Urban Transportation: Metropolitan Planning Organizations' Efforts to
Meet Federal Planning Requirements (Chapter Report, 09/17/96,
GAO/RCED-96-200).

Pursuant to a congressional request, GAO reviewed: (1) metropolitan
planning organizations' (MPO) implementation of the Intermodal Surface
Transportation Efficiency Act of 1991 (ISTEA) planning requirements; and
(2) whether the Department of Transportation's certification review
process ensures that MPO in larger urban areas comply with those
planning requirements.

GAO found that: (1) some MPO have found three of the ISTEA planning
requirements particularly challenging to implement; (2) the citizen
involvement requirement has helped MPO develop transportation plans that
better reflect their regions' needs; (3) the financial constraint
requirement has led MPO to obtain better revenue projections from their
state transportation departments and transit agencies and to exclude
those projects that exceed projected revenues; (4) the project selection
authority requirement has forced MPO to become consensus builders with
states, localities, and transit agencies in identifying projects and
improved MPO selection processes; (5) in some instances, states have
resisted MPO and local efforts to assume greater authority over
transportation projects; (6) MPO believe that their efforts to meet
ISTEA requirements have improved their transportation plans and that the
requirements should continue; (7) some state transportation departments
do not support ISTEA planning requirements and some believe that the
financial constraint requirement should be eliminated because of the
difficulties in making long-range revenue projections; and (8) as of
January 1996, the Federal Highway Administration (FHwA) and the Federal
Transit Administration (FTA) had certified 54 of the 55 MPO reviewed,
but the certification reports are not useful in assessing trends or
problem areas in the ISTEA planning process because of the reports'
variation in format, depth, and content and the conditional
certification of MPO despite significant deficiencies in their
transportation planning processes.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-96-200
     TITLE:  Urban Transportation: Metropolitan Planning Organizations' 
             Efforts to Meet Federal Planning Requirements
      DATE:  09/17/96
   SUBJECT:  Urban planning
             Ground transportation operations
             Mass transit operations
             Future budget projections
             State/local relations
             Highway planning
             Road construction
             Transportation law
             Reporting requirements
IDENTIFIER:  Springfield (MA)
             Philadelphia (PA)
             Worcester (MA)
             Chicago (IL)
             Detroit (MI)
             New York (NY)
             FHwA Congestion Mitigation and Air Quality Improvement 
             Program
             Los Angeles (CA)
             Tampa (FL)
             St. Louis (MO)
             DOT Transportation Improvement Program
             Milwaukee (WI)
             Durham (NC)
             Atlanta (GA)
             Dallas (TX)
             Fort Worth (TX)
             New Orleans (LA)
             Pensacola (FL)
             National Highway System
             FHwA Highway Bridge Replacement and Rehabilitation Program
             FHwA Interstate Maintenance Program
             Reading (PA)
             Albany (NY)
             Boston (MA)
             
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Cover
================================================================ COVER


Report to Congressional Requesters

September 1996

URBAN TRANSPORTATION -
METROPOLITAN PLANNING
ORGANIZATIONS' EFFORTS TO MEET
FEDERAL PLANNING REQUIREMENTS

GAO/RCED-96-200

Urban Transportation Planning

(342902)


Abbreviations
=============================================================== ABBREV

  AASHTO - American Association of State Highway and Transportation
     Officials
  ACIR - Advisory Commission on Intergovernmental Relations
  AMPO - Association of Metropolitan Planning Organizations
  CAA - Clean Air Act
  CMAQ - Congestion Mitigation and Air Quality Improvement Program
  DOT - United States Department of Transportation
  EPR - Enhanced planning review
  FHWA - Federal Highway Administration
  FTA - Federal Transit Administration
  GAO - United States General Accounting Office
  ISTEA - Intermodal Surface Transportation Efficiency Act of 1991
  MPO - Metropolitan Planning Organization
  TIP - Transportation Improvement Program
  TMA - Transportation Management Area

Letter
=============================================================== LETTER


B-265945

September 17, 1996

The Honorable John H.  Chafee
Chairman
The Honorable Max S.  Baucus
Ranking Minority Member
Committee on Environment and
 Public Works
United States Senate

The Honorable John W.  Warner
Chairman, Subcommittee on Transportation
 and Infrastructure
Committee on Environment and
 Public Works
United States Senate

In response to your request, this report (1) discusses the
experiences of metropolitan planning organizations (MPO) in
implementing the planning requirements of the Intermodal Surface
Transportation Efficiency Act of 1991 and (2) examines the extent to
which the U.S.  Department of Transportation's certification review
process ensures that the MPOs in larger urban areas comply with the
act's planning requirements.  This report recommends that the
Secretary of Transportation develop standard reporting formats for
assessing and reporting on the MPOs' compliance with the planning
requirements so that the Department can identify any nationwide
patterns in planning deficiencies, the underlying causes of these
planning deficiencies, and the extent to which the MPOs have made
progress in implementing the requirements. 

We are sending copies of this report to the Secretary of
Transportation; the Director, Office of Management and Budget; and
interested congressional committees.  We will make copies available
to others upon request. 

Please contact me at (202) 512-2834 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
VI. 

John H.  Anderson, Jr.
Director, Transportation and
 Telecommunications Issues


EXECUTIVE SUMMARY
============================================================ Chapter 0


   PURPOSE
---------------------------------------------------------- Chapter 0:1

Key urban issues, such as traffic congestion, air pollution, and the
economic viability of neighborhoods and commercial areas, are
significantly affected by decisions on how federal transportation
funds are invested.  These decisions, in turn, stem from the
transportation planning efforts undertaken by the 339 metropolitan
planning organizations (MPO) in the United States.  An MPO is not a
discrete decision-making body with real jurisdictional powers but can
be viewed as a consortium of governments and other bodies--such as
transit agencies and citizens groups--that join together for
cooperative transportation planning. 

The Chairman and Ranking Minority Member, Senate Committee on
Environment and Public Works, and the Chairman of that Committee's
Subcommittee on Transportation and Infrastructure asked GAO to review
the metropolitan transportation planning requirements of the
Intermodal Surface Transportation Efficiency Act of 1991 (ISTEA) and
determine the challenges that the MPOs--the primary transportation
planning agencies in urban areas--face in implementing those
requirements.  Specifically, this report (1) discusses the MPOs'
experiences in implementing ISTEA's planning requirements and (2)
examines the extent to which the U.S.  Department of Transportation's
certification review process ensures that the MPOs in larger urban
areas comply with ISTEA's requirements. 


   BACKGROUND
---------------------------------------------------------- Chapter 0:2

ISTEA began a new era in urban transportation planning by making key
changes that either strengthened the planning requirements that had
existed in earlier laws or were significant innovations.  ISTEA
retained the requirement that planners develop a 20-year plan that
identifies a vision for the regional transportation system and a
3-year transportation improvement program that identifies the
projects to be implemented over this period.  For the first time, all
of the nation's 339 MPOs must financially constrain their
transportation plans--that is, they must include only those projects
that can be paid for with reasonably available or projected revenues. 
In addition, ISTEA re-emphasized the public's involvement in
transportation planning by requiring a formal and ongoing process for
citizens' participation in the transportation planning process. 
ISTEA also requires the Secretary of Transportation to certify that
the transportation planning efforts in larger urban areas conform to
ISTEA's planning provisions.  To meet this requirement, the Federal
Highway Administration and the Federal Transit Administration jointly
evaluate the planning processes in urban areas with populations over
200,000. 


   RESULTS IN BRIEF
---------------------------------------------------------- Chapter 0:3

The MPOs have found three of ISTEA's planning requirements
particularly challenging to meet:  requiring greater involvement by
citizens, limiting short- and long-term transportation plans to
reasonable revenue projections (the financial constraint
requirement), and selecting transportation projects.  The MPOs found
that the requirement to involve citizens had ensured that their
transportation plans better reflected their regions' transportation
needs.  The financial constraint requirement led the MPOs to obtain
more reliable revenue projections from the state departments of
transportation and transit agencies and to exclude those projects
that could not be financed within budget constraints.  ISTEA's
project selection authority required the MPOs to become consensus
builders, effectively working with the states, localities, and
transit agencies in identifying projects.  In some cases, the efforts
of the MPOs and the local officials to assume greater authority have
encountered resistance from the states. 

Despite the difficulties encountered, the MPOs that GAO interviewed
said that their efforts to meet these three planning requirements had
improved their transportation plans.  As a result, the 13 MPOs that
GAO interviewed unanimously endorsed the continuation of the ISTEA
planning requirements.  In contrast, state departments of
transportation officials that GAO interviewed did not uniformly
support the continuation of ISTEA's planning requirements.  For
example, some states and the American Association of State Highway
and Transportation Officials--the national organization of state
transportation agencies--support the elimination of the requirement
to financially constrain the MPOs' long-term plans because of the
difficulty in determining reliable revenue projections over the
20-year duration of the plan. 

As of January 1996, the Federal Highway Administration and the
Federal Transit Administration had reviewed 55 MPOs.  Twenty-three
were certified without qualification, and 31 were certified subject
to certain corrective actions being taken.  The certification of one
MPO was held in abeyance because of significant areas of
noncompliance.  In reviewing 55 certification reports, GAO found that
the reports are of limited usefulness in assessing trends or problem
areas in the ISTEA planning process.  First, the certification
reports vary widely in format and content because the Department did
not develop standard criteria for assessing or reporting the MPOs'
compliance.  Second, three MPOs were conditionally certified despite
significant deficiencies in their urban transportation planning
processes.  For example, the governing board at one certified MPO had
not met publicly since 1976 and had not developed a process to
involve citizens. 


   GAO'S ANALYSIS
---------------------------------------------------------- Chapter 0:4


      THREE OF ISTEA'S KEY
      PLANNING REQUIREMENTS POSED
      CHALLENGES FOR MPOS
-------------------------------------------------------- Chapter 0:4.1

ISTEA's planning requirements posed considerable challenges for the
MPOs.  GAO found that three were particularly challenging:  (1)
involving the public more extensively, (2) financially constraining
transportation programs, and (3) identifying transportation projects. 
According to a 1992 MPO study, before ISTEA, the MPOs' efforts to
involve citizens were narrowly focused and had low visibility.  In
response to ISTEA, the MPOs hired more staff and increased funding to
effectively involve the general public.  For example, the
Springfield, Massachusetts, MPO hired a consultant in part to
translate the jargon of technical planning into understandable terms
for a newsletter aimed at the general public.  The Philadelphia MPO
tripled its spending on citizens' involvement, from about $90,000 in
1991 to $300,000 in 1995.  Overall, all 13 MPOs that GAO interviewed
noted that their efforts to meet ISTEA's public involvement
requirements had resulted in plans and programs that were more
reflective of the public's transportation needs, and hence provided
broader and stronger public support. 

According to several studies, ISTEA's requirement that the MPOs
develop transportation improvement programs that reflect reliable
revenue projections was a significant challenge.  The requirement
assumed that all of the MPOs could develop a list of proposed
projects, in priority order, and then exclude those projects that did
not fit within the budget constraint.  A 1992 study found that some
MPOs submitted lengthy, unconstrained "wish lists" to their state
departments of transportation, deferring the real decision-making
authority to the states.\1 In some urban areas, financially
constraining the transportation improvement program meant abandoning
50 percent or more of the proposed projects.  While many of these
projects had scant prospects for implementation, deleting them was
politically difficult and very unpopular with the projects' sponsors. 

The MPOs' efforts to identify which transportation projects to fund
posed challenges similar to those surrounding the financial
constraint requirement.  Because the MPOs were not traditionally
strong decision-making bodies, their capacity to identify projects
was in doubt at the outset of ISTEA.  The planning and programming
decisions were often deferred to the states or to transit operators
because the MPOs generally did not have the authority to play a
decision-making role.  To make the transition, the MPOs had to
develop a consensus-building relationship with the local communities,
the transit agencies, and the states.  GAO's interviews with 13 MPOs
showed that a cooperative and constructive relationship with the
state was especially critical. 


--------------------
\1 Intermodal Surface Transportation Efficiency Act of 1991:  Promise
to Performance, Report to the Federal Highway Administration,
Institute of Public Administration, Dec.  1992. 


      MPOS INTERVIEWED BELIEVE
      THAT EFFORTS TO MEET
      PLANNING REQUIREMENTS ARE
      BENEFICIAL
-------------------------------------------------------- Chapter 0:4.2

Despite initial difficulties, the 13 MPOs that GAO interviewed
support ISTEA's planning provisions and believe that the provisions
have improved their transportation plans.  For example, some MPOs
noted that their efforts to involve citizens were valuable in
educating interested members of the public and forced the planners to
deal with significant public opposition to projects early in the
planning process.  As a result, the projects were less likely to be
disrupted closer to implementation.  The financial constraint
requirement resulted in transportation plans that could be
implemented as the planning process became more rational than
political.  In addition, the transportation planners started to
consider innovative financing methods to help generate revenues to
carry out the plans--such as toll roads--that would have been
politically difficult before.  Finally, 8 of the 13 MPOs that GAO
interviewed said that ISTEA had a great or very great impact on
enhancing their ability to select projects.  Various provisions of
ISTEA--including the financial constraint requirement and funding
flexibility--were cited as contributing to this change. 

While the state officials that GAO interviewed generally supported
ISTEA's planning requirements, their support was often conditional. 
For example, many of these state officials supported the financial
constraint requirement as long as the federal regulations allowed
some over-programming--that is, allowed the total cost of the
proposed projects included in the transportation improvement plans to
slightly exceed the expected revenues.  According to the states, this
practice would enable the MPOs to undertake another project in the
event that a higher-priority project ran into unexpected delays. 


      DOT 'S CERTIFICATION REPORTS
      PROVIDE LIMITED GUIDANCE FOR
      REAUTHORIZING ISTEA
-------------------------------------------------------- Chapter 0:4.3

ISTEA required the Secretary of Transportation to certify that the
MPOs in larger urban areas had complied with ISTEA's planning
provisions and to withhold federal transportation funds from urban
areas that did not comply.  GAO's review of the Department's reports
on all 55 certification reviews issued between July 1994 and January
1996, as well as discussions with MPO, state, and DOT officials,
revealed two main concerns about DOT's management of the
certification program.  First, GAO found that the reports on
certification reviews varied significantly in their depth, content,
and format.  Some reports went into significant detail and were
richly descriptive of the MPOs' planning efforts.  Other reports were
cursory and summary.  Second, three MPOs were conditionally certified
even though their planning procedures appeared to fall significantly
short in several key areas.  For example, the Department certified
the Worcester, Massachusetts, MPO even though the MPO's technical
board had not met publicly since 1976, no process to involve citizens
had been formally adopted, no local officials were members of the
MPO, and neither the short-term nor the long-term plan was
appropriately financially constrained.  These MPOs were certified on
the condition that corrective actions be taken. 

Department officials stated that because of the newness of the
planning requirements, the Department developed flexible criteria for
federal officials to use in reviewing the MPOs' compliance and
encouraged reviewers to take a flexible approach in assessing whether
the MPOs had complied with the planning requirements.  However, the
lack of initial criteria for assessing compliance and the resulting
variety in the content and format of the reports make it difficult to
develop a broad overview of the MPOs' compliance with the planning
requirements.  Such an overview would be especially useful because
the certification reviews are the most comprehensive assessment of
the MPOs' performance that will likely be conducted. 


   RECOMMENDATION
---------------------------------------------------------- Chapter 0:5

GAO recommends that the Secretary of Transportation direct the
Administrators of the Federal Highway Administration and the Federal
Transit Administration to develop reporting formats for assessing and
reporting on the MPO's compliance with ISTEA's planning requirements
that will enable the Department to identity any nationwide patterns
in planning deficiencies, the underlying causes of these planning
deficiencies, and the extent to which the MPOs have made progress in
meeting the requirements. 


   AGENCY COMMENTS
---------------------------------------------------------- Chapter 0:6

After providing a draft of this report to DOT for review, GAO met
with DOT officials, including the Chief, Metropolitan Planning
Division, Federal Highway Administration, and the Chief, Statewide
Planning Division, Federal Transit Administration.  The DOT officials
disagreed with GAO's conclusion that the information gathered during
the certification reviews should be used to develop an overview of
the MPOs' progress in meeting ISTEA's planning requirements.  They
stated that the certification reviews are not intended to assess the
MPOs' overall progress.  Instead, they serve to assess the compliance
of individual MPOs with ISTEA's planning requirements and to provide
feedback on each MPO's efforts to meet the requirements.  They also
stated that the certification process is only one of several
activities that the Department is taking to promote and assess the
MPOs' compliance.  As a result, DOT disagreed with the recommendation
that it develop standard criteria and reporting formats for
certification reviews.  The officials stated that the recommendation,
particularly the call for standard criteria, was too prescriptive and
that GAO direct its recommendation to the Congress instead. 

GAO has incorporated information into the report that describes the
additional activities which Department officials stated that they
have undertaken or plan to undertake to assess the MPOs' progress in
meeting ISTEA's planning requirements.  In addition, GAO has modified
its proposed recommendation by deleting its call for standard
criteria to address the Department's need for flexibility in
responding to GAO's recommendation.  However, GAO believes that the
scope and effort that the Department has placed in the certification
reviews clearly suggest that the reviews are critical elements in
assessing how well the MPOs have met the requirements.  A standard
reporting format would not limit the Department's flexibility to
tailor the certification reviews to the particular needs of each MPO. 
Rather, it would provide the Department and the Congress with rich
sources of information that they could use to evaluate whether or not
the MPO planning provisions should be continued. 

DOT officials also suggested technical and editorial changes to the
report, which have been incorporated where appropriate. 


INTRODUCTION
============================================================ Chapter 1

The quality of life in urban areas is and will continue to be
significantly affected by decisions on the use of federal
transportation funds.  Key urban issues, such as traffic congestion,
air pollution, and the economic viability of neighborhoods and
commercial areas, are significantly affected by the decisions on how
these funds are spent.  The decisions, in turn, grow out of the urban
transportation planning process and the role of the nation's 339
metropolitan planning organizations (MPO). 


   MPOS VARY IN SIZE AND
   RESPONSIBILITY
---------------------------------------------------------- Chapter 1:1

Since the early 1970s, MPOs have been significant players in urban
transportation planning.  An MPO is not a discrete decision-making
body with real jurisdictional powers, such as a city or county
government.  Instead, an MPO is best viewed as a consortium of
governments and other bodies--such as transit agencies and citizens
groups--that join together for cooperative transportation planning. 
An MPO's organization and membership often consists of (1) a
policy-making board involving elected officials from the local
governments in the metropolitan area; (2) a technical committee
consisting of professional staff of local, state, and federal
transportation agencies; and (3) an MPO staff.\2 The MPO's primary
mission is to develop a consensus on a long-term transportation plan
for an urban area and to develop a transportation improvement program
(TIP) that identifies projects to implement the plan.  How each of
the 339 MPOs in the United States fulfills this mission depends on
its relationship with the state department of transportation and
other transportation operators, the number of local governments in
the region, the size and experience of the MPO staff, the growth rate
of the population, and the number of transportation modes in the
region. 

According to a 1995 report on MPOs by the U.S.  Advisory Commission
on Intergovernmental Relations (ACIR), some MPO-like organizations
existed in the 1950s to prepare special metropolitan planning studies
in Chicago, Detroit, New York, and Philadelphia.\3 In 1970, federal
policy fostered the development of comprehensive urban transportation
planning by requiring the creation of planning agencies in areas with
populations of 50,000 or greater to carry out cooperative planning at
the metropolitan level.  Originally, all MPOs were treated alike
under federal laws and regulations.  In the mid-1980s, when funding
for metropolitan planning was reduced, preference for funding was
given to those MPOs in metropolitan areas over 200,000 in population,
areas now known as Transportation Management Areas (TMA). 

ISTEA's funding provisions also provided additional discretion and
funding to those MPOs located in areas violating the federal air
quality standards.  ISTEA established the Congestion Mitigation and
Air Quality program (CMAQ) and authorized $6 billion over 6 years to
help the areas not in attainment with the air quality standards
(nonattainment areas) reach compliance with the Clean Air Act's (CAA)
requirements.  With CMAQ funds, the MPOs located in the areas that
are not in compliance with the federal standards for ozone or carbon
monoxide emissions can approve projects that help control or reduce
these emissions. 

The population and geographic area covered by the MPOs also determine
the breadth of their responsibilities and the support they have to
meet their ISTEA planning requirements.  Some MPOs, such as those in
New York, Chicago, and Los Angeles, plan for urbanized populations of
over 6 million.  Typically, these MPOs are well financed and have a
dedicated professional staff of 100 or more.  At the other extreme,
the MPOs that plan for urban areas with populations just over 50,000
may have no staff or a single county government employee working part
time for the MPO. 

In addition, the MPOs' planning duties can be complicated by the
boundaries of jurisdictions in metropolitan areas.  As growth occurs,
urbanized areas sometimes overrun the MPOs' boundaries or become so
large that state and local officials establish more than one MPO to
serve the area.  Currently, 14 contiguous urbanized areas within a
single state have two or more MPOs.  In these locations, such as
Florida's Tampa Bay area, cooperation and coordination among the MPOs
are essential.  Other urban areas cross state lines.  For example,
the Philadelphia MPO plans for the Pennsylvania and New Jersey
portions of the Philadelphia urban area, and the St.  Louis MPO plans
for the Missouri and Illinois portions of the urban area.  The task
of these MPOs is complicated by their having to deal with two or more
state governments and more than one Federal Highway Administration
(FHWA) or Federal Transit Administration (FTA) region. 


--------------------
\2 For illustrative purposes, see appendix I for a detailed
description of the organization and membership of the Chicago Area
Transportation Study--the MPO for the Chicago urbanized area. 

\3 MPO Capacity:  Improving the Capacity of Metropolitan Planning
Organizations to Help Implement National Transportation Policies,
U.S.  Advisory Commission on Intergovernmental Relations, May 1995. 


   ISTEA PRESENTED MPOS WITH NEW
   CHALLENGES
---------------------------------------------------------- Chapter 1:2

The ACIR report noted that ISTEA brought three new, far-reaching
philosophies to the administration of the federal surface
transportation programs:  (1) the decentralization of decision-making
to the state and local governments, and particularly to the MPOs in
the larger metropolitan areas with populations of 200,000 or more;
(2) stronger environmental connections, especially to the CAA; and
(3) the elevation of nontraditional goals and stakeholders to new
prominence in the planning and decision-making processes. 

ACIR noted that the decentralization of decisions gave many MPOs a
larger area to plan for, more miles of road to make decisions about,
more flexibility to consider alternatives to the automobile, a lead
role in allocating certain federal transportation funds, a longer
horizon to consider for the planning process, and a responsibility to
consider many transportation-related public policies.  In 129 urban
areas with populations greater than 200,000,\4 --the TMAs--ISTEA
gives the MPOs the authority to select projects from the TIP, in
consultation with the state.  In other areas, the selection of
projects is to be carried out by the state in cooperation with the
MPO. 

Environmental considerations have become more of a driving force in
the MPOs' work as well.  The MPOs in nonattainment areas must develop
transportation plans that ensure that the CAA's requirements are met. 
In constraining the transportation plans to meet the CAA's goals, the
MPOs cannot, with limited exceptions, spend any federal funds on any
highway projects that will exacerbate existing air quality problems
or lead to new violations of federal air quality standards.  The
MPO-developed transportation plans must contribute to reducing motor
vehicle emissions. 

The elevation of nontraditional goals and stakeholders in the MPO
planning process is specified in the ISTEA section that requires the
MPOs to consider 16 factors\5 when developing their metropolitan
plans.  Some of the planning factors require planners to consider the
effects of transportation policies on land-use development; the
social, economic, energy, and environmental impacts of transportation
decisions; provide for the efficient movement of freight; and ensure
connections with international borders, ports, and airports and
intermodal facilities.  These planning factors address many of the
ways that transportation relates to other values and the unintended
impact of transportation and transportation facilities.  ISTEA stated
that these factors must be considered as part of the planning
process.  In addition, ISTEA and subsequent planning regulations
emphasized an early and continuous effort to involve citizens that
actively seeks input from direct stakeholders and other members of
the public, including those traditionally underserved by the existing
transportation systems.  The public's involvement is to be sought at
various points in the planning process, including the development of
the plan, the TIP, and individual projects. 


--------------------
\4 Three urban areas under 200,000 in population have been designated
TMAs at the request of the state governor. 

\5 The 16th was added as part of the National Highway System
Designation Act of 1995.  See appendix III for a list of these
factors. 


   MPOS MUST PRODUCE TWO PLANNING
   DOCUMENTS
---------------------------------------------------------- Chapter 1:3

Taking into consideration all of the relevant requirements of ISTEA
and the CAA, the MPOs must develop two basic planning documents--the
transportation plan and the transportation improvement program.  The
first document--the transportation plan--is a long-term document that
specifies a 20-year vision for a metropolitan area's transportation
system.  The plan is to include short- and long-range strategies
leading to the development of an integrated and efficient intermodal
transportation system.  The plan is to be revised and updated at
least every 3 years in those areas not meeting the federal air
quality standards and at least once every 5 years in other areas.  An
acceptable plan must be a realistic, implementable document
describing how the transportation system will serve metropolitan
development objectives, address congestion and air quality concerns,
and address other issues. 

The TIP is a much more detailed document that specifies a list of
priority projects to be implemented in each year covered.  It must
include all transportation projects that will receive federal
transportation funding and be clearly based on the objectives laid
out in the plan.  The TIP covers a period of at least 3 years and
must be updated every 2 years.  After approval by the governor, the
metropolitan TIP must be included in the state TIP,\6

which is then subject to review and approval by the Federal Highway
Administration (FHWA) and the Federal Transit Administration (FTA). 

ISTEA specifies that the plans and TIPs include a financial component
that demonstrates how the plans will be funded and implemented.  The
TIP must be financially constrained each year and must include only
those projects for which funding has been identified using current or
reasonably available revenue sources.  The state and the transit
operators must provide information early in the process of developing
the TIP about the amount of federal, state, and other funds likely to
be available.  This financial constraint requirement was a major
change in federal policy.  Before ISTEA, long-range plans and TIPs
were often lengthy "wish lists" of projects proposed by local
governments, transit operators, and others.  Because such plans and
programs bore no relation to the available financial resources, many
projects were never implemented.  Hence, the real implementation
decisions took place outside of the formal planning process.  Thus,
under ISTEA the financial constraint requirement ensures that the
implementation decisions come directly from a systematic planning
process. 


--------------------
\6 Under ISTEA, the states must also develop both a long-term
transportation plan and a statewide TIP.  After approval by the
governor, the metropolitan TIPs are to be incorporated without
modification in the state TIP. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
---------------------------------------------------------- Chapter 1:4

Concerned about the abilities of the MPOs to meet the demands of
ISTEA's planning requirements, the Chairman and the Ranking Minority
Member, Senate Committee on Environment and Public Works, and the
Chairman of that Committee's Subcommittee on Transportation and
Infrastructure requested us to determine the challenges that the MPOs
face in implementing ISTEA's metropolitan planning requirements. 
Specifically, this report (1) discusses the MPOs' experiences in
implementing ISTEA's planning requirements and (2) examines the
extent to which the U.S.  Department of Transportation's
certification review process ensures that the MPOs in larger urban
areas comply with ISTEA's requirements. 

To assess the challenges that the MPOs faced in meeting ISTEA's
metropolitan planning requirements, we reviewed numerous surveys,
reports, conference summaries, and other literature on urban
transportation planning that have been published since 1991.  In
addition, we spoke to representatives of FHWA, FTA, and other
national experts.  We also obtained and analyzed the results of a
1994 nationwide survey of all MPOs in the United States conducted by
the National Association of Regional Councils (NARC).\7 On the basis
of these efforts, we determined that three of ISTEA's planning
provisions--(1) the requirements for involvement by citizens in
developing plans and programs, (2) financially constraining the
transportation improvement program, and (3) project
identification--were particularly challenging for the MPOs.  To
further explore these key issues, we conducted in-depth telephone
interviews with officials of 13 MPOs and 11 state transportation
planning agencies.  These organizations are listed in appendix II. 
The MPOs we selected included those that had great or little
difficulty with planning requirements (on the basis of their
responses to the NARC survey) and represented different regions in
the United States.  All but 1 of the 13 MPOs we interviewed represent
urban areas with populations of 200,000 or greater--the
transportation management areas.  With each MPO, we discussed why it
did or did not have difficulty with selected planning requirements,
the reasons for the difficulty or lack of it, the benefits and
drawbacks of the planning requirement, and whether the Congress
should reconsider these or any other of ISTEA's planning
requirements. 

To determine whether DOT's certification review process was ensuring
that MPOs comply with planning requirements, we obtained and reviewed
DOT's guidance for field staff conducting the reviews and discussed
with FHWA and FTA officials the rationale behind DOT's approach to
the reviews.  We also obtained copies of the 55 certification reports
published through January 5, 1996, and reviewed and analyzed their
contents.  Finally, we spoke to selected MPOs and states about their
views on the advantages and drawbacks of the certification process. 

We performed our work from August 1995 through July 1996 in
accordance with generally accepted government auditing standards. 
After providing a draft of this report to DOT for review and comment,
we met with DOT officials, including the Chief, Metropolitan Planning
Division, Federal Highway Administration, and the Chief, Statewide
Planning Division, Federal Transit Administration.  Where necessary,
we modified the report to address their comments and suggestions. 


--------------------
\7 The National Association of Regional Councils is a national
advocacy group that advances the interests of regional planning
organizations, including MPOs. 


MPOS SEE PLANNING PROVISIONS AS
BENEFICIAL AND SUPPORT
CONTINUATION
============================================================ Chapter 2

Three of ISTEA's key planning requirements--for extensive public
involvement in planning and programming, for the financial constraint
of TIPs, and for the MPOs' authority to select projects--posed
significant challenges.  Despite these challenges, the MPOs we
interviewed believe that their efforts to meet these requirements
have been beneficial.  Furthermore, both the MPOs we interviewed and
the national organization representing MPOs support continuing these
three provisions.  The state transportation planning officials we
interviewed were less unanimously supportive of these provisions, and
the American Association of State Highway and Transportation
Officials (AASHTO) advocates eliminating the requirement to
financially constrain the long-term transportation plans. 


   EFFORTS TO INVOLVE CITIZENS
   IMPROVE THE ACCEPTABILITY OF
   PLANS AND PROGRAMS
---------------------------------------------------------- Chapter 2:1

ISTEA's requirements for extensive involvement by members of the
general public in the transportation planning process required
considerable changes at many of the nation's MPOs.  The public
participation requirement has challenged the MPOs to expand the
resources devoted to involving citizens and apply more effective
techniques for soliciting public input.  Despite the initial
challenges, all 13 MPOs we interviewed believed that ISTEA's
requirements were desirable and beneficial to the planning process. 
According to the MPOs we spoke to, effective public outreach serves
to inform the public of key regional transportation issues, helps
ensure that programs contain projects truly needed by the public, and
identifies "problem" projects early in the planning process. 
According to the MPOs and states we interviewed, changes to this
requirement, if any, should ensure that the MPOs have sufficient
flexibility to develop those programs best suited to their local
areas. 


      ISTEA'S REQUIREMENTS TO
      INVOLVE CITIZENS IN THE
      PLANNING PROCESS MADE NEW
      DEMANDS ON MANY MPOS
-------------------------------------------------------- Chapter 2:1.1

According to DOT's guidance, ISTEA intended that the MPOs' efforts to
involve citizens would lead to transportation plans and programs that
are more reflective of a community's mobility and accessibility needs
and more cognizant of the broader issues, such as the effects of
transportation investments on the environment, urban neighborhoods,
and the general quality of life.  The efforts to involve citizens
were to include an open exchange of information and ideas between
transportation decision makers and the public, including all
individuals and groups potentially affected by transportation
decisions.  Such efforts were to occur at various stages of the
transportation planning process, including the development of the
long-term plan, the TIP, and individual projects. 

At the outset of ISTEA, the MPOs' ability to meet the act's public
involvement requirements was in doubt.  A 1992 study commissioned by
DOT noted that public participation in transportation planning had
been relatively narrow and of low visibility, except for critical
episodes when contentious issues arose.  The urban areas that did
have extensive public participation efforts before ISTEA were those
that had active civic cultures.\8 The 1995 ACIR report found that
participation by the public is one of the areas emphasized by ISTEA
in which the MPOs need the most assistance. 


--------------------
\8 Intermodal Surface Transportation Efficiency Act of 1991:  Promise
to Performance, Institute of Public Administration, Dec.  1992, pp. 
65-66. 


      EFFECTIVE EFFORTS TO INVOLVE
      CITIZENS REQUIRE GREATER
      RESOURCES, ENHANCED
      EXPERTISE, AND A BALANCING
      OF INTERESTS
-------------------------------------------------------- Chapter 2:1.2

DOT's regulations also note that an effective effort to involve
citizens requires the MPOs to provide the public with timely and
relevant information on transportation planning, full public access
and input to key decisions, and opportunities for the public's early
and continuing involvement.  These requirements have been challenging
to the MPOs for a number of reasons.  Specifically, we found that
ISTEA's requirement for involving the public challenges the MPOs to
(1) significantly expand the resources devoted to that involvement,
(2) develop new methods for soliciting public input, and (3)
effectively use the results of their efforts to involve the public. 

First, the efforts to involve citizens required greater resources
than the MPOs may have been devoting.  A 1994 planners manual\9 found
that effective involvement by the public would require not only
greater commitment from MPO managers and public officials, but also
significant postage and publication budgets and more staff time than
most MPOs would likely expect.  Our interviews with the MPOs and the
states clearly bore this out.  Eleven of the 13 MPOs we interviewed
told us they had expanded their efforts to involve citizens since
ISTEA, and 7 of them said that the need for additional resources was
a challenge.  Typically, the MPOs told us that while they had made
some limited efforts to involve the public before ISTEA, these were
often cursory.  For example, the St.  Louis MPO's effort grew from a
standing citizens committee into a multifaceted program to involve
more people.  This MPO's efforts to inform and educate the public now
include transportation issue papers distributed to target audiences,
public speaking engagements before community groups via a speakers
bureau, press releases on topical transportation-related issues, and
articles in MPO periodicals.  The efforts to obtain input from the
public include public meetings, smaller focus groups, surveys, and
project solicitations.  Similarly, an official of the Philadelphia
MPO told us that the MPO has tripled its spending on involvement by
the public--from $90,000 to about $300,000 annually--and now has two
full-time staffers exclusively devoted to the effort. 

Second, the development and implementation of programs to involve the
public may call for knowledge and skills that may not have been
readily available to MPOs at the outset of ISTEA.  The 1995 ACIR
report also found that the MPOs needed research on the techniques
that will encourage citizens' participation, especially those
techniques that have been successful in highly populated areas, and
the services of experts trained in such techniques.  The report found
that the MPOs needed to be more sophisticated in using the media to
build support from the public.  These issues also arose in our
interviews with the MPOs and the states.  In open-ended discussions,
4 of the 13 MPOs noted the difficulty presented by selecting and
implementing the appropriate techniques for involving the public. 
For example, an official of the St.  Louis MPO told us that
identifying the best method is the biggest problem the MPO faces in
its attempts to involve the public.  The official added that the
problem is an ongoing one, as the public response to individual
techniques seems to diminish over time.  The Springfield,
Massachusetts, MPO noted that in developing transportation
newsletters, simply translating the planners' technical jargon into
readable language for the general public is a large task.  The MPO
has hired a specialist to assist with this effort.  Such technical
assistance may be key for many MPOs--the Milwaukee MPO, which did not
have much difficulty with ISTEA's requirements for involving
citizens, credited technical assistance from the University of
Wisconsin's extension service as a significant factor in the
program's success. 

Finally, the MPOs must determine how input from the process of
involving the public will influence plans and programs.  Nearly all
of the MPOs we interviewed found it difficult to get the general
public interested and involved in transportation planning issues. 
These MPOs noted that, typically, "John Q.  Public" will become
interested in transportation planning only if a specific project will
affect his well-being.  He may get very involved, for example, if he
believes that a road-widening project will increase the traffic near
his home and hence harm the value of his property.  As a result, the
public's input generally may not reflect the views of a cross-section
of the general public.  Several MPOs said that getting input from
lower-income and minority communities is particularly challenging. 
On the other hand, certain interest groups, often with a narrowly
defined agenda, may be very active in commenting on the
transportation planning process.  As a result, the interest of
activists with specific agendas may dominate the process of involving
the public.  One MPO official noted that citizens' involvement has
given professional groups a vehicle for expressing their views and
dominating the public discussion.  In putting together plans and
programs, the MPOs must balance the input of activists with the
transportation needs of the broader public. 


--------------------
\9 ISTEA Planners Workbook, Surface Transportation Policy Project,
Oct.  1994. 


      MPOS WE INTERVIEWED BELIEVE
      ISTEA'S PROVISIONS FOR
      INVOLVING THE PUBLIC ARE
      BENEFICIAL AND SUPPORT
      CONTINUATION
-------------------------------------------------------- Chapter 2:1.3

Despite the difficulties and imperfections inherent in the efforts to
involve the public, all of the MPOs we interviewed believe that
effective involvement by the public is critical to good planning. 
All 13 MPOs noted that their efforts to meet ISTEA's requirements for
involving the public have resulted in plans and programs that are
more reflective of the public's transportation needs and hence enjoy
broader and stronger public support.  Also, citizens' latent
opposition to projects is uncovered much earlier in the planning
process.  For example, the Durham, North Carolina, MPO told us of a
project that would widen a four-lane road to eight lanes.  All of the
technical analyses supported the need for this project, but the MPO
ran into significant public opposition as the construction phase
neared.  The project was delayed for over a year, which, according to
the MPO official, might well have been avoided if the public's input
had been sought earlier in the planning process. 

For the reasons outlined above, the 13 MPO officials we spoke to
unanimously supported the continuation of the requirement for
involving the public in transportation planning.  However, MPO and
state planning officials emphasized the importance of flexibility in
selecting the appropriate techniques for inviting citizens' input and
the concomitant importance of avoiding overly prescriptive federal
regulations.  For example, a Florida state department of
transportation official stated that techniques that work well for
communities in Florida's panhandle may be ineffective in the Hispanic
and Caribbean communities of south Florida.  An official at the St. 
Louis MPO stated that any one technique for involving the public has
a relatively short shelf life, with diminishing returns over time. 
Hence, it is important to vary techniques--such as surveys, public
meeting, focus groups, and so on--over time. 


   FINANCIAL CONSTRAINT ENSURES
   REALISTIC PROGRAM OF PROJECTS
---------------------------------------------------------- Chapter 2:2

Financially constraining TIPs--the 3-year plan--was a new requirement
for many MPOs.  A 1994 planner's guide noted that prior to ISTEA,
many TIPs were laden with more projects than could be afforded and
that bringing these TIPs into balance was politically painful.  Also,
successfully constraining a TIP requires reliable projections of
revenue--projections that were not always available.  Despite these
difficulties, all but two of the MPOs we spoke to had developed
financially constrained TIPs, and all MPOs believed that the practice
was critical to meaningful short-term planning.  As the requirement
has forced a realization of limited resources, it has encouraged
planners to explore other options for local and regional financing. 
The MPOs we interviewed all supported continuing the TIP constraint
in ISTEA. 


      DEVELOPMENT OF CONSTRAINED
      PROGRAMS SEEN AS CHALLENGING
-------------------------------------------------------- Chapter 2:2.1

ISTEA requires MPOs to ensure that their TIPs include a ranked list
of projects and a financial plan that demonstrates how the program
can be implemented with reasonably available resources.  For example,
a TIP featuring $10 million in highway and transit improvements would
have to show that these projects could be paid for with federal,
state, local, or other funds that were demonstrably available.  This
requirement was a significant change to federal planning
requirements.  According to the National Association of Regional
Councils (NARC), before ISTEA, there were pressures to include as
many projects as possible in the TIP, regardless of the cost. 
Consequently, proposed transportation spending was sometimes more an
outcome of political influence than of a rational planning process. 
NARC noted that by ensuring that planners develop and limit
investment programs on the basis of realistic budgets, transportation
spending would be a rational outcome of the planning process. 

The MPOs and states we interviewed stated that the requirement to
financially constrain TIPs is one of the most challenging of ISTEA's
planning requirements.  Because many MPOs had not financially
constrained TIPs before ISTEA, both their technical ability to
develop financial plans and their institutional wherewithal to
exclude projects not falling within the budget were in doubt at the
outset of ISTEA.  A nationwide survey of MPOs conducted by the
National Association of Regional Councils found that financially
constraining the TIP was the most difficult of eight selected ISTEA
planning requirements. 


      FINANCIAL CONSTRAINT
      REQUIRES DEVELOPING REGIONAL
      CONSENSUS AND EFFECTIVE
      WORKING RELATIONSHIP WITH
      THE STATE
-------------------------------------------------------- Chapter 2:2.2

Our interviews with the MPOs and the states, as well as other studies
of MPOs under ISTEA, reveal that the financial constraint requirement
presented the MPOs with two main challenges.  First, the MPOs had to
develop a regional consensus as to which programs would be on the
TIP.  Second, the MPOs had to obtain reliable estimates of the funds
available from the state departments of transportation. 

Because a financially constrained TIP is a defined and realistic
program of transportation spending, it must be based on a regional
consensus about which projects are best suited to meet a region's
transportation needs.  Highways, mass transit, and other projects can
be proposed by many entities, including the state, cities, counties,
transit agencies, and community groups.  The financial constraint
requirement forces policy-makers to consider trade-offs and make
choices among these alternative transportation investments.  In
open-ended discussions, 6 of the 13 MPOs that we interviewed noted
the difficulties involved in reaching such a consensus.  For example,
the Atlanta MPO noted that its 1992 TIP contained about four times as
many projects as could be paid for with reasonably available
resources.  To bring the TIP into balance, it had deleted about $400
million worth of planned projects by 1993.  This action did not
please the sponsors of deleted projects, although many projects had
scant chance of implementation.  Similarly, the MPO for Dallas/Ft. 
Worth noted that the MPO and the state department of transportation
had a significant dispute because a freeway improvement advocated by
the state was not included in the financially constrained TIP. 

A reliable estimate of available revenues is indispensable in
financially constraining the TIP.  Because much of the funding for
urban transportation--both state and federal--comes from the state
departments of transportation, the MPOs depend on their states to
provide guidance on the financial resources that can reasonably be
expected to be available during the TIP period.\10 Most MPOs either
did not raise this issue or told us that the state departments of
transportation have been cooperative and have provided financial
estimates with reasonable timeliness.  However 3 of the 13 said that
the states' lack of willingness to provide reliable estimates of the
available revenues has been a hurdle in developing financially
constrained TIPs.  At two MPOs, the inability to obtain reliable
financial information was the center of disputes between the MPO and
the state department of transportation about the ability of the MPO
to select projects.  For example, officials of one MPO told us that
the state department of transportation did not provide estimates of
the available funds, except in the form of draft state TIPs.  In
essence, the MPO said that the state had refused to provide any
estimates of the future revenues that the MPO could use to develop a
local TIP. 

Another MPO told us that it had submitted a TIP that was financially
constrained on the basis of the revenue estimates provided by the
state.  The TIP was included in the state's transportation
improvement program, which was subsequently rejected by FHWA/FTA
because the state's revenue assumptions included a drawdown of its
unobligated balances, which is not possible without congressional
action.  As a result, the MPO had to develop a revised TIP with about
one-third the resources of the original TIP.  The state's action and
the subsequent rejection of the TIP created considerable resentment
among the local officials and project sponsors in the region. 


--------------------
\10 Moving Urban America, Transportation Research Board Special
Report 237, National Academy Press, 1993. 


      MPOS WE INTERVIEWED SUPPORT
      CONTINUING THE FINANCIAL
      CONSTRAINT REQUIREMENT
      BECAUSE IT HAS PRODUCED
      BETTER INVESTMENT PROGRAMS
-------------------------------------------------------- Chapter 2:2.3

Twelve of the 13 MPOs we interviewed told us they had developed
financially constrained TIPs under ISTEA.  Furthermore, all of the
MPOs we spoke to unanimously supported the continuation of the
requirement to financially constrain the TIP, as did 7 of the 11
state transportation offices we interviewed.  All of the MPOs we
spoke to noted that the financial constraint requirement forces the
development of TIPs that include the projects that will be
implemented.  Officials of the New Orleans MPO, for example, told us
that before ISTEA, the system of selecting and implementing
transportation projects had broken down.  There was little sense of
real priority in the TIP.  Because the TIP is now financially
constrained, its credibility and "implementability" are significantly
enhanced, and the priorities spelled out in the TIP now drive
investments.  Similarly, an Atlanta MPO official told us that the
commitment to the projects on the TIP is much greater because the TIP
is now a firm program of transportation investment priorities. 

In addition to establishing a meaningful program of projects, the
financial constraint requirement has led to tangential benefits. 
Many MPOs said that the financial constraint requirement has forced
regional elected officials to realize the gap between transportation
needs and reasonably available revenues.  As a result, regional
policy-makers are examining other revenue- raising measures,
including innovative financing mechanisms.  For example, the staff of
the Pensacola, Florida, MPO told us that the regional policy-makers
were considering establishing a toll authority for that fast-growing
region.  Also, several MPOs noted that the financial constraint
requirement is indispensable in giving the MPOs real authority to
select projects.  By financially constraining TIPs, the MPO produces
a ranked list of projects that will drive transportation investments. 


      FINANCIAL CONSTRAINT OF
      LONG-TERM PLAN PRESENTS
      ADDITIONAL DIFFICULTIES
-------------------------------------------------------- Chapter 2:2.4

The comments we received from MPOs about the financial constraint
requirement for the long-term plan to some extent paralleled those we
received about the TIP requirement.  However, some MPOs and states
noted that financially constraining long-range planning is
particularly difficult because obtaining reliable estimates of the
available resources for a 20-year period is impossible.  As a result,
some states and MPOs said that they have had to apply the constraint
on the basis of current resources, which limits the vision of the
long-term plan.  As several MPO and state representatives explained,
new revenue sources that the MPOs could use over a 20-year period are
not easily identified at the time the plan is developed.  As a
result, the long-term plan may be much more conservative than it
needs to be.  Several MPOs have found a way around this dilemma. 
Three MPOs that we interviewed said that they developed two long-term
plans--a constrained plan for the federal requirement and an
unconstrained, or "visionary," plan to outline a more extensive
transportation agenda for the region. 


   MPOS' ENHANCED AUTHORITY TO
   IDENTIFY PROJECTS IS DERIVED
   FROM VARIOUS PROVISIONS OF
   ISTEA
---------------------------------------------------------- Chapter 2:3

ISTEA required that the MPOs--and by extension, the regional
interests--in the larger urban areas have a greater influence on
transportation investment decisions than other transportation
planners.  Key wording in ISTEA gives the MPOs in the larger urban
areas substantial influence on identifying projects to be included in
transportation programs as well as on the projects selected from the
programs.  These MPOs are responsible for identifying all projects
for implementation, except projects under the National Highway System
and the Bridge and Interstate Maintenance programs.  While there was
uncertainty about the MPOs' ability to take on this decision-making
authority at the outset of ISTEA, the MPOs and states we interviewed
believe that ISTEA has enhanced the MPOs' authority to select
projects.  While this enhanced authority was attributed to various
provisions of ISTEA, a cooperative and constructive working
relationship with the state was essential. 


      ISTEA REQUIRES NEW
      DECISION-MAKING ROLE FOR
      LARGER MPOS
-------------------------------------------------------- Chapter 2:3.1

ISTEA requires that the MPOs in the larger urban areas--those with
populations of 200,000 or more--take on a significantly larger role
in identifying transportation projects to meet the regions' mobility
needs.  Before ISTEA, the MPOs were generally seen as entities that
were outside of the decision-making process; they developed lists of
projects but deferred real decision-making authority to the state
transportation agencies.  According to the 1995 NARC study, ISTEA
stressed that the MPOs be transformed from weak advisory bodies into
strong decision-making partners working more closely and on an equal
footing with the state transportation agencies and other key
stakeholders.  The MPOs were to play a pivotal role in planning as
leaders, managers, and builders of consensus among other agencies
that may have different perspectives and priorities.  As a result,
transportation decisions--that is, project identification--would be
an outgrowth of a regionally based process and hence better meet the
regions' mobility needs. 

At the outset of the ISTEA era, the capacity of the MPOs to assume
this leadership/decision-making role was in question.  The MPOs were
not traditionally strong decision-making bodies, and federal policy
had de-emphasized urban transportation planning during the 1980s.  As
a result, the planning capacity of many MPOs deteriorated during this
time.  As the Institute of Public Administration noted in 1992, the
MPOs' budgets, functions, staffs, and technical capacities dwindled
during the 1980s.  Perhaps as a result, DOT analysts conducting
comprehensive planning reviews between 1991 and 1993 found that
important metropolitan planning and programming decisions were
determined primarily by the states or by transit operators.  The MPOs
were generally not assuming a decision-making role.\11 At the start
of the ISTEA era, therefore, the MPOs needed to strengthen their
ability to forge consensus on both project financing priorities and
the development of TIPs.\12


--------------------
\11 Lyons, William M.  The FTA-FHWA MPO Reviews--Planning Practice
Under ISTEA and the CAA.  Volpe National Transportation Systems
Center, U.S.  Department of Transportation, Jan.  1994, p.  6. 

\12 Institute of Public Administration, p.  22. 


      MPOS' WORKING RELATIONSHIPS
      WITH STATES AND LOCALITIES
      ARE KEY TO PROJECT
      IDENTIFICATION AUTHORITY
-------------------------------------------------------- Chapter 2:3.2

In our interviews, we found that political and institutional
factors--that is, an MPO's working relationship with the state
department(s) of transportation, regional transit agencies, and local
governments--were the key difficulty in the MPOs' assuming the
authority for selecting projects.  Six of the 13 MPOs we spoke to
noted that forging a consensus among the disparate interests in the
metropolitan area was a challenge.  For example, the Atlanta MPO said
that it was very difficult to get all the relevant parties--the
state, the local government, the transit agencies, and so on--working
together to develop a unified TIP.  While the pre-ISTEA TIP was not
really a document that drove investment decisions, the participants
perceived that under ISTEA, the development of the TIP would have a
real and lasting impact. 

It was clear from our discussions with MPOs that a cooperative and
constructive relationship with the state departments of
transportation is essential in expanding the MPOs' authority.  Nine
of the 12 large MPOs we interviewed\13 said that the states had
facilitated the MPOs' project identification, although in some cases
several years passed before a constructive working relationship
developed.  For example, a representative of the St.  Louis MPO said
that the Missouri department of transportation was not at first
cooperative with the MPO's effort to assume more decision-making
authority.  More recently, however, the MPO and the state have signed
a memorandum of agreement spelling out the agencies' respective roles
and recognizing the more prominent role the MPO will play in
selecting projects. 

Two MPOs said that the states continue to resist the MPOs' and
regional interests' efforts to assume greater authority over project
identification.  In both cases, the difficulties were rooted in the
fundamental disagreements between the MPO and local officials on the
one hand and the MPO and the state government on the other hand about
the appropriate level of the MPO's and the local government's
influence on the development of the TIP.  One MPO said that the
state's TIP process did not allow the MPO to participate fully in the
process of selecting projects.  For example, the state had limited
certain federal funds for pedestrian projects in a manner that the
MPO believed was inconsistent with ISTEA.  An official of the state
department of transportation told us that it gets extensive input and
advice from the MPO and other regional interests in determining the
projects to be included in the state's plans.  However, the state
agency is opposed to suballocating federal and state transportation
funds to the MPOs.  At the other MPO, we found that by dominating the
voting power on the MPO's decision-making body, the state
transportation department was in effect the MPO.  As a result, the
voice of municipal governments and other regional interests were not
effectively represented in developing TIPs. 


--------------------
\13 One of the 13 MPOs we interviewed--the Reading, Pennsylvania,
MPO--does not plan for a transportation management area and hence was
not granted project selection authority by ISTEA.  Because of this,
we discussed the project selection issue with only with 12 MPOs. 


      MPOS WE INTERVIEWED BELIEVE
      THEIR AUTHORITY HAS
      INCREASED AND SUPPORT
      ISTEA'S DELEGATION OF THE
      AUTHORITY TO SELECT PROJECTS
-------------------------------------------------------- Chapter 2:3.3

Most MPOs we interviewed--8 of 12--said that ISTEA had a great or
very great impact on their authority to select projects.  Their
comments revealed that no single provision of ISTEA can be credited
with this change.  As table 2.1 reveals, several of ISTEA's
provisions have contributed to this change.  For example, ISTEA
states that projects in urban areas with populations of 200,000 or
greater shall be selected by the MPO in consultation with the state,
except projects under the National Highway System and the Bridge and
Interstate Maintenance programs.  The MPOs typically stated that this
provision had some impact but was mainly symbolic.  For example, one
official told us that the selection of projects from a financially
constrained TIP was little more than an administrative sign-off.  Of
much greater significance was the development of a financially
constrained TIP.  As an official of the Albany, New York, MPO
explained, all of the projects in a financially constrained TIP are
intended for implementation; consequently, the development of the TIP
is the real decision point for project identification. 



                               Table 2.1
                
                  ISTEA's Provisions Influencing MPOs'
                     Authority to Identify Projects

                        Impact on MPO's
ISTEA provision         planning authority      Caveats
----------------------  ----------------------  ----------------------
MPO's selection of      Signals ISTEA's intent  Mainly of symbolic
projects from TIP       that MPOs and regional  value; MPOs and others
                        interests have greater  noted that because all
                        influence on            implemented projects
                        transportation          must come from TIP,
                        investments             TIP development is
                                                project identification

MPO's development of    Ensures that TIP will   Requires state
ranked, financially     be limited to only      cooperation and
constrained TIP         those projects for      acceptance of MPO-
                        which funds are         developed TIP
                        available and
                        commitment is serious

STP-urban\a and CMAQ\b  Urban-oriented          Requires state
programs                programs for which      concurrence that MPO
                        MPOs have project       will have authority to
                        selection authority     target these funds

Funding flexibility     Gives MPO decision-     Expands MPO's
                        makers a wide latitude  authority only if
                        in choosing highway,    project identification
                        transit, or other       authority is
                        projects                established
----------------------------------------------------------------------
\a Surface Transportation Program. 

\b Congestion Mitigation Air Quality Program. 

Source:  GAO's interviews with MPOs. 

Four of the 12 large MPOs that we interviewed said that ISTEA had
only little or some influence on their authority to select projects. 
Two of these noted that their influence increased only minimally
after ISTEA because they had an acceptable level of influence before
ISTEA.  For example, the Milwaukee MPO told us that it has long had a
constructive working relationship with the Wisconsin Department of
Transportation.  Although the MPO noted that ISTEA had some impact on
its authority, it said that it did not just wrest authority from the
state and present its decisions as a fait accompli; a cooperative
working relationship with the state was critical.  As discussed
above, two other MPOs had different experiences.  Despite the range
of views on ISTEA's impact, the MPOs we interviewed unanimously
supported both the ISTEA language that delegates the authority to
select projects to larger MPOs and the other provisions that have
enhanced the MPOs' authority. 


   STATES AND MPOS HAVE DIFFERENT
   PERSPECTIVES ON PLANNING
   PROVISIONS
---------------------------------------------------------- Chapter 2:4

MPOs and states to some extent have differing views on continuing
ISTEA's planning provisions.  While the MPOs we interviewed
unanimously endorsed the continuation of the public participation,
financial constraint, and project selection requirements, some states
opposed the continuation of these requirements.  Furthermore, AASHTO
and the Association of Metropolitan Planning Organizations (AMPO)
have taken differing views. 

As table 2.2 indicates, AASHTO and AMPO have differing positions on
continuing certain planning provisions of ISTEA.  AMPO cited ISTEA's
requirements for involving the public as a model piece of legislation
for ensuring broad-based involvement by citizens and local elected
officials.  While noting the benefits of involving the public, AASHTO
stated that the regulations on such involvement are too detailed and
prescriptive.  It emphasized state and local flexibility in
developing the process of involving the public.  It also noted that
the detailed requirements in federal regulations and guidance can
lead to substantial delays on projects and to court challenges. 
Nearly all the state officials we interviewed supported the
continuation of the requirements to involve the public that are
contained in the legislation.  However, as noted earlier, some states
also expressed concern about the impacts of overly prescriptive
regulations. 



                               Table 2.2
                
                   Comparison of AASHTO's and AMPO's
                     Positions on Selected Planning
                          Provisions of ISTEA

ISTEA's planning
provision               AMPO's position         AASHTO's position
----------------------  ----------------------  ----------------------
Involvement of the      Supports continuation   More emphasis on
public                                          flexibility in
                                                developing public
                                                involvement approaches

Financial constraint    Supports continuation   Allow for
of TIP                                          overprogramming

Financial constraint    Supports continuation   Eliminate legislative
of long-term plan                               requirement

MPOs' authority to      Extend decision-        Increase population
select projects         making role to all      threshold from 200,000
                        MPOs, except those      to 1 million
                        wishing to defer to
                        the states
----------------------------------------------------------------------
Sources:  GAO's presentation of data from AASHTO's Reauthorization
Policy Statements, Interim Report, Dec.1995, and ISTEA II:  Building
a Coalition, Association of Metropolitan Planning Organizations,
Jan.1996. 

According to AMPO's policy statement, ISTEA's requirements for
financially constrained plans and programs are consistent with sound
business practices and strongly supports the continuation of the
requirements.  AASHTO's states that in financially constraining TIPs,
MPOs should have the flexibility to program at a level that enables
them to deal with the uncertainty of project schedules and with
fluctuating levels of federal funding.  State officials expressed
similar concerns.  Four of the 11 state planning officials we
contacted opposed the retention of this requirement.  While they
support the principle of financially constraining the TIP, they
believe that the regulatory interpretation is too strict.  Three of
the four stated that the planning regulations should allow some
over-programming.  As one MPO explained, delays are inevitable on
some projects because of environmental permitting or other reasons. 
Because the process of amending a TIP--for example, adding a new
project--is very time consuming and administratively difficult,\14
this delay can be substantial.  Several states we interviewed noted
that a modest over-programming of the TIP--for example, by 10
percent--would circumvent this problem by including a short list of
"ready to go" projects that could be funded in the event that other,
higher-priority TIP projects were delayed. 

AMPO supported the financial constraint requirement for the long-term
(20-year) plan.  AASHTO, however, stated that the implementing
regulations do not take into account the difficulty of predicting the
amounts and sources of funding over a 20-year period.  AASHTO noted
that the requirement was unrealistic and could prevent MPOs from
taking advantage of fiscal partnering arrangements.  As a result,
AASHTO calls for eliminating the ISTEA requirement to financially
constrain long-term plans.  In addition, 5 of the 11 states we
interviewed opposed the continuation of this requirement.  Typically,
the states said that it is not possible to develop a reliable
estimate of revenues over a 20-year period and that financially
constraining the long-term plan inhibits a vision for the regional
transportation system. 

AMPO and AASHTO's are perhaps in clearest disagreement over the issue
of the MPOs' authority to select projects.  AMPO favors extending
decision-making authority to all of the MPOs that desire to assume
it.  Potentially, this action would increase from 129 to 339 the
number of MPOs with the authority to select projects.  AASHTO's
proposal to raise the threshold for the transportation management
area to 1 million people would take the authority to select projects
away from about 94 MPOs that currently have it.  AASHTO contends that
raising the threshold would restrict the authority to those urbanized
areas likely to have the resources to meet the burdens this authority
implies.  AASHTO's position on this issue was not well reflected in
our interviews--only 2 of the 11 state officials we contacted opposed
the retention of ISTEA's current wording.  Not surprisingly, these
two states are the ones where we encountered a significant
disagreement between the state and the MPO on the question of
selection authority. 


--------------------
\14 Among other things, an amended TIP must undergo a 30-day comment
period and be tested for conformity with the state's air quality
plan. 


   CONCLUSIONS
---------------------------------------------------------- Chapter 2:5

The desirability of ensuring adequate involvement by the public and
financial constraints on transportation programs was not disputed by
the MPOs and states we interviewed, nor by AASHTO and AMPO. 
Furthermore, the difficulties of financially constraining long-term
plans is clearly a challenge that some states and MPOs have met.  In
view of the benefits of these provisions, the problems faced in
meeting these requirements may not require legislative changes.  The
key dispute we encountered among the three issues we explored--the
delegation of the authority to select projects to a greater or lesser
number of metropolitan planning organizations--is essentially an
issue to be resolved through congressional deliberations. 


FHWA'S AND FTA'S CERTIFICATIONS OF
MPOS
============================================================ Chapter 3

To ensure that urban transportation plans and programs are an
outgrowth of the planning process that ISTEA prescribes, ISTEA
required the Secretary of Transportation to conduct planning
certification reviews at the MPOs in transportation management areas. 
The MPO and state officials we spoke to generally supported the
certification process and described it as helpful and constructive. 
However, in reviewing 55 certification reports, we found that the
reports are of limited usefulness in assessing trends or problem
areas in the ISTEA planning process.  First, the certification
reports vary widely in format and content because the Department did
not develop standard formats for assessing or reporting the MPOs'
compliance.  Second, three MPOs were certified despite significant
deficiencies in the urban transportation planning process. 
Accordingly, the results of the certification reviews cannot be used
to develop a reliable understanding of the MPOs' progress in meeting
ISTEA's planning requirements.  This is an especially critical issue
because the certification reviews are by far the most in-depth
assessments of the MPOs' performance in transportation planning. 


   CERTIFICATION REVIEWS
   SUPPLEMENT SELF-CERTIFICATION
---------------------------------------------------------- Chapter 3:1

ISTEA requires that the Secretary of Transportation certify that
metropolitan transportation planning conforms with ISTEA's planning
provisions.  Specifically, at least once every 3 years, FHWA and FTA
must jointly review and evaluate the planning processes for each of
the nation's 129 MPOs located in TMAs.  If, on the basis of their
joint review, FHWA and FTA determine that the planning process meets
or substantially meets the planning requirements, they may either
jointly certify the planning process or conditionally certify the
process subject to specified corrective actions.  If FHWA and FTA
find that the planning process in a TMA does not meet the
requirements, certification is denied, and FHWA and FTA may withhold
all or part of the apportioned federal highway and transit funds, or
withhold their approval of certain projects. 

This requirement was a significant change in federal oversight
policy.  Since 1983, the urban transportation planning regulations
have required that the state and the MPO "self-certify" that the
urban transportation planning process is in conformance with the
continuing, cooperative, and comprehensive (3-C) process called for
in the law and the regulations.  Self-certification was intended to
grant increased responsibility for transportation planning to the
states and MPOs.  Under ISTEA, the MPOs and the states will continue
to self-certify annually. 

The FHWA and FTA certification reviews are comprehensive.  First,
they cover all 129 TMAs with the results of the reviews reflective of
large urban areas.  Second, the reviews cover a range of planning
topics focusing on six areas: 

  -- incorporation of the 15 planning factors in the planning
     process,

  -- development of early and continuing involvement by the public,

  -- completion of detailed alternative studies when considering
     major transportation investments in a corridor,

  -- development of a congestion management system incorporating
     measures to reduce travel demand,

  -- assurance that plans and programs conform with air quality plans
     and the Clean Air Act Amendments of 1990, and

  -- development of financial constraints on plans and programs. 

Certification reviews consist of a desk audit, during which FHWA and
FTA staff review pertinent files and supporting documentation
pertaining to the planning process; a site visit that includes
extensive meetings with members of the MPO's governing board and
technical staff, state transportation officials, and other local
officials; a public meeting to allow members of the general public to
share their impressions of the planning process; and the preparation
of a report on the certification review.  The on-site reviews can
last 5 days and include eight or more representatives of FHWA and FTA
staff from headquarters, the regions, and field offices. 

In commenting on a draft of this report, DOT officials stated that
although the certification reviews are the formal mechanism for
ensuring compliance, DOT uses a number of other means as well.  For
example, DOT reviews and approves planning work programs for all
metropolitan areas, assesses the TIP and TIP amendments for
conformity with that state's air quality plan in areas not meeting
federal air quality standards, and reviews and approves state TIPs. 
DOT is also conducting a series of enhanced planning reviews (EPR) in
a much more limited number of urban areas.  According to an official
of DOT's Volpe Transportation Center, the EPRs are intended to be
less judgmental and regulatory oriented than the certification
reviews. 


   MPOS AND STATES HAVE MIXED
   VIEWS ON CERTIFICATION PROCESS
---------------------------------------------------------- Chapter 3:2

The MPOs and the states have differing views on the certification
review process.  The MPOs and states we interviewed generally see the
process as constructive and helpful and support its continuation. 
However, some also noted that the reviews could be done more
efficiently and the results reported in a more timely manner.  AASHTO
has called for the elimination of the certification reviews because
they are time consuming. 

Five of the 12 large MPOs we interviewed had been certified as of May
1996.  Each of these MPOs told us that the certification review was
constructive and helpful and stated that the requirement for
certification by DOT should be continued.  For example, the
representatives of the Milwaukee MPO said that the process was
constructive and that it would be unwise for the federal government
to dole out money with no accountability for compliance with the
federal planning guidelines.  Also, the certification review provides
local elected officials and MPO staff the opportunity to meet with
federal officials and get a better feel for what is expected, as well
as useful critiques of how the MPO staff approach their job.  The
Springfield, Massachusetts, MPO staff told us that FHWA and FTA
reviewers helped begin the movement toward greater regional control
of the MPO.  For example, the certification review began a dialogue
on the need to give regional officials greater representation on the
MPO's board. 

On the other hand, one MPO noted that the on-site reviews could be
completed in less time.  For example, the planning staff of the
Pensacola MPO said that the on-site visit took almost a full week and
could have been done in a day and a half.  Attributing the length of
the visit to the fact that it was a first-time effort, they said that
the visits would likely be briefer in subsequent reviews. 

Officials from 8 of 11 states we contacted had experiences with the
process of MPO certification reviews.  Four of them supported the
continuation of the process, one opposed continuation, and two were
neutral or had no opinion.  While most of these state officials
supported the process, several noted that DOT should emphasize a
constructive process rather than a fault-finding audit approach.  A
Texas official noted that the reviews, in contrast to the practice of
self-certification, give the planners an objective assessment of
their performance.  AASHTO advocates eliminating the certification
reviews.  It asserted that the reviews are too time consuming and
cumbersome for many states and do little to improve the planning
process. 


   DOT HAS CERTIFIED NEARLY ALL
   PLANNING PROCESSES REVIEWED
---------------------------------------------------------- Chapter 3:3

As of January 12, 1996, DOT had issued certification reports on 55
MPOs.  Twenty-three MPOs were certified without qualification, and 31
were certified subject to certain corrective actions being taken.  To
date, one MPO has not been certified--the MPO for the Boston
metropolitan area; its certification was held in abeyance.\15 The
overriding issue in this case was the insufficient role that local
elected officials had played in the planning process.  For example,
in meetings between FHWA and FTA staff and 12 local elected
officials, the local officials unanimously complained that they had
virtually no opportunity to be part of the decision-making process. 
While Boston was the sole instance in which DOT postponed
certification of the planning process, our review of the reports on
certification reviews indicate that conditional certifications were
issued for some MPOs in serious noncompliance with ISTEA's planning
requirements.  For example, the reports on other Massachusetts MPOs
noted insufficient local representation and state dominance of the
planning process.  The Worcester, Massachusetts, MPO was certified
even though it had no local officials on its policy body, the MPO's
technical board had not met publicly since 1976, no public
involvement process had been formally adopted, and TIPs and
transportation plans were not appropriately financially constrained. 
In addition, although the Springfield, Massachusetts, MPO's policy
body had not met in 14 years and included no local elected officials,
the MPO was certified. 

Numerous instances of noncompliance were also identified in the
report for the Louisville, Kentucky, MPO.  The over-arching issue was
a lack of communication and cooperation among the key regional
planning entities.  The states of Kentucky and Indiana, as well as
the city of Louisville, were carrying out many planning activities
outside of the MPO process, prompting the reviewers to state that
they found parochialism far more prevalent than regionalism.  FHWA's
review noted that the entities in the urbanized area were more
concerned with getting their "piece of the pie" than with the good of
the region.  As a result of these concerns, the reviewers recommended
that the MPO be conditionally certified for 1 year. 

DOT certified these MPOs because of its flexible approach in the
first round of reviews.  According to an FHWA headquarters official,
the current round of reviews began 3 years after ISTEA's passage but
only a year after the final planning regulations were issued.  As a
result, DOT felt that a phase-in of requirements and a lenient
approach in the first round of reviews were appropriate.  This was
particularly true during the pilot reviews, which included the
reviews of Worcester and Louisville.  Decertification, the official
said, would have occurred only in the case of egregious
noncompliance, such as the failure to submit a TIP. 


--------------------
\15 FHWA and FTA allowed the MPO's self-certification to stand,
thereby allowing the urban area to receive federal highway and
transit funds. 


   FORMAT OF REPORTS NOT CONDUCIVE
   TO NATIONWIDE ASSESSMENT OF
   MPOS' PROGRESS
---------------------------------------------------------- Chapter 3:4

Because the certifications must be completed every 3 years, FHWA and
FTA regional and divisional offices are devoting considerable
resources to the certification reviews.  For example, officials in
FHWA's Region 4 estimated that FHWA and FTA had spent a total of
1,105 staff days in conducting and reporting the results of 19
certification reviews within their region, averaging 58 staff days
per review.  In addition, FHWA and FTA personnel in two other regions
we contacted spent 420 staff days and 408 staff days, respectively,
completing the certification reviews in their own jurisdictions over
the same period.  This accounting does not include the travel and per
diem costs involved in the reviews.  A certification review can last
5 days and include 8 or more representatives from FTA and FHWA
headquarters and regional and field offices. 

Despite this large resource commitment, in our review of the 55
reports on certification reviews published through January 12, 1996,
we found that the reports on certification reviews were not
documented in a way that allows comparisons between one MPO and
another, or a meaningful assessment of the progress that the MPOs are
making in meeting the planning requirements.  The reports vary
significantly in format, depth, and content.  In one FHWA region, for
example, all six of the reports on certification reviews that we
examined were four pages or less in length, were written in a very
summary fashion, and contained limited discussions of how the MPOs
complied with the six focal areas under review.  By contrast, the
certification reports from several other FHWA regions were quite
lengthy, as long as 29 pages and averaging over 15 pages.  As a
result, a national overview of the MPOs' progress in meeting the
planning requirements would be quite difficult to develop. 

Variations also exist in the use of the key terms of certification
reviews, such as "corrective action required" or "corrective action
recommended." For example, one region's reports clearly distinguish
corrective actions as areas where steps are needed to correct a
regulatory deficiency from those which are optional recommendations
for improvement.  In some certification reports from other regions,
however, it was not possible to distinguish corrective actions from
recommendations.  For example, the cover letter of one report stated
that the MPO was certified subject to certain corrective actions. 
However, the body of the report did not name the corrective actions
that the MPO was to undertake.  Instead, it included a discussion of
11 recommendations, although it was not clear if these
recommendations were required for certification or whether they were
left to the discretion of the MPO. 

According to FHWA headquarters officials, the certification reviews
were not intended to help assess a trend toward improvements in
metropolitan transportation planning efforts.  Instead, the purpose
was to assess whether an individual MPO had substantially complied
with the planning requirements.  Furthermore, DOT wanted to avoid a
defined format, so as to give certifying officials the flexibility to
conduct the reviews in a way best suited to the MPO and its unique
circumstances.  Also, DOT wanted to encourage innovation and
experimentation in conducting the reviews. 


   CONCLUSIONS
---------------------------------------------------------- Chapter 3:5

Although DOT provided its certification reviewers with the
flexibility to assess the MPOs' compliance with ISTEA planning
requirements, the result of this flexibility has been that the
certification reports provide limited information on how well MPOs
have met these important ISTEA provisions.  For example, the
certification reports do not allow the Department to determine if the
difficulties faced in financially constraining TIPs were similar
across most MPOs, or whether these reasons had similar root causes. 
Given the resources going into the effort and the resultant depth of
the reviews, collecting consistent data for an overall assessment is
important and would not preclude the Department's need for
flexibility.  Collecting these data is further justified since the
certification reviews are by far the most comprehensive reviews of
the MPOs' performance that are likely to be conducted. 


   RECOMMENDATION
---------------------------------------------------------- Chapter 3:6

We recommend that the Secretary of Transportation direct the
Administrators of the Federal Highway Administration and the Federal
Transit Administration to develop reporting formats for assessing and
reporting on the MPOs' compliance with ISTEA's planning requirements
in such a way that the Department can identity any nationwide
patterns in planning deficiencies, the underlying causes of these
planning deficiencies, and the extent to which the MPOs have made
progress in meeting the requirements. 


   AGENCY COMMENTS
---------------------------------------------------------- Chapter 3:7

DOT officials disagreed with our conclusion that the information
gathered during the certification reviews should be used to develop
an overview of the MPOs' progress in meeting ISTEA's planning
requirements.  DOT officials stated that the certification reviews
were not intended to assess the MPOs' overall progress; rather, they
were intended to review the efforts of individual MPOs and provide
those MPOs feedback on what they must do to fully meet ISTEA's
planning requirements.  In addition, officials stated that the
certification process is one of several activities that the
Department has or plans to take to determine the MPOs' compliance
with the planning requirements and thereby assess the MPOs' overall
progress in meeting the requirements.  These additional activities
include the Department's approval of TIPs and their conformity with
state air quality plans; the sponsorship of studies, focus groups,
and conferences on the MPOs' progress; and the use of enhanced
planning reviews.  The Department will use this body of information
to assess the MPOs' compliance with the planning requirements and
thereby provide the Congress with information on whether the MPO
planning provisions should be continued in ISTEA's successor
legislation.  As a result of these concerns, DOT officials disagreed
with the recommendation in our draft report that it develop standard
criteria and reporting formats for its certification reviews so that
the Department could assess and report on the MPOs' compliance with
ISTEA's planning requirements.  DOT officials stated that the
recommendation was too prescriptive, particularly in its call for
standard criteria, and suggested that we direct our recommendation to
the Congress instead. 

We have incorporated information in the report that describes the
additional activities that Department officials stated they have
undertaken or plan to undertake to assess the MPOs' progress in
meeting ISTEA's planning requirements.  In addition, we have modified
our proposed recommendation by deleting our original call for
standard criteria to address the Department's request for more
flexibility in responding to our recommendation.  However, we
disagree with the Department's characterization of the certification
reviews as only one element in a broader effort to assess the MPOs'
compliance and progress.  The scope and effort that the Department
has placed in the certification reviews clearly suggest that the
information obtained through the reviews is critical in assessing how
well the MPOs have met the requirements.  The certification reviews
cover all 129 MPOs in the nation's largest urban areas, assess the
MPOs' progress in six key planning areas, and require significant
FHWA and FTA headquarters and regional staff time to complete.  In
contrast, the enhanced planning reviews as well as DOT-sponsored
studies have reviewed only a small number of MPOs.  Given this
investment, we believe it is appropriate for the Department to
develop standard formats for documenting the results of the
certification reviews.  A standard reporting format would not limit
the Department's flexibility to tailor the certification reviews to
the particular needs of the MPO.  Rather, it would provide the
Department and the Congress with rich sources of information that
they could use to evaluate whether or not the MPO planning provisions
should be continued. 

DOT officials also suggested technical and editorial changes to the
report.  Where appropriate, we incorporated these changes. 


ORGANIZATION AND MEMBERSHIP OF THE
CHICAGO AREA TRANSPORTATION STUDY
(CATS)
=========================================================== Appendix I



   (See figure in printed
   edition.)


LIST OF MPOS AND STATE AGENCIES
INTERVIEWED
========================================================== Appendix II

State                   Urbanized area          MPO name
----------------------  ----------------------  ----------------------
======================================================================
Arizona                 Phoenix                 Maricopa Association
                                                of Governments

======================================================================
Florida                 Pensacola               West Florida Regional
                                                Planning Council

======================================================================
Georgia                 Atlanta                 Atlanta Regional
                                                Commission

Illinois                Chicago                 Chicago Area
                                                Transportation Study

======================================================================
Louisiana               New Orleans             Regional Planing
                                                Commission

======================================================================
Massachusetts           Springfield             Pioneer Valley
                                                Planning Commission

======================================================================
Missouri                St. Louis               East-West Gateway
                                                Coordinating Council

======================================================================
New Jersey              North Jersey            North Jersey
                                                Transportation
                                                Coordinating Council

======================================================================
New York                Albany                  Capital District
                                                Transportation
                                                Committee

======================================================================
North Carolina          Durham                  Durham/Chapel Hill/
                                                Carboro MPO

Oregon                  Portland                Metropolitan Service
                                                District

======================================================================
Pennsylvania            Philadelphia            Delaware Valley
                                                Regional Planning
                                                Commission
                        Reading
                                                Berks County Planning
                                                Commission

======================================================================
Texas                   Dallas/Ft. Worth        North Central Texas
                                                Council of Governments

Washington              Seattle                 Puget Sound Regional
                                                Council

                        Vancouver               Southwest Washington
                                                Regional
                                                Transportation Council

Wisconsin               Milwaukee               Southeast Wisconsin
                                                Regional Planning
                                                Commission

                        Madison                 Dane County Regional
                                                Planning Commission
----------------------------------------------------------------------
Note:  We interviewed 13 MPOs and 11 states in bold print using a
standard set of questions.  We interviewed other MPOs and states in a
more preliminary phase of our work. 


ISTEA'S 16 PLANNING FACTORS
========================================================= Appendix III

In developing plans and programs, MPOs are to consider the following
16 factors.\16

1.  Preservation of existing transportation facilities and, where
practical, ways to meet transportation needs by using existing
transportation facilities more efficiently. 

2.  The consistency of transportation planning with applicable
federal, state, and local energy conservation programs. 

3.  The need to relieve congestion and prevent congestion from
occurring where it does not yet occur. 

4.  The likely effect of transportation policy decisions on land use
and development and the consistency of transportation plans and
programs with the provisions of all applicable short- and long-term
land-use development plans. 

5.  The programming of expenditures on transportation enhancement
activities as required in the Surface Transportation Program. 

6.  The effects of all transportation projects to be undertaken
within the metropolitan area, without regard to whether such projects
are publicly funded. 

7.  International border crossings and access to ports, airports,
intermodal transportation facilities, major freight distribution
routes, national parks, recreation areas, monuments and historic
sites, and military installations. 

8.  The need for connectivity of the roads within the metropolitan
area with the roads outside the metropolitan area. 

9.  The transportation needs identified through the use of the
management systems required by section 303 of Title 23 of the U.S. 
Code. 

10.  Preservation of rights-of-way for construction of future
transportation projects, including identification of unused
rights-of-way which may be needed for future transportation corridors
and identification of those corridors for which action is most needed
to prevent destruction or loss. 

11.  Methods to enhance the efficient movement of freight. 

12.  The use of life-cycle costs in the design and engineering of
bridges, tunnels, or pavement. 

13.  The overall social, economic, energy, and environmental effects
of transportation decisions. 

14.  Methods to expand and enhance transit services and to increase
the use of such services. 

15.  Capital investments that would result in increased security in
transit systems. 

16.  Recreational travel and tourism. 



(See figure in printed edition.)Appendix IV

--------------------
\16 ISTEA specified the first 15 planning factors.  The 16th was
added by the National Highway System Designation Act of 1995. 


PHONE INTERVIEW WITH MPOS ON
SELECTED ASPECTS OF METROPOLITAN
TRANSPORTATION PLANNING
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)




(See figure in printed edition.)Appendix V
PHONE INTERVIEW WITH STATE DOTS ON
SELECTED ASPECTS OF METROPOLITAN
TRANSPORTATION PLANNING
========================================================= Appendix III



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION

CHICAGO FIELD OFFICE

Marvin E.  Bonner
Joseph A.  Christoff, (312) 220-7703
Catherine A.  Colwell
Michael P.  Hartnett
David I.  Lichtenfeld

SEATTLE FIELD OFFICE

Brian A.  Estes

WASHINGTON, D.C. 

Phyllis F.  Scheinberg


BIBLIOGRAPHY
=========================================================== Appendix 1

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Clean Air Through Transportation:  Challenges in Meeting National Air
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Consideration of the 15 Factors in the Metropolitan Planning Process,
NCHRP Synthesis 217, National Cooperative Highway Research Program. 
Washington, DC:  Transportation Research Board, 1995. 

Dahms, Lawrence D.  "Regional Context of Intermodal Decisions," in
ISTEA and Intermodal Planning - Concept, Practice, and Vision,
Proceedings of a Conference.  Irvine, California:  Dec.  1992. 

DeCorla-Souza, Patrick, and Ronald-Jensen Fisher.  "Comparing
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Dimitriou, Harry T.  Urban Transport Planning - A Developmental
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Dittmar, Hank.  "A Broader Context for Transportation Planning - Not
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Chicago IL:  Winter 1995. 

"Federalism and the Intermodal Surface Transportation Efficiency Act
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