ODOT-FHWA Programmatic Categorical Exclusion Agreement

PCE/CE Quality Control / Quality Assurance Procedures & Future Statewide Outlook

October 8, 2020 PCE-CE DeliveryVirtual Workshop

Presented by Susan White, Statewide NEPA Program

ODOT Quality Control & Assurance for CEs & PCEs

Quality Assurance

Findings Recommendations

Improvements

Program Quality

Assurance

Region Quality Control

Quality Control vs Quality Assurance

• Quality Control• Project-level• Performed prior to deliverable completion/approval• Catches errors• Encourages discussions

• Quality Assurance• Program-level • Performed on completed projects or deliverables• Measures & tracks program/project performance• Determines if procedures should change/be added• Builds overall program strength & consistency• Encourages discussions

PCE Agreement & QA/QCPCE Agreement stipulates that ODOT Develop & Conduct –

• Quality Control & Assurance Measures

• Consistent statewide practices• Region Quality Control / Peer Review

procedures• Statewide QC Peer Review forms &

checklists• Interdisciplinary QA reviews & hold

in-person meetings to discuss• QA Review Findings &

Recommendations to…• Revise guidance, forms, procedures,

and/or policy

PCE Agreement & QA/QC cont’d.

Professional Qualification Requirements (p. 453-4)ODOT will ensure that only individuals who meet the PCE Agreement qualifications, below, will prepare and approve PCE documents. As per the PCE Agreement (page 4, Section IV.8.(A-C)), each ODOT PCE document preparer and/or approver must: • Be knowledgeable with and follow the appropriate subsections 23

CFR 771 through 774, and FHWA and ODOT procedures for environmental analysis and NEPA compliance;

• Have completed, at a minimum, Introduction to NEPA and Transportation Decision-making web-based course FHWA-NHI-142052; and

• Have adequate experience addressing NEPA compliance for transportation projects or until such time have their work reviewed by staff having the necessary experience.

PCE Agreement & QA/QC cont’d.

QC Peer Review Procedures (p. 453-5)PCE/CE document preparers1 and approvers must have the minimum training, knowledge, and experience (i.e., professional qualification requirements) as per the PCE Agreement (IV.A.8-9).

The Statewide PCE Quality Control Peer Review Checklist & Comment Log2 is a required attachment to the PCE Approval. Completing the QC checklist/comment log documents that the PCE files have received the ODOT-established quality control review prior to signing & finalizing/approving the PCE or CE documents.

• 1 Consultants hired by ODOT, or LPA staff, who prepare PCE/CE documents may [as per approved tasks from ODOT-approved SOW templates] provide draft documents to ODOT for review and approval by the REC assigned to that ODOT or LPA project.

• 2There are separate QC peer review forms for NGDs and CEs.

PCE Agreement & QA/QC cont’d.Required Documents

PCE/CE and Supporting Documents (p. 453-10)• Environmental Prospectus (i.e., replacement for the “Part 3”)

• Project Vicinity Map (via GIS web mapping application on ODOT website)

• PCE Determination (for PCEs only)

• Draft PCE Approval or CE Closeout (the NEPA approval document)

• Supporting environmental “clearance” documents as stated in the PCE Approval or CE Closeout

• (if applicable) Revised Project Vicinity Map

• Completed PCE, NGD, or CE Region Quality Control Peer Review Checklist & Comment Log

• Final/signed PCE Approval or CE Closeout (after QC peer review)• NOTE: for NGDs, only the NGD Document (the NEPA approval document),

Project Vicinity Map, and NGD QC Peer Review are required

News Flash!“New Agency-wide Quality Control & Assurance

Initiative for All ODOT Project Delivery Disciplines”

QC Processes to be incorporated in consultant SOWs very soon!

Agency-wide QA/QC Initiative –Goals for Statewide Consistent Processes

“One ODOT” QA/QC applies to HQ, regions, disciplines, consultants, and LPAs alike. Same procedures, same templates, same checklists, same expectations.

Same expectations improves accuracy of deliverables regardless of author & reviewer.

Consultants and LPAs are now required to use ODOT QA/QC plans, processes, templates, checklists, etc.

• Less rework• Higher quality• On-time

delivery• Less cost

overruns• More reliability• Less time =

more

Consistency Accuracy Add to Contracts/IGAs Improve Deliverables

Agency-wide QA/QC Initiative – All Disciplines To Have Documented QC

• Existing “Old” Practices….• Different QA/QC plans in regions• Different QA/QC processes for outsourced and

LPA projects• QA/QC practices not documented• Few existing environmental discipline QC

forms or processes• Each Consultant Firm’s own QA/QC Plan

• ….too many QC approaches to count!

Agency-wide QA/QC Initiative (cont.) – Documented QC

• As of Today –• Each ODOT Discipline now has QC

• Procedures• Checklists (or other documentation format)

• Each ODOT Discipline to incorporate their QC tasks/forms into ODOT SOW templates, WOCs

• CE/PCE QC in place since 2015

• Statewide Quality ASSURANCE is the next step to develop

QA procedures already in place for PCEs (since 2015)

REC & Cultural Teams meeting, The Dalles, 2016

• Region Environmental Coordinator ensures all environmental deliverables have been QCd (decided by QC committee)

• REC “tracks” deliverable QC completion• REC captures signatures & dates of QC

documents in E-STR form (see inset pic)• REC signs E-STR for each project delivery

milestone (e.g., DAP, PS&E, etc.)

• Environ. discipline leads responsible for their own QC to be performed – review, sign, date each QC checklist/form

• E.g., biology, wetlands, NEPA, cultural, etc.

• Environmental Statement of Technical Review (E-STR) – walkthrough

• Optional, if time allows (PD chart)

Introducing the New “E-STR” QC-Tracking Form

PCE/CE Quality Assurance Reviews (PCE Agreement, More Detail)

• Page 6: “ODOT agrees to develop, carry out, and report on regular quality control and quality assurance activities to ensure that its PCE approvals are made in accordance with applicable law and this Agreement.”

• Page 6: “The report[s] will include a description of actions taken by ODOT as part of its quality control and quality assurance efforts under Section VII.A.”

• Hence, ODOT NEPA Manual….• Section 453 – PCE/CE QA/QC procedures• Section 453.1 – E-STR Guide for PCEs/CEs• Section 456 – PCE/CE Communication Plan

• Page 4: “ODOT is responsible for [7.] Providing for quality assurance and quality control of consultant-produced documents.”

• Hence, Section 453.1 – E-STR Guide for PCEs/CEs

CE/PCE Quality Assurance Review Process• QA reviews are done twice a year• QA reviewers are a mix of RECs, NEPA program

staff/managers, FHWA Oregon, and sometimes discipline specialists

• Each reviewer uses standard QA review questions to review randomly selected PCEs (completed during last 6 months)

• Reviewers come to a scheduled meeting to discuss their findings and observations

• Collective group recommendations are made• QA Review Summary (findings &

recommendations) – prepared by ODOT for FHWA review/approval

• QA/QC results from the year included in Mid-Year and Annual Reports for FHWA, per PCE Agreement

QUESTIONS