Environmental process | Environmental review | Environmental Management Plan

Environmental Management Plan (Green Sheet) process

• Environmental Management Plan Manual: Tracking Mitigation Commitments (PDF)
• Appendix A: Roles and Responsibilities
• Green Sheet Template (Excel)
• Commitments Library (Excel)

Introduction

The Environmental Management Plan (EMP), also called the Green Sheet, is the method the Minnesota Department of Transportation (MnDOT) uses to track social, economic, and environmental commitments identified during the project development process to ensure these commitments are implemented. The EMP is flexible and can adapt to different project scopes; from smaller projects with limited environmental effects to large and complex projects that require extensive tracking and reporting. Currently, the EMP applies only to the state highway construction program and does not apply to state aid projects.

For purposes of this guide, a commitment is a measurable action taken to avoid, minimize, or mitigate project-related impacts to the human and natural environment. Tracking environmental commitments is necessary for these reasons:

1. To ensure that environmental commitments are implemented
2. Comply with state and federal law and Federal Highway Administration (FHWA) oversight requirements, and
3. Build and maintain trust between MnDOT and its regulators, partners, and stakeholders. 

Environmental commitments are identified at several points during project development and delivery. The process starts with project development and continues through environmental review, plan development, construction, and maintenance. As a living document, the EMP develops concurrently with the project and adjusts to reflect changes in project impacts, scope, and design. If the project scope or design changes from prior plan review, the project manager coordinates with functional areas to re-evaluate changes and updates to environmental commitments. During final design, the EMP is reviewed to ensure that all mitigation and environmental commitments are part of the plans, specifications, and estimates (PS&E) package. The EMP is incorporated into the plan to serve as a checklist of environmental commitments and a reference of how each commitment will be implemented. During construction, the EMP is used to ensure and document completion of mitigation and environmental commitments.
The EMP process intends to capture all environmental commitments. However, any commitments included in permits or other legal documents, or elsewhere in special provisions, that are not included in the Green Sheet, must still be completed by the contractor.

All MnDOT-led and MnDOT-let transportation projects beginning construction in the 2026 calendar year require EMPs. As part of the phase in process, since December 1, 2018, all projects with federal environmental assessments and environmental impact statements required EMPs. In addition, EMPs have been required on State environmental assessment worksheets (EAW).  Starting in 2020, EMPs have been getting phased in on an increasing number of projects regardless of the type of environmental document.

Regulatory requirement

MnDOT is required to ensure that federal-aid projects comply with all environmental commitments, laws, and regulation. The FHWA Minnesota Division has directed MnDOT to demonstrate compliance to the Code of Federal Regulation (CFR) including NEPA design and construction phases. The Environmental Management Plan (EMP) is the MnDOT process for complying with these requirements.

23 C.F.R. part 771.109(d):

When entering into Federal-aid project agreements pursuant to 23 U.S.C. 106, it shall be the responsibility of the State highway agency to ensure that the project is constructed in accordance with and incorporates all committed environmental impact mitigation measures listed in approved environmental review documents unless the State requests and receives written FHWA approval to modify or delete such mitigation features.

While not a specific regulatory requirement, MnDOT has elected to use EMPs for state-funded MnDOT- led and MnDOT- let transportation projects.

Process Throughout Project Delivery

Environmental commitments are identified at several points during project development and delivery. The process starts with project development and continues through environmental review, plan development, construction, and maintenance. As a living document, the EMP develops concurrently with the project and adjusts to reflect changes in project impacts, scope, and design.

As such, the process involves multiple positions or functional roles to complete the tasks associated with development of an EMP. Although roles vary from district to district, the process is consistent statewide.
The table below outlines the main tasks associated with phases of project delivery. Tasks are assigned to roles including:  Environmental Review Specialists, Subject Matter Experts, Project Managers, Designers, Project Supervisors, Inspectors, or Maintenance. Designation of responsibilities vary by district.

*Only one role can be assigned to this task.

Consultant Led Plan Development

Consultant led project development should follow the process outlined in the manual.  The template Scope of Work currently assumes the consultant is involved after Early Notification Memorandum review and until 100% plan turn in. If this is not the case, the scope needs to be adjusted. The Scope of Work directs the consultant to create the Environmental Management Plan according to instructions in this manual. This includes using the designated ProjectWise folder for EMPs and providing drafts for review at pre-identified plan reviews.

Design-Build Projects

The process of developing and implementing an EMP will differ for design-build projects.
MnDOT will begin the EMP as described in the Manual, when the Early Notification Memo is sent for a project.  Commitments will be updated to the extent possible and included in the request for proposals.  After the project is awarded the design-build contractor will update the commitments and the plans as necessary to ensure that the project effectively implements all commitments.