Ellis Sou Sop Fin


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How trends in TxDOT’s shift toward standardization of the environmental process conflicts with national trends toward project-specific environmental processes as well as TxDOT’s adoption of the Primavera V.6 project management system. Proposes the use of compliance action plans as a tool for adapting standards to project-specific needs.

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  • These are pretty exciting times at TxDOT. TxDOT is revolutionizing itself. Just about nobody’s gonna do things the way they used to, and ENV is no exception. As Melissa has just noted, an ongoing program for developing standards and procedures is being extended into new territory. NEXT
  • To build on what Melissa said, I’m going to provide a little more history to establish a little more context for how we’ve gotten here and for where we’re going. We will discover that TxDOT’s need to implement standardization leads to a challenge, namely, how do we standardize complexity in a way that is tailored to specific projects? This discussion will lead to another challenge, namely, how do we help Project Managers do appropriate startups in the P6 environment? Finally, I will propose to you that compliance action plans are a natural outgrowth of our SOU and SOP programs, and that this can be an important tool for addressing both challenges. NEXT
  • ENV has been moving toward standardization for a long time now. We standardized archeological deliverables in the late 90s. You could hear squeals of protest all over the state until the contractors realized they no longer had to guess what we wanted. We carried the process further in our own nonarcheological contracts. During negotiations on the CDA for SH 130 segments 5 & 6, Cintra/Zachry wanted to assume control of the entire environmental process. We couldn’t give it to them for legal reasons, so the question arose: If you can’t give us control, can you do something to increase predictability that our stuff will be accepted? During a break, Cintra and ENV hit on the idea of using standards for submissions, which subsequently became known as standards of uniformity. The principle was that CZ could do anything they want, but if they followed the standards without errors affecting the regulatory outcome, the deliverables would move on to the next step. In 2007, we kicked off the SOUs for SH 130, but at the same time we proposed something new: a compliance action plan or CAP. They accepted this proposal. NEXT
  • Having standards is a good thing, but having standards plus guidelines on when to use them is better. The CAP consists of a series of triggers: basically, events or conditions that precipitate a compliance obligation plus a set of compliance actions needed to address the triggers. Importantly, we directed the CAP to Project Managers instead of specialists because it is project managers who need to know when to involve specialists. Because the project had already been through NEPA, the CAP addressed issues that would apply during a long-term construction, operations, and maintenance project. The CAP therefore was generic and structured to deal largely with issues that would arise during and after the design-build phase. Although there were known unresolved issues, the CAP was structured primarily to deal with unknown issues because the known issues were already covered in the contract itself. NEXT
  • Shift gears. A 2005 audit showed that both TxDOT and local governments were having trouble fulfilling procurement, administrative, and monitoring requirements for CMAQ projects. The audit showed that part of the problem was a lack of procedures and training. So TxDOT formed the local government project procedures task force under the Construction Division. Although the audit had focused largely on contracting issues, the task force’s mission was to develop a comprehensive set of procedures and a training program for all areas of project development and implementation. The LGPP effort went live in early 2009, and is ongoing. ENV’s section of the procedures is a compliance action plan that grew out of the effort for SH 130. NEXT
  • So like the SH 130 CAP, the LGPP CAP consists of a set of triggers and their corresponding actions. But unlike the SH 130 CAP, the set of triggers applies to project development so that the scope of the CAP covers projects from beginning to end, regardless of whether they are long or short-term projects, and regardless of whether they are massive or small. Thus, the LGPP CAP is a generic plan for addressing environmental requirements that we know must be addressed during project development plus unknown issues that could arise during or after project development NEXT
  • In March 2008, ENV went to the administration with a proposal to shift review of programmatic categorical exclusions to the districts. The decentralization was based on the use of standards of uniformity, which was a direct outgrowth of the SH 130 experience. It also was based on a proposal to monitor system performance through a programmatic QA/QC process. When we finished our pitch, David Casteel or John Barton, I don’t remember which asked, do you think you this would work in a system of regional environmental centers? It seemed clear that this wasn’t the first time they talked about decentralizing environmental review, and although their pitch caught us a little flat-footed, we said, swell sure, we can’t see why not. And so now we have the regionalized system NEXT
  • There is a common thread in these developments. All of these systems are imperfect, in large part because they were substantial departures from business as usual. But they all work despite their hiccups, and they are maturing as they are used. Significantly, they illustrate an emerging theme. Collectively and individually, they emphasize working under an umbrella of mutually shared expectations. Standardization of content and procedure is part of the process for creating shared expectations. And the result of working under shared expectations is that we get increased predictability of the outcomes of our actions. NEXT
  • That’s probably more than enough history. As Melissa noted, ENV is expanding the scope of SOUs and SOPs beyond the PCE prgram and into the realm of CEs, EAs, and EISs. This process is complicated by the fact that the more complex the project, the harder it is to work within standardized parameters Moreover, at the national level, FHWA and AASHTO are moving toward an environmental process in which procedures and documents are tailored to the peculiarities of specific projects. Here in Texas, FHWA has proposed to establish EIS/EA teams to work with local entities to begin the environmental process with an established understanding of how each project should proceed. So there’s a significant trend in the broader context that is not moving toward standardization. NEXT
  • Which presents us with a challenge. Recent history suggests that the more we have standardized the process, the smoother it has become, hiccups notwithstanding. But our CEs, EAs, and EISs are the projects that take up most of our time, so there’s a bunch at stake if we can streamline them through SOUs and SOPs. But, because these projects are complex, we need to balance standardization against the need for project-specific solutions to meet both public and FHWA expectations. NEXT
  • To complicate matters just a little bit more, TxDOT is shifting rapidly toward using P6 as its primary project management tool. As you know, P6 requires Project Managers to assign and schedule resources, including environmental resources, as part of the overall project management process. As you probably also know, the process starts out with a standard generic template that includes standard values for resources, but it does so without regard to whether or not the standard applies to a specific project. So the P6 process requires the Project Manager to adapt the standard template to the requirements of the specific project NEXT
  • In our environment of increased transparency, a lot will be riding on the project managers’ ability to deliver on the commitments recorded in P6. So basically, everybody’s success rides on the project managers’ success And it being a Newtonian world in which everybody is downhill from somebody, those of us who are not project managers will be under the same pressure as they are. They will need very reliable estimates of resource needs and availability, and they will need them very early since the longer they wait, the more they risk competing for resources that already have been committed. So how can we help ensure the project managers’ success, and with it both our own and the department’s success? NEXT
  • Our challenge changes a little. It’s very useful to have standard P6 templates that incorporate baselines for predictable resource needs and schedules, but we need to reconcile these baselines with inevitable differences among projects. NEXT
  • SOUs and SOPs are mutually reinforcing tools, and they have proven their value over the short time over which the PCE decentralization program has been in place But, the SOU concept can be stretched only so far before it stifles innovation, and the more complex the project, the more it calls for innovation. It’s also important that SOU’s are tools for making successful deliverables, which are only part of the process. The move toward SOPs has played its role, too. We’ve become increasingly adept at using SOPs as tools for meeting expectations through well defined roles, responsibilities, and processes. But as valuable as these tools are, they don’t jointly or individually address a key issue for project managers. The project manager has a specific project with specific risks to address, and he or she needs a plan for addressing them NEXT
  • So we need something in addition to SOUs and SOPs to address the challenge of adapting generic processes to specific projects. I am proposing to you that the concept of a compliance action plan presents part of the solution. You will recall that I have characterized the previous CAPs as generic. And they are definitely generic because they require additional effort to apply them in specific cases. NEXT
  • But in the same way that we pushed the SH 130 CAP to cover project development, let’s push the LGPP CAP further still. Let’s add to that generic CAP a project-specific risk analysis with which we can identify project-specific compliance needs. We’ll discover that we can resolve some issues without using standard resource levels, and we’ll discover other issues that are likely to require greater than usual effort. Now let’s add to that a list of named resources to address compliance needs, and a schedule for completing compliance needs. If we have been clever, and TxDOT staff are quite capable of being clever, we will have developed both a project-specific plan for project engineers and a project-specific process that generates a project-specific document for FHWA. So it turns out that a more fully fleshed out CAP concept may be part of the solution for both challenges, especially when used with a system of SOUs and SOPs that help keep us on the same page.. NEXT
  • Now why do I believe this? I think it’s safe to say that in the environmental process you have a choice between spending a bunch of effort now and running a significant chance of expensive surprises late in the game. A CAP gets you off to a good start and so on, but its other values include helping you prepare for contingencies and then to learn lessons about how to get better at evaluating risk. NEXT
  • So, shall we hang together, or shall we hang separately? I think that in addition to helping Project Managers plan good projects, a project-specific, risk-based CAP also will facilitate resource sharing by identifying the resources that are actually needed. It also could be an important component in the environmental management system TxDOT is developing under a consent agreement and final order from EPA. And last but not least, agreement up front on what is needed can help us eliminate a persistent source of conflict by keeping us on the same page so we can avoid late surprises. In short, adoption of a CAP-based system could help us avoid the noose. NEXT
  • Ellis Sou Sop Fin

    1. 1. Standards of Uniformity/ Standard Operating Procedures Program G. Lain Ellis, Ph.D. Environmental Affairs Division (View in Notes Page mode for script)
    2. 2. Quote of the day We must, indeed, all hang together, or assuredly we shall all hang separately. Benjamin Franklin
    3. 3. What happens next <ul><li>A little bit of history </li></ul><ul><li>An initial challenge: </li></ul><ul><ul><li>How do we reconcile standardization with need for project-specific documents? </li></ul></ul><ul><li>An additional challenge: </li></ul><ul><ul><li>How do we help Project Managers under P6? </li></ul></ul><ul><li>A shift to Compliance Action Plans </li></ul>
    4. 4. A little history <ul><li>1997-99: 1 st standardized specs for archeology </li></ul><ul><li>1999-2006: standardized specs for others </li></ul><ul><li>May 2006: SH 130 Seg. 5 & 6 negotiations </li></ul><ul><ul><li>CZ wants increased predictability </li></ul></ul><ul><ul><li>ENV/CZ agree to develop standards for submissions </li></ul></ul><ul><li>June 2007: ENV/CZ kick off SOUs and Compliance Action Plan (CAP) for SH 130 </li></ul>
    5. 5. SH 130 Compliance Action Plan <ul><li>Set of triggers for environmental compliance </li></ul><ul><li>Set of actions required by each trigger </li></ul><ul><li>For project managers, not environmental specialists </li></ul><ul><li>CAP: </li></ul><ul><ul><li>Covers post-NEPA portion of the project </li></ul></ul><ul><ul><li>Programmatic approach to multi-decade program </li></ul></ul><ul><li>Generic plan to deal with unknown issues </li></ul>
    6. 6. A little more history <ul><li>2005: Audit shows uneven performance on local government CMAQ projects </li></ul><ul><li>2005-2008: Local Government Project Procedures (LGPP) Task Force </li></ul><ul><ul><li>SOPs and training program </li></ul></ul><ul><li>Early 2009: LGPP implemented and ongoing </li></ul><ul><li>Environmental section of LGPP is a CAP </li></ul>
    7. 7. LGPP CAP <ul><li>Like SH 130 CAP </li></ul><ul><ul><li>Set of triggers and corresponding actions </li></ul></ul><ul><ul><li>Made for project managers </li></ul></ul><ul><li>Unlike SH 130 CAP: </li></ul><ul><ul><li>Covers project development </li></ul></ul><ul><ul><li>Applies to long-/short-term projects </li></ul></ul><ul><li>Generic plan to identify and resolve known and unknown requirements </li></ul>
    8. 8. Just a little more history <ul><li>March 2008: ENV proposes decentralization of PCE approval based on: </li></ul><ul><ul><li>SOUs to promote successful 1 st -time review </li></ul></ul><ul><ul><li>Programmatic QA/QC to monitor performance </li></ul></ul><ul><li>Early 2008: ADMIN considers regionalization </li></ul><ul><li>March-July 2008: Development and initial rollout </li></ul><ul><li>October 2008: Regionalized PCE review </li></ul>
    9. 9. A common thread <ul><li>All are imperfect </li></ul><ul><li>They all work anyway </li></ul><ul><li>An emerging theme: </li></ul><ul><ul><li>Mutually shared expectations </li></ul></ul><ul><ul><li>Increased standardization </li></ul></ul><ul><ul><li>Increased predictability of outcome </li></ul></ul>
    10. 10. Back to the present <ul><li>ENV expanding scope of SOUs/SOPs, but: </li></ul><ul><ul><li>More complex projects harder to standardize </li></ul></ul><ul><ul><li>FHWA/AASHTO moving to tailored documents </li></ul></ul><ul><ul><li>FHWA proposing project-specific EIS/EA teams </li></ul></ul><ul><li>Broader context not moving to standardization </li></ul>
    11. 11. The challenge <ul><li>Need more standardization for CEs, EAs, EISs </li></ul><ul><li>But, need project-specific compliance solutions </li></ul>
    12. 12. New kid on the block <ul><li>Primavera 6 becoming primary project management tool </li></ul><ul><li>Project Manager has to assign resources/dates </li></ul><ul><li>Initially uses standard template that includes resources whether needed or not </li></ul><ul><li>Adapts template to specific projects to avoid over-/underprogramming resources </li></ul>
    13. 13. No pressure, but… <ul><li>Everybody’s success boils down to success of Project Managers </li></ul><ul><ul><li>They need right resources </li></ul></ul><ul><ul><li>They don’t need surprises </li></ul></ul><ul><ul><li>They need reliable estimates of resource needs/availability </li></ul></ul><ul><ul><li>And they need these estimates early. </li></ul></ul><ul><li>How can we help ensure their success? </li></ul>
    14. 14. The modified challenge <ul><li>Reconcile standardization with project-specific compliance </li></ul><ul><li>Give Project Managers what they need for planning and executing specific projects </li></ul>
    15. 15. Back to SOU/SOP program <ul><li>SOU concept can be stretched only so far </li></ul><ul><ul><li>Don’t want to stifle innovation </li></ul></ul><ul><ul><li>Tools for successful deliverables </li></ul></ul><ul><li>SOPs play a major role </li></ul><ul><ul><li>Define roles, responsibilities, and sequences of actions </li></ul></ul><ul><ul><li>Tools for meeting mutual expectations </li></ul></ul><ul><li>But SOUs and SOPs are not plans, and Project Managers have specific risks to address </li></ul>
    16. 16. Re-enter the CAP <ul><li>Recall: </li></ul><ul><ul><li>SH 130 CAP post-NEPA only </li></ul></ul><ul><ul><li>LGPP CAP adds project development </li></ul></ul><ul><ul><li>Both are generic </li></ul></ul><ul><ul><li>Both require effort to adapt to specific activities </li></ul></ul>
    17. 17. Push the CAP concept once more <ul><li>Start with generic CAP </li></ul><ul><ul><li>Add project-specific risk analysis </li></ul></ul><ul><ul><li>Identify project-specific compliance needs </li></ul></ul><ul><ul><li>Add named resources </li></ul></ul><ul><ul><li>Add scheduled dates </li></ul></ul><ul><li>Two birds, one stone: </li></ul><ul><ul><li>Project-specific plan for Project Managers </li></ul></ul><ul><ul><li>Project-specific process/document for FHWA </li></ul></ul>
    18. 18. Some things best done with CAPs <ul><li>Start this project right </li></ul><ul><li>Identify compliance tasks for this project </li></ul><ul><li>Manage environmental risk on this project </li></ul><ul><li>Find resources for this project </li></ul><ul><li>Agree who does what when on this project </li></ul><ul><li>Roll with the punches on this project </li></ul><ul><li>Establish accountability on this project </li></ul>
    19. 19. Hang together, or hang separately? <ul><li>Adoption of project-specific risk-based CAP addresses: </li></ul><ul><ul><li>Needs of Project Managers </li></ul></ul><ul><ul><li>Basis for resource sharing in regionalization </li></ul></ul><ul><ul><li>Environmental management system </li></ul></ul><ul><ul><li>Persistent sources of conflict late in process </li></ul></ul><ul><li>May help us avoid the noose altogether </li></ul>
    20. 20. Questions?