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Guidance on Indirect Effects and Cumulative Impacts Analyses

This guidance was developed because we recognized that ODOT needs a consistency of approach on Indirect Effects and Cumulative Impacts analyses undertaken on ODOT projects. Consultants and agencies also need the certainty of what ODOT wants to see in these analyses. This resulting ODOT guidance is intended to be used by Central Office and District staff, as well as prequalified NEPA consultants working on ODOT projects. Our objective is to establish a consistent, legally sufficient, and efficient process on how to consider, analyze, and address environmental impacts from indirect effects and cumulative impacts when developing Federal-aid transportation projects.

ODOT’s guidance is not intended to be an extensive ‘how to’ manual on ICE. Other state DOTs have developed such manuals in great detail (and length) in recent years and those sources are linked in this new document for reference. Rather, we have chosen to mirror the 2011 AASHTO practitioner’s handbook (included here), which is an overview and which, along with other primary sources, uses the terminology “indirect effects and cumulative impacts.” ODOT is therefore using language that is consistent with these sources. However, in this guidance ODOT will use the commonly used, and easy to remember, acronym “ICE” to refer to these analyses. This ODOT document will provide guidance and reference to other states’ processes so that practitioners in Ohio have an understanding of what ODOT expects an ICE analysis to contain. We anticipate that ICE analyses will only need to be rarely done.

Opportunity Corridor Project in Cleveland
Opportunity Corridor Project in Cleveland


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ODOT has been assigned FHWA's responsibilities pursuant to the Surface Transportation Project Delivery Program, otherwise known as NEPA Assignment. The environmental review, consultation, and other actions required by Section 4(f) of the Department of Transportation Act are being carried out by ODOT pursuant to 23 U.S.C. 327 and a Memorandum of Understanding dated June 6, 2018, and executed by FHWA and ODOT.