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40 CHAPTER FIVE CONCLUSIONS The responses provided by local program agency (LPA) program coordinators in the ten focus state departments of transportation (DOTs) provided valuable insight into how the federal-aid program is structured and implemented for small- scale projects. The report addresses how states have used flexibilities in federal requirements to establish streamlining practices that enable smoother project delivery. Many states are already engaged in using practices that they find effective, and this report synthesizes information on these practices as reported by the ten focus states. More than 50 interviews were conducted with the DOT LPA coordinators and other staff members in a variety of state agencies, metropolitan planning agencies, national interest groups, and local agencies. Infor- mation obtained in the interview sessions was used to acquire a more precise idea of the concerns and effective practices of LPA program participants across the study states. Overall, the synthesis found that DOTs have developed many methods for effective delivery of small-scale federal-aid projects, but no one state is employing all of these methods in their respective programs. Specific effective practices reported by focus states are presented per topic area in Table C1 in Appendix C. OBSERVATIONS AND CONCLUSIONS Based on the literature review, surveys, and interviews con- ducted during this study, the following general observations and conclusions can be made: Certification of small-scale federal-aid project spon-⢠sors was identified as an effective practice because it reduces some of the administrative burden on DOTs by placing more responsibility for project delivery on local agencies. The six focus states in this study that have an LPA certification process indicated that the states allow some larger local agencies (that are certi- fied) to administer small-scale federal-aid projects on behalf of smaller agencies or nonprofit organizations that either are not certified or do not have the appropri- ate staff or adequate resources to conduct federal-aid projects. DOTs cited this approach as having a stream- lining effect by allowing smaller agencies access to federal funds to produce projects that previously would not have been possible. Many DOTs consider their leadership of the National ⢠Environmental Policy Act (NEPA) phase of LPA proj- ects as a streamlining practice, based on the higher level of familiarity of DOT staff with the environmental process. FHWA noted that if local agencies handle the NEPA process themselves, additional time and money can accumulate quickly. All states included in the case study have an environmental staff member who works with local agencies, providing guidance throughout the NEPA process, and potentially someone similar from the right-of-way office for real estate acquisition and appraisals. Some DOTs mentioned that the use of programmatic ⢠agreements between agencies expedites the environ- mental process on small-scale federal-aid projects. Agreements created for completing environmental actions related to Section 106, endangered species, and categorical exclusions for off-system projects are just some examples. This practice is used primarily for projects that incur very little impact to the socioeco- nomic or natural environment, such as replacing traffic signs, pavement maintenance or preservation activities, and signalization-related projects. The agreements sig- nificantly reduce the number and complexity of envi- ronmental studies and associated paperwork required to obtain the clearance to move ahead with final design and construction phases of project delivery. Several effective practices reported involved the ⢠orchestration of federal, state, and local funding. Many survey respondents cited effectively securing federal funding for small-scale projects through the creation of a uniform documented process (e.g., an organized step-by-step approach that ensures all federal approvals are met before proceeding to the next step, etc.) during the project selection phase. Another effective practice reported entails ensuring that local funding matches are available before projects are selected for implemen- tation. Pennsylvania highlighted the use of local money to complete design work in order to alleviate the design agreements and other documentation that tend to slow down the design process. In California, state law requires the swapping of state funds to cover the fed- eral share for a certain amount of rural county Surface Transportation Program projects, relieving small-scale projects from the administrative burden rendered from some of the federal-aid requirements. Iowa uses a state match rather than a local agency match in federal-aid programs so its state-aid funding is not held up.
41 System and state systems, as preapproved by the DOT. Some DOTs created specifications for local agencies to use directly without going through the specification approval process. This process was reported as saving time and reducing costs to local agencies because, under this approach, they would not be required to use more complex state specifications or to hire DOT-qualified design consultants or materials testing laboratories. FURTHER RESEARCH One purpose of this study was to identify gaps in the knowl- edge about the effective delivery of small-scale federal-aid projects and indicate possible research to address them. Seven major research needs are presented: Responses were consistent among the ten states regard-⢠ing the application of federal regulations. In each case, the federal regulations were applied consistently; that is, a distinction typically was not made between the appli- cation of federal regulations on off-system projects and the application of regulations on those projects that are within the right-of-way of federal-aid routes. The com- mon reason given by focus states was that the potential confusion generated by making the distinction would outweigh the benefits of any off-system streamlining measures. However, it is important to investigate the impacts of allowing flexibilities whenever possible. Focus states cited various funding issues as impeding ⢠the efficient delivery of small-scale federal-aid projects. Future studies could outline current practices of using state-aid in lieu of federal-aid funds and other innova- tive methods of project financing, including details on state legislation that allow this practice. A majority of the focus states indicated that bridge ⢠projects overwhelmingly take the longest time to com- plete, closely followed by Transportation Enhancement activities, High Priority Projects, and congressionally authorized projects or earmarks. A study to explore why and how these projects become the most time-con- suming could create opportunities for finding solutions to delivering them more efficiently in the future. A future synthesis topic could explore effective prac-⢠tices used at the local agency level for procuring and efficiently using federal funds for local agency projects. The synthesis could survey both larger and smaller local agencies in states that have certification programs. It could include interviews with local agencies to focus on successful practices that local agencies have used to obtain federal funds, innovative ways to provide their limited match funds, and approaches to delivering projects on-time and on-budget despite staff turnover and shortages. It would also provide an opportunity to evaluate and assess certification programs to view the performance results of some of these programs. DOTs strongly stressed the effectiveness of holding ⢠early and frequent project meetings with local agen- cies to ensure that they get off to a successful start. Continual periodic status meetings are held to ensure that LPA projects are developing in the most efficient manner possible, particularly because other competing regional projects and priorities can cause a small-scale project to become lost among projects of higher pri- orities. Status meetings were reported to help project sponsors and their teams stay on target because LPA projects have historically taken much longer to com- plete when the sponsor is not very involved. To ensure that federal regulations for the LPA program ⢠are being met consistently, many DOTs have identified recurring training sessions as an effective practice for project delivery. Another effective practice demon- strated by most states is to hold âas-neededâ training sessions to address any particular concerns a local agency may have during project implementation. An effective practice for project delivery involves ⢠generating checklists to specifically identify what is expected and required of a local agency in each phase of a particular project. Throughout the survey analy- sis and focus state interviews, it became evident that checklists exist in virtually every phase of a project in at least one state, demonstrating the process as wide- spread among the study states. In many cases, the use of simplified checklists for different stages of project delivery has been shown to improve local agency under- standing of what is required of them per each project phase in terms of schedule and federal requirements. Inconsistencies between the interpretation and the ⢠implementation of regulatory requirements were identified as an issue, but the level of concern varied from state to state. Ongoing and open communica- tions between LPAs, their state DOT, and the FHWA Division Office is the key to clarifying the interpreta- tion of regulations, resolving differing expectations, and implementing best practices and/or streamlining the process. It was noted that DOT respondents from states with smaller programs indicated better success with minimizing the potential for variable interpre- tation of federal regulations, followed by subsequent rapid corrective action when irregularities arise. The focus states that allow the tying together, or bun-⢠dling, of several small LPA projects into a single larger project at any phase of project delivery consistently highlighted this approach as an effective practice to getting small projects built efficiently. This approach was cited as particularly useful when dealing with funding programs that have expedited obligation and expenditure requirements, such as American Recovery and Reinvestment Act. Many of the focus states allow local agencies to use ⢠their own materials or construction specifications and design standards for roadways off the National Highway
