Section 4(f) Managing the Environmental & Project Development Process Presented by the Ohio...

Section 4(f)

Managing the Environmental & Project Development ProcessPresented by the Ohio Department of Transportation

Provides protection to the following type of properties: Publicly-owned Parks and Recreation Areas Publicly-owned Wildlife and Waterfowl Refuges Private and publicly-owned Historic Sites

What is Section 4(f)?


2

Department of Transportation Act of 1966 United States Code (USC)

49 USC 1653(f) 23 USC 138 49 USC 303 23 USC 138

FHWA Policy Paper (1985, 1989, 2005, 2012) 23 CFR 771.135 (2002) SAFETEA-LU/Section 6009 de minimis (2005) 23 CFR 774 (2008)

Legislative History


3

Federal-Aid Highway Act of 1956 Engineering outweighed community values

Threatened parks and recreation areas Use of parkland seen as less destructive 37 Interstate openings in 1964

Interstate Era


4

Senator Yarborough (TX) introduced 4(f) provision in DOT Act of 1966 in direct response to a project linking Downtown San Antonio to the airport through a park

A Law is Born


5

Section 138 amended to include 4(f) language:

The Secretary shall not approve any project which requires the use of any significant 4(f) property unless:

(1) There is no feasible and prudent alternative to the use of such land, and;

(2) Such program includes all possible planning to minimize harm resulting from such use


Federal-Aid Highway Act of 1968

6

Feasible Constructed with sound engineering

Prudent The evaluation of unusual factors or unique

problems such as cost, environmental, social and economic impacts, or community disruption that reaches extraordinary magnitude

Feasible & Prudent


7

Citizens for Overton Park v. Volpe Use of 4(f) property requires that no unique

problems or unusual factors are involved with the alternatives Upholds feasible and prudent

Social, economic, environmental impacts, community disruption, and/or costs resulting from such alternatives have to reach extraordinary magnitudes

Potential or adverse impacts are formally documented as part of NEPA

1971 Supreme Court Verdict


8

Congress decided it was time to change the law SAFETEA-LU

Better Consistency Better Decisions

Fast Forward to 2005


9

Exempted Interstate System from 4(f) Section 6007

de minimis impacts for parks, recreation areas, wildlife & waterfowl refuges, and historic sites

Section 6009(a) Clarified feasible and prudent

Section 6009(b)

SAFETEA-LU Provisions


10

The Secretary shall not approve any project which requires the use of any significant 4(f) property unless:

(a) It is determined that:

(1) There is no feasible and prudent alternative to the use of such land, and;

(2) Such project includes all possible planning to minimize harm resulting from such use.

(b) de minimis


Present Day

11

In order for the statute to apply to projects, the following conditions must be true:

USDOT funding and/or approval is required Related to transportation Requires the use of land from a 4(f) property No regulatory rules or exceptions apply

23 CFR 774.11 and 774.13

Applying Section 4(f)


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4(f) only applies to USDOT agencies FHWA, FTA, FRA…

USDOT funds required for 4(f) to apply Projects with federal approvals can trigger 4(f)

NHS, IMS/IJS… ODOT prepares determination and associated

documentation FHWA responsible for determinations, evaluations,

findings, and overall compliance


Authority & Responsibility

13

Role property plays based on recreation needs and/or community values

If available and up-to-date, a management plan helps define significance and major purpose

Property presumed significant unless Official with Jurisdiction (OWJ) concludes otherwise

23 CFR 774 FHWA retains final decision

in determining significance


Significance

14

Approved by recognized OWJ Designed to officially designate

major purpose and/or function FHWA retains final decision on

whether plan articulates activities, functions, and major purpose


Management Plan

15

Federal, state, or local agency that owns or administers a 4(f) property or has been empowered to represent on matters related to a property

Examples include, but not limited to: National Park Service Ohio Department of Natural Resources Park Manager/Director City Manager Parks and Recreation Director School Superintendent County Commissioners/Township Trustees

For Cultural Resources, the State Historic Preservation Officer (SHPO) is the OWJ


OWJ Definition

16

Land from a 4(f) property is permanently incorporated into a transportation facility

Temporary occupancy of 4(f) property that is adverse to its functions and activities

Constructive use


Use Definition

17

Proximity impacts, without acquisition of land, cause 4(f) property to be substantially impaired

Capability to perform vital functions or attributes are diminished

Value of property in terms of its significance and enjoyment are substantially reduced or lost

Degree of impairment is determined through consultation with OWJ


Constructive “Use”

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Five Levels of Determination

No Use No incorporation of a 4(f) propertyinto a transportation facility

de minimis“Use,” but because of avoidance, minimization,or mitigation there is no adverse effect on the

attributes, features, or activities of a 4(f) property

Programmatic Evaluation

Minor “Use” of a 4(f) property that meetscriteria established by FHWA

Individual Evaluation

“Use” of a 4(f) property that does not meetProgrammatic Evaluation criteria

No 4(f) No impacts to an existing 4(f) property ORproperty is not subject to 4(f)

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Adjacent properties do not meet criteria

OR 4(f) property is adjacent to the proposed project

area, but will not be impacted Discuss accordingly in environmental document No formal coordination required


No 4(f) Determination

20

No incorporation of land from a 4(f) property into a transportation facility will occur

Key activities, features and/or attributes of 4(f) property are not diminished

Issued by OES Policy Staff for park, recreation areas, and wildlife/waterfowl refuges

Issued by OES Cultural Resources Section at the end of the Section 106 process


No Use Determination

21

FHWA identified exceptions to 4(f) approval 23 CFR 774.13

Do not compromise preservation purpose Contact OES if you have a possible exception


Exceptions

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774.13(a) - Restoration, rehabilitation, or maintenance of transportation facilities listed on or eligible for the NRHP

“No Adverse Effect” to historic qualities 774.13(b) - Archaeological sites listed or eligible for

the NRHP; but not considered important for preservation-in-place


Exceptions

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774.13(d) - Temporary occupancy of land that does not constitute a “use”

Commonly referred to as “Temporary No Use” Short duration and no change in ownership Minor scope; property changes are minimal No anticipated adverse physical impacts and no

interference with protected activities, features or attributes, on a temporary or permanent basis

Land must be fully restored to a condition at least as good as that which existed prior to construction

OWJ concurrence required

Exceptions


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774.13(f) - Certain trails, paths, bikeways, and sidewalks, in the following circumstances:

Trail projects funded under the Recreational Trails Program, 23 U.S.C. 206(h)(2)

National Historic Trails and the Continental Divide National Scenic Trail, with the exception of those trail segments that are historic sites

Occupies a transportation right-of-way without limitation to any specific location within that right-of-way, as long as continuity is maintained

Part of the local transportation system and function primarily for transportation

Exceptions


25

Project Description Mapping & Photographs Purpose & Need Description of 4(f) property

For Cultural Resources Complete 106 process, with effect determination

For Parks and Recreation Areas Obtain OWJ Concurrence that proposed undertaking

will not affect overall activities, functions, or attributes

Submittals


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de minimis

No Use No incorporation of a 4(f) propertyinto a transportation facility

de minimis “Use” but because of avoidance, minimization,or mitigation there is no adverse effect on the

attributes or functions of the 4(f) property





No 4(f)No impacts to an existing 4(f) property OR

property is not subject to 4(f)

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Established in SAFETEA-LU Simplifies processing and approval of a

transportation use of a 4(f) property Considers avoidance, minimization, mitigation, or

enhancements to a 4(f) property Applies to any level of NEPA documentation Does not replace Programmatic or Individual

Evaluations OES coordinates de minimis with FHWA

de minimis


28

Impact will not adversely affect activities, features, and attributes of the resource

Analysis of avoidance alternatives not required Public notice, review, and comment opportunity is

required if: Property is a park, recreation area, or refuge Include notice in the NEPA document

OWJ concurrence is required

de minimis


29

Can apply when a temporary use of property is determined to be adverse

For multiple 4(f) properties: Each property considered separately No project wide consideration Mitigation for each individual property


de minimis

30

Recreation Concurrence from OWJ Public Involvement

Press Release/Public Notice, at a minimum

Cultural Resources Determination of “No Adverse Effect” or “No Historic

Properties Affected” Concurrence with SHPO

Intent to apply de minimis FHWA has considered views of consulting parties

de minimis Requirements


31

Project Description Mapping & Photographs Purpose & Need Description of 4(f) property Discussion of avoidance, mitigation, minimization, or

enhancements Public Involvement Materials Press Release

Only for Parks, Recreation Areas, and Refuges OWJ Concurrence


de minimis Submittals

32

Programmatic Evaluations

No Use No incorporation of land from a 4(f) propertyinto a transportation facility

de minimis Impact Finding

“Use” but because of avoidance, minimization,or mitigation there is no adverse effect on the






No 4(f) No impacts to an existing 4(f) propertyProperty is not subject to 4(f)

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“…time-saving procedural alternative to preparing Individual 4(f) evaluations…for certain minor uses of a 4(f) property…”

Based on experience with a specific set of conditions that includes project type, degree of use, and evaluation of avoidance alternatives

May only be used if specific conditions are met



34

Issued by FHWA Independent Walkway and Bikeways Historic Bridges Minor Involvements with Historic Sites Minor Involvements with Parks, Recreation Lands

and Wildlife & Waterfowl Refuges Net Benefits to a Section 4(f) Property

Specifics of each are different Apply each on its own terms

http://www.environment.fhwa.dot.gov/4f/4fnationwideevals.asp



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Separate, stand alone document May be submitted concurrently with NEPA

document but often done earlier Avoidance Alternatives Analysis required

Not for Independent Walkway and Bikeways Demonstrates why alternatives that avoid 4(f)

property are not feasible and prudent FHWA has 15 calendar days to object



36

Projects with primary purpose of providing bicycle or pedestrian facilities

Can apply as long as the project will not: Impact endangered species habitat Create major impacts or public controversy Create adverse social or economic impacts Displace families and/or businesses

Obtain OWJ Concurrence Avoidance Alternatives Analysis not required


Independent Walkway & Bikeways

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Can be used when the following criteria is met: The proposed project will impair historic integrity

either by rehabilitation or demolition The proposed project meets specific criteria on

alternatives, findings, and mitigation Agreement among SHPO, FHWA, and ACHP is

reached through Section 106 process A finding of “Adverse Effect”


Historic Bridges

38

Can be used when the following criteria is met: The proposed project will not remove or alter

historic buildings, structures, or objects The proposed project will not disturb or remove

archaeological resources determined important for preservation-in-place

Section 106 finding of either “No Historic Properties Affected" or “No Adverse Effect“

Does not apply to EIS projects Essentially replaced by de minimis


Minor Involvements w/Historic Sites

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Can be used when the following criteria is met: Proximity impacts on remaining 4(f) property will

not impair features, attributes, or function OWJ concurs with assessment of impacts and

proposed mitigation No objection from appropriate federal agency if

land was encumbered with a federal interest Does not apply to EIS projects Essentially replaced by de minimis


Minor Involvements w/Parks, Recreation Areasand Wildlife & Waterfowl Refuges

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A transportation use of a park, recreation area, wildlife and waterfowl refuge, or historic site occurs

Assessment of impacts incorporates appropriate measures to minimize harm

Subsequent mitigation incorporated to preserve, rehabilitate and enhance existing features and values that qualified the property for protection

Must obtain OWJ concurrence Applies to all NEPA document levels


Net Benefit

41

Required for the following Programmatics: Historic Bridges Minor Involvements w/Historic Sites Minor Involvements w/Parks, Rec. Areas and

Wildlife & Waterfowl Refuges Net Benefits to a Section 4(f) Property

Analysis demonstrates no feasible and prudent alternative to the “use” of a 4(f) property


Alternatives Analysis

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Project Description Mapping and Photographs Purpose & Need Description of 4(f) property Impacts Discussion Avoidance Alternatives Analysis Measures to Minimize Harm Summary


Programmatic Evaluation Submittals

43


No Use No incorporation of land from a 4(f) propertyinto a transportation facility

de minimis “Use” but because of avoidance, minimization,or mitigation there is no adverse effect on the






No 4(f) No impacts to an existing 4(f) property orproperty not subject to 4(f)

44

Required when conditions of the Programmatic Evaluations are exceeded

Prepared as a stand-alone document Reviewed by other federal agencies Requires FHWA legal sufficiency review

Level 3 & 4 CE, EA, or EIS 4(f) submitted with environmental document

Refer to FHWA Technical Advisory T6640.8A Oct. 30, 1987


Individual Evaluations

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Project Description Project Mapping & Photographs Purpose & Need 4(f) Property Description Impacts to 4(f) Property Avoidance Alternatives Analysis Measures to Minimize Harm/Mitigation Summary


Individual Evaluations for CEs

46

Stand-alone document

OR Separate section of EA Draft/Final document submittal has same

information as in an EIS Coordination with appropriate agencies

Individual Evaluations for EAs


47

Typically: DEIS contains Draft 4(f) evaluation FEIS contains Final 4(f) evaluation ROD contains summary of 4(f) approval

Individual Evaluations for EISs


48

Project Description Description of 4(f) Property Impacts to 4(f) Property Avoidance Alternatives Analysis Measures to Minimize Harm Coordination with OWJ Mapping and Photographs Summary Conclusion of no feasible and prudent alternatives is

made in Final, following coordination of draft


Individual Evaluation & DEIS

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Include all information from Draft, plus: Basis for No Feasible and Prudent Alternatives Basis for conclusion that all possible planning to

minimize harm has been completed Summary of Formal Coordination Copies of formal coordination comments Concluding Statement:

“Based upon the above considerations, there is no feasible and prudent alternative to the use of land from (4[f] property) and the proposed action includes all possible planning to minimize harm to (4[f] property) resulting from such use.”


Individual Evaluation & FEIS

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OES Review 30 Calendar Days

FHWA Review 30 Calendar Days

14 copies to National Park Service 45 Calendar Days

Two copies to HUD or USDA Only when coordination is required (rare)

Plan for at least 6 months!!!


Individual 4(f) Approval Process

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4(f) PROPERTY DETERMINATIONNo impacts

Not subject to 4(f) No 4(f)

ProtectedNo incorporation of 4(f) property “No Use”

ProtectedTemporary Occupancy Temporary “No Use”

ProtectedPermanent Incorporation

“No Adverse Effect”“Temporary Adverse Effect”

de minimis

ProtectedMinor “Use” Programmatic Evaluation

ProtectedMajor Adverse “Use” Individual

Determination Quick Guide

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Type of 4(f) PropertiesManaging the Environmental & Project Development Process

Presented by the Ohio Department of Transportation

53

4(f) Publicly-owned and open to the public

AND Significant for park or recreation purposes

Constitutes major purpose or function Incidental, secondary, occasional or dispersed park

or recreational activities do not constitute a major purpose

Must be officially designated by OWJ May have multiple OWJ


Parks & Recreation Areas

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NOT 4(f) Privately-owned

OR Open to a select group and not the entire public

Gated or public housing communities Military personnel and their dependents Students of a public school Students, faculty and alumni of a public college or

university


Parks & Recreation Areas

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Not defined in 4(f) law or FHWA Regulations FHWA considers the National Wildlife Refuge System

Administration Act as contemporaneous legislation in implementation of 4(f) for refuges

National Wildlife Refuges are 4(f) properties No individual determination of 4(f) status

needed

Wildlife & Waterfowl Refuges


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For purposes of 4(f), properties that may function as refuges include:

State or Federal Wildlife Management Areas Wildlife Reserves Preserve or Sanctuary Waterfowl Production Areas

Includes wetlands and uplands set aside for refuge purposes, in a form of public ownership



57

4(f) Significant publicly-owned property (including waters)

officially designated as refuge by recognized OWJ May have multiple OWJ

Review management plan (if one exists) to determine if major purpose is for:

Conservation, restoration, management of endangered species, protection of habitat, etc.

Recreational activities, including hunting and fishing, are consistent with preservation



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NOT 4(f) Privately-owned land Major purpose is for non-4(f) activities

POINT TO REMEMBER “Open to the public” requirement only applies to

parks and recreation areas Most refuges allow public access, while others do

not, especially during certain times/seasons Public access does not determine 4(f) Review management plan/primary purpose



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4(f) Listed on or eligible for listing on the National Register

of Historic Places (NRHP) Public or Private Ownership


Historic Sites

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4(f) Listed on or eligible for listing on the NRHP Includes individually eligible or listed properties that

contribute to the eligibility of the district Properties within the bounds of a district are assumed

to contribute, unless stated or determined not to be through 106 consultation


Historic Districts

61

4(f) requirements essentially the same as for any historic site determined eligible under Section 106

While not expressly stated in regulations, the importance and significance of NHLs should be considered in 4(f) analysis of least overall harm pursuant to 23 CFR 774.3(c)(1)(iii)

When an adverse effect finding is determined through the Section 106 process and the Secretary of Interior elects to participate, their representative (typically NPS) is the recognized OWJ


National Historic Landmarks

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Consultation with SHPO (OWJ) results in: Rehabilitate Bridge

No Adverse Effect = No Use Adverse Effect = Use

Demolish Bridge Adverse Effect = Use

Donations (Re-Use) Historic Integrity Maintained = No Use

Historic Bridges


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4(f) Listed on or eligible for listing on the NRHP and

important for preservation in place Includes sites discovered during construction SHPO Consultation

NOT 4(f) Important for data recovery only

SHPO Consultation


Archaeological Sites

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4(f) Listed on or eligible for the NRHP and important for

preservation in place Consultation w/SHPO

NOT 4(f) As a result of SHPO consultation, it is determined the

project would occupy only a part of the district considered a non-contributing element

OR Only important for data recovery


Archaeological Districts

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4(f) Applies to portions of public property designated or

identified in an approved management plan for park, recreation, or wildlife & waterfowl refuge purposes, and determined significant

Includes eligible or listed historic sites

NOT 4(f) Park, recreation, or refuge is not the primary purpose

or function No approved plan or plan out-of-date


Multiple-Use Land Holdings

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Playground defined as the area of school property developed and/or used for public park or recreation purposes:

Baseball Diamonds Soccer Fields Tennis Courts Track & Field Facilities Jungle Gyms/Swing Sets Open Space or Practice Fields

4(f) applies to the “playground” area, not the entire school campus

School Playgrounds


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4(f) Publicly-owned and open to the public

AND Serves organized or substantial “walk-on” activities

determined significant for recreation Coordination with OWJ determines significance for

recreational purposes May be more than one OWJ Public agency or organization may be authorized

to use after school hours

School Playgrounds


68

NOT 4(f) Serves school activities and functions only

OR Privately-owned and not opened to the public

School Playgrounds


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Consult with OWJ (Superintendent) to determine recreational significance

OES developed OWJ Letters to be used for these type of projects

Section 4(f) Toolkit (OES website) Contact OES for further guidance

Safe Routes to School and 4(f)


70

4(f) Publicly-owned Designated or functions primarily for recreation Part of Approved Management Plan

Review plan during early consultation with OWJ Helps determine primary purpose

NOT 4(f) Primary purpose is for transportation

Regardless if public or private Considered part of local transportation system Not considered significant for recreation

Bikeways


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Improvement to an existing 4(f) property by a Transportation Enhancement Activity (TEA)

“Use” does not occur when purpose is the preservation or enhancement of the activities, features, or attributes that qualified the property for 4(f) protection

Obtain OWJ Concurrence If a TEA permanently incorporates 4(f) property into

a transportation facility, a “use” occurs Exception at 23 CFR 774.13(g)


Transportation Enhancements

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4(f) Publicly-owned, operated and managed for the

primary purpose of public recreation

NOT 4(f) Privately owned

Even if open to the public

Golf Courses


73

POINTS TO REMEMBER Courses on land owned by public agencies but

managed and operated by private entities may be subject to 4(f) depending on lease agreement

Greens-fees or tee times do not alter 4(f) requirements of public ownership, public access, and recreation significance

Courses that are historic sites are not subject to public ownership and access requirements

Military golf courses not subject to 4(f)

Golf Courses


74

Publicly-owned properties of this nature are not considered parks, recreation areas, or refuges

Not subject to 4(f) unless it is an historic site Publicly-owned zoos evaluated case-by-case

Review Management Plan Considered significant for park, recreation area,

or historic site


Museums, Aquariums and Zoos

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4(f) Open to the public and functions primarily for public

recreation other than an annual fair Applies only to the portion(s) of land significant

for park or recreational purposes

NOT 4(f) Functions primarily for commercial purposes:

Stock Car Races Horse Racing County or State Fairs

Fairgrounds


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Defined as:“A river and the adjacent area within the boundaries of a component of the National Wild & Scenic Rivers System”

Lands in National Wild & Scenic River corridors managed for multiple purposes may be subject to 4(f)

Contingent on manner in which they are managed Four Federal agencies manage WSR corridors:

U.S Forest Service National Park Service (NPS) U.S. Fish and Wildlife Service (USFWS) Bureau of Land Management


Wild & Scenic Rivers

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WSR corridors can have three designations: Wild Scenic Recreational

When determining 4(f): Review River Designation Review how the river is being used Review Management Plan

WSR designation does not in itself invoke 4(f) in the absence of significant 4(f) attributes and qualities



78

4(f) Portions of land designated for recreation or other 4(f)

purposes within a WSR Corridor Review Management Plan

NOT 4(f) Rivers under study (unless significant for above) No approved Management Plan Lands within WSR corridor not open to the public Primary purpose related to non-4(f) activities



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4(f) Publicly-owned

AND OWJ has designated and determined property to be

significant for park, recreational area, or refuge Must be in a city or county Master Plan Desire or intent to designate is not sufficient

NOT 4(f) Privately owned

Planned 4(f) Properties


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Public easements in perpetuity considered publicly-owned land for the purpose the easement exists

Lease agreements may constitute permanent and proprietary interests

Consult with FHWA For conservation easements, FHWA considers

ownership, significance, and major purpose


Easements & Lease Agreements

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SECTION 4(f)PROGRAMMATIC AGREEMENT


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Ohio was the first State DOT to create an agreement with FHWA specific to 4(f)

October 2001 Applies to all levels of environmental classifications Applies only to federally-funded projects Revised Agreement executed 8/24/2012


Background

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Processes Non-Individual Section 4(f) Actions Defines responsibilities regarding Documentation,

Public Involvement, Training, and Monitoring. Establishes a process to effectively coordinate with

the OWJ Establishes procedures to expedite project delivery

per Every Day Counts initiatives Ensures regulations are properly met

What it Does for ODOT


84

Does not delegate FHWA responsibility for making a final 4(f) Approval

FHWA can grant advanced approval for actions described in the agreement

ODOT’s determination based on conditions of the advanced approval ends the paperwork process, unless objection is received

All documentation available through CE Online System or other electronic means

Public Involvement as it relates to Section 4(f) properties better defined

Highlights


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Establishes processing and documentation of exceptions in accordance with 23 CFR 774.13

Establishes a concurrent review process for de minimis determinations for historic properties

FHWA review time matches timeframe allotted for SHPO review per Section 106 PA 15 calendar days

If no objection received from FHWA upon SHPO concurrence, the determination is considered complete upon notification to FHWA

Highlights


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SECTION 6(F)LAND & WATER CONSERVATION FUND ACT

(LWCF)Managing the Environmental & Project Development Process

Presented by the Ohio Department of Transportation

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Preserve, develop, and assure accessibility to all outdoor recreation resources

Strengthen health and vitality Provide funds for and authorize Federal assistance to

the States in the planning, acquisition, and development of certain land and water areas and facilities


LWCF Purpose

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Established by Congress in 1965 Comprised of revenue from offshore oil and gas

leasing, not taxpayer dollars Program divided into two parts:

Grants to State and local governments Federal acquisition of lands, waters, and interests

necessary to achieve the natural, cultural, wildlife, and recreation management objectives of the NPS and other federal land management agencies


Background

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Over $14.4 billion granted to state and local governments to acquire new lands for recreation

Over 40,000 grants approved Over 3 million acres of lands purchased and

protected for recreation purposes Over 29,000 projects have developed basic

recreation facilities in every state and territory


Background

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LWCF Act contains strong provisions to protect federal investments and quality of resources

Discourages casual "discards" of park and recreation facilities by ensuring that alterations or "conversions from recreation use" will bear a cost

Assures taxpayers that investments in the "national recreation estate" will not be squandered


Regulatory Protection

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Section 6(f)(3) No property acquired or developed with LWCF shall be

converted to non-public outdoor recreation uses Such conversion will only be approved if:

In accordance with an existing Statewide Comprehensive Outdoor Recreation Plan (SCORP)

AND Only upon such conditions as deemed necessary

to assure the substitution of other recreation properties of at least equal fair market value and of reasonably equivalent usefulness and location



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Section 6(f)(3) “Anti-conversion" requirement applies to parks and

other sites that received LWCF Regardless if acquisition was for parkland

development or rehabilitation of facilities A small grant for development of a picnic shelter in a

park of hundreds or even thousands of acres provides anti-conversion protection to the entire park site



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Coordination with ODNR/NPS required Conversion Report

Detailed Project Description and Impacts Identifies potential replacement property

Requires preliminary approval from ODNR Appraisals for property to be converted and

replacement property Alternatives Considered Environmental Screening Form (ESF) Mapping


6(f) Conversion Process

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Approval of any conversion request requires: Evaluation of all practical alternatives Design modifications or other mitigation to

reduce impacts Replacement land of equivalent usefulness and

location Coordination with all relevant agencies has taken

place and approvals received


6(f) Conversion Process

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4(f) applies to publicly-owned parks, recreation areas, and wildlife & waterfowl refuges

6(f) applies to properties that received LWCF 6(f) coordination is required with Department of the

Interior (DOI)/NPS In Ohio, ODNR liaisons with NPS

4(f) approval required prior to 6(f) approval


4(f)/6(f) Relationship

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