Standards of Uniformity/Standard Operating Procedures Program

G. Lain Ellis, Ph.D.Environmental Affairs Division

(View in Notes Page mode for script)

Quote of the day

We must, indeed, all hang together, or assuredly we shall all hang separately.

Benjamin Franklin

What happens next A little bit of history An initial challenge:

How do we reconcile standardization with need for project-specific documents?

An additional challenge: How do we help Project Managers under P6?

A shift to Compliance Action Plans

A little history 1997-99: 1st standardized specs for archeology 1999-2006: standardized specs for others May 2006: SH 130 Seg. 5 & 6 negotiations

CZ wants increased predictability ENV/CZ agree to develop standards for submissions

June 2007: ENV/CZ kick off SOUs and Compliance Action Plan (CAP) for SH 130

SH 130 Compliance Action Plan Set of triggers for environmental compliance Set of actions required by each trigger For project managers, not environmental

specialists CAP:

Covers post-NEPA portion of the project Programmatic approach to multi-decade program

Generic plan to deal with unknown issues

A little more history 2005: Audit shows uneven performance on

local government CMAQ projects 2005-2008: Local Government Project

Procedures (LGPP) Task Force SOPs and training program

Early 2009: LGPP implemented and ongoing Environmental section of LGPP is a CAP

LGPP CAP Like SH 130 CAP

Set of triggers and corresponding actions Made for project managers

Unlike SH 130 CAP: Covers project development Applies to long-/short-term projects

Generic plan to identify and resolve known and unknown requirements

Just a little more history March 2008: ENV proposes decentralization

of PCE approval based on: SOUs to promote successful 1st-time review Programmatic QA/QC to monitor performance

Early 2008: ADMIN considers regionalization

March-July 2008: Development and initial rollout

October 2008: Regionalized PCE review

A common thread All are imperfect They all work anyway An emerging theme:

Mutually shared expectations Increased standardization Increased predictability of outcome

Back to the present ENV expanding scope of SOUs/SOPs, but:

More complex projects harder to standardize FHWA/AASHTO moving to tailored documents FHWA proposing project-specific EIS/EA teams

Broader context not moving to standardization

The challenge Need more standardization for CEs, EAs,

EISs But, need project-specific compliance

solutions

New kid on the block Primavera 6 becoming primary project

management tool Project Manager has to assign resources/dates Initially uses standard template that includes

resources whether needed or not Adapts template to specific projects to avoid

over-/underprogramming resources

No pressure, but… Everybody’s success boils down to success of

Project Managers They need right resources They don’t need surprises They need reliable estimates of resource

needs/availability And they need these estimates early.

How can we help ensure their success?

The modified challenge Reconcile standardization with project-

specific compliance Give Project Managers what they need for

planning and executing specific projects

Back to SOU/SOP program SOU concept can be stretched only so far

Don’t want to stifle innovation Tools for successful deliverables

SOPs play a major role Define roles, responsibilities, and sequences of actions Tools for meeting mutual expectations

But SOUs and SOPs are not plans, and Project Managers have specific risks to address

Re-enter the CAP Recall:

SH 130 CAP post-NEPA only LGPP CAP adds project development Both are generic Both require effort to adapt to specific activities

Push the CAP concept once more Start with generic CAP

Add project-specific risk analysis Identify project-specific compliance needs Add named resources Add scheduled dates

Two birds, one stone: Project-specific plan for Project Managers Project-specific process/document for FHWA

Some things best done with CAPs Start this project right Identify compliance tasks for this project Manage environmental risk on this project Find resources for this project Agree who does what when on this project Roll with the punches on this project Establish accountability on this project

Hang together, or hang separately? Adoption of project-specific risk-based CAP

addresses: Needs of Project Managers Basis for resource sharing in regionalization Environmental management system Persistent sources of conflict late in process

May help us avoid the noose altogether

Questions?