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Transportation Improvement Program Revision Process (2011)

Chapter: CHAPTER THREE State of the Practice for Addressing Transportation Improvement Program Revisions

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Suggested Citation:"CHAPTER THREE State of the Practice for Addressing Transportation Improvement Program Revisions." National Academies of Sciences, Engineering, and Medicine. 2011. Transportation Improvement Program Revision Process. Washington, DC: The National Academies Press. doi: 10.17226/14557.
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Suggested Citation:"CHAPTER THREE State of the Practice for Addressing Transportation Improvement Program Revisions." National Academies of Sciences, Engineering, and Medicine. 2011. Transportation Improvement Program Revision Process. Washington, DC: The National Academies Press. doi: 10.17226/14557.
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Suggested Citation:"CHAPTER THREE State of the Practice for Addressing Transportation Improvement Program Revisions." National Academies of Sciences, Engineering, and Medicine. 2011. Transportation Improvement Program Revision Process. Washington, DC: The National Academies Press. doi: 10.17226/14557.
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Suggested Citation:"CHAPTER THREE State of the Practice for Addressing Transportation Improvement Program Revisions." National Academies of Sciences, Engineering, and Medicine. 2011. Transportation Improvement Program Revision Process. Washington, DC: The National Academies Press. doi: 10.17226/14557.
×
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Suggested Citation:"CHAPTER THREE State of the Practice for Addressing Transportation Improvement Program Revisions." National Academies of Sciences, Engineering, and Medicine. 2011. Transportation Improvement Program Revision Process. Washington, DC: The National Academies Press. doi: 10.17226/14557.
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15 CHAPTER THREE STATE OF THE PRACTICE FOR ADDRESSING TRANSPORTATION IMPROVEMENT PROGRAM REVISIONS status and as appropriate impacts of conformity analysis on process schedule; TIP amendment and modification pro- cedures; and triggers for a TIP revision. Every MPO was also asked specific questions tailored to that MPO in order to generate clarity or additional information related to prior survey responses. Appendix B contains the complete notes from each tele- phone interview. The following paragraphs summarize the findings from the MPO case examples, surveys, and litera- ture review. VOLUME AND FREQUENCY OF REVISIONS One MPO requested as many as 300 to 1,000 TIP changes per month; other MPOs also cited volumes of changes in the hundreds in some fiscal quarters. Owing to external circum- stances such as the economy, ARRA, other grant programs, air quality, and shifts in transportation priorities, the TIP has become a more dynamic document. With so many fac- tors to consider, MPOs are struggling to limit both major and minor changes to projects. Some MPOs have success- fully used forms and database technologies to manage TIP changes. For example, the Chicago Metropolitan Agency for Planning (CMAP) has developed an online database tool for recording and even processing administrative amendments, and the Atlanta Regional Commission (ARC) has plans to do the same after the next TIP update. These tools allow revi- sion sponsors (typically state DOTs, local governments, or other members of the MPO trigger the revision) to log in and suggest changes to the MPO staff, which then determines the level of process required to complete the revision. Sys- tems such as these also hold project sponsors more account- able for the changes they make to projects, as they are the ones responsible for filling out the paperwork. A second and more common way that MPOs are handling the large number of TIP revisions generated by ARRA is to group a number of revisions together for processing at a single series of MPO meetings (technical and policy boards). ARC has migrated to a quarterly system of processing administra- tive modifications, and is pushing the same for amendments as well. The staff at ARC reports good, albeit gradual, accep- tance of the quarterly update system. Predictable update The preceding chapters described the TIP revision process and time lines of various stages of that process. The follow- ing paragraphs highlight some of the findings from the 10 case examples conducted for this study. The methodology for selecting and conducting the MPO cases is discussed first. SUMMARY OF METROPOLITAN PLANNING ORGANIZATION CASE EXAMPLES To delve more deeply into the challenges now faced in the TIP revision process, as well as to gain further insight on the responses that individual MPOs may contribute toward answering those challenges, 10 brief case examples were developed based on telephone interviews to supplement the findings of the literature review and MPO survey. The selec- tion of the MPO cases was based on three factors: (1) affir- mative responses when asked in the MPO survey instrument if they would be willing to participate in a follow-up inter- view; (2) geographic, air quality, and size diversity among the case studies; and (3) survey responses indicating that the MPO was employing innovative measures in its TIP modi- fication process that could be of interest to other MPOs. The following 10 MPOs were chosen for case examples: • Atlanta Regional Commission (Atlanta, GA) • Capital District Transportation Committee (Albany, NY) • Central Massachusetts Regional Planning Commission (Worcester, MA) • Chicago Metropolitan Agency for Planning (Chicago, IL) • Community Planning Association (Boise, ID) • Duluth–Superior Metropolitan Interstate Council (Duluth, MN) • Missoula MPO (Missoula, MT) • North Central Texas Council of Governments (Dallas, TX) • Wasatch Front Regional Planning Commission (Salt Lake City, UT) • Wilmington Area Metropolitan Planning Council (Wilmington, DE) Each MPO was asked the same baseline questions for comparison purposes: population; air quality conformity

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

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

18 CMMPO. Although the document lays out the minimum thresholds, the state and CMMPO may set stricter thresholds or require additional actions. The following are cost and/or percentage thresholds that trigger an amendment for FHWA- and FTA-financed projects. FHWA <$10 million $1 million increase >$10 million 10% FTA >10% of the total project cost Florida DOT and MPOs The Florida DOT and MPOs have collaborated on program management guidance for TIP processes, including revisions. Project cost change thresholds for an amendment are sim- ply 20% of project cost and $2 million change; other thresh- olds include major scope changes, adverse impacts to fiscal constraint, and inconsistency with the long-range transpor- tation plan or adopted project priorities. TIMELINESS OF REVISIONS Although the ARRA stimulus money created urgencies to adopt TIP revisions, many MPOs and DOTs have had to deal with quick turnaround times to make changes to the TIP. Many MPOs noted that because their policy boards meet monthly, processing frequent changes is not a problem. However, in cases where a board does not meet as frequently or a change simply cannot wait, some MPOs and DOTs have agreed to procedures to expedite the process. One MPO has started to allow absentee voting when an action is required quickly to avoid project delays. Another MPO added a clause to its public participation plan that allows for major amend- ments to be processed, in extenuating circumstances, without the 30-day public notice as long as 75% of the Policy Board is present and approves the change. A different MPO, which has a strict schedule for processing all of its TIP changes quarterly, will, in special circumstances, process an out-of- cycle modification at the next available meeting. STAKEHOLDER AND PUBLIC AWARENESS AND ENGAGEMENT MPOs noted that when new TIP revision processes are installed, it is important that these changes be communi- time, but holds them for processing until the next scheduled opportunity. Its administrative modifications are processed by staff with no official action required by the ARC Board. It spells out what triggers a modification and notes that there is no formal comment period required to process administra- tive changes. However, full advance disclosure of the pro- posed changes is made to all agencies with a vested interest in the affected project. The monetary threshold for a modification is as follows: • Revising a project description without changing the overall project scope and intent (e.g., less than 10% change in project length), conflicting with the environ- mental document or changing the conformity finding. • Increasing the costs of project phases by less than $2 million or 20% of the amount to be authorized. The 20% scenario amount may not exceed $10 million. Wasatch Front Regional Council The Wasatch Front Regional Council (WFRC) spells out its modification process in the Appendix (Section X) of its 2010– 2015 TIP. To reduce the number of potential amendments and streamline the process to modify the TIP, all the MPOs in Utah, Utah DOT, the Utah Transit Authority, and FHWA col- laborate on the TIP/STIP modification process. They estab- lished “staff modifications,” “Board modifications,” and “full amendments.” The triggers for Board modifications are spelled out, and these require approval from the WFRC or WFRC delegated body and the Transportation Commission. The following are thresholds and triggers for staff modi- fications and Board modifications: • Staff modifications are minor changes and require administrative approval from the MPO and DOT exec- utive directors. The cost threshold for staff modifica- tions are project activities where there was a change in funding source and a need for additional funding less than 25% (but not more than $250,000) of the pro- grammed amount. • The cost thresholds for a board modification are requests for funding greater than 25% (or over $250,000) of the programmed amount. Central Massachusetts MPO The Central Massachusetts MPO (CMMPO) lays out its amendment/adjustment procedures in its Draft 2011–2014 TIP. An amendment is called for when there is a significant change to the TIP (triggers for this are detailed in the docu- ment). It will require formal action by the Policy Board. An adjustment is called for when lesser actions affecting the TIP (triggers for this are detailed in the document) may be accommodated through an administrative procedure of the

19 cated both internally and externally. The ARC has developed the Blueprint, a comprehensive guide to LRTP, TIP, and other processes that it manages. This document also con- tains information specific to public–private partnerships, congressional earmarks, and other program elements. The ARC has also developed an interactive map of TIP projects, a project submittal form, and a significant portion of its web- site to help engage stakeholders and the public. In an environment of frequent TIP revisions, especially multiple revisions to the same project, it is important to help the public understand what has prompted these changes and why they are necessary. Consolidating the TIP revisions to one specific meeting, instead of holding a meeting for each revision, and providing detailed project data in a standardized template are strategies cited for improving public awareness and engagement when there are multiple project adjustments.

Next: CHAPTER FOUR Conclusions and Future Research Needs »
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TRB’s National Cooperative Highway Research Program (NCHRP) Synthesis 419: Transportation Improvement Program Revision Process compiles and documents the different ways that metropolitan planning organizations (MPOs) approach revising a Transportation Improvement Program (TIP) once it has been adopted.

Federal legislation requires MPOs to adopt and regularly update a TIP identifying a prioritized list of projects covering a four-year period.

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