The Bridge as Bat Cave
A sharp decline in bat numbers prompts Oregon’s Department of Transporation to build habitats into bridges.
By Tina Grady Barbaccia
Build a bridge, save a bat.
That’s what the Oregon Department of Transportation (ODOT) has done as part of its Oregon Transportation Investment Act (OTIA III) State Bridge Delivery Program, a 10-year, $1.3-billion program that is repairing and replacing hundreds of bridges across the state.
Knowing that bat numbers in the United States have fallen sharply since the 1960s, ODOT proactively incorporated bat habitats on bridge projects to promote roosting. Included in these measures was the development of an outcome-based Bat Habitat Enhancement environmental performance standard (EPS).
Aware of what a laborious process it could be to obtain permits for each bridge separately, ODOT initiated a program — environmental programmatic permitting — that incorporated both state and federal partners, which served as the process that brought together myriad agencies under one permit. This captured regulatory commitments on a program level versus a project level. The state and federal partners together formed the Programmatic Agreements Reporting and Implementation Team, or PARIT. The team met regularly to resolve any challenges and discuss common goals. This not only sped up the bridge permitting process, but it allowed the team to develop other innovations under the same programmatic such as wildlife passages and the Fluvial Performance Standard (go to www.obdp.org/partner/environmental/performance/ for more information) — enhancements that may have been otherwise overlooked.
The normal standalone project delivery process includes a biological opinion, and then an assessment that must be processed through each agency. “It can be a complicated, time-consuming process just to get everything lined up for one site,” says Geoff Crook, environmental manager for the OTIA III Bridge Delivery Unit. “Regulations are often prescriptive and define what you can and cannot do in a quantitative way. However, instead of having many permits with many agencies, a programmatic batches everything together. Our solution was to take a collaborative approach to deliver the program. Focusing on areas of mutual agreement — e.g., safety, economic development, efficiency and environmental stewardship — we developed a single set of environmental performance standards that meets the intent of all the contributing agencies’ regulations while allowing contractors maximum flexibility in how they achieved them.”
This allowed the biological opinion to be batched together to make everything eligible under one permit. The formation of a multi-agency PARIT team also allowed ODOT quick access to decision makers, which allows for quicker responses times and flexibility during design and construction.
“That is efficiency in and of itself,” Crook says. The streamlined process was also cost-effective. In a cost-benefit analysis of the return on investment for programmatic permitting in terms of cost avoided, return on investment (ROI) was $3.19 for every $1 spent, according to Crook. Using a traditional permitting approach, the ROI was 75 cents for every $1 spent. What’s more, the efficiency of putting together a programmatic permitting process enabled ODOT to wrap up the environmental portion of the 10-year bridge program this past fall. Originally set for completion in 2013, the environmental programmatic permitting team wrapped up its work in only seven years. By some estimates, it would have taken 50 years to permit all the bridges — nearly as long as the 75-year expected lifespan for the structures themselves — if the traditional permitting process was used.
One program, multiple agencies
In the development of environmental programmatic permitting, performance standards of multiple regulatory agencies were synthesized to satisfy multiple requirements under one permit.
Included in the programmatic permit were standards for bat habitats. “We’d like to do something for the uplift of the species,” Crook says.
Bats are not a regulated species in Oregon, although in some states they are “endangered” or “threatened.” But bat numbers have been declining, so when the programmatic permit was being developed, ODOT worked with the Oregon Department of Fish and Wildlife and the U.S. Department of Fish and Wildlife to develop standards that could be rolled into the programmatic. The standard outlines a goal — to maintain, replace or improve roosting on bridges over waterways. This standard was only developed for bridges over waterways because this is where bats’ primary food source is.
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