Mark Sanborn

The proposed revisions to 771.119 and 771.123 could complicate the process of contracting with consultants to complete environmental assessments or environmental impact statements. In the case of 771.119, FTA should clarify what is meant by “informal scoping.” If informal scoping means project sponsors consulting with stakeholders about the general scope of a project for FTA’s approval prior to hiring a consultant, this provision should be a reasonable means to try to ensure that EA documents are not more extensive and costly than necessary. In the case of 771.123, the completion of formal scoping prior to contracting for EIS documents could mean that the contract for a consultant assisting with the project would have to be revised and the scope and fee renegotiated following scoping. This could delay preparation and completion of the EIS document. This contract revision would also be necessary if “informal scoping” for an EA involves extensive public outreach or preparation of plans requiring consultant assistance.