DISCRETIONARY 

TRANSPORTATION 

GRANTS

DOT Should Take 

Actions to Improve the 

Selection of Freight 

and Highway Projects

Report to Congressional Committees

November 2017

GAO-18-38

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-38, a report to 

congressional committees.

November 2017

DISCRETIONARY TRANSPORTATION GRANTS

DOT Should Take Actions to Improve the Selection of 

Freight and Highway Projects

What GAO Found

In 2016, the Department of Transportation (DOT) developed a multi-phased 

review and selection process for a new grant program—the Fostering 

Advancement in Shipping and Transportation for the Long-term Achievement of 

National Efficiencies (FASTLANE). DOT awarded FASTLANE grants to 18 

freight and highway projects. Multiple teams of reviewers evaluated 218 

applications based on an evaluation plan that outlined the criteria and process 

for evaluating applications. GAO found that the awarded projects addressed key 

program requirements, such as ensuring that at least 10 percent of awarded 

funds went to small projects and 25 percent to projects located in rural areas.

DOT generally followed the process outlined in the FASTLANE evaluation plan; 

however the plan resulted in inconsistencies and allowed for broad discretion

during certain team reviews. GAO found the Technical Review Teams—teams of 

modal administration representatives tasked with assessing potential projects 

against established criteria—used different definitions when assigning technical 

ratings, likely contributing to scoring variances. In addition, GAO found the 

evaluation plan gave the Senior Review Team—a team of senior officials 

responsible for assembling the list of projects for consideration by the 

Secretary—broad discretion when assembling the list. For example, the 

evaluation plan and other guidance did not specify the conditions under which

the Senior Review Team may take certain actions to potentially advance large 

projects that did not initially meet certain statutory requirements—likely affecting 

which projects were forwarded to the Secretary of Transportation to be 

considered for awards. Without defined procedures in the evaluation plan to 

ensure all applications are reviewed similarly, DOT may be vulnerable to 

questions about the integrity of the selection process.

DOT’s FASTLANE review process followed some and partially followed other

recommended discretionary grant award practices that GAO has previously 

identified based on Office of Management and Budget and other guidance. For 

example, DOT followed the practice of assessing applicants’ capability to 

account for funds. However, DOT only partially followed some grant practices,

including the recommended practice to document the rationale for award 

selections. Based on a review of FASTLANE’s decision-making documentation, 

GAO was unable to determine the rationale for selecting the 18 awarded 

projects. This documentation restated the anticipated benefits of the selected

projects, but did not otherwise provide insight into why some projects were 

selected for awards over others. Without complete documentation of the 

decision-making, the transparency of the application review and selection 

process is limited. Further, DOT did not finalize the evaluation plan prior to 

announcing the solicitation of applications for fiscal year 2016 grants, as required 

by DOT guidance. In June 2017, DOT announced a new grant program that 

supersedes the FASTLANE program. According to DOT officials, the solicitation 

of applications for the new program was also made without an evaluation plan in 

place, raising concerns the new program may encounter consistency and

View GAO-18-38. For more information, transparency issues similar to those identified in the FASTLANE program. 

contact Susan Fleming at (202) 512-2834 or 

flemings@gao.gov.

Why GAO Did This Study

In December 2015, the Fixing 

America’s Surface Transportation Act 

(FAST Act) authorized DOT to award 

$4.5 billion in discretionary grants for 

fiscal years 2016 through 2020; DOT 

awarded $759.2 million in fiscal year 

2016. 

The FAST Act required GAO to assess 

FASTLANE’s processes for selecting 

grants. This report addresses: (1) the 

processes used to evaluate and award 

FASTLANE grants, (2) the extent to 

which DOT followed its FASTLANE 

evaluation plan, and (3) the extent to 

which the process aligned with 

recommended practices and DOT’s 

own guidance for awarding 

discretionary grants. GAO reviewed 

DOT and FASTLANE documentation, 

analyzed FASTLANE’s fiscal year 

2016 data, and interviewed DOT 

officials and 13 FASTLANE applicants 

selected to include projects of varying 

sizes, locations, and modes.

What GAO Recommends

GAO is making three 

recommendations to DOT, including 

that DOT develop an evaluation plan 

that clearly defines how review teams 

apply criteria, assess applications, and 

assign ratings, among other things 

before soliciting applications; and that 

key decisions be documented 

throughout the application review and 

selection process. DOT concurred with 

our recommendations.
Page i GAO-18-38 Discretionary Transportation Grants

Letter 1

Background 3

DOT Developed Review and Selection Processes and Awarded 

18 FASTLANE Grants That Met Size and Location 

Requirements 7

DOT’s Review Teams Followed the FASTLANE Evaluation Plan, 

but the Plan Resulted in Technical Review Inconsistencies and 

Allowed the Senior Review Team Broad Discretion 19

DOT’s FASTLANE Process Did Not Fully Align with 

Recommended Discretionary Grant Practices or Its Own 

Guidance 25

Conclusions 33

Recommendations for Executive Action 34

Agency Comments 34

Appendix I Objectives, Scope, and Methodology 36

Appendix II Comments from the Department of Transportation 39

Appendix III GAO Contact and Staff Acknowledgments 40

Tables

Table 1: Criteria for Proposed Projects in the Fostering 

Advancements in Shipping and Transportation for the 

Long-term Achievement of National Efficiencies 

(FASTLANE) Grant Program 5

Table 2: Department of Transportation’s (DOT) Fostering 

Advancement in Shipping and Transportation for the 

Long-term Achievement of National Efficiencies 

(FASTLANE) Selections and Funding Allocations by 

Recipient (fiscal year 2016) 17

Table 3: Fostering Advancement in Shipping and Transportation 

for the Long-term Achievement of National Efficiencies 

(FASTLANE) Technical Rating Definitions (fiscal year 

2016) 20

Table 4: Technical Review Ratings by Mode (fiscal year 2016) 22

Contents
Page ii GAO-18-38 Discretionary Transportation Grants

Table 5: Department of Transportation’s (DOT’s) Use of 

Recommended Discretionary Grant Practices for the 

Fostering Advancement in Shipping and Transportation 

for the Long-term Achievement of National Efficiencies 

(FASTLANE) Grant Awards (fiscal year 2016) 26

Figures

Figure 1: Fostering Advancement in Shipping and Transportation 

for the Long-term Achievement of National Efficiencies 

(FASTLANE) Review and Selection Process (fiscal year 

2016) 9

Figure 2: Characteristics of Fostering Advancement in Shipping 

and Transportation for the Long-term Achievement of 

National Efficiencies (FASTLANE) Applications (fiscal 

year 2016) 10

Figure 3: Modal Technical Review Ratings for Fostering 

Advancement in Shipping and Transportation for the 

Long-term Achievement of National Efficiencies 

(FASTLANE) (fiscal year 2016) 11

Figure 4: Cost Effectiveness Ratings for Fostering Advancement 

in Shipping and Transportation for the Long-term 

Achievement of National Efficiencies (FASTLANE) (fiscal 

year 2016) 13

Figure 5: Project Readiness Ratings for Fostering Advancement in 

Shipping and Transportation for the Long-term 

Achievement of National Efficiencies (FASTLANE) (fiscal 

year 2016) 14
Page iii GAO-18-38 Discretionary Transportation Grants

Abbreviations

DOT Department of Transportation 

FAST Act Fixing America’s Surface Transportation Act 

FASTLANE Fostering Advancement in Shipping and Transportation for

the Long-term Achievement of National Efficiencies (grant 

program)

FHWA Federal Highway Administration 

FRA Federal Railroad Administration 

INFRA Infrastructure for Rebuilding America (grant program)

MARAD Maritime Administration 

NEPA National Environmental Policy Act 

NOFO notice of funding opportunity 

TIGER Transportation Investment Generating Economic Recovery

(grant program)

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately.
Page 1 GAO-18-38 Discretionary Transportation Grants

441 G St. N.W.

Washington, DC 20548

November 2, 2017

The Honorable John Thune

Chairman

The Honorable Bill Nelson

Ranking Member 

Committee on Commerce, Science and Transportation

United States Senate

The Honorable John Barrasso

Chairman

The Honorable Tom Carper

Ranking Member

Committee on Environment and Public Works

United States Senate

The Honorable Bill Shuster

Chairman

The Honorable Peter A. DeFazio

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

Federal transportation grants provide critical funding to help build 

highways, bridges, mass transit systems, and port infrastructure. The 

federal government awards discretionary grants (i.e., competitive grants) 

to nonfederal parties, including state and local governments to help 

achieve national objectives. According to federal spending data reported 

on USAspending.gov, in fiscal year 2016, federal agencies awarded over 

$666 billion in grants, about $56 billion of which was awarded by the 

Department of Transportation (DOT). In December 2015, the Fixing 

America’s Surface Transportation Act (FAST Act) authorized DOT to 

award $4.5 billion in discretionary grants for nationally significant freight 

and highway projects for fiscal years 2016 through 2020.1 In turn, DOT 

developed the Fostering Advancement in Shipping and Transportation for 

 1

Pub. L. No. 114-94, §1101(a)(5), 129 Stat. 1312, 1323 (2015).

Letter
Page 2 GAO-18-38 Discretionary Transportation Grants

the Long-term Achievement of National Efficiencies (FASTLANE) grant 

program, designed to fund freight and highway projects. 2

The FAST Act included a provision that we assess DOT’s FASTLANE 

grant selection process.3 This report addresses: (1) the processes used 

to evaluate and award FASTLANE grants and the outcomes of those 

processes, (2) the extent to which DOT followed its FASTLANE 

evaluation plan, and (3) the extent to which the process was aligned with 

recommended practices and DOT’s own guidance for awarding 

discretionary grants.

To address our objectives, we reviewed agency documents including the 

March 2016 notice of funding opportunity (NOFO),4 the FASTLANE 

evaluation plan, training materials provided to technical teams that 

conducted the reviews, and other program guidance and documents 

explaining the criteria and processes used for the FASTLANE grant 

program. We interviewed DOT officials about whether and how they 

applied the program’s criteria and processes. We compared the 

FASTLANE program criteria and processes to DOT’s documentation of its 

FASTLANE grant decisions for fiscal year 2016 and DOT’s agency-wide 

financial assistance guidance (DOT’s guidance).5 As part of our review of 

the decision documents, we interviewed officials about the applicant data 

and their views on the quality of FASTLANE data. We determined that the 

data were sufficiently reliable for the purposes of producing descriptive 

statistics about the applicants and of determining whether the awards met 

key statutory requirements. We also interviewed DOT officials about how 

the requirements affected the evaluation and selection process. We did 

 2

On June 29, 2017, DOT announced in a new Notice of Funding Opportunity (NOFO) that 

the FASTLANE program was being renamed the Infrastructure for Rebuilding America 

(INFRA) program which we will briefly discuss later in the report. 82 Fed. Reg. 31135 (July 

5, 2017). A NOFO is a notice announcing the agency is soliciting project applications to 

receive grant funds and includes information on the program, eligibility, and application 

submission and review information, among other things. This review, authorized by the 

FAST Act, focuses on the fiscal-year 2016 process for awarding grants authorized by the 

FAST Act under the FASTLANE process.

3

Pub. L. No. 114-94, § 1105(a), 129 Stat. 1312, 1336 (codified at 23 U.S.C. § 117(n)(2)).

4

A notice of funding opportunity (NOFO) is a notice announcing the agency is soliciting 

project applications to receive grant funds and includes information on the program, 

eligibility, and application submission and review information, among other things.

5

DOT, Financial Assistance Guidance Manual (Washington, D.C., March 2009 and 

December 2016).
Page 3 GAO-18-38 Discretionary Transportation Grants

not review each application to determine the extent to which the individual 

application aligned with selection criteria. Nor did we assess whether the 

projects selected by DOT for grant awards would achieve the benefits 

stated in the applications or evaluate the costs or the merit of the projects.

We compared GAO best practices for discretionary grant programs6 to 

information from the 2016 NOFO, the FASTLANE evaluation plan, 

guidance to applicant reviewers, other program-related guidance, and 

statements made by DOT officials regarding their implementation of the 

program. Similarly, we compared DOT’s guidance to the FASTLANE 

documents and processes. We also interviewed a non-generalizable 

sample of 13 FASTLANE program applicants, which we selected to 

provide a range of factors such as the size and location of the proposed 

project and the transportation mode to obtain information on the 

challenges they faced, if any, during the FASTLANE program’s 

application process and the consistency of DOT’s communications 

throughout the process. Although information obtained from these 

interviews cannot be generalized to all program applicants, the interviews 

provided insights into applicants’ experiences with the program. Further 

details on our scope and methodology can be found in appendix I.

We conducted this performance audit from October 2016 to November

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

States and local governments are among the eligible entities that may 

apply for FASTLANE grants. The program may fund large and small 

freight or highway projects if the awarded projects meet the statutory 

 6

GAO, Intercity Passenger Rail: Recording Clearer Reasons for Awards Decisions Would 

Improve Otherwise Good Grantmaking Practices, GAO-11-283 (Washington, D.C.: Mar 

10, 2011)

Background
Page 4 GAO-18-38 Discretionary Transportation Grants

requirements outlined in the FAST Act.7 Some key statutory requirements 

for FASTLANE awards include:

• Ten percent of available funds are reserved for small projects. 

Minimum awards for individual projects are $25 million for large 

projects, and $5 million for small projects. Large projects had to meet 

seven additional statutory requirements in order to be eligible for 

selection by the Secretary.8 The Secretary only had to consider these 

requirements for small projects. At least 25 percent of available funds 

are also reserved for rural areas unless DOT does not receive enough 

qualified rural project applicants.9

• FASTLANE grants may be used for up to 60 percent of a proposed 

project’s future eligible costs. Total federal assistance may not exceed 

80 percent of future eligible costs.10

• No more than $500 million, in aggregate, over fiscal years 2016 

through 2020 may be used to fund freight rail, water (including ports), 

or other freight intermodal projects.

In March 2016, DOT issued a NOFO for $759.2 million available for 

award for the first round of FASTLANE grant awards (fiscal year 2016) 

that reflected several federal goals outlined in the FAST Act. 11 According 

 7 The minimum project size for large projects is equal to or the lesser of $100 million or 30 

percent of a state’s fiscal year 2015 federal-aid apportionment. For projects in multiple 

states, the minimum size is equal to or the lesser of $100 million or 50 percent of the 

larger participating state’s fiscal year 2015 apportionment. A small project is an eligible 

project that does not meet the minimum project size for a large project.

8

The seven statutory requirements for large projects are that the project: (1) generates 

national or regional economic, mobility, or safety benefits; (2) is cost-effective; (3) 

contributes to one or more of the goals described in 23 U.S.C. § 150; (4) is based on the

results of preliminary engineering; (5) has one or more stable and dependable funding or 

financing sources to construct, maintain, and operate, and contingency amounts to cover 

unanticipated cost increases; (6) cannot be easily and efficiently completed without other 

federal funding or financial assistance; and (7) is reasonably expected to begin 

construction no later than 18 months after the date of obligation of funds for the project. 23 

U.S.C. § 117(g).

9 As defined by the FAST Act, the term “rural area” means an area that is outside an 

urbanized area with a population of over 200,000.

10For federal land management agencies that apply jointly with a state, federal funds not 

made available under titles 23 or 49 of United States Code may be used for the nonfederal share.

1181 Fed. Reg. 10955 (Mar. 2, 2016). In November 2016, DOT issued a funding 

announcement for $850 million for the second year of FASTLANE grant awards (fiscal 

year 2017). 81 Fed. Reg. 76688 (Nov. 3, 2016).
Page 5 GAO-18-38 Discretionary Transportation Grants

to DOT’s NOFO, the program provides an opportunity to address 

nationally or regionally significant challenges across the nation’s 

transportation system including: (1) improving the safety, efficiency, and 

reliability of the movement of freight and people; (2) generating national 

or regional economic benefit and an increase in the global economic 

competitiveness of the United States; (3) reducing highway congestion 

and bottlenecks; (4) improving connectivity between modes of freight 

transportation; (5) enhancing the resiliency of critical highway 

infrastructure and help protect the environment; (6) improving roadways 

vital to national energy security; and (7) addressing the impact of 

population growth on the movement of people and freight. To address 

these goals, DOT used six criteria to evaluate applications—four 

designated as merit criteria “outcomes” and two designated as “other”

criteria (see table 1).

Table 1: Criteria for Proposed Projects in the Fostering Advancements in Shipping and Transportation for the Long-term 

Achievement of National Efficiencies (FASTLANE) Grant Program

Merit Criteria Description

Economic Outcomes • Improving connectivity between freight modes of transportation.

• Improving roadways vital to national energy security.

• Facilitating freight movement across land border crossings.

• Addressing the impact of population growth on the movement of people and freight.

Mobility Outcomes • Maintaining highways, bridges, and freight infrastructure in a state of good repair.

• Enhancing the resiliency of critical surface transportation infrastructure.

• Significantly reducing highway congestion and bottlenecks.

Safety Outcomes • Achieving a significant reduction in traffic fatalities and serious injuries on the surface 

transportation system, as well as improving interactions between roadway users.

• Reducing the likelihood of train derailments or high consequence events.

• Improving safety in transporting certain types of commodities.

Community and Environment 

Outcomes

• Extending benefits to the human and natural environment, or enhancing personal mobility and 

accessibility. This includes reducing the negative effects of existing infrastructure, removing 

barriers, avoiding harm to the human and natural environment, and using design improvements to 

enhance access (where appropriate) and environmental quality for affected communities.

• Reflecting meaningful community input provided during project development.

Other Criteria Description

Partnership and Innovation • Demonstrates strong collaboration among a broad range of stakeholders or uses innovative 

strategies to pursue primary outcomes listed above including efforts to reduce delivery delays.

• Additional consideration will be given for the use of innovative and flexible designs and 

construction techniques or innovative technologies.
Page 6 GAO-18-38 Discretionary Transportation Grants

Other Criteria Description

Cost Share • Has one or more stable and dependable sources of funding and financing to construct, 

maintain, and operate the project.

• Demonstrates that the project cannot be easily and efficiently completed without other federal 

funding or financial assistance available to the project sponsor.

• Additional consideration will be given to the use of nontraditional financing, as well as the use of 

non-federal contributions.

• Additional consideration may be given to the form of cost sharing presented in the application. 

Firm commitments of cash that indicate a complete project funding package and demonstrate 

local support for the project are more competitive than other forms of cost sharing.

Source: Department of Transportation fiscal year 2016 notice of funding opportunity | GAO-18-38

Since 2011, we have reviewed a number of other DOT grant programs 

and found limited transparency in the programs’ grant award processes 

and insufficient documentation of award decisions. The programs we 

reviewed include the following:

• The Transportation Investment Generating Economic Recovery 

(TIGER) grant program: In March 2011, we first reviewed the TIGER 

program and found that DOT did not document final grant award 

decisions and its rationale for selecting lower-rated projects over 

higher-rated ones. We recommended that DOT document key 

decisions for all major steps in the future reviews of applications, and 

this recommendation was implemented.12 However, when we 

reviewed the fifth round of the TIGER program in May 2014, we found 

that DOT deviated from its established procedures and did not 

document key decisions, including decisions to advance lower-rated 

projects over higher-rated projects.13 We again recommended that 

DOT document major decisions in the application evaluation and 

project selection process, among other things. DOT agreed with this 

recommendation, and it remains open pending a DOT Inspector 

General audit of the TIGER program.

 12GAO, Surface Transportation: Competitive Grant Programs Could Benefit from 

Increased Performance Focus and Better Documentation of Key Decisions, GAO-11-234, 

(Washington, D.C.: Mar 30, 2011).

13GAO, Surface Transportation: Actions Needed to Improve Documentation of Key 

Decisions in the TIGER Discretionary Grant Program, GAO-14-628R, (Washington, D.C.: 

May 28, 2014).
Page 7 GAO-18-38 Discretionary Transportation Grants

• The High Speed Intercity Passenger Rail grant program: In March 

2011, we found that the rationales for selection decisions were too 

vague for us to verify whether final selection criteria had been applied. 

We recommended that the Federal Railroad Administration (FRA) 

document the substantive reasons behind award decisions to better 

ensure accountability of federal funds.14 FRA implemented this 

recommendation.

• The Hurricane Sandy transit resilience grant program: In December 

2016, we found that the Federal Transit Administration (FTA) did not 

take sufficient steps to ensure the process was consistent or 

appropriately documented.15 We also noted a pattern of problems with 

DOT discretionary grant programs and found that DOT did not have 

clear department-wide requirements for what should be documented 

when evaluating potential projects. Because of the repeated problems 

we found in previous programs, we recommended that the Secretary 

issue a directive that governs department-wide and modal 

administration grant programs. We also recommended that DOT 

determine how the evaluation process will be overseen to ensure a 

consistent review of applications. DOT agreed with the 

recommendations and has taken some actions.

 14GAO-11-283.

15GAO, DOT Discretionary Grants: Problems with Hurricane Sandy Transit Grant 

Selection Process Highlight the Need for Additional Accountability, GAO-17-20, 

(Washington, D.C.: May 28, 2014).

DOT Developed 

Review and Selection 

Processes and 

Awarded 18 

FASTLANE Grants 

That Met Size and 

Location 

Requirements
Page 8 GAO-18-38 Discretionary Transportation Grants

To review the submitted applications, DOT developed a multi-phased 

review process. Technical Review Teams from the Federal Highway 

Administration (FHWA), Maritime Administration (MARAD), and FRA 

assessed and rated applications. A Senior Review Team consisting of 

senior departmental officials then assembled a list of projects for 

consideration by the Secretary to consider for award. Throughout the 

process, a Quality Control and Oversight Team consisting of officials from 

the Office of the Secretary and the team leaders of the technical review 

teams was responsible for ensuring consistency across project 

evaluations and that the review teams provided appropriate 

documentation. DOT outlined these processes for reviewing and selecting 

applications in an internal May 2016 evaluation plan. More details on the 

evaluation process were outlined in additional FASTLANE guidance, 

which was issued to reviewers involved in the review and selection 

process (see Fig. 1).

DOT’s FASTLANE Review 

and Selection Processes
Page 9 GAO-18-38 Discretionary Transportation Grants

Figure 1: Review and Selection Process for the Fostering Advancement in Shipping 

and Transportation for the Long-term Achievement of National Efficiencies 

(FASTLANE) Grant Program (Fiscal Year 2016)

a

The Quality Control and Oversight Team consisted of officials from the Office of the Secretary and 

team leaders from the modal technical reviews, among others.

b

Modal Technical Review Teams consisted of staff from FHWA, FRA, and MARAD.

c

Cost Effectiveness Review Teams consisted of modal administration economists.

d

Project Readiness Review Teams consisted of project delivery experts.

e

The Senior Review Team consisted of senior departmental officials.

First, according to the evaluation plan, the Quality Control and Oversight 

Team undertakes the Intake Review Phase. The Quality Control and 

Oversight Team assesses each of the applications to determine (1) 

Intake Review
Page 10 GAO-18-38 Discretionary Transportation Grants

eligibility, (2) project size (Large or Small), (3) initial highway and nonhighway cost components, (4) Urban/Rural designation, and (5) the 

appropriate modal technical review team. DOT received 218 applications 

in April 2016 requesting a total of about $9.8 billion, about thirteen times 

the $759 million available for award applications. Project sponsors from 

46 states and the District of Columbia submitted applications, over 37 

percent of which were located in rural areas. Proposed highway projects 

represented the largest number of applications by project type, 

comprising about 58 percent. (See fig. 2) In addition, 58 percent of all 

proposed projects qualified as a small project, and 63 percent as an 

urban project.16

Figure 2: Characteristics of Applications for the Fostering Advancement in Shipping and Transportation for the Long-term 

Achievement of National Efficiencies (FASTLANE) Grant Program (Fiscal Year 2016)

Of the 218 applications submitted for FASTLANE funding for fiscal year 

2016, the Quality Control and Oversight Team initially identified six 

projects that were ineligible for funding.17

The remaining 212 eligible projects proceeded to the Technical Review 

phase where they were assigned to a modal team from the FHWA, FRA, 

 16 The term “urban” means an area with a population of more than 200,000 individuals, as 

defined by the Bureau of the Census.

17An additional project received a technical, cost effectiveness, and project readiness 

review, but was later found to be ineligible because its total project costs classified it as a 

large project (large projects have total project costs equal to or the lesser of $100 million 

or 30 percent of a state’s fiscal year 2015 federal-aid apportionment) and the project’s 

scope was insufficient to make a minimum $25 million award.

Modal Technical Review
Page 11 GAO-18-38 Discretionary Transportation Grants

and MARAD. Technical Review Teams assessed potential projects 

against the six DOT criteria (see table 1) and assigned one of the 

following ratings: “recommended,” “acceptable,” or “not recommended” as 

well as developed narrative analyses. These narratives describe how the 

application addresses each of the selection criteria. According to DOT 

officials, they designed the evaluation process to focus less on specific 

ratings and more on the overall analysis, including the narratives. Once 

the teams assigned their ratings, a member from the Quality Control and 

Oversight Team was responsible for ensuring that the analyses provided 

enough information for the Senior Review Team and that the ratings were 

assigned consistent with the program’s guidelines. If the Technical 

Review team rated a project as “recommended,” the project was 

automatically forwarded for additional reviews by Cost Effectiveness and 

Project Readiness Review teams.18 Of the eligible 212 applications 

assigned to the modal technical teams for review, about 69 percent of the 

applications, or 147 projects, received the highest technical rating of 

“recommended,” and were advanced for further review (see fig 3).

Figure 3: Modal Technical Review Ratings for Fostering Advancement in Shipping 

and Transportation for the Long-term Achievement of National Efficiencies 

(FASTLANE) (fiscal year 2016

 18 The Senior Review Team may also request other projects receive a Cost Effectiveness 

and Project Readiness review during a later phase of the review process.
Page 12 GAO-18-38 Discretionary Transportation Grants

In total, 160 applications (147 “recommended” applications, as well as 13 

additional applications that were rated “acceptable”) were assessed by 

the Cost Effectiveness Review Team. The Cost Effectiveness reviews 

were primarily completed by modal administration economists and DOT 

officials told us they also included statisticians and a transportation 

analyst. As part of their review, they assigned one of four ratings: (1) 

benefits exceed costs; (2) benefits reasonably likely to exceed costs; (3) 

costs reasonably likely to exceed benefits; and (4) costs exceed benefits 

as well as narrative analyses.19 According to staff that conducted the Cost 

Effectiveness reviews we interviewed, the ratings were primarily based on 

their assessment of uncertainty regarding the application’s stated 

assumptions and the Benefit-Cost Ratio estimate. However, according to 

DOT officials, the ratings were not intended to disqualify any project at 

this phase, but to provide additional information on the projects. In total, 

about 75 percent of the 160 applications reviewed by the Cost 

Effectiveness Teams were found to have “benefits exceed costs” or 

“benefits likely to exceed costs” (see fig 4).

 19To award a large project, the Secretary must determine that the project is cost effective. 

For small projects, the statute directs the Secretary to consider the project’s cost 

effectiveness and mobility benefits.

Cost Effectiveness Review
Page 13 GAO-18-38 Discretionary Transportation Grants

Figure 4: Cost Effectiveness Ratings for Fostering Advancement in Shipping and 

Transportation for the Long-term Achievement of National Efficiencies (FASTLANE) 

(Fiscal Year 2016)

Concurrently with the Cost Effectiveness reviews, the Project Readiness 

Review Teams, which were comprised of modal project delivery experts, 

assessed the 160 applications against a number of factors to assess the 

likelihood the project would proceed to construction within 18 months of 

obligation and identify any other potential risks to the project’s 

completion.20 Members of the Project Readiness team told us they 

evaluated a project’s readiness by evaluating the information provided in 

the application, such as the status of the National Environmental Policy 

Act (NEPA) requirements,21 technical feasibility, project risks and 

 20To award a large project, the Secretary must determine that the project is reasonably 

expected to begin construction not later than 18 months after obligation. As a result, 

obligation must occur no later than September 30, 2019 and construction no later than 

March 30, 2021.

21The National Environmental Policy Act (NEPA) requires federal agencies to integrate 

environmental values into their decision-making processes by considering the 

environmental impacts of their proposed actions and reasonable alternatives to those 

actions. To meet NEPA requirements, federal agencies may be required to prepare a 

detailed statement known as an environmental impact statement. The Environmental 

Protection Agency reviews and comments on environmental impact statements prepared 

by other federal agencies.

Project Readiness Review
Page 14 GAO-18-38 Discretionary Transportation Grants

mitigation, committed capital, and contingency reserves, among other 

factors. The teams then assigned one of three ratings: low risk, moderate 

risk, and high risk as well as prepared narrative analyses. Project 

Readiness Team members said low risk applications, for example, may 

have completed the NEPA process and sufficiently demonstrated that 

they were able to complete the project; a moderate risk designation 

meant that a project may have had potential issues of which decisionmakers should be aware (e.g. there might be a high environmental risk). 

Further, they told us high risk project designations were reserved for 

severe “red flags,” such as the applicant’s needing state legislation to 

approve the project. In total, about 96 percent of eligible applications were 

found to be either “low” or “moderate” risk, as shown in figure 5. However, 

similar to the Cost Effectiveness reviews, DOT officials told us the ratings 

were not intended to disqualify any projects, but provide additional 

information on the projects.22

Figure 5: Project Readiness Ratings for Fostering Advancement in Shipping and 

Transportation for the Long-term Achievement of National Efficiencies (FASTLANE) 

(Fiscal Year 2016)

 22Overall, 21 projects received the highest possible scores in each of three rating 

categories (“recommended”, “benefits exceed costs”, and “low risk”) and 4 were awarded 

grants.
Page 15 GAO-18-38 Discretionary Transportation Grants

The Quality Control and Oversight team, in addition to being involved 

throughout the process, used the information from the technical analyses, 

cost effectiveness, and project readiness reviews to assess whether large 

projects met the seven additional statutory requirements. A large project 

cannot be added to the list of consideration by the Secretary unless it

satisfied all seven statutory requirements. Of the 160 projects that 

received the technical, cost effectiveness and project readiness reviews, 

74 were considered large projects and had to meet the additional 

statutory requirements. For each requirement, the evaluation plan 

required the Quality Control and Oversight Team to document whether 

the project (1) meets the requirement, (2) does not meet the requirement, 

or (3) additional information is necessary to make a determination. 

According to members from the Quality Control and Oversight Team, if 

the teams’ narratives did not provide enough information to determine 

whether a project met a requirement, they typically documented 

“additional information is necessary,” and rarely documented that a 

project did not meet the requirement. Officials told us that for a project to 

be documented as not meeting a requirement, the applications generally 

had to explicitly state it could not meet the statutory requirement.

The responsibility of the Senior Review Team was to assemble a list of 

projects for consideration by the Secretary. The Senior Review Team 

consisted of senior departmental officials from the Office of the Secretary, 

FHWA, FRA, and MARAD who had been requested to serve by the 

Secretary. Senior Review Team members had access to all applications, 

the narrative analyses, and the three ratings assigned by the various 

technical review teams. According to the evaluation plan, a Senior 

Review Team member could also request that a project that did not 

receive a cost effectiveness or project readiness review be referred to the 

Cost Effectiveness and Project Readiness Teams for review. Projects that 

did not receive such reviews initially were those rated as “acceptable” or 

“not recommended” during the modal administration technical review. 

FASTLANE guidance stated that a Senior Review Team member must 

provide one of the following rationales to request such a review: (1) the 

technical review evaluation did not take into account new or additional 

information that supports a different rating with regard to specific selection 

criteria; (2) the technical review evaluation did not properly weigh the 

selection criteria; or (3) the project should be considered by the Secretary 

for its contributions to geographic diversity among grant recipients. Of the 

13 applications that were rated as “acceptable” and received cost 

Large Project Requirements

Senior Review
Page 16 GAO-18-38 Discretionary Transportation Grants

effectiveness and project readiness reviews, 12 were requested to 

receive these reviews by the Senior Review Team.23

Of the 160 applications that received a Technical, Cost Effectiveness, and 

Project Readiness review, the Senior Review Team assembled a list of 

130 projects (88 small projects and 42 large projects) to be considered by 

the Secretary for award. Under the evaluation plan, all small projects that 

were rated “recommended” were automatically included on the list of 

projects for consideration by the Secretary. For large projects that did not 

initially meet all seven statutory requirements based on the grant 

application, the Senior Review Team could provide additional information 

themselves or request the Quality Control and Oversight Team obtain the 

necessary information which could potentially enable the project 

application to meet the requirements. Of the 74 large projects forwarded 

to the Senior Review Team, 32 of the projects did not make the list of 

consideration because they were unable to meet all 7 requirements.24

The evaluation plan required the Secretary to present initial project 

selections to the Senior Review Team. At that time, Senior Review Team 

members could advise the Secretary on any project on the list of projects 

for consideration. However, the Secretary had the authority to select any 

eligible project for award that satisfied the statutory requirements.

In September 2016, DOT announced it had selected 18 applicants to 

receive approximately $759 million in funding (see table 2). All of the 

awarded projects received a cost effectiveness rating of “benefits exceed 

costs,” or “benefits were reasonably likely to exceed costs.” Similarly, all 

awarded projects received a Project Readiness rating of “low” or 

“moderate” risk.25 The amount awarded to individual projects ranged from 

$5 million for a small highway project to $165 million for a large 

 23The other application rated “acceptable,” according to DOT officials, was advanced to 

the Cost Effectiveness and Project Readiness teams prematurely before the Technical 

Review Team finalized the rating. In total, 11 of the 13 “acceptable” applications were 

eventually included on the list of projects for consideration.

24Senior Review Team members had the option of removing any large or small project 

from the list if they provided a criteria-based reason for doing so.

25Of the 18 projects awarded, 16 were rated as “recommended” and 2 were rated as 

“acceptable” by the Technical Review Teams. Six had a Cost Effectiveness rating of 

“benefits exceed costs” and 12 were “reasonably likely to exceed costs.” Eight had a 

Project Readiness rating of “moderate risk” and 10 were rated as “low risk.”

Project Selection

DOT Awarded 18 Projects 

That Met Statutory Project 

Size and Location 

Requirements
Page 17 GAO-18-38 Discretionary Transportation Grants

multimodal project. The two largest recipients—the Atlantic Gateway 

Project and the Arlington Memorial Bridge Reconstruction Project—

account for about a third of the total funding awarded. Further, three out 

of the seven proposed projects that were characterized as “multimodal”

were awarded funds.

Table 2: Department of Transportation’s (DOT) Selections and Funding by Recipient for the Fostering Advancement in 

Shipping and Transportation for the Long-term Achievement of National Efficiencies (FASTLANE) Grant Program (Fiscal Year 

2016)

In dollars 

Project Name and Location Urban or Rural Project Type Size Award Amount

Atlantic Gateway: Partnering to Unlock the I95 Corridor (Richmond, VA)Urban Multimodal Large 165,000,000 

Arlington Memorial Bridge Reconstruction 

Project (Washington, DC)

Urban Highway Large 90,000,000 

US 69/75 Bryan County (Oklahoma City, 

OK)

Rural Grade Crossing Large 62,000,000 

I-10 Freight CoRE (Baton Rouge, LA) Rural Highway Large 60,000,000 

Interstate 10 Phoenix to Tucson Corridor 

Improvements (Phoenix, AZ)

Rural Highway Large 54,000,000 

SR-11 Segment 2 and Southbound 

Connectors (Sacramento, CA)

Urban Highway Large 49,280,000 

South Lander Street Grade Separation and 

Railroad Safety Project (Seattle, WA)

Urban Grade Crossing Large 45,000,000 

Port of Savannah International Multi-Modal 

Connector (Garden City, GA)

Urban Port Large 44,000,000 

Conley Terminal Intermodal Improvements 

and Modernization (East Boston, MA)

Urban Port Large 42,000,000 

I-39/90 Corridor Project (Dane, WI) Rural Highway Large 40,000,000 

I-390/I-490/Route 31 Interchange, Lyell 

Avenue Corridor Project (Albany, NY)

Urban Highway Large 32,000,000 

Cedar Rapids Logistics Park (Ames, IA) Rural Multimodal Small 25,650,000 

Coos Bay Rail Line - Tunnel Rehabilitation 

Project (Coos Bay, OR)

Rural Rail Small 11,000,000 

Truck Parking Availability System (TPAS) 

(Tallahassee, FL)

Rural Highway Small 10,778,237 

Cross Harbor Freight Program (New York, 

NY) 

Urban Port Small 10,672,590 

Maine Intermodal Port Productivity Project 

(Augusta, ME)

Urban Port Small 7,719,173 

U.S 95 North Corridor Access Improvement 

Project (Boise, ID)

Rural Highway Small 5,100,000 
Page 18 GAO-18-38 Discretionary Transportation Grants

In dollars 

Project Name and Location Urban or Rural Project Type Size Award Amount

Strander Boulevard Extension and Grade 

Separation Phase 3 (Tukwila, WA)

Urban Multimodal Small 5,000,000 

TOTAL 759,200,000

Source: GAO analysis of DOT data. | GAO-18-38

Based on our analysis, we found that the award amounts—such as the 

minimum a project can receive and the mix of funds awarded to rural and 

small projects—met the program’s statutory requirements. As shown in 

table 2, eight rural projects (four large projects and four small projects) 

received awards totaling about $269 million, 35 percent of the total funds 

awarded. In addition, seven small projects received about $75 million or 

10 percent of the total funds awarded, as required by the FAST Act. 

According to DOT officials, large awarded projects also met the seven 

additional statutory requirements for large projects.26 While there was no 

requirement to distribute awards across different modes of transportation 

under the FAST Act, no more than $500 million could be awarded to nonhighway projects, in aggregate, for fiscal years 2016 through 2020. Of the 

total funds awarded for fiscal year 2016, over $173 million of the $500 

million was awarded to seven non-highway projects or projects with nonhighway components. Further, under the FAST Act, the Secretary must 

consider geographic diversity during the selection process, but there were 

no other requirements related to geography.

 26 We did not review each application to independently determine if applications aligned 

with the statutory requirements or if the applications would achieve their stated benefits or 

costs. However, we did review DOT’s documentation on its evaluation of statutory 

requirements, and whether DOT determined that requirements were met. We also 

interviewed DOT officials who commented on how the requirements affected the 

evaluation and selection process.
Page 19 GAO-18-38 Discretionary Transportation Grants

Based on our review of the available documentation and interviews with 

DOT officials, we found DOT generally followed the application review 

process outlined in the evaluation plan. For example, the review teams 

conducted the required reviews at the appropriate times and provided 

ratings and narratives, when required. The FASTLANE evaluation plan, 

according to DOT officials, was intended to provide flexibility for the 

Secretary to select from a large list of projects assembled by the Senior 

Review Team. We found the 18 awarded projects were selected from the 

130 projects provided to the Secretary by the Senior Review Team. 

Officials said this large list of projects was to ensure that the Secretary 

had enough options to meet the statutory requirements. DOT officials also 

told us the design of the process ensured that the staff’s responsibility 

was to provide information to decision-makers at the highest level of 

review and not to disqualify projects. For example, the technical review 

teams were given fewer rating categories that, according to DOT officials, 

were “less precise” than the TIGER grant program to provide additional 

flexibility to the Secretary to be able to meet the program’s statutory 

requirements.

27 However, we found that the intended flexibility outlined in 

the evaluation plan and the discretion provided to the Senior Review 

Team by the evaluation plan and other guidance may have contributed to 

inconsistencies in assigning ratings and some differences in how 

applications were reviewed.

The evaluation plan did not state how technical review teams should 

apply the technical rating definitions; allowing the three technical review 

teams from FHWA, MARAD, and FRA to apply DOT’s selection criteria 

differently when assigning technical ratings, contributing to scoring 

variances. FASTLANE guidance for reviewers provided uniform 

definitions for the three rating categories, each of which hinged on the 

extent to which the project aligned with the selection criteria. (See table 

3). As discussed earlier, the three technical review teams reviewed 

applications and assigned each project one of three ratings. The 

evaluation plan provided each team with the flexibility to design its

structure and organization differently to accommodate differences in the 

number of applications and number of evaluators available and according 

to DOT officials, possible distinctions in project types.

 27Specifically, the TIGER grant program and the Hurricane Sandy transit resilience grant 

program: selected from four rating categories, which included a “highly recommended”

category.

DOT’s Review Teams 

Followed the 

FASTLANE 

Evaluation Plan, but 

the Plan Resulted in 

Technical Review 

Inconsistencies and 

Allowed the Senior 

Review Team Broad 

Discretion

Technical Review Team 

Ratings
Page 20 GAO-18-38 Discretionary Transportation Grants

Table 3: Technical Rating Definitions for the Fostering Advancement in Shipping 

and Transportation for the Long-term Achievement of National Efficiencies 

(FASTLANE) Grant Program (Fiscal Year 2016)

Rating Description

Recommended The project aligns well with the selection criteria.

Acceptable The project aligns with the selection criteria.

Not Recommended The project does not align with the selection criteria.

Source: DOT FASTLANE guidance | GAO-18-38

However, the technical review teams used different technical rating 

definitions when applying ratings during the evaluation processes. The 

evaluation plan and other FASTLANE guidance for reviewers did not 

state how technical review teams should determine whether a project 

“aligns well,” “aligns,” or “does not align” with the selection criteria. For 

example, for each of the ratings, the evaluation plan and FASTLANE 

guidance for reviewers did not state how many of the six selection criteria 

an applicant must meet to receive a “recommended,” “acceptable,” or “not 

recommended” rating. (See table 1.) According to DOT’s guidance, the 

structure of the evaluation process must be clearly defined in order for 

reviewers to apply the rating system accurately and fairly, and the 

evaluation plan should include information relative to the procedure to 

ensure an objective evaluation. For the FASTLANE program, DOT 

officials told us FHWA, MARAD, and FRA each crafted their own 

evaluation processes to account for the unique aspects of the various 

transportation modes; this process was intended to help ensure that 

projects were compared against other projects of the same mode 

consistently. To monitor consistency, the Quality Control and Oversight 

Team also reviewed the analyses and ratings. However, we found that

the technical rating definitions were not clearly defined and that the 

technical teams for the three modal administrations applied the selection 

criteria inconsistently when rating applications.

• FRA: FRA’s technical review team members told us that they rated 

applications “recommended” if the rail project met one or more of the 

six criteria. They rated potential projects “acceptable” if raters could 

not connect the project to any of the criteria, and “not recommended”

ratings were reserved for applications that lacked enough information 

for the team to be able to make a determination.

• MARAD: MARAD’s technical review team members—which consisted 

of five people—told us they generally required at least three of the six 
Page 21 GAO-18-38 Discretionary Transportation Grants

criteria to be met in order to assign a “recommended” rating. They 

explained that each reviewer assessed each application individually 

and rated each of the six criteria “recommended,” “acceptable,” or “not 

recommended.” An individual reviewer’s overall rating for the project 

was “recommended” if three or more criteria were “recommended.” 

After the reviewers determined their individual overall ratings, they 

determined a consensus rating—for example, if three out of five 

reviewers rated an application as “acceptable” then the final rating 

was “acceptable.”

• FHWA: FHWA’s technical review team members told us that their 

rating process was changed after they began reviewing projects. 

Originally, FHWA officials said an application needed to specifically 

mention freight benefits in order to receive a “recommended” rating. 

However, officials also said the Quality Control and Oversight Team 

intervened and redefined FHWA’s definitions of “recommended” and 

“acceptable.” After the change, FHWA technical review team 

members said projects had to “strongly meet” one of the six selection 

criteria or meet multiple criteria to a lesser degree. For example, they 

told us stronger cases could be made for projects that produced 

regional and national benefits. “Acceptable” projects met one criterion

and “not recommended” projects failed to meet any criteria.

Because of these inconsistencies, projects reviewed by MARAD faced a 

higher barrier to being rated “recommended” as they had to meet multiple 

selection criteria to receive that rating (see table 4). This relatively high 

bar may have contributed to the lower percentage of MARAD-reviewed 

projects being automatically forwarded for the additional analysis required 

to be considered by the Secretary for award.28

 28Quality Control and Oversight officials told us that MARAD’s scores were lower because 

it was more difficult for port projects to demonstrate their benefits to the National Highway 

System. However, when we spoke to MARAD officials they told us that they required more 

than one criterion to be met to get a “recommended” rating. 
Page 22 GAO-18-38 Discretionary Transportation Grants

Table 4: Technical Review Ratings by Mode (Fiscal Year 2016)

Header Total Applicants Recommended Acceptable Not Recommended

MARAD 32 13 41 percent 18 56 percent 1 3 percent

FRA 47 32 68 percent 12 26 percent 3 6 percent

FHWA 133 102 77 percent 23 17 percent 8 6 percent

Source: GAO analysis of DOT data. | GAO-18-38

Note: Percentages are rounded to the nearest percent.

We found the Senior Review Team took different actions when assessing 

large projects; however, the evaluation plan and other guidance did not 

clearly specify the conditions in which these actions could be taken. More 

specifically, the evaluation plan and other guidance intended for the 

Senior Review Team to exercise broad discretion when deciding to take 

certain actions for large project applications that did not initially meet the 

large project statutory requirements. As we previously discussed, a large 

project cannot be added to list of projects for consideration unless it 

satisfies all seven statutory requirements. Overall, the Quality Control and 

Oversight Team determined nine out of the 74 large project proposals 

that received technical, cost effectiveness, and project readiness reviews 

were determined to clearly meet all seven statutory requirements based 

on the information documented in those reviews. These nine projects 

were subsequently put on the list of projects for consideration. However, 

a Senior Review member could add a project to the list that the Quality 

Control and Oversight Team determined did not meet one or more of the 

requirements by: (1) providing additional information themselves sufficient 

to meet the requirements or (2) requesting the Quality Control and 

Oversight Team to reach out to the applicant to seek such information. 

Quality Control and Oversight Team members said they refrained from 

communicating with applicants regarding additional information related to 

the statutory requirements unless specifically requested to do so by the 

Senior Review Team. They also said they were hesitant to disqualify 

applicants because, in part, they were directed to provide the most project 

options to senior leadership during the Senior Review Team meetings.

In addition, according to DOT’s funding announcement, DOT may award 

funds for a component of a larger project if that component meets all of 

the eligibility requirements. We found the Senior Review Team took steps 

to remove specific components of some large projects proposals from 

funding consideration so the project could meet one or more of the 

Senior Review Team 

Assessments
Page 23 GAO-18-38 Discretionary Transportation Grants

statutory requirements. More specifically, the Senior Review Team 

advanced components of five large projects. DOT officials told us that the 

Senior Review Team had discretion in deciding whether to separate or 

otherwise modify the components of any project proposal and that other 

project proposals may have also been able to be eligible if modified.29

The Senior Review Team advanced two large projects to the list of 

consideration by the Secretary after the team removed certain 

components from the applications that did not meet one or more of the 

large project statutory requirements. According to the Senior Review 

Team documentation:

• The Senior Review Team removed the planning component, which 

was one of four project elements in order for the project to meet two of 

the statutory requirements: (1) the project is reasonably expected to 

begin construction within 18 months and (2) the project is based on 

the results of preliminary engineering.

• For another project, the Senior Review Team considered separating 

the large project into multiple, independent small projects, in part,

because the Cost Effectiveness Team identified certain components 

as not cost effective. The Quality Control and Oversight Team also 

found that an engineering component of the large project proposal 

would not be able to meet one or more of the statutory requirements. 

Consequently, the Senior Review Team added the application to the 

list of projects for consideration as an integrated large project, but 

removed the engineering component.30

The Senior Review Team analyzed the other three large project 

proposals in terms of their independence as small projects. For example, 

the Senior Review Team separated a large project into two independent 

small project proposals, in part, because as a large project all of its 

components initially did not meet some of the large project requirements. 

The Senior Review Team decided to examine its components separately 

and split the project into two independent small projects: one for 

construction and one for planning. Consequently, the construction project 

 29Officials told us not all large project applications or their evaluations identified specific 

components.

30The original project included highway and rail components; however, the technical 

review team determined that the rail components were not cost effective on their own. 

Evaluated as one large project, however, the Senior Review Team determined that the 

entire project was cost effective. The engineering component was removed because it 

could not meet the 18-month statutory timeframe to begin construction. 
Page 24 GAO-18-38 Discretionary Transportation Grants

received one of the small project awards. In another example, after six of 

seven components of a large project were unable to meet the cost 

effectiveness requirement, the Senior Review Team added the remaining 

component as a small project to the list of consideration. However, this 

project did not receive an award.

Based on our review of DOT’s documentation, we found the Senior 

Review Team added an additional 33 large project proposals to the list of 

projects for consideration by requesting or providing additional 

information or by modifying the project proposals.31 However, it is unclear 

if any other projects would have been able to meet the statutory 

requirements if similar actions had been taken and, consequently, been 

added to the list of projects for consideration by the Secretary. For 

example, some applications with high ratings in all three technical 

categories were not included on the list of projects for consideration 

because one or more large project requirements received an “additional 

information is necessary” but the Senior Review Team took no further 

action. One such project, for example, had ratings of “recommended,”

“benefits exceed costs,” and “low risk,” but received no follow up to obtain 

additional information regarding one of the statutory requirements. On the 

other hand, for one awarded project, DOT obtained additional information 

regarding two statutory requirements and, later, modified the project 

proposal by removing a specific component so it could meet another two 

of the statutory requirements.

The lack of clearly defined procedures for the review teams and the 

discretion given to the teams by the evaluation plan and other guidance 

likely contributed to differences in how certain applications were 

reviewed, possibly affecting which projects were ultimately forwarded to 

the Secretary. According to internal control standards, it is important to 

clearly define the procedures and mechanisms that enforce 

management’s directives to achieve its objectives in accordance with 

internal control standards.32 DOT guidance also states an objective 

 31According to DOT officials, a large number of projects did not explicitly address the 

specific requirement requiring applicants to demonstrate that their project cannot be easily 

or efficiently completed without federal funding in their application. As a result, the Under 

Secretary of Transportation for Policy requested the Quality Control and Oversight Team 

reach out to all applicants that did not initially meet this statutory requirement. After this 

communication, 17 applicants were added to the list.

32GAO, Standards for Internal Control in the Federal Government, GAO-14-704G

(Washington, D.C.: September 2014)
Page 25 GAO-18-38 Discretionary Transportation Grants

review is essential to ensuring a selection of applicants that best meet the 

needs of the program consistent with the published selection criteria. The 

guidance states such objectivity is essential to provide assurance to the 

public that the evaluation process is impartial and fair. Without defined 

procedures to ensure all applications are review similarly, DOT may be 

vulnerable to questions about the integrity of the process.

In comparing DOT’s FASTLANE grant award process to recommended 

practices for awarding discretionary grants, we found that DOT followed 

three recommended practices and partially followed three other practices. 

Specifically, we found that DOT followed the recommended practices: (1)

of communicating with potential applicants prior to the competition, (2) of

developing a technical review panel with certain characteristics, and (3) of 

assessing applicants’ capabilities to account for funds. DOT partially 

followed the recommended practices: (1) of having a plan for 

administering the technical review, (2) of notifying applicants of awards 

decisions, and (3) of documenting the rationale for award decisions. 

However, for one of those practices—documenting the rationale for 

awards decisions—DOT’s documentation of officials’ decision-making at 

critical stages of the application review process was limited. While 

documentation from the technical reviews and notes from the Senior 

Review Team meetings existed, they provided insufficient insight into the 

decisions to include certain projects and not others on the list of 130 

projects for consideration to the Secretary. The limited documentation 

ultimately limited the transparency around the Secretary’s final selection 

of the 18 projects that received awards. Further, the FASTLANE 

processes did not fully follow DOT’s guidance. For example, DOT did not 

develop the evaluation plan for the FASTLANE program prior to issuing a 

NOFO.

Our prior work identified six recommended practices for awarding 

discretionary grants across the federal government based on our review 

of grantmaking policies and guidance used by the Office of Management 

and Budget and four other federal agencies, including DOT (see table 

5).33 Following these practices can help ensure a fair and objective 

evaluation during selection of discretionary grant awards.

 33The other agencies were the Departments of Commerce, Education, and Labor. See 

GAO-11-283. 

DOT’s FASTLANE 

Process Did Not Fully 

Align with 

Recommended 

Discretionary Grant 

Practices or Its Own 

Guidance

DOT Followed Some 

Recommended Practices 

but Did Not Fully Follow 

Others
Page 26 GAO-18-38 Discretionary Transportation Grants

Table 5: Department of Transportation’s (DOT) Use of Recommended Discretionary Grant Practices to Award Fostering 

Advancement in Shipping and Transportation for the Long-term Achievement of National Efficiencies (FASTLANE) Grants

(Fiscal Year 2016)

Practice Attributes of practice DOT followed

Communicate with potential applicants prior 

to the competition

Provide information prior to making award decisions on 

available funding; key dates; competition rules (i.e., eligibility, 

technical review of application; and selection criteria); funding 

priorities; types of projects to be funded; outreach efforts to 

new applicants and pre-application assistance.

Yes

Develop a technical review panel with certain 

characteristics

Use a technical review panel consisting of reviewers who hold 

relevant expertise, do not have conflicts of interest, apply the 

appropriate criteria, and are trained.

Yes

Assess applicants’ capabilities to account for 

funds

Assess applicants’ abilities to account for funds by determining 

if applicants meet eligibility requirements, checking previous 

grant history, assessing financial management systems, and 

analyzing project budgets.

Yes

Plan for administering the technical review Develop a plan for the technical review that describes the 

number of panels and reviewers and includes methods for 

assigning applications to review panels, identifying reviewers, 

recording the results of the technical review, resolving scoring 

variances across panels, and overseeing the panel to ensure a 

consistent review.

Partially

Notify applicants of awards decisions Notify unsuccessful and successful applicants of selection 

decisions in writing and provide feedback on applications.

Partially

Document rationale for awards decisions Document the rationale for awards decisions, including the 

reasons individual projects were selected or not selected and 

how changes made to requested funding amounts may affect 

applicants’ ability to achieve project goals.

Partially

Source: GAO analysis of federal agency guidance and the FASTLANE evaluation and selection process. | GAO-18-38

Note: Based on our assessment of whether DOT followed the practice: 

“Yes”= agency addressed all attributes of the practice; 

“Partially”= agency addressed some, but not all attributes of the practice; and

“No”= agency did not address any attributes of the practice.

DOT’s FASTLANE grant award process followed three recommended 

practices for awarding discretionary grants.

• Communicate with potential applicants prior to the competition: DOT 

issued a NOFO to notify the public about the $759.2 million available 

for award in 2016. The announcement provided information, for 

example, on key dates, eligibility information, an overview of the 

selection criteria and competition rules, as well as DOT contact 

information for potential applicants to obtain additional information. To 

help potential applicants understand application requirements, DOT 
Page 27 GAO-18-38 Discretionary Transportation Grants

conducted webinars on how to apply for a FASTLANE grant and how 

to develop estimates of benefits and costs for projects. Most of the 

applicants we spoke with (11 of 13) told us that the NOFO provided 

adequate information for them to determine whether they should 

apply. For example, one applicant told us that the NOFO was clear 

and helped the organization decide to submit an application. That 

applicant also attended both webinars and said that they were very 

informative, particularly the question and answer sessions.

• Develop a technical review panel with certain characteristics: DOT 

assembled technical review panels that included transportation 

specialists in rail, maritime, and highways; economists; environmental 

specialists; and project delivery experts. All technical review teams 

received training, and DOT established team leads to ensure that 

reviewers applied the appropriate criteria when reviewing applications. 

DOT required reviewers to sign conflict-of-interest and nondisclosure 

agreements to help assure a fair review consistent with DOT 

guidance.

• Assess applicants’ capabilities to account for funds: The Quality 

Control and Oversight team assessed whether applicants met 

eligibility requirements as outlined in the FAST Act during the intake 

review phase. The NOFO also required applicants to show evidence 

of the viability and completeness of the project’s financing package 

and to submit a detailed project budget containing a breakdown of 

how the funds would be spent. The Project Readiness Team 

assessed this information, including whether there was evidence of 

the applicant’s ability to manage the grants and whether the applicant 

was an experienced federal grantee.

In addition, we found DOT partially followed the practices of planning for 

administering the technical review and notifying applicants of awards 

decisions.

• Plan for administering the technical review: DOT developed an 

evaluation plan for the technical review that outlined the review 

panels’ roles, how applications would be assigned for review, and how 

results would be recorded. However, as discussed earlier, we found 

the evaluation plan did not specify how technical criteria were to be 

applied, allowing for varied scoring methods across review panels and 

other differences.

• Notify applicants of awards decision: DOT did not inform unsuccessful 

applicants as called for by the recommended practice. Similar to the 

recommended practice, DOT’s guidance requires that unsuccessful 

applicants be notified of their status. However, DOT officials said that 
Page 28 GAO-18-38 Discretionary Transportation Grants

by the time selections had been finalized (after they had notified the 

authorizing congressional committees of proposed selections) DOT 

had received dozens of requests for debriefings from applicants who 

learned from a Congress member that their project was not among 

those proposed for selection. DOT officials said that at the time, it was 

not apparent that a notification was necessary because information on 

the selected projects had already been made public. Consequently, 

DOT did not notify unsuccessful applicants in writing or otherwise. 

Federal Internal Control Standards states that management should 

communicate quality information externally through external lines so 

that internal parties can achieve their objectives.34 Instead of a formal 

notification, DOT offered to provide feedback to applicants if 

requested. However, one applicant specifically stated that the 

organization did not know that it could receive feedback on the 

applications, and another said that it would have been helpful if this 

had been explained in the NOFO. Timely and substantive feedback 

can help applicants determine whether to expend the resources to 

apply in future rounds and to better appropriate time and resources 

necessary to reapply (e.g., hiring contractors to complete the 

application). In contrast, when we reviewed the High Speed Intercity 

Passenger Rail grant program, we found that FRA sent letters to 

individual applicants regarding its decision, and if the application was 

not selected, a brief explanation was provided.35 DOT officials for the 

FASTLANE grant program acknowledged that this is an area that they 

may want to revisit in the future.

Although DOT partially followed the recommended discretionary grant 

practice for agencies to document the rationale for award selection, the 

practice was limited. Based on our analysis of the available FASTLANE 

documentation from the Technical Review and Senior Review Teams and 

documentation related to the Secretary’s decisions, we were unable to 

determine the rationale for the final selection of 18 projects for award. 

Specifically, the documentation provided limited insight into why the 18 

awarded projects were selected over other projects on the list of 

consideration forwarded to the Secretary. In addition, we found that 

DOT’s FASTLANE selection process did not fully adhere to DOT’s 

guidance. According to DOT’s guidance, awards should be given to 

applicants most likely to achieve the intended public purpose. However, 

 34GAO-14-704G.

35GAO-11-283.

DOT Did Not Fully 

Document Project 

Selection Rationales or 

Fully Align the Program 

with DOT’s Guidance, 

Limiting Transparency
Page 29 GAO-18-38 Discretionary Transportation Grants

DOT officials told us that project selection was not based on project 

ratings, but rather was determined by the Secretary, who could choose 

any of the projects on the list of projects for consideration. In addition, 

limiting the technical review ratings to three possible ratings categories 

(i.e., “recommended,” “acceptable,” and “not recommended”)—combined 

with DOT officials’ statements that the FASTLANE program was focusing 

less on specific ratings and more on narrative analyses —made it more 

difficult to readily distinguish among the majority of applications and 

determine which projects were the most likely to achieve the intended 

public purpose.36 Lastly, DOT’s technical review process shifted the 

decision-making to higher levels of review—the Senior Review Team and 

the Secretary. The process as designed, intended the Secretary to have 

broad flexibility to select projects for awards from any of the 130 projects 

on the list of consideration. However, taking this approach for selecting 

projects for awards increases the importance of documenting the 

decision-making at the higher levels of review.

Documentation from the Senior Review Team—which summarized three 

Senior Review Team meetings and as outlined in DOT guidance—

provides little insight into ultimate project selections. Documentation of 

rationales requesting that some lower-rated projects receive further 

review were generally vague statements of a project’s anticipated benefits 

instead of one of the three rationales outlined in guidance to the team.37

For example, one project was advanced for further review because a 

senior review member stated, “the applicant has been a good partner,”

and “the project should be advanced based on mobility and safety 

benefits.” Another project was forwarded because a Senior Review Team 

member said it should be advanced “due to its mobility and safety 

benefits;” no other documentation was provided. Of 12 total “acceptable”

 36The FASTLANE program rated the majority of the project applications (147 or 69 

percent) as “recommended” (see fig 3). However, applications for the TIGER grant 

program and the Hurricane Sandy Resiliency Grant program contained four technical 

ratings categories including an additional rating category of “highly recommended,” a 

higher standard, which could provide some additional insight into the decision-making.

37As stated earlier, members could request that a project rated “acceptable” or “not 

recommended” receive cost effectiveness and project readiness reviews to support being 

added to the list of projects for consideration by the Secretary. Guidance for the Senior 

Review Team stated that in order to do this, the team member must provide one of the 

following rationales: (1) the technical review evaluation did not take into account new or 

additional information that supports a different rating with regard to specific selection 

criteria; (2) the technical review evaluation did not properly weigh the selection criteria; or 

(3) the project should be considered by the Secretary for its contributions to geographic 

diversity among grant recipients.

Senior Review Team and the 

Secretary’s Decision-making 

Documentation
Page 30 GAO-18-38 Discretionary Transportation Grants

project proposals that Senior Review Team members forwarded for cost 

effectiveness and project readiness reviews, only 3 included rationales 

that specifically referred to deficiencies in the original technical review 

evaluation. DOT officials said that these meeting summaries occasionally 

reverted to “short hand” but essentially equated to a conclusion that the 

initial evaluation did not properly weigh the benefits. Without clear 

documentation of Senior Review Team rationales—including information 

indicating the information that was found to be insufficient and why in 

previous reviews—there is limited insight into how the final project 

selections were made.

On two other occasions, according to DOT meeting notes, the Senior 

Review Team met with the Secretary to advocate for specific projects that 

the Secretary should consider for awards. The minutes state anticipated 

benefits of the projects that each Senior Review Team advocated, but do 

not indicate why these projects, according to DOT’s guidance, “best 

address the program requirements and are, therefore, most worthy of 

funding.” Nor do the minutes indicate how individual Senior Review Team 

members chose the projects they highlighted. One DOT official told us 

that Senior Review Team members used their broad expertise when 

advocating for specific projects. However, DOT officials told us that 

Senior Review Team members were no longer with the agency and no 

one remaining at DOT could provide any additional insight into how these 

final selection decisions were ultimately made.38 As a result, we were 

unable to determine whether selection decisions made by the Secretary 

best met the goals of the program. According to DOT’s guidance, awards 

should be given to applicants most likely to achieve the intended public 

purpose. The documentation supporting the Secretary’s project selection 

decision describes the anticipated benefits of selected projects; however, 

the documentation does not provide insight as to why the Secretary 

selected the specific 18 projects out of the 130 eligible projects.

Without complete documentation, there is limited transparency of the 

application review and selection process. As previously discussed, the 

review process also included fewer technical rating categories. The fewer 

categories made it more difficult to readily distinguish among the majority 

of applications. Furthermore, DOT officials said that the technical reviews 

 38We spoke to one remaining DOT official who was present at Senior Review Team 

meetings, but this person advised on legal matters, not technical matters, and could not 

provide additional information on how projects were selected other than what was 

presented in the FASTLANE documents we reviewed.
Page 31 GAO-18-38 Discretionary Transportation Grants

were designed to provide information to decision-makers, not to disqualify 

projects, resulting in forwarding as many projects as possible to the 

Secretary. However, by shifting the final decision-making to the Secretary 

it increased the importance of documenting decision-making at those 

higher levels of review to help better understand the rationale for why 

projects were selected or not selected to receive awards. For example, 

better documentation of the recommendations made by the Senior 

Review Team could have helped ensure a more transparent selection 

process.

Past discretionary grant programs we reviewed applied various 

approaches to increase the transparency of the Secretary’s rationale for 

selecting projects for awards. For example, past discretionary grant 

programs had Senior Review Teams provide a list of recommended 

projects to the Secretary based on objective criteria, ranked potential 

projects in tiers or categories, or presented documented funding 

scenarios or strategies for the Secretary’s consideration. While we cited 

some problems with documentation in these programs, the project 

selection processes did provide some insight into the final selection 

rationales. For example:

• During our review of the TIGER program, we reported that the Senior 

Review Team conducted a series of meetings that occurred over 

about 2 months. In each meeting, the review team evaluated about 6 

to 12 projects, discussed project strengths and weaknesses, identified 

areas for clarification or follow-up and ranked each project in a tier 

based on the likelihood that DOT would fund the project. At the 

conclusion of its assessment, the Senior Review Team developed a 

memo with a list of projects that it recommended for award.39

• During our review of the Hurricane Sandy transit resilience grant 

program, we reported that the FTA Administrator provided the 

Secretary with funding scenarios that funded “highly recommended”

projects and various strategies for using remaining funds. The 

Secretary chose to fund all “highly recommended” projects and 

various “recommended” projects based on one of the strategies 

recommended by the Senior Review Team.40

 39GAO 11-234.

40GAO-17-20.
Page 32 GAO-18-38 Discretionary Transportation Grants

• During our review of the High Speed Intercity Passenger Rail grant 

program, we reported that FRA senior officials recommended projects 

to the Secretary based on technical review scores and selection 

criteria, and the Secretary concurred with the recommendations.41

DOT did not finalize the FASTLANE evaluation plan prior to publishing 

the NOFO as required by DOT guidance. DOT’s guidance states that 

grant programs should finalize the evaluation plan prior to publishing a 

NOFO and make no subsequent changes to the plan after the 

announcement. When DOT issued its NOFO, the agency was still 

developing the evaluation plan and did not provide the evaluation plan to 

its reviewers until May 2016. DOT officials stated that the staff began 

developing the evaluation plan concurrent with the development of the 

NOFO, but the evaluation plan was not finalized until later, following 

approval by the Office of the Secretary. We also noted this problem in the 

Hurricane Sandy transit-resilience grant program.42 On November 14, 

2016—approximately 2 months after fiscal year 2016 FASTLANE grant 

awards were officially announced— DOT opened the applications for the 

second round of FASTLANE grants for fiscal year 2017. Applications 

were due about a month later.43

On June 29, 2017, after DOT applications for the second funding round 

were closed, DOT announced that the FASTLANE program was being 

superseded by a new grant program—— the Infrastructure for Rebuilding 

America (INFRA) program. Similar to the FASTLANE program, DOT 

officials told us that they had not yet developed an evaluation plan, 

contrary to DOT’s guidance. The lack of an evaluation plan raises the 

possibility that the INFRA program may encounter some of the same 

issues we identified with consistency and transparency in the FASTLANE 

program. The INFRA program will award approximately $1.5 billion in 

grants for fiscal years 2017-2018. DOT is currently accepting the initial 

round of applications for INFRA. According to the new INFRA NOFO, the 

 41GAO-11-283.

42GAO-17-20. In the report we noted preparing the plan before the NOFO goes out helps 

to ensure a consistent evaluation process, but FTA did not develop the plan until 2 months 

after the funding announcement. We also found that DOT did not have clear departmentwide requirements for what should be included in the evaluation plan to ensure a 

consistent evaluation of proposals and recommended that DOT develop those 

requirements.

43FASTLANE Round 2 applications were due December 15, 2016.

DOT Did Not Develop the 

FASTLANE Evaluation 

Plan In Accordance with 

DOT Guidance and Has 

Yet to Develop a Plan for 

the INFRA Program
Page 33 GAO-18-38 Discretionary Transportation Grants

program is derived from the same statutory requirements in the FAST Act 

as the FASTLANE program, but creates new selection criteria.44 DOT 

officials told us that some small projects will be awarded in 2017 based 

on the FASTLANE NOFO and on August 2, DOT notified Congress of 10

proposed grants for fiscal year 2017 totaling almost $78.9 million. 

However, all large projects would instead be awarded in fiscal year 2018, 

along with additional small projects under the INFRA program. According 

to the NOFO, large project applicants can resubmit their previous 

FASTLANE applications, but must also explain how the project 

competitively addresses the new INFRA grant criteria.45 Applications will 

close for the initial round of applications for the INFRA program on 

November 2, 2017.

Funding for highways and freight projects is highly competitive, as 

demonstrated by the over 200 applications submitted to the FASTLANE 

program. Accordingly, it is critical that the application review and selection 

process be consistent and transparent. However, the FASTLANE 

evaluation plan, which guides the application and review process, 

provided a great amount of flexibility that resulted in scoring variances 

and allowed review teams broad discretion in the application review 

process. Furthermore, the application review and selection process 

resulted in a large number of applications—130 projects—being 

forwarded to the Secretary for award consideration. Ultimately, the 

Secretary chose 18 projects for awards. However there was limited 

documentation of the rationale for the decision-making in the review 

process, especially of the Senior Review Team’s assessments, and it is 

not clear why some projects were ultimately selected for award over 

others.

Given the number of projects forwarded to the highest level of review and 

the limited number of projects that received awards, it is even more 

important that application selection process be transparent. Developing 

an evaluation plan, before the solicitation of applications, that includes 

detailed guidance on how applications are to be reviewed; that details 

 4482 Fed. Reg. 31135 (July 5, 2017). The merit criteria for the INFRA program are: 

national and regional economic vitality, leveraging of federal funding, performance and 

accountability, and potential for innovation—which includes safety, environmental review 

and permitting, and project delivery approach.

45DOT’s 2016 financial assistance guidance states that the evaluation plan should be 

developed prior to the announcement, and could be updated under certain circumstances. 

Conclusions
Page 34 GAO-18-38 Discretionary Transportation Grants

how applicants are to be notified of the selection results; and that reflects 

thorough documentation of the decision-making rationale for selecting 

projects for awards may help to ensure the application review and 

selection process is consistent and transparent. DOT recently announced 

that the FASTLANE program is being superseded by a new program—the 

INFRA program—and the agency is currently accepting project 

applications. However, DOT does not have an evaluation plan in place for 

the new program. Developing an evaluation plan that addresses the 

causes of inconsistencies and limited transparency we found in the 

FASTLANE application review and selection process could enhance the 

credibility of DOT award decisions and bring stability to the process for 

awarding grants authorized by the FAST Act.

We are making the following three recommendations to DOT:

The Secretary of Transportation should develop an evaluation plan for the 

INFRA program in advance of issuing the notice of funding opportunity 

and ensure the program’s evaluation plan clearly defines how all review 

teams should apply criteria, assess applications, and assign ratings to 

ensure that all applications are consistently reviewed. (Recommendation 

1)

The Secretary of Transportation should ensure all program applicants be 

notified in writing of the outcomes of the application selection process. 

For unsuccessful applicants, the notification should include a brief 

explanation of the decision. (Recommendation 2)

The Secretary of Transportation should require INFRA program teams 

document their decision-making rationale throughout all levels of review 

in the application selection process. (Recommendation 3)

We provided a draft of this report to DOT for review and comment. DOT 

responded with a letter in which it agreed with our recommendations and 

emphasized its commitment to improve the Infrastructure for Rebuilding 

America program. This letter is reprinted in appendix II. 

Recommendations for 

Executive Action

Agency Comments
Page 35 GAO-18-38 Discretionary Transportation Grants

We are sending copies of this report to appropriate congressional 

committees and to the Secretary of Transportation. In addition, the report 

is available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or flemings@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who contributed to this report are 

listed in appendix III.

Susan Fleming

Director, Physical Infrastructure Issues
Appendix I: Objectives, Scope, and 

Methodology

Page 36 GAO-18-38 Discretionary Transportation Grants

The Fixing America’s Surface Transportation Act (FAST Act) included a 

provision that we assess the Department of Transportation’s (DOT) the 

Fostering Advancement in Shipping and Transportation for the Long-term 

Achievement of National Efficiencies (FASTLANE) grant program.1 This 

report addresses: (1) the processes used to evaluate and award 

FASTLANE grants and the outcomes of those processes, (2) the extent to 

which DOT followed its FASTLANE evaluation plan, and (3) the extent to 

which the process was aligned with recommended practices and DOT’s 

own guidance for awarding discretionary grants.

To describe the processes used to evaluate and award FASTLANE 

grants and the outcomes of those processes, we identified the criteria and 

processes outlined in the evaluation plan and reviewed DOT documents 

explaining the process, including the March 2016 notice of funding 

opportunity (NOFO) and training materials provided to technical teams 

that conduct the reviews.

To determine the extent to which DOT followed its evaluation plan while 

evaluating and selecting projects, we compared these criteria and 

processes to DOT’s decision documentation and DOT’s financial 

assistance guidance (DOT’s guidance). Specifically, we requested 

documentation of the Review Teams’ assessments of applications, and 

DOT provided its FASTLANE application evaluation spreadsheet. We 

assessed the reliability of the data in this spreadsheet by interviewing 

members from each review team as well as DOT officials who helped 

develop the process for the review teams to record their assessments. 

We also assessed the data for missing values, duplicate records, and 

other indicators of potential reliability issues. We determined that the data 

were sufficiently reliable for the purposes of producing descriptive 

statistics about the applicants and to determine whether the awards met 

key statutory requirements. More specifically, we produced statistics 

describing the applicants in terms of their technical ratings and other key 

variables, such as size (large or small), location (urban or rural area), and 

assigned modal technical review team. We did not review each 

application to determine the extent to which the individual application 

aligned with the selection criteria.

 1

Pub. L. No. 114-94, § 1105(a), 129 Stat. 1312, 1336 (2015) (codified at 23 U.S.C. § 

117(n)(2)).

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 37 GAO-18-38 Discretionary Transportation Grants

Further, we interviewed DOT officials who participated in evaluating and 

selecting projects to obtain information on whether and how they applied 

the criteria and processes. Specifically, we spoke to members from the 

three technical review teams from the Federal Highway Administration 

(FHWA), Federal Railroad Administration (FRA), and the Maritime 

Administration (MARAD), the Cost Effectiveness and Project Readiness 

Teams, and the Quality Control and Oversight Team. We also spoke with 

DOT officials on how the Senior Review Team assembled the list of 

projects to be considered by the Secretary because officials who were a 

part of the Senior Review Team were no longer with the agency.2

To determine the extent to which the process was in compliance with key 

statutory requirements as defined in the Fixing America’s Surface 

Transportation (FAST) Act, we analyzed the award recipients by their 

project size and location. We also interviewed officials from DOT who 

commented on how the requirements affected the evaluation and 

selection process. We did not assess whether the applications selected 

by DOT will achieve the stated benefits or costs or the merit of their 

selection.

To determine the extent to which the FASTLANE process aligned with 

recommended practices for awarding discretionary grants, we compared 

the process to these practices. Specifically, the recommended practices 

relate to (1) communicating with potential applicants prior to the 

competition, (2) planning for administering the review of applications, (3) 

developing a technical review panel with certain characteristics, (4) 

assessing applicants abilities to manage grant funds, (5) notifying 

applicants of decisions, and (6) documenting reasons for award 

decisions.3 To determine the extent to which DOT used these 

recommended practices for awarding discretionary grants, we compared 

these practices to information from the 2016 NOFO, the FASTLANE 

evaluation plan, guidance to applicant reviewers, other program-related 

guidance, and statements made by DOT officials regarding their 

implementation of the grant award program. For this effort, one analyst 

carried out the comparison and two other analysts verified the 

comparison results. Where differences existed, the analysts discussed 

 2

According to DOT officials, one official that attended meeting was still present within the 

agency, but that official was there in an acting capacity.

3

GAO, Intercity Passenger Rail: Recording Clearer Reasons for Awards Decisions Would 

Improve Otherwise Good Grantmaking Practices, GAO-11-283 (Washington, D.C.: March 

10, 2011)
Appendix I: Objectives, Scope, and 

Methodology

Page 38 GAO-18-38 Discretionary Transportation Grants

them and reached agreement. To determine the extent to which the 

process aligned with DOT’s guidance we compared the guidance to the 

FASTLANE documents and processes described above.

In addition, to obtain the applicants’ perspectives, we spoke with a nongeneralizable sample of 13 applicants on the challenges they faced 

during the FASTLANE program’s application process and the consistency 

of DOT’s communication. We selected applicants primarily based on 

demographics (i.e. project size, location, and transportation mode), if the 

Senior Review Team modified the project, and if the project was rated 

highly but unable to meet one or more statutory requirements and did not 

receive additional communications from DOT. To increase the diversity of 

our sample, we also considered the project sponsor (State Department of 

Transportation, local government, port authority, etc.), whether a project 

received an award, and whether the project also applied for a 

Transportation Investment Generating Economic Recovery (TIGER) 

grant. Because this was not a random or representative sample, the 

views of these applicants cannot be generalized to all FASTLANE 

applicants.

We conducted this performance audit from October 2016 to November

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Comments from the Department 

of Transportation

Page 39 GAO-18-38 Discretionary Transportation Grants

Appendix II: Comments from the Department 

of Transportation
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 40 GAO-18-38 Discretionary Transportation Grants

Susan Fleming, (202)-512-2834 or flemings@gao.gov

In addition to the contact named above, Sharon Silas (Assistant Director), 

Amy Higgins (Analyst in Charge), Ross Gauthier, David Hooper, Delwen 

Jones, Ying Long, Ned Malone, Josh Ormond, and Elizabeth Wood made 

key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(101195)
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