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16 cycles offer greater opportunities for cross-checking data to to ensure that all the information was entered into the form prevent a secondary, "clean-up" amendment later; more pub- correctly (CMAP and ARC are two examples). Second, the lic awareness; and reduced staff time to process individual change to a cyclic schedule for processing TIP administrative TIP changes. ARC staff noted that if any agency took issue modifications was seen as another way of helping to ensure with a proposed administrative modification, then the pro- that a project sponsor considers the request thoroughly, posed revision immediately was withdrawn and moved to because an error during the project submittal implies a con- amendment status. The amendment would then require con- siderable wait until the next cycle. The MPOs noted that, siderably more attention, analysis, public engagement, and for TIP amendments, considerably more discussion occurs board review than an administrative modification. among the MPO, state DOT, or other sponsoring agency because the amount of information typically required to A few MPOs mentioned that because they update their process the amendment is greater than that for an adminis- TIP on a yearly basis, they do not have as many project trative modification. Amendments, for example, may require changes as they would if they updated it less frequently. an understanding of forecasted travel impacts that requires new modeling efforts, fiscal impact assessments, or mobile source emissions analyses. INITIAL INFORMATION AND CONSISTENCY OF INFORMATION AMENDMENT AND MODIFICATION GUIDANCE To process amendments and modifications, information detailing the change is needed from the sponsoring agency Federal regulations contain overarching definitions of what (often the state DOT). Some MPOs have successfully uti- constitutes an amendment versus a modification, but it is lized forms or shared databases to track changes and stream- left up to the individual MPO to coordinate with the state line the process, whereas others report having struggled to DOT, transit operators, and federal transportation agencies get accurate and consistent information. A common theme to further define an administrative modification and amend- in the case study interviews was that the MPOs may have a ment. To properly define the difference, some MPOs have form, or in one case a database, for TIP changes, but they are created their own guidance and coordinate with their respec- not used. One of the reasons given for this is that the sponsor- tive DOTs, others work under a single statewide guidance, ing agency is used to e-mailing one point person; the other is and some have informal memorandums of understanding that filling out forms or entering information into a database (MOUs) in place with their DOT. What has seemed to work, is time-consuming and cumbersome for staff. However, the when guidance is lacking, is bringing all the MPOs in the lack of a centralized system or at least common procedures state together with their DOT to discuss the problem areas and forms can lead to inconsistent information among the and clarify what degree of change to a project will trigger an sponsoring agency, the MPO, and the DOT, thus creating amendment. more work at all levels. One MPO noted that the TIP has turned into a dynamic document, but because they receive The following are examples of the administrative modifi- word of TIP changes verbally or over e-mail they then have cation and amendment threshold guidance reports obtained to work backwards to track down exactly what the change from MPOs. entails and why it is taking place. Other MPOs are realizing that they have differing information from their state DOTs Capital District Transportation Committee regarding finances or project scopes, adding extra steps to the revision process. One state has implemented a system The Capital District Transportation Committee (CDTC) wherein once a TIP change has been adopted, the MPO is breaks out amendments according to minor and major the entity that makes the change to the project in the STIP. amendments. Minor amendments can be approved by Although this procedure adds an extra step for the MPO, all CDTC or New York State DOT (NYSDOT) in some cases the information, particularly the financials, is consistent at or the Planning Committee in others. Major amendments go all levels. through the Planning Committee for recommendations and then to the Policy Committee for final approval. The CDTC Without accurate and thorough information in the earli- sets thresholds for changes based on project additions as well est stage of a TIP revision, the same project may go through as scope and cost changes. multiple revisions that could have been accomplished all at once. Several MPOs noted that it was not uncommon for Addition of project under or equal to $250,000: The one project to go through multiple revision processes as new Planning Committee internally discusses and approves. or updated information came available to the sponsoring No Policy Board action is necessary unless the Planning agency (DOT or member jurisdictions). The responses to Committee finds it necessary. If one element of a proj- this situation were somewhat obvious, but important. First, ect is changed, then the CDTC or NYSDOT staffs can some MPOs have created a project revision template or form approve the revision.

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17 Addition of project over $250,000: The Planning Project Cost Percentage Increase in Committee makes recommendations on the change Project Cost to the Policy Board, which has final approval over the change. If only one element of the project is changing, <$250,000 75% then no action by the Policy Board is required. Changes to the scope or cost of the project of 25% or $250,001$1 million 30% more (min: $250,000) or over $500,000 require discus- sion of the Planning Committee but no Policy Board $1 million$3 million 20% action. Cost changes over 50% of the total project value or more than $3 million require actions by both the >$3 million 15% Planning Committee and Policy Board. DuluthSuperior Metropolitan Interstate Council Missoula MPO The Duluth-Superior Metropolitan Interstate Council (MIC) Montana MPOs work under draft procedures established is a bi-state MPO that has two sets of TIP procedures, one cooperatively with the Montana DOT, but these procedures for Minnesota and one for Wisconsin. Within its Public have not been formally adopted. The purpose is to clearly Involvement Plan, the Minnesota formal TIP amendments define administrative modifications and establish a procedure are approved by the Technical Advisory Committee (TAC) for processing them. Changes that do not meet the modifica- and MIC at regularly scheduled public meetings. tion criteria are considered amendments and require public review and comment, redemonstration of fiscal constraint, TIP administrative modifications are needed when a or a conformity determination (for "nonexempt" projects in project is moved into the current TIP year from a later year. nonattainment and maintenance areas). Justification is needed to explain which specific projects are deferred to maintain fiscal constraint. Administrative Minor changes that do not affect scope, financial con- amendments are allowed for cost increases up to the follow- straint, air quality conformity, or NEPA environmental doc- ing total project costs. umentation do not meet the thresholds for an amendment. Cost change thresholds for an amendment are as follows: Project CostPercentage Increase in Project Cost Project CostPercentage Increase in Project Cost <$1 million$3 million 50% Under $100,000 30% $3 million$10 million 35% $100,000500,000 25% $10 million$50 million 20% $500,000$1 million 20% $50 million$100 million 15% $1 million$2 million 15% >$100 million 10% Over $2 million 10% Major amendments in Wisconsin include a 30-day public comment period and analysis of air quality and community North Central Texas Council of Governments impact assessment/environmental justice. The amendment then proceeds through the regular MIC, TAC, and state The North Central Texas Council of Governments DOT approval process. A major amendment is necessary if (NCTCOG) established a quarterly revision cycle for TIP an added or deleted project meets the thresholds of 10% of changes. Administrative amendments are TIP modifications the total federal funding programmed for the calendar year, that do not require action of the Regional Transportation or $1,000,000. Council (Policy Board) for approval. Instead, the Director of Transportation for the MPO approves TIP modifications that Atlanta Regional Commission meet a multitude of conditions, which can be found in the full policies and procedures. Administrative amendments The Atlanta Regional Commission (ARC) defines its amend- are allowed for cost increases up to the following percent- ment process in Appendix D of its Public Involvement Plan. ages based on the total project cost. It will accept revisions from project sponsors at any point in