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Environmental process | Scoping | Interstate Access Requests/Interstate Access Modification Requests

Interstate Access Requests/Interstate Access Modification Requests process

Purpose

The following is an outline of Interstate Access Request (IAR) or Interstate Access Modification Request (IAMR) procedures for analysis and documentation in relation to MnDOT requests for changes in Interstate System access. This process is applicable when a project is on, adjacent to, or may impact the operations/safety of the Interstate, not just for new or modified existing Interstate interchanges (see bulleted list in Background section below for specific criteria). This is an iterative process that works in parallel with the National Environmental Policy Act (NEPA) process and includes a Safety, Operations, and Engineering (SOE) analysis followed by final documentation in the IAR/IAMR.

There is agreement between the Federal Highway Administration (FHWA) and the Minnesota Department of Transportation (MnDOT) that the procedures must be followed by any party conducting such work, whether internal MnDOT staff or a locally led project on the Interstate System, to ensure shared expectations are met and the formal access change request is efficiently processed. Regardless of project proposer, these procedures apply to access changes on the existing Interstate System and new Interstate Systems—not to non-Interstate highways.

Study requirements will differ depending on the complexity of the site in question. Highway routes through heavily developed urban areas with high traffic volumes will undergo greater scrutiny than routes through sparsely populated rural areas with lower traffic volumes. The complexity will affect the limits of the study area, the level of analysis, the measures of effectiveness displayed as evidence in the SOE and IAR/IAMR and the required level of detail of geometric layouts. Other factors such as interchange spacing and complexity of treatment may also elevate study requirements. No matter the level of complexity, all projects must follow the IAR/IAMR process, including discussion of the two IAR/IAMR policy points and five NEPA policy points.

Note that non-standard, complex concepts will require relatively well-developed design drawings to support FHWA’s determination of engineering and operational acceptability. It should also be noted that this process will include review, acceptance, and approval from many MnDOT functional groups including: 

    1. District Planning (review, comment, and approve traffic forecasts)
    2. District Traffic Engineering (produce intersection counts; review, comment, and approve Operational Analysis and Safety Analysis)
    3. District Program Delivery (review, comment, and approve overall IAR/IAMR document)
    4. Geometric Design Support Unit (review, comment, and approve geometrics associated with project concepts)
    5. Office of Environmental Stewardship (review, comment, and approve policy points included in the NEPA document and alternative analysis)
    6. Federal Highway Administration (review, comment, and approve IAR/IAMR and NEPA document)

Background

FHWA has retained all approval rights to the control of access on the Interstate System. This is necessary to protect the integrity of the Interstate System and the extensive investment associated with it. To obtain approval from FHWA to add or modify access to the Interstate System, a request in conformance with this guidance must be submitted to FHWA through MnDOT. This applies to all access changes on the Interstate System regardless of funding and oversight. This guidance is limited to:

    • New interchange(s)
    • Additional lane(s), such as added capacity lanes—general purpose or restricted lanes (E-ZPass)—and auxiliary lanes
    • Modifications to existing interchanges involving access control revisions for new ramps or relocation or elimination of existing ramps
    • Relocation of entrance or exit ramp noses
    • Modification of the access control on arterial roadways at interchanges
    • Projects with potential to change operations of the Interstate and/or interchange (such as a change to a freeway/arterial roadway within one interchange/intersection of an Interstate)
    • Initial construction or modification of transit-only access
    • Initial construction or modification to managed lane-only access

Interchange reconfiguration is a change in access even though the number of actual points of access may not change; for example, replacing one of the direct ramps of a diamond interchange with a loop, or changing a cloverleaf interchange into a fully directional interchange is considered as a revised access.

Access approval is a two-part process that was developed to manage risk and provide flexibility. The first part is an SOE analysis process. The second part is finalizing and documenting the analysis for the recommended alternative in the IAR/IAMR. The SOE and IAR/IAMR work in parallel with the NEPA process.

Level of IAR/IAMR

Level 1: Some access requests require review and approval from FHWA Headquarters in Washington, D.C. These include new freeway-to-freeway interchanges, major modifications of a freeway-to-freeway interchange, and new partial interchanges or new ramps to/from continuous frontage roads that create a partial interchange. Because both the FHWA Minnesota Division Office and Headquarters review the document, this is a longer process.

Level 2: These access requests are approved in the FHWA Minnesota Division Office and do not require FHWA Headquarters approval. These include new freeway-to-crossroad interchanges, modifications of existing freeway-to-crossroad interchanges, completion of basic movements at a partial interchange, abandonment of ramps or interchanges (unless creating a partial interchange), capacity improvements on the Interstate or at an interchange, and safety projects that may impact operations of the Interstate or an interchange.

Level 3: In some cases, a project makes minor modifications to the Interstate or interchange (including ramp terminals or crossroad) that do not negatively affect operations of the Interstate. These types of modifications do not require a full IAR/IAMR, as outlined in Step 23, below.

IAR/IAMR interaction with NEPA

The SOE and IAR/IAMR must be developed in conjunction with the NEPA process. Information developed in the SOE will inform the NEPA document throughout the process.

It is intended that the NEPA process and the IAR/IAMR process be an iterative and symbiotic process. As alternatives are being developed, we are evaluating those elements that will impact both documents. These elements are safety analysis, operational analysis, geometrics, alternatives considered, consistency of the proposed alternatives with Regional Land-Use Plans or Transportation Plans and social, economic, and environmental (SEE) impact considerations.  Each time refinement of an alternative occurs, these elements would be updated, and the associated impacts of the alternative would need to be updated in the NEPA document. Each decision point, including alternatives screening, in the project development process is to leverage the data in both the NEPA and IAR/IAMR documentation.

The approval of the NEPA document cannot occur until the Draft IAR/IAMR has been reviewed by FHWA and resolution of the comments has been achieved. IAR/IAMR approval action is always after approval of the associated NEPA document (i.e., Categorical Exclusion, Finding of No Significant Impact, Record of Decision).

Basic information for traffic analysis of added access to the Interstate

Data must be sufficient so FHWA and MnDOT can perform an independent analysis. A specific situation or project may require additional information or requirements beyond what is defined. In urban areas with closely spaced interchanges and heavy congestion, it may be necessary to go beyond the adjacent interchange(s). This information will be documented in the Methods and Assumptions Memo referenced in Step 2

Policy points

The IAR/IAMR will include two policy points and the NEPA document will include five NEPA policy points.

Interstate access policy points

    1. An operational and safety analysis has concluded that the proposed change in access does not have a significant adverse impact on the safety and operation of the Interstate facility (which includes mainline lanes, existing, new, or modified ramps, and ramp intersections with crossroad) or on the local street network based on both the current and the planned future traffic projections. The analysis should, particularly in urbanized areas, include at least the first adjacent existing or proposed interchange on either side of the proposed change in access (Title 23, Code of Federal Regulations (CFR), paragraphs 625.2(a), 655.603(d) and 771.111(f)). The crossroads and the local street network, to at least the first major intersection on either side of the proposed change in access, should be included in this analysis to the extent necessary to fully evaluate the safety and operational impacts that the proposed change in access and other transportation improvements may have on the local street network (23 CFR 625.2(a) and 655.603(d)). Requests for a proposed change in access should include a description and assessment of the impacts and ability of the proposed changes to safely and efficiently collect, distribute, and accommodate traffic on the Interstate facility, ramps, intersection of ramps with crossroad, and local street network (23 CFR 625.2(a) and 655.603(d)). Each request should also include a conceptual plan of the type and location of the signs proposed to support each design alternative (23 U.S.C. 109(d) and 23 CFR 655.603(d)).
    2. The proposed access connects to a public road only and will provide for all traffic movements. Less than “full interchanges” may be considered on a case-by-case basis for applications requiring special access, such as managed lanes (e.g., transit or high occupancy vehicle and high occupancy toll lanes) or park and ride lots. The proposed access will be designed to meet or exceed current standards (23 CFR 625.2(a), 625.4(a)(2), and 655.603(d)). In rare instances where all basic movements are not provided by the proposed design, the report should include a full-interchange option with a comparison of the operational and safety analyses to the partial-interchange option. The report should also include the mitigation proposed to compensate for the missing movements, including wayfinding signage, impacts on local intersections, mitigation of driver expectation leading to wrong-way movements on ramps, etc. The report should describe whether future provision of a full interchange is precluded by the proposed design.

Except in the most extreme circumstances, all interchanges should provide for all the basic movements. Partial interchanges (less than full interchanges) are generally unacceptable, in part because they have undesirable operational characteristics.  Private-road access is not permitted on the Interstate System.

Five NEPA policy points (include in the NEPA document)

For guidance on the policy points to be addressed in the NEPA process, contact Lisa Elliott,
Environmental Assessment Unit Supervisor, MnDOT Office of Environmental Stewardship.

  1. The need being addressed by the request cannot be adequately satisfied by existing interchanges to the Interstate, and/or local roads and streets in the corridor can neither provide the desired access, nor can they be reasonably improved (such as access control along the surface streets, improving traffic control, modifying ramp terminals and intersections, adding turn bays or lengthening storage) to satisfactorily accommodate the design-year traffic demands (23 CFR 625.2(a)).

    The NEPA document (not the IAR/IAMR) must demonstrate that an access point is needed for regional traffic needs and not to solve local transportation needs. It is of utmost importance to maintain the integrity and primary function of the Interstate System. The Interstate facility must not be permitted to become part of the local circulation system but is to be maintained as the main regional and inter-state highway as it was intended to be. All reasonable measures must be made to provide local access and mobility by means of the non-Interstate network. Existing or possible future roads or streets in the vicinity of the Interstate facility must be evaluated or considered for use as connections to the existing adjacent interchange ramps, in lieu of adding a new interchange or ramp(s). Evaluation means you must define and vet alternative(s) to address this policy point.
  1. The need being addressed by the request cannot be adequately satisfied by reasonable transportation system management (TSM) (such as ramp metering, mass transit, and High Occupancy Vehicle facilities), geometric design, and alternative improvements to the Interstate without the proposed change(s) in access (23 CFR 625.2(a)).

    All TSM strategies, including those that involve improvements to the existing non-Interstate roads and streets, must be fully evaluated (in the NEPA document) in lieu of new or revised access to the Interstate System. Evaluation means you must define and vet alternative(s) to address this policy point.
  1. The proposal considers and is consistent with local and regional land use and transportation plans. Prior to receiving final approval, all requests for new or revised access must be included in an adopted Metropolitan Transportation Plan, in the adopted Statewide or Metropolitan Transportation Improvement Program (STIP or TIP), and the Congestion Management Process within transportation management areas, as appropriate, and as specified in 23 CFR 450, and transportation conformity requirements of 40 CFR 51 and 93.

    Coordination with strategic, approved long-term transportation plans must be ensured, to avoid fragmented consideration of revised or added access. The NEPA document must include a discussion about how the proposal fits into the overall transportation plans for the area and, if it is an addition to the current plans for the area, how it affects the current plans. The access proposal does not have to be included in official transportation plans or approved by metropolitan planning organizations (MPOs) or similar organizations prior to submittal to FHWA. However, if the project is within an MPO area, coordination with the MPO must occur and documentation provided to articulate the MPO perspective on meeting this policy point. All such coordination must be completed before FHWA approval of the NEPA document and IAR. This must form part of the normal project development process. The expectation is that any proposal is considered in view of currently known plans for transportation facilities or land use planning. The plans are as follows:
    1. Duluth–Superior Metropolitan Interstate Council: Sustainable Choices 2050 Long Range Metropolitan Transportation Plan
    2. Grand Forks–East Grand Forks Metropolitan Planning Organization: 2045 Metropolitan Transportation Plan
    3. Saint Cloud Area Planning Organization: Metropolitan Transportation Plan: Looking Ahead 2050
    4. Fargo–Moorhead Metropolitan Council of Governments: Metropolitan Transportation Plan
    5. Twin Cities Metropolitan Council Transportation Policy Plan Appendix F: 2020 Update to the 2040 Transportation Policy Plan
    6. La Crosse Area Planning Committee: Metropolitan Transportation Plan
    7. Rochester–Olmsted Council of Governments: 2045 Long Range Transportation Plan
    8. Mankato/North Mankato Area Planning Organization: Long Range Transportation Plan 2045 Update

  2. In corridors where the potential exists for future multiple interchange additions, a comprehensive corridor or network study must accompany all requests for new or revised access with recommendations that address all the proposed and desired access changes within the context of a longer-range system or network plan (23 U.S.C. 109(d), 23 CFR 625.2(a), 655.603(d), and 771.111).

    To the extent practicable, MnDOT will program, and thus allow coordinated analysis and project development, of logical Interstate segments which may include multiple access sites (interchanges). The NEPA and IAR policy points process must act as the corridor/network look. This corridor/network look includes the traffic analysis incorporating a sensitivity analysis component for interchanges (new or modified) within the traffic study area that have successfully gotten through the NEPA process but have not yet been constructed as well as new/modified interchanges that are in approved plans (such as local comp. plans). The NEPA/IAR process evaluates alternatives for the purpose/need at hand but does not provide environmental clearance for those interchanges that are already IAR-approved or interchanges that are only in a planning document. The sensitivity analysis evaluates the performance and viability of each alternative at hand with and without those other potential interchanges in the study area to better understand system dynamics.
  1. When a new or revised access point is due to a new, expanded, or substantial change in current or planned future development or land use, requests must demonstrate appropriate coordination has occurred between the development and any proposed transportation system improvements (23 CFR 625.2(a) and 655.603(d)). The request must describe the commitments agreed upon to assure adequate collection and dispersion of the traffic resulting from the development with the adjoining local street network and Interstate access point (23 CFR 625.2(a) and 655.603(d)).

    MnDOT and FHWA must ensure the Interstate System is preserved and improved in an orderly and coordinated manner to serve the public and maintain the essential function of this most important highway network. Therefore, if private development is the impetus behind the need for access, it is necessary to coordinate efforts with the private party to develop the access to achieve mutual benefits with no safety or operational adverse impacts on the Interstate users.

Interstate Access Request/Interstate Access Modification Request and the NEPA Process

Step 1: Start

This activity begins at the time the need for a project is determined—usually at the start of scoping.

Step 2: Early coordination meeting with FHWA about NEPA and IAR/IAMR requirements

This step sets the framework for the development of the proposed project from start to finish.  The intent is to meet with the FHWA Minnesota Division office to reach consensus on the parameters that will be used to develop and analyze the project, including:

    1. Day of opening and design year traffic forecast for analysis
    2. Required Intersection Control Evaluation (ICE) reports
    3. Safety analysis for the project and years of crash data for baseline
    4. Appropriate level of traffic analysis required for the project
    5. Full simulation
      1. Limits of analysis for all roadways
    6. Highway Capacity Manual analysis
    7. Likely level of environmental documentation required for the project

These decisions must be agreed upon by both parties, documented in a Methods and Assumptions Memo and kept in the project file for future reference. This will also assist in the development of a scope of services for a consultant contract, if necessary.

Step 3: Review consistency with MPO policy plans

If the proposed project falls within the limits of a Metropolitan Planning Organization, the project shall be reviewed for consistency with that agency’s policy plan to determine consistency. This process shall be documented in the NEPA document as well as kept within the project file. (See links provided in NEPA policy point 3, above, for the plans to coordinate.)

Step 4: Develop safety analysis for existing conditions

Safety on the project corridor must be reviewed to develop the baseline that will be used for comparison. The crash history for a reasonable period (typically 5 years, but long enough time to identify potential crash clusters or trends with the study area’s current roadway geometrics/configuration as documented in the Methods and Assumptions Memo) will be reviewed to determine if there are any clusters of crashes, determine the crash rate for the corridor, and develop the severity rate for the corridor. This will be documented in a summary report for the overall traffic analysis for the project.

Steps 5 and 6: Obtain existing traffic data and develop existing traffic forecast

Obtain existing traffic data to develop the existing traffic forecast for the project corridor. The forecast should include data for all roadways and intersections within the project limits and include:

    1. Existing Average Annual Daily Traffic (AADT)
    2. AM/PM peak period volumes
    3. Heavy Commercial AM/PM AADT
    4. Turning movements at intersections
    5. Existing queue lengths at intersections
    6. If applicable, oversize/overweight freight movements of high frequency

The existing traffic forecast will be documented in an overall traffic report and in the development of the purpose and need for the project. This forecast must be reviewed and approved by MnDOT.

Step 7: Review existing conditions of assets and any other needs

Review each asset within the project study area to determine if the project should include it in scope or needs. This includes assets such as pavements, bridges, traffic signals, drainage structures, signage, sidewalks, American Disability Act (ADA) accommodations, traffic mitigation, etc. Also review any other needs along the corridor, such as those related to walkability and bikeability. These needs will be identified and documented within the NEPA document consistent with the Transportation Project Development Process (TPDP) subject guidance for purpose and need statements.

Step 8: Distribute Early Notification Memo

This initiates the review of the project by the key functional areas, including the Cultural Resources Unit, Environmental Investigation Unit, and Threatened and Endangered Species.

Step 9: Develop no-build alternative forecast

Develop the no-build traffic forecast. The forecasted year is 20 years from the day of opening. This should include data for all roadways and intersections within the project limits and include:

    1. Average Annual Daily Traffic (AADT)
    2. AM/PM peak period volumes
    3. Heavy Commercial AM/PM AADT
    4. Turning movements at intersections
    5. Queue lengths at intersections
    6. If applicable, oversize/overweight freight movements of high frequency

The no-build forecast will be documented in an overall traffic report and in the development of the purpose and need for the project. This forecast must be reviewed and approved by MnDOT.

Step 10: Develop safety analysis for no-build for the forecasted year

Based upon the forecasted volumes for the forecasted year, the project area shall be evaluated for safety based upon crashes, crash rates, and severity rates. This will be documented in the traffic report.

Step 11: Develop operational analysis for existing conditions (calibrated model)

Based upon the information provided in steps 5 and 6, the operational analysis model can be developed for the no-build scenario. This model will be calibrated to reflect the current operations of the corridor being evaluated. This analysis shall be reviewed and approved by MnDOT.

Step 12: Develop operational analysis for no-build alternative in the forecasted year

Based upon the results of Steps 9 and 11, the operational analysis for the no-build alternative in the forecasted year can be modeled. This will assist in the identification of expected level of service, safety, and mobility in the forecasted year if nothing is done on the corridor. This analysis shall be reviewed and approved by MnDOT.

Step 13: Develop purpose and need statement and evaluation criteria for project

Based upon the results from Steps 7, 8, 10, and 12, the purpose of the project, the need for the project, and the criteria that will be used to evaluate and measure compliance with the purpose and need will be developed.

The operational analysis will assist with the identification of mobility issues, the existing safety analysis will identify potential crash clusters or issues on the existing corridor, the evaluation of the existing conditions of the assets on the corridor will allow for the assessment to update or replace the infrastructure to preserve the integrity of the roadway, the review of consistency with the MPO Policies will ensure compliance with the vision, and the distribution of the Early Notification Memorandum will assist in identification of SEE issues to be addressed with the project. The selection criteria should reflect the evaluation of these needs.

Note: Following the TPDP guidance for developing purpose and need statements, safety and/or mobility may not necessarily be a project need. A safety and operational analysis is still required as part of the SOE and IAR/IAMR documentation.

Step 14: Reaffirm appropriate level of analysis for the IAR/IAMR and affirm NEPA class of action

This is a follow-up meeting from Step 2. Additional information is available to the project team to assess the scope of the project at a high level. Based upon the information that has been gathered, the identification of the purpose and need for the project, and the criteria that will be used to evaluate each proposed build alternative, a decision can be made regarding the appropriate class of action for NEPA (Environmental Impact Statement, Categorical Exclusion, or Environmental Assessment) and the level of analysis required for evaluating operations and safety on the project.

Step 15: Develop concepts for build alternatives (LAY 1040 in P6)

Based upon the purpose and need for the project, alternatives that address the needs of the project should be developed for further analysis, including preliminary geometric layouts and profiles.

Step 16: Evaluate SEE impacts and the five NEPA policy points for all build alternatives

SEE Impacts and the five NEPA policy points will be part of the evaluation for each of the build alternatives and the no-build alternative. Examples of SEE impacts include Section 7, Section 10, 401/404 Permit, etc. This will be in addition to the criteria developed for evaluation in Step 13.

Step 17: Develop build alternative(s) forecast

Develop the build forecast to model traffic for each build alternative. This should include data for all roadways and intersections within the project limits and include:

    1. Average Annual Daily Traffic (AADT)
    2. AM/PM peak period volumes
    3. Heavy Commercial AM/PM AADT
    4. Turning movements at intersections
    5. Queue lengths at intersections
    6. If applicable, oversize/overweight freight movements of high frequency

The build forecast(s) will be documented in an overall traffic report and in the development of the purpose and need for the project. These forecast(s) must be reviewed and approved by MnDOT.

Step 18: Develop safety analysis for build alternatives in the forecasted year

Using the agreed upon method for measuring and documenting safety performance for the build alternatives, evaluate the effectiveness of each build alternative in comparison to the no-build alternative in the forecasted year.

Step 19: Develop operational analysis for build alternatives in the forecasted year

Develop operational analysis for each build alternative in the forecasted year. This analysis must be reviewed and approved by MnDOT.

Step 20: Refine build concepts for the forecasted year

The development and refinement of the alternatives should be an iterative process where you evaluate the safety and operations of each alternative and, if there are crash clusters or congestion predicted, determine if they could be mitigated with additional scope. For example, if the original operational analysis shows congestion between two ramps, would an auxiliary lane between the ramps mitigate that congestion? If so, the SEE impacts and the analysis for the safety and mobility shall be updated, such that the NEPA document has the appropriate information.

Step 21: Develop the draft NEPA document

Develop the draft NEPA document (Categorical Exclusion, Environmental Assessment, Draft Environmental Impact Statement) based on the information gathered through the evaluation of performance for each of the needs, the SEE impacts, the safety analysis, and the mobility analysis.

Step 22: Select recommended alternative based upon NEPA and SOE analysis

After step 21, each alternative should be evaluated in comparison to the no-build alternative for the criteria developed. A recommended alternative should be selected based upon the alternative that meets the purpose and need for the project and provides reasonable performance at a reasonable price against the selection criteria and the associated SEE impacts.

Step 23: Determine if full IAR/IAMR is required

This is another checkpoint in the process. Meet with FHWA to review the project and reach consensus on the next steps. A Level 3 decision would be that no further analysis is required; in this case, add a memo to the project file to document that decision and complete the NEPA document. Alternatively, with a Level 1 or 2 decision, proceed with completing the full IAR/IAMR. Evaluate the recommended alternative for day of opening and complete the IAR/IAMR document.

Step 24: Update draft NEPA document based upon revised impacts and IAR/IAMR considerations

Update the draft NEPA document based upon the information gathered from the analysis performed for the project and addressing the seven policy points. Five of these policy points are addressed as part of the NEPA Document while two of the policy points are addressed in the IAR/IAMR.

Step 25: Develop day of opening forecast for the recommended alternative

Develop the day of opening forecast for the recommended alternative. The day of opening date should be agreed upon and documented with FHWA concurrence. The forecast should include data for all roadways and intersections within the project limits, including:

    1. Average Annual Daily Traffic (AADT)
    2. AM/PM peak period volumes
    3. Heavy Commercial AM/PM AADT
    4. Turning movements at intersections
    5. Queue lengths at intersections
    6. If applicable, oversize/overweight freight movements of high frequency

Document the day of opening forecast in the overall traffic report. This forecast shall be reviewed and approved by MnDOT. Depending on the complexity or importance the forecast plays in the decision-making process, MnDOT may request the MPO to review and comment on the forecast.

Step 26: Develop day of opening safety analysis for the recommended alternative

Develop the day of opening safety analysis for the recommended alternative. This shall include discussion of crash rates and severity rates. It should also identify any crash clusters predicted based on the design.

Step 27: Develop draft signing plan for recommended alternative

The draft signing plan for the recommended alternative shall be developed and documented in the IAR/IAMR document.

Step 28: Develop day of opening operational analysis for the recommended alternative

The operational analysis for the recommended alternative shall be developed and analyzed for day of opening. This analysis shall be reviewed and approved by MnDOT.

Step 29: Confirm policy points are addressed

There are seven policy points that need to be addressed. Five of these policy points will be documented in the NEPA document and two policy points will be documented in the IAR/IAMR document. Verify that they have each been addressed.

Step 30: Develop draft IAR/IAMR

Develop the draft IAR/IAMR based upon the analysis that has been completed to date. Complete the two policy points to be addressed in the document. 

Step 31: MnDOT review of the IAR/IAMR

The project manager shall submit the draft document for review by MnDOT functional areas.  The project manager must gather and resolve comments from MnDOT internal review before submitting to FHWA for review. 

Step 32: FHWA review of the IAR/IAMR

The draft document shall be routed to FHWA for review. E-mail it to Anna Varney, Traffic Operations Engineer, FHWA Minnesota Division. The review could require 30 days (Level 2) to 90 days (Level 1), dependent upon the need to route the document to Washington, D.C. for review.

Step 33: Review and update the IAR/IAMR based upon FHWA comments

The FHWA comments shall be reviewed and resolved prior to resubmitting the document to FHWA.

Step 34: FHWA review of the IAR/IAMR

The revised Draft IAR/IAMR shall be resubmitted to FHWA for review. This duration is expected to be two weeks.

Step 35: Complete NEPA document

The NEPA document (Categorical Exclusion, Environmental Assessment/Finding of No Significant Impact, or Environmental Impact Statement/Record of Decision) cannot be approved unless FHWA accepts that the IAR/IAMR has been developed to an acceptable level.

Step 36: Finalize IAR/IAMR document and route for approval

Upon receiving concurrence from FHWA, the final document can be processed for final approval at MnDOT and FHWA.

Step 37: Complete staff-approved layout

Upon the approval of the NEPA Document and the IAR/IAMR, the final geometric layout can be developed and routed for approval.