacy of the legal sufficiency determination made by counsel.
Legal sufficiency review requests will be made by the Environmental Planner and accompanied by the
following documents:
1. A transmittal memo signed by the Environmental Planner requesting a legal sufficiency review
2. A paper copy of the document to be reviewed
3. An electronic copy of the document in MS Word format with track changes enabled
4. An electronic copy of each technical study in .pdf format
5. A copy of the EA/EIS Quality Control Checklist
4.3.1 Environmental Document File Preparation Requirements and Considerations

1. Purpose and Need Statement
2. Discussion of Alternatives
3. Indirect and cumulative effects analysis
4. Scope of review of environmental resources and any significant impact to, and mitigation for,
those resources (e.g. air, water, vegetation, Section 7, cultural resources, environmental justice
etc.)
5. Coordination with local, tribal, and resources agencies, and documented responses to concerns
raised
6. Availability for public review and comment, and adequacy of responses to those comments; and
7. Whether all applicable requirements have been substantially satisfied (including laws,
regulations, executive orders, FHWA policies, and ADOT guidance.)
4.3.2 Individual Section 4(f) File Preparation Requirements and Considerations

1. Section 4(f) applicability determination
2. How is the Section 4(f) document presented in the file-stand alone or included in an EA
a. An EIS legal sufficiency review could include a Section 4(f) Evaluation
3. Alternatives Analysis using Feasible and Prudent Standard including avoidance and least harm
analysis (if required)
4. Identification and discussion of minimization and/or mitigation measures
5. Consultation and coordination with agency owning or administering the Section 4(f) resource;
FHWA if a constructive use determination, Department of Interior, Housing and Urban
Development and US Department of Agriculture
6. Section 4(f) conclusion and determination
Upon submission from ADOT, the reviewing attorney shall ensure receipt of all documents prior to
conducting the review. The attorney will document receipt of files to ADOT. The review shall
commence the first business day after documented receipt of complete files. ADOT has a goal of 22
days for completion of legal sufficiency review. Prior notice may allow schedules to accommodate a
shorter review time by eliminating “Queue time.”
The attorney will provide to ADOT when the review is completed; the dates the attorney sent comments
to and to whom, the dates responses were received, any follow-on discussions and the date of final legal
sufficiency. These procedures apply to both Environmental Documents and Section 4(f) reviews.
22
ADOT will make changes to the document and submit revisions through generally accepted ENV
document review process. The goal of this process is to complete revisions within 10 business days.
ADOT will provide to AGO or reviewing attorney the following:
1. A transmittal memo or suitable electronic document stating the document has been revised
pursuant to legal sufficiency review and requesting AGO acceptance of changes made.
2. A copy of revised document in MS Word format with track changes showing additions and
deletions.
3. A copy of comment matrix and with comment responses
Upon acceptance of changes and completion of final review, the attorney will forward the legal
sufficiency review, comments, and legal sufficiency finding to the ADOT ENV Administrator. This finding
will contain the following language:
“I have reviewed the proposed Final Environmental Impact Statement (FEIS) [and/or Section 4(f)
evaluation] for the Project (Federal Project Number), which proposed to build [short description
of the project and its location]. Pursuant to the provisions of 23 CFR § 771.125(b) [and/ or 23
CFR §774.7(d]), I find the proposed FEIS [and/or Section 4(f) evaluation] for this project to be
legally sufficient.
In order to ensure that the legal sufficiency review is conducted on a final document, subsequent
changes to the document already reviewed for legal sufficiency, from any source, must be reviewed by
the attorney to assess any implications on the finding of legal sufficiency. It is the NEPA Assignment
Manager’s responsibility to ensure any subsequent changes are referred to the reviewing attorney.
If the attorney is reviewing an EA, the attorney sends a memo to the Environmental Planning
Administrator stating the document “is ready for signature.”
4.4 QA/QC Resources

The following documents are available to support quality assurance in developing documents and
quality control in reviewing them:
• #15 Preparing High-Quality NEPA Documents for Transportation Projects
• Improving the Quality of Environmental Documents
• FHWA Memorandum on Improving the Quality of NEPA Documents
5 SECTION 4(F) DOCUMENTS REVIEW AND APPROVAL
This section only provides guidance on how to process projects with potential Section 4(f) resources; it
does not provide guidance on conducting Section 4(f) evaluations. Please reference 23 CFR 774, the
FHWA Policy Paper and the ADOT Section 4(f) Manual for more information on how to identify and
evaluate Section 4(f) properties and impacts.
CEs, at a minimum, document that there is “no Section 4(f) use” on the CE Checklist. An EA and EIS will
document whether or not Section 4(f) properties are involved in a project. Additional forms have been
incorporated in the Section 4(f) Manual to provide documentation if there is a question of whether or
not a property is a Section 4(f) property or if a Section 4(f) use is questioned. Equivalents that amount to
“negative declarations” are not required in every instance to document when Section 4(f) is not
applicable. For example projects on the Interstate that fall within applicability requirements of 23 CFR
23
774.11 do not require additional Section 4(f) documentation. A paving project within the existing
transportation right-of-way requires no Section 4(f) documentation beyond that in the CE.
Note; the Cultural Resources Program Manager can perform all of the duties of the HPT Team Lead in
regard to Section 106 and Section 4(f) document review and approval. The NEPA Assignment Manager
may delegate Section 4(f) review to the suiltable staff within Environmental Planning.
5.1 Section 4(f) Involving Historic Properties

HPT Specialists are responsible for identifying (with the assistance of the project team and consultants)
historic Section 4(f) resources. If a potential Section 4(f) property is identified within or near a project’s
Area of Potential Effect (APE) the HPT Specialist coordinates with the HPT Team Lead and the
Environmental Planner for consideration as needed and appropriate for the project circumstances. Such
information could include:
 A description of the project with emphasis on the potential 4(f) resource(s) boundaries
 A preliminary assessment regarding applicability of the potential Section 4(f) property under 23
CFR 774.11 and what exception may apply under 23 CFR 774.13
 Potential Section 4(f) use and, if so, what type (temporary, permanent or constructive)
 Recommended Section 4(f) processing option for the project as appropriate (documenting
applicability, no use, exceptions, de minimis impact, or programmatic or individual evaluation)
The HPT Team Lead consults with the ENV Administrator as needed and communicates concurrence or
provides direction to the HPT Specialist and Environmental Planner in regard to the issues in question. If
warranted the HPT Specialist documents the decisions made on projects in which there is a question of
whether or not a historic property is a Section 4(f) property or if a potential Section 4(f) impact use is in
question. The “No Section 4(f) Property/Use Form” may be used to document the decision. Note that a
“No Section 4(f) Property/Use Form” is not required for every lack of a Section 4(f) property or no use
of a Section 4(f) property on a project.
5.1.1 Reviews for exceptions and de minimis impact involving historic properties:
Exceptions
a. HPT Lead reviews all Section 106 consultation letters that include Official with
Jurisdiction (OWJ) coordination. Section 106 compliance is used by ADOT for the
application of exceptions outlined in 23 CFR 774.13.
b. HPT prepares a Section 4(f) Applicability/Exceptions Form to document exceptions

applied under 23 CFR 774.13 for historic properties for HPT Lead approval.
De minimis Impact
a. HPT Lead reviews all Section 106 consultation letters that include OWJ coordination for
a Section 4(f) use. The letter includes a statement that ADOT intends to make a de
minimis impact determination.
b. HPT prepares the Section 4(f) De Minimis Impact on Historic Properties Form for HPT
Lead approval the form. ENV Administrator may also approve the form.
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5.1.2 Reviews for programmatic and individual Section 4(f) evaluations involving historic properties:
1. The Environmental Planner, HPT, and ENV Administrator discuss and agree on processing
options of a Section 4(f) use with a programmatic or individual Section 4(f) evaluation
2. The Environmental Planner and HPT Specialist work with the consultant team to develop the
initial Section 4(f) document
3. The Environmental Planner provides the initial Section 4(f) document to the HPT Team Lead, and
the AGO for an individual Section 4(f) evaluation, for QC and legal pre-review
a. The Environmental Planner may also elect to have the NEPA Assignment Manager
review the document. Note the NEPA Assignent Manager or delegate must review the
document if Section 4(f) properties other than historic properties are involved.
4. The HPT Lead’s review comments and any legal comments received are sent by the
Environmental Planner to the consultant for incorporation into the final draft Section 4(f)
document
5. The Environmental Planner and HPT Specialist ensure any NEPA Assignment Manager and legal
reviewer comments are addressed
6. Individual Section 4(f) evaluations shall be provided to the OWJ over the Section 4(f) resource
and to the Department of the Interior, and as appropriate, to the Department of Agriculture and
the Department of Housing and Urban Development. A minimum of 45 days for review and
receipt of comments shall be provided.
7. The Environmental Planner ensures a Legal Sufficiency statement is included in the project file
for a final individual Section 4(f) evaluation (if not included in an EIS)
8. ENV Administrator approves programmatic and individual Section 4(f) evaluations
a. The HPT Team Lead or NEPA Assignment Manager can approve a Section 4(f) evaluation
involving a historic property in the absence of the ENV Administrator.
Constructive Use
If there is a potential for a Section 4(f) use that requires a constructive use consideration the decision on
the Section 4(f) processing approach is to be made by the ENV Administrator. Constructive use
determinations require coordination and approval from FHWA Headquarters through the FHWA Arizona
Division.
5.2 Section 4(f) Involving Parks, Recreation Areas, and Wildlife and Waterfowl Refuges
Environmental Planners are responsible for identifying (with the assistance of the project team and
consultants) publicly owned parks, recreational areas, and wildlife and waterfowl refuges as Section 4(f)
resources. If a potential Section 4(f) property is identified within or near a project’s study area or
footprint the Environmental Planner coordinates with the Project Delivery Manager or the NEPA
Assignment Manager for consideration as needed and appropriate to the project circumstances. Such
information could include:
25
 A description of the project with emphasis on the potential 4(f) resource(s) boundaries
 A preliminary assessment regarding applicability of the potential Section 4(f) property under 23
CFR 774.11 and what exception may apply under 23 CFR 774.13
 Potential Section 4(f) use and, if so, what type (temporary, permanent or constructive)
 Recommended Section 4(f) processing option for the project as appropriate (documenting
applicability, no use, exceptions, de minimis impact, or programmatic or individual evaluation)
The Project Delivery Manager or NEPA Assignment Manager consults with the ENV Administrator as
needed and communicates concurrence or provides direction to the Environmental Planner in regard to
the issues in question. A decision is made before coordination with an OWJ is initiated.
The Environmental Planner documents the decisions made on projects in which there is a question of a
potential Section 4(f) property or if a potential Section 4(f) impact use is in question. The “No Section
4(f) Property/Use Form” may be used to document the decision. Note that a “No Section 4(f)
Property/Use Form” is not required for every lack of a Section 4(f) property or no use of a Section 4(f)
property on a project.
5.2.1 Reviews for exceptions and use with de minimis impact involving parks, recreation areas and
wildlife and waterfowl refuges:
Exceptions
a. For approval of exceptions the Environmental Planner completes the Section 4(f)
Applicability/Exceptions Form and emails the draft form to the Project Delivery
Manager or NEPA Assignment Manager for review.
i. The ENV Administrator is included in the draft form transmittal when there is an
exception applied that requires OWJ concurrence
b. The ENV Administrator, or delegate, approves the Section 4(f) Applicability/Exceptions

Form
De minimis Impact
a. Environmental Planner coordinates with the NEPA Assignment Manager or Project

Delivery Manager before initiating contact with the OWJ when there is a Section 4(f) use
with a de minimis impact determination
b. The Environmental Planner emails the draft Section 4(f) De Minimis Impact on Public
Parks, Recreational Areas and Wildlife and/or Waterfowl Form to the Manager for
review
c. After a draft has been reviewed the Environmental Planner ensures coordination and
public involvement requirements are conducted
d. Environmental Planner signs the Section 4(f) De Minimis Impact on Public Parks,
Recreational Areas and Wildlife and/or Waterfowl Form and the ENV Administrator
approves the form
26
5.2.2 Reviews for programmatic and individual Section 4(f) evaluations involving parks, recreation
areas and wildlife and waterfowl refuges:
1. The Environmental Planner, NEPA Assignment Manager and ENV Administrator discuss and
agree on processing options of a Section 4(f) use with a programmatic or individual Section 4(f)
evaluation
2. The Environmental Planner and HPT Specialist work with the consultant team to develop the
initial Section 4(f) document
3. Environmental Planner provides the initial Section 4(f) document to the NEPA Assignment
Manager, and the AGO for an individual Section 4(f), for QC and legal pre-review
4. The NEPA Assignment Manager’s review comments and any legal comments are sent to the
consultant for incorporation into the final draft Section 4(f) document
5. The Environmental Planner ensures any NEPA Assignment Manager and legal review comments
are addressed
6. Individual Section 4(f) evaluations shall be provided to the OWJ over the Section 4(f) resource
and to the Department of the Interior, and as appropriate to the Department of Agriculture and
the Department of Housing and Urban Development. A minimum of 45 days for review and
receipt of comments shall be provided.
7. The Environmental Planner ensures a Legal Sufficiency statement is included in the project file
for a final individual Section 4(f) evaluation (if not included in an EIS)
8. ENV Administrator approves programmatic and individual Section 4(f) evaluations
a. The NEPA Assignment Manager can approve a Section 4(f) evaluation involving a park or
refuge in the absence of the ENV Administrator.
Constructive Use
If there is a potential for a Section 4(f) use that requires a constructive use consideration the decision on
the Section 4(f) processing approach is to be made by the ENV Administrator. Constructive use
determinations require coordination and approval from FHWA Headquarters through the FHWA Arizona
Division.
27
APPENDIX
28
CE Quality Control Checklist

Project Data:
Project Name: ADOT Project Number:

Route or Location: Federal-Aid Number:
Environmental Planner: CE Reviewer:
Project Information
Project Information
All Project Information boxes are complete and correct: Project Name, ADOT Project Number, Federal-
Yes ☐ No ☐ aid Number, CE Start Date, Estimated Construction Cost, Programming/Fiscal Constraint, Construction
Administration and FMIS Designation
Location and Limits
Yes ☐ No ☐ Route and MP Limits provided (or LPA project location)?
Yes ☐ No ☐ City and County?
Existing land ownership of facility provided (ADOT ROW, underlying land management agency or
Yes☐ No ☐ n/a ☐ tribal lands for easements or LPA ROW)? n/a for certain (c)(1) CEs.
Purpose and Description
Complete Scope of work listed in Bullet Format, and consistent with Stage project plans current in
Yes ☐ No ☐ review and technical reports?
New ROW or permanent easements and/or temporary construction easements (TCEs) information
Yes☐ No ☐ n/a ☐ provided?
Yes☐ No ☐ n/a ☐ Description of known substantial detours or new temporary access roads?
Type of CE
(c)(1) CE Box Checked, if Appropriate? If “Yes” then the remainder of the CE QC Checklist can be
Yes☐ No ☐ n/a ☐
bypassed and the form approved.
Yes ☐ No ☐ CE type selected is appropriate (more than one type of CE may apply)
Environmental Review Section [excluding (c)(1) CE]
Air Quality Determination selected based upon Exempt project, Technical Specialist email or report in
Yes☐ No ☐ n/a ☐ file as applicable?
Noise Determination selected based upon Exempt project, Technical Specialist email or report in file as
Yes☐ No ☐ n/a ☐ applicable? n/a for Geotechnical.
Biological Resources ESA Determination selected based upon Technical Specialist email or report in
Yes ☐ No ☐ file as applicable?
Cultural Resources Section 106 Determination selected based upon Technical Specialist email or
Yes ☐ No ☐ report in file?
Yes☐ No ☐ n/a ☐ Is there documentation in the file for any determination other than “n/a – no Section 4(f) properties”?
Section 404 Clean Water Act Determination selected based upon Technical Specialist email or report
Yes☐ No ☐ n/a ☐ in file as applicable?
401 Clean Water Act Determination selected based upon Technical Specialist email or report in file as
Yes☐ No ☐ n/a ☐ applicable?
Hazardous Material Determination selected based upon Technical Specialist email or report in file as
Yes☐ No ☐ n/a ☐ applicable?
Yes☐ No ☐ n/a ☐ Environmental Justice/Title VI Determination selected is appropriate?
Yes☐ No ☐ n/a ☐ Public Involvement for the project has been conducted consistent with 23 CFR 771.111?
29
Environmental Review Section [Continued]

If Other Considerations are included ensure the appropriate documentation is in the file. For example
Yes☐ No ☐ n/a ☐ if the project impacts adjacent farmlands an NRCS overview of farmland should be in the file.
Constraints under 23 CFR 771.117(e)
Are all constraints checked? These are only required for the following CE types: (c)(26), (c)(27),
Yes☐ No ☐ n/a ☐ (c)(28).
Yes☐ No ☐ n/a ☐ Is additional information provided for any “Yes” constraint checked?
NEPA Certification and Determination
The project meets the definition of a CE under 23 CFR 771.117(a) and (b) and the correct authorizing
Yes ☐ No ☐ MOU is selected?
Environmental Commitments
Yes☐ No ☐ n/a ☐ ENV Commitments are included with the project and any permits and flyers are attached?
ENV-Drive Folder Review
Yes ☐ No ☐ All applicable template folders are in the Project File?
Yes ☐ No ☐ All applicable Tech Reports in the Project File?
Yes ☐ No ☐ All the Tech Review comment emails have been saved to the “Review Comments” folder?
Reviewer Comments
CE Reviewer: Date:
Click here to enter text.
30
Individual CE Quality Control Form

Project Information:
Project Name: ADOT Project Number:

Route or Location: Federal-Aid Number:
Environmental Planner:
This form is to be completed for CEs prepared for projects that are individually documented and approved under
23 CFR 771.117(d) and approved pursuant to 23 USC 327 and the 327 MOU executed by ADOT and FHWA.
Certification:
This CE complies with ADOT Environmental Planning guidance and the requirements of all applicable federal laws,
regulations and Executive Orders. I acknowledge the appropriate quality controls have been approved and signed. The
CE is ready for signature.
☐ ADOT District and Project Manager have been sent a copy of the Environmental Commitments for review
☐ A completed CE QC Checklist is located in the Project File
☐ The ADOT Civil Rights Office received a copy of the CE Checklist
☐ The CE is logged in the MOU Tracking and Reporting spreadsheet
NEPA Assignment Manager: Date:

31
EA Quality Control Checklist
Project Name: ☐ Federal Assigned ☐ Federal Not Assigned (FHWA)
TRACS No: Federal-aid No: QC Review Begin Date :
District: Project Sponsor:
Planner to conduct QC
review of content if Major Required Content
present :
Yes No N/A
☐ ☐ ☐ Cover Page and Table of Contents
Yes No N/A
☐ ☐ ☐ Follows Cover Page and Table of Contents format in ADOT EA/ EIS Guidance Manual Appendix A
☐ ☐ ☐ Project Title, full TRACS Number, full federal-aid project number, route, and termini
☐ ☐ ☐ Signature block, document statement, and contacts
☐ ☐ ☐ 23 U.S.C. 327 MOU assignment language is on cover page of the EA
review of content if
EA Specific Review Section
present :
Yes No N/A
☐ ☐ ☐ EA Table of Contents: include list of tables, figures, appendices,
☐ ☐ ☐ Proposed Project
☐ ☐ ☐ Introduction: Brief introduction including suitable figures
Existing Facility or Project Description
☐ ☐ ☐ Logical termini and independent utility description discussion
☐ ☐ ☐ Includes location, length, type of improvements, and any ROW / Easements needed
Yes No N/A Purpose and Need
☐ ☐ ☐ Purpose and Need Statements
☐ ☐ ☐ Planning Requirements
Project is Consistent with Arizona Regional Transportation Plan, State Transportation Plan, Transportation Plan, and is in ADOT Five
☐ ☐ ☐ Year Construction Program (required for final environmental document)
Yes No N/A Alternatives
☐ ☐ ☐ Discussion of Project build alternative(s)
☐ ☐ ☐ Estimated Project Cost Information
☐ ☐ ☐ Project No-build Alternative
☐ ☐ ☐ Identification of Preferred Project Alternative for Final Environmental Document
☐ ☐ ☐ Locally Preferred Project Alternative should one have been identified
☐ ☐ ☐ Project Alternatives Considered But Eliminated From Further Consideration
☐ ☐ ☐ Comments and Coordination (Public Involvement and Agency Coordination)
☐ ☐ ☐ Commitments (table recommended)
☐ ☐ ☐ EA Avoidance, Minimization and/or Mitigation Measures
☐ ☐ ☐ References Cited
☐ ☐ ☐ List of Acronyms
32
When reviewing project files for environmentally relevant document information, confirm topic files do exist
electronically and the file contents contain complete public records supporting the decisions within the Technical Area
Content Review checkboxes reviewed below.
Technical Area Content Review-
present : Affected Environment / Impacts / Avoidance, Minimization and Mitigation Measures
Verify investigation outcomes and project effects are appropriate for each topic.
Included in this Not required for
Document this Document
Verify applicable avoidance, minimization, mitigation measures, and commitments
Yes No
for each review topic.
☐ ☐ ☐ ☐ Right of way/Displacements
☐ ☐ ☐ ☐ Land Use (Consistent with current STIP/TIP, RTP, or MTP)
☐ ☐ ☐ ☐ Farmlands
☐ ☐ Community Impacts, LEP, ROW/Displacements, community facilities, community cohesion,
☐ ☐
public health and safety
☐ ☐ ☐ ☐ Environmental Justice
☐ ☐ ☐ ☐ Utilities/Emergency Services
☐ ☐ ☐ ☐ Traffic and Transportation/Pedestrian and Bicycle Facilities
☐ ☐ ☐ ☐ Visual/Aesthetics
☐ ☐ ☐ ☐ Economics
☐ ☐ ☐ ☐ Historic Resources
☐ ☐ ☐ ☐ Archeological Resources
☐ ☐ ☐ ☐ Water Quality
☐ ☐ ☐ ☐ Floodplain
☐ ☐ ☐ ☐ Hazardous Materials
☐ ☐ ☐ ☐ Joint Development (If applicable)
☐ ☐ ☐ ☐ Air Quality
☐ ☐ ☐ ☐ FHWA air quality conformity determination (place in appendix)
☐ ☐ ☐ ☐ Noise Requirements
☐ ☐ ☐ ☐ Ecosystems (Wetlands, Wildlife, T&E Species, Natural Communities)
☐ ☐ ☐ ☐ Construction Impacts
☐ ☐ ☐ ☐ Mitigation Summary
☐ ☐ ☐ ☐ Indirect Impacts
☐ ☐ ☐ ☐ Cumulative Impacts
☐ ☐ ☐ ☐ Section 4(f) – If applicable
☐ ☐ ☐ ☐ Section 6(f) – If applicable
☐ ☐ ☐ ☐ FHWA Constructive Use Determination
Attach comments as needed. Identify comment by section or paragraph number when reviewing, e.g. Section XX.yy comment…..; Section
YY.zz comment…..
Draft EA Checklist Approval
Checklist Approver: Date:

33
EA Quality Control Form

Project Name: Construction Project Administration

ADOT Project Number: ADOT CA Agency
Federal-Aid Number:
Planning Requirements:
Estimated Project Construction Cost:
NEPA Start Date: Click here to enter a date. Fiscal Constraint/Design Concept and Scope
Draft Environmental Document Approval:
I have reviewed this Draft EA and find that it complies with ADOT Environmental Planning guidance and the
requirements of all applicable federal laws, regulations and Executive Orders
☐ The consultant has submitted a quality control certification
☐ The required Technical Section(s) review has been completed
☐ An EA Quality Control Checklist has been completed and the environmental document meets all ADOT
requirements
Environmental Planner: Date:

I have reviewed this Draft EA and find that it complies with ADOT Environmental Planning guidance and meets all
ADOT requirements
☐ The completed quality control reviews are located in the Project File
☐ Legal counsel has reviewed the draft environmental document (optional)

34
Final Environmental Document Approval:
I have reviewed this Final EA and FONSI and find that it complies with ADOT Environmental Planning
guidance and the requirements of all applicable federal laws, regulations and Executive Orders
☐ All Project Team comments have been adequately addressed and incorporated in the final
environmental document
☐ All substantive public and agency comments have been adequately addressed and responses
incorporated in the final environmental document
☐ Any necessary technical report updates have been completed and are located in the project file
☐ A legal sufficiency review has been completed if an individual Section 4(f) evaluation was
completed as part of the EA (if applicable)

FONSI for Approval:
I have reviewed this Final EA and FONSI and find that it complies with ADOT Environmental Planning guidance
and all ADOT requirements

35
EIS Quality Control Checklist

Project Name: ☐ Federal Assigned ☐ Federal Not Assigned (FHWA)
TRACS No: Federal-aid No: QC Review Begin Date :
District: Project Sponsor:
present :
Yes No N/A
Yes No N/A
☐ ☐ ☐ Follows Cover Page and Table of Contents format in ADOT EA/ EIS Guidance Manual Appendix A
☐ ☐ ☐ Project Title, full TRACS Number, full federal-aid project number, route, and termini
☐ ☐ ☐ Signature block, document statement, and contacts
☐ ☐ ☐ 23 U.S.C. 327 MOU assignment language is on cover page of the EIS
EIS Specific Review Section
present :
Yes No N/A
☐ ☐ ☐ EIS ROD
☐ ☐ ☐ Follows document type format in ADOT EA/EIS Guidance Manual Appendix A
☐ ☐ ☐ Decision
☐ ☐ ☐ Alternatives considered; selection of the Preferred Alternative is noted and discussed
☐ ☐ ☐ FHWA Transportation Conformity Finding is present-when applicable
☐ ☐ ☐ EIS Executive Summary

☐ ☐ ☐ Introduction
☐ ☐ ☐ Purpose and Need Statement Paragraph
☐ ☐ ☐ Alternatives Considered Paragraph Summary
☐ ☐ ☐ Affected Environment, Environmental Consequences, and Mitigation Measures Summary
☐ ☐ ☐ Public and Agency Coordination
☐ ☐ ☐ Cooperating Agency Evaluation Summary
☐ ☐ ☐ Table of Contents: include list of tables, figures, appendices, and List of Acronyms
☐ ☐ ☐ Proposed Project
☐ ☐ ☐ Introduction: Brief introduction including suitable figures
☐ ☐ ☐ Existing Facility or Project Description
☐ ☐ ☐ Logical termini and independent utility description discussion
☐ ☐ ☐ Includes location, length, type of improvements, and any ROW / Easements needed
☐ ☐ ☐ Purpose and Need
☐ ☐ ☐ Purpose and Need Statements
☐ ☐ ☐ Planning and Programming Status
Project is Consistent with Arizona Regional Transportation Plan, State Transportation Plan, Transportation Plan, and is in ADOT Five
☐ ☐ ☐ Year Construction Program (required for final environmental document)
☐ ☐ ☐ Alternatives
☐ ☐ ☐ Discussion of Project build alternative(s)
☐ ☐ ☐ Estimated Project Cost Information
36
present :
Yes No N/A
☐ ☐ ☐ Project No-build Alternative
☐ ☐ ☐ Identification of Preferred Project Alternative for Final Environmental Document
☐ ☐ ☐ Locally Preferred Project Alternative should one have been identified
☐ ☐ ☐ Project Alternatives Considered But Eliminated From Further Consideration

☐ ☐ ☐ Avoidance, Minimization and/or Mitigation Measures
☐ ☐ ☐ Comments and Coordination (Public Involvement and Agency Coordination)
☐ ☐ ☐ Permits and Approvals Needed
☐ ☐ ☐ Commitments (table recommended)
☐ ☐ ☐ List of Preparers-EIS only
☐ ☐ ☐ Distribution List-EIS only
☐ ☐ ☐ References Cited
When reviewing project files for environmentally relevant document information, confirm topic files do exist
electronically and the file contents contain complete public records supporting the decisions within the Technical Area
Content Review checkboxes reviewed below.
Planner to conduct QC Technical Area Content Review-
present : Affected Environment / Impacts / Avoidance, Minimization and Mitigation Measures
Verify investigation outcomes and project effects are appropriate for each topic.
Included in this Not required for
Document this Document
Verify applicable avoidance, minimization, mitigation measures, and commitments
Yes No N/A for each review topic.
☐ ☐ ☐ ☐ ☐ Right of way/Displacements
☐ ☐ ☐ ☐ ☐ Land Use
Consistent with current STIP/TIP, RTP, or MTP
☐ ☐ ☐ ☐ ☐ Farmlands
☐ ☐ ☐ Community Impacts, LEP, ROW/Displacements, community facilities, community cohesion,
☐ ☐
public health and safety
☐ ☐ ☐ ☐ ☐ Environmental Justice
☐ ☐ ☐ ☐ ☐ Utilities/Emergency Services
☐ ☐ ☐ ☐ ☐ Traffic and Transportation/Pedestrian and Bicycle Facilities
☐ ☐ ☐ ☐ ☐ Visual/Aesthetics
☐ ☐ ☐ ☐ ☐ Economics
☐ ☐ ☐ ☐ ☐ Historic Resources
☐ ☐ ☐ ☐ ☐ Archeological Resources
☐ ☐ ☐ ☐ ☐ Water Quality
☐ ☐ ☐ ☐ ☐ Floodplain
☐ ☐ ☐ ☐ ☐ Hazardous Materials
☐ ☐ ☐ ☐ ☐ Joint Development (If applicable)
☐ ☐ ☐ ☐ ☐ Air Quality
☐ ☐ ☐ ☐ ☐ FHWA air quality conformity determination (place in appendix)
☐ ☐ ☐ ☐ ☐ Noise
☐ ☐ ☐ ☐ ☐ Ecosystems (Wetlands, Wildlife, T&E Species, Natural Communities)
☐ ☐ ☐ Relationship between local short-term uses of the maintenance of the human environment and
☐ ☐ the maintenance and enhancement of the long term productivity
37
☐ ☐ ☐ Any Irreversible and irretrievable commitments or resources which would be involved in the
☐ ☐ proposed action
☐ ☐ ☐ ☐ ☐ Construction Impacts
☐ ☐ ☐ ☐ ☐ Mitigation Summary
☐ ☐ ☐ ☐ ☐ Indirect Impacts
☐ ☐ ☐ ☐ ☐ Cumulative Impacts
☐ ☐ ☐ ☐ ☐ Section 4(f) – If applicable
☐ ☐ ☐ ☐ ☐ Section 6(f) – If applicable
☐ ☐ ☐ ☐ ☐ FHWA Constructive Use Determination
Attach comments as needed. Identify comment by section or paragraph number when reviewing, e.g. Section XX.yy comment…..; Section
YY.zz comment…..
Draft EIS Checklist Approval
Checklist Approver: Date:

38
EIS Quality Control Form

Project Name: Construction Project Administration

ADOT Project Number: ADOT CA Agency
Federal-Aid Number:
Planning Requirements:
Estimated Project Construction Cost:
NEPA Start Date: Click here to enter a date. Fiscal Constraint/Design Concept and Scope
Draft Environmental Document Approval:
I have reviewed this Draft EIS and find that it complies with ADOT Environmental Planning guidance
and the requirements of all applicable federal laws, regulations and Executive Orders
☐ An EIS Quality Control Checklist has been completed and the environmental document meets all
ADOT requirements

I have reviewed this Draft EIS and find that it complies with ADOT Environmental Planning guidance and meets
all ADOT requirements
☐ The Arizona Attorney General’s Office has reviewed the Draft EIS (ADOT requirement)
I acknowledge the Draft EIS is ready for signature and agency and public review

39
Final Environmental Document Approval:
I have reviewed this Final EIS and ROD and find that it complies with ADOT Environmental Planning
guidance and the requirements of all applicable federal laws, regulations and Executive Orders.
☐ All Project Team comments have been adequately addressed and incorporated in the final
environmental document
☐ All substantive public and agency comments have been adequately addressed and responses
incorporated in the final environmental document
☐ Any necessary technical report updates have been completed and are located in the project file

I have reviewed this Final EIS and ROD and find that it complies with ADOT Environmental Planning guidance
and all ADOT requirements.
☐ A Legal Sufficiency Review for the Final EIS and ROD has been completed and the AGO Legal
Sufficiency determination is located in the Project File

40
Amendments to QAQC Plan

Description of Modification
Version* Change Date Responsible

V1 Start of 327 MOU 4/16/19
V1a 327 MOU date added on page 4. Self-Assessment section mofified 01/21/20 PAO
page 7. Clarification added that the Wetland Biologist reviews
cooperating agency letters sent to the Corps and the Biologist reviews
cooperating agency letters sent to the USFWS (pg. 15). EA and EIS QC
Checklists modified. Reference to EJ Checklist deleted from CE QC
Form. Note added to QA Forms for final technical report updates.
Note*: version stays the same for minor changes with sub-version letter added.
41

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April 2019

ADOT Environmental Planning

1.1 Quality Assurance (QA)

1.2 Quality Control (QC)

2 CE ASSIGNMENT AND NEPA ASSIGNMENT

2.1 Assignment of FHWA Environmental Review Responsibility

2.1.1 CE Assignment - State Assumption of Responsibility for Categorical Exclusions

2.1.2 NEPA Assignment - Surface Transportation Project Delivery Program

2.2 Involvement with FHWA

2.4 CE Assignment MOU Requirements

2.4.1 CE Assignment – Reporting and Annual Self-Assessment

2.4.1.1 CE Assignment Self-Assessment Report Outline

2.4.2 CE Assignment – FHWA Monitoring

1. CE decisions are appropriately and timely documented.

2.4.2.1 FHWA Monitoring Review Coordination

2.5 NEPA Assignment MOU Requirements

2.5.1 NEPA Assignment – Self-Assessments

2.5.1.1 NEPA Assignment Self-Assessment Report Outline

2.5.1.2 FHWA Audit Coordination

2.5.2 NEPA Assignment - Performance Measures

i. Maintain documented compliance with procedures and processes set forth in

 Percent of approved environmental documents that have all supporting

[This is a percentage obtained by number of projects with signed NEPA

ii. Maintain documented compliance with requirements of all applicable

 Percent of approved environmental documents that have approvals for other

[This is a percentage obtained by number of projects with signed NEPA

B. QA/QC for NEPA decisions:

a.Legal sufficiency determinations made by counsel; this shall include

 Percent of Federal Register notices reviewed for legal sufficiency prior to

[This is a percentage obtained by total number of Notices of Intent and Notices

[This is a percentage obtained by total number of FEIS, FEIS/ROD and individual

b. Compliance with FHWA's and ADOT's environmental document

 Percent of individually documented CE’s with a CE Quality Control Checklist and

[Percentage is obtained by total number of projects with documented quality

c. Completeness and adequacy of documentation of project records for

 Percent of approved final environmental documents with completed CE/EA/EIS

[Percentage is obtained by total number of projects with documented quality

C. Relationships with agencies and the general public:

i. Maintain communication among ADOT, Federal and State resource

 Agency and public communication

[This is a percentage measuring notification. Percentage is obtained by number

ii. Maintain effective responsiveness to substantive comments received from

iii. Maintain effective NEPA conflict resolution processes whenever

D. Increased efficiency and timeliness in completion of NEPA process:

i. Compare time of completion of environmental document approvals before

 Time of completion of EAs

[Compare actual project EA delivery production time to historical average before

 Actual time to complete key interagency consultations

[Section 7 Biological Opinions (Section 7 initiation letter to Biological Opinion) and

3.1.1 Environmental Document

3.1.2 NEPA Document(s)

3.1.3 Environmental Review Document(s)

3.2 Documentation Review

3.2.1 Documentation Resources

3.2.2 Document Readability

3.3 Types of NEPA Documentation

3.3.1 Categorical Exclusions (CE)

3.3.2 Environmental Assessments