GAO 

United States Government Accountability Office

Report to Congressional Committees

PUBLIC 

TRANSPORTATION 

Better Data Needed to 

Assess Length of New 

Starts Process, and 

Options Exist to 

Expedite Project 

Development 

August 2009 

GAO-09-784 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

August 2009

PUBLIC TRANSPORTATION 

Better Data Needed to Assess Length of New Starts

Process, and Options Exist to Expedite Project 

Highlights of GAO-09-784, a report to Development 

congressional committees 

The New Starts program is an 

important source of new capital 

investment in mass transportation. 

To be eligible for federal funding, a 

project must advance through the 

different project development 

phases of the New Starts program, 

including alternatives analysis, 

preliminary engineering, and final 

design. The Federal Transit 

Administration (FTA) evaluates 

projects as a condition for 

advancement into each project 

development phase of the program. 

FTA has acted recently to 

streamline the process. This report 

discusses the (1) time it has 

generally taken for projects to 

move through the New Starts 

process and what Congress and 

FTA have done to expedite the 

process and (2) options that exist 

to expedite the process. In 

response to a legislative mandate, 

GAO reviewed statutes, FTA 

guidance and regulations, and 

project data. GAO also interviewed 

Department of Transportation 

(DOT) officials, projects sponsors, 

and industry stakeholders. 

What GAO Recommends

GAO recommends that DOT 

consider options to expedite 

project development and continue 

to improve its data collection 

efforts. DOT agreed with the first 

recommendation but not the 

second, which GAO revised to 

better reflect FTA’s efforts to date 

and the ongoing need for complete 

and reliable data to help strengthen 

the program. 

Insufficient data are available to describe the time it has taken for all projects 

to move through the New Starts process. Nevertheless, 9 of 40 projects that 

have received full funding grant agreements since 1997, and had complete 

data available, had milestone dates that ranged from about 4 to 14 years to 

complete the project development phases. However, the data from these 9 

projects are not generalizeable to the 40 New Starts projects. FTA has not 

historically retained all milestone data for every project, such as the dates that 

project sponsors apply to enter preliminary engineering and FTA’s subsequent 

approval. Although not required by its records retention policy, FTA has 

retained milestone data from some projects longer than 2 years. However, 

GAO was unable to obtain complete and reliable project milestone data from 

FTA. FTA officials acknowledged that, while not historically perfect, the 

agency has retained sufficient milestone data to help manage the New Starts 

program. Nevertheless, recognizing the importance of having complete 

milestone data, FTA has taken several steps in recent years to more 

consistently collect and retain such data. In addition, GAO found that project 

sponsors do not consistently retain milestone data for projects that have 

completed the New Starts process. 

Congress and FTA have taken action to expedite projects through the New 

Starts process. For example, legislative action created the Public-Private 

Partnership Pilot Program (Penta-P) to study the benefits of using publicprivate partnerships for certain new fixed-guideway capital projects, such as 

accelerating project delivery. In addition, FTA has implemented 

administrative changes to expedite the New Starts process. For example, FTA 

has developed and offered training workshops for project sponsors and has 

introduced project delivery tools. These tools include checklists for project 

sponsors to improve their understanding of the requirements of each phase of 

the New Starts process. 

Project sponsors and industry stakeholders GAO interviewed identified 

options to help expedite project development within the New Starts program. 

These options include tailoring the New Starts evaluation process to risks 

posed by the projects, using letters of intent more frequently, and applying 

policy and guidance changes only to future projects. Each option has 

advantages and disadvantages to consider. In addition, FTA must also strike 

the appropriate balance between expediting project delivery and maintaining 

the accountability of the program. For example, by signaling early federal 

support of projects, letters of intent could help project sponsors use 

potentially less costly and time-consuming alternative project delivery 

methods, such as design-build. However, such early support poses some risk. 

It is possible that with more frequent use of letters of intent, FTA’s 

commitment authority could be depleted earlier than expected, which could 

affect the anticipated funding stream for future projects. Furthermore, some 

options, like combining one or more statutorily required project development 

phases, would require legislative action. 

View GAO-09-784 or key components.

For more information, contact Susan Fleming 

at (202) 512-2834 or flemings@gao.gov. 
Page i GAO-09-784 

Contents 

Letter 1

Background 3 

Insufficient Data Prevent Complete Assessment of the Time It 

Takes Projects to Move through the Process, but Congress and 

FTA Have Taken Action to Expedite the Process 10 

Options Exist That Could Expedite the New Starts Project 

Development Process 18 

Conclusions 25 

Recommendations for Executive Action 25 

Agency Comments and Our Evaluation 26 

Appendix I Administration Requests $1.83 Billion in Fiscal Year 

2010 Funding for New Starts, Small Starts, and Very 

Small Starts Projects 28 

Appendix II Scope and Methodology 34 

Appendix III Timeline Data on New Starts Projects That We 

Collected from Project Sponsors, by Mode 37 

Appendix IV GAO Contact and Staff Acknowledgments 40 

Tables 

Table 1: New Starts Projects Evaluated and Rated for Fiscal Year 

2010 by Phase of New Starts Process 28 

Table 2: Small Starts and Very Small Starts Projects Evaluated and 

Rated for Fiscal Year 2010 30 

Table 3: New Starts and Small Starts Project Sponsors Interviewed 35 

Figures 

Figure 1: New Starts Project Planning and Development Process 5 

Figure 2: FTA’s Current New Starts Evaluation Process 7 

Public Transportation 
Figure 3: New Starts Planning and Project Development Durations 

for the Nine Projects with Complete Data 14 

Figure 4: Allocation of FTA’s Recommended Fiscal Year 2010 

Budget for New Starts 32 

Abbreviations 

DOT Department of Transportation 

ESWA early systems work agreement 

FFGA full funding grant agreement 

FTA Federal Transit Administration 

LPA locally preferred alternative 

NARA National Archives and Records Administration 

NEPA National Environmental Policy Act 

PCGA project construction grant agreement 

PDA project development agreement 

Penta-P Public-Private Partnership Pilot Program 

PMOC project management oversight contractor 

Recovery Act American Recovery and Reinvestment Act 

SAFETEA-LU Safe, Accountable, Flexible, Efficient 

 Transportation Equity Act: A Legacy for Users 

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 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 

Page ii GAO-09-784 Public Transportation
Page 1 GAO-09-784 

 

United States Government Accountability Office

Washington, DC 20548 

 

August 6, 2009 

The Honorable Christopher J. Dodd 

Chairman 

The Honorable Richard C. Shelby 

Ranking Member 

Committee on Banking, Housing, and Urban Affairs 

United States Senate 

The Honorable James L. Oberstar 

Chairman 

The Honorable John L. Mica 

Ranking Member 

Committee on Transportation 

 and Infrastructure 

House of Representatives 

Since the early 1970s, much of the federal government’s share of new 

capital investment in mass transportation has come through the Federal 

Transit Administration’s (FTA) New Starts program. Through this 

program, FTA identifies and recommends new fixed-guideway transit 

projects for grants, typically through full funding grant agreements 

(FFGA).1

 Over the last decade, the New Starts program has provided state 

and local agencies with over $10 billion to help design and construct 

transit projects nationwide. 

The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A 

Legacy for Users (SAFETEA-LU), which authorized the New Starts 

program through fiscal year 2009, identifies criteria for how FTA evaluates 

and rates projects.2

 FTA must prioritize projects for funding by evaluating, 

rating, and recommending potential projects on the basis of specific 

financial commitment and project justification criteria—including mobility 

improvements, cost-effectiveness, economic development effects, land 

1

Fixed guideway systems use and occupy a separate right-of-way for the exclusive use of 

public transportation services. These fixed guideway systems include fixed rail, exclusive 

lanes for buses and other high-occupancy vehicles, and other systems. A FFGA establishes 

the terms and conditions for federal funds available for the project, including the maximum 

amount of government financial assistance. 

2

Pub. L. No. 109-59, § 5309(j), 119 Stat. 1144, 1584 (2005). 

Public Transportation 
 

use, environmental benefits, and operating efficiencies. Using these 

statutorily identified criteria, FTA evaluates potential projects annually 

and as a condition for advancement into each phase of the New Starts 

process, including preliminary engineering, final design, and construction. 

FTA refers to projects in the preliminary engineering or final design 

phases as being in the “pipeline” through which successful projects 

advance to receive funding. 

We have previously identified FTA’s use of a rigorous and systematic 

evaluation process to distinguish among proposed New Starts investments 

as a model for other transportation programs.3

 However, we and other 

stakeholders and policymakers have also identified challenges facing the 

New Starts program. For example, our past reviews found that many 

program stakeholders thought that FTA’s process for evaluating New 

Starts projects was too time consuming, costly, and complex. These issues 

and the upcoming reauthorization of all surface transportation programs, 

including the New Starts program, have led stakeholders and 

policymakers to examine the existing evaluation and rating process and 

consider potential modifications and other options to reduce the 

complexity, cost, and time it takes for a New Starts project to go through 

the pipeline. 

We are required by SAFETEA-LU to report each year on FTA’s processes 

and procedures for evaluating, rating, and recommending New Starts 

projects for federal funding and on FTA’s implementation of these 

processes and procedures.4

 This report discusses the (1) time it has 

generally taken for proposed projects to move through the New Starts 

process, and what Congress and FTA have done to expedite the process, 

and (2) options that exist to expedite the process. In addition, appendix I 

contains an overview of FTA’s fiscal year 2010 New Starts Annual Report

and budget request. To address these objectives, we reviewed SAFETEALU and other New Starts statutory requirements, FTA guidance and 

regulations governing the New Starts program and other FTA documents, 

including the annual New Starts report, and interviewed transportation 

experts, transit consultants, transit industry associations, and Department 

of Transportation (DOT) officials about the time it takes for a New Starts 

 

3

GAO-07-917, Public Transportation: Future Demand Is Likely for New Starts and Small 

Starts Programs, but Improvements Needed to the Small Starts Application Process 

(Washington, D.C.; July 27, 2007). 

4

49 U.S.C. § 5309(k)(2). 

Page 2 GAO-09-784 Public Transportation
 

project to move through the New Starts process, as well as the options 

that exist to expedite the process. We also interviewed 9 project sponsors 

about 10 projects. We selected these projects based on a range of 

characteristics, including: (1) timing (i.e., when projects received a FFGA); 

(2) mode (i.e., heavy rail, light rail, or bus); (3) scope (i.e., the total cost of 

the project); and (4) geographic area. In addition, we gathered, and took 

steps to verify, FTA data on project milestone approval dates to determine 

how long the 40 projects that received a FFGA after June 1997 took to 

complete the New Starts process. We also attempted to gather data 

directly from project sponsors on project milestone approval and 

application dates for these 40 projects to determine how long it took 

projects to complete the New Starts process. Appendix II contains 

additional information about our scope and methodology. For this report, 

we did not consider how projects are rated or examine the efficacy of 

FTA’s evaluation measures.5

 We conducted this performance audit from 

January 2009 to August 2009, 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. 

FTA generally funds New Starts projects through FFGAs, which are 

required by statute to establish the terms and conditions for federal 

participation in a New Starts project.6

 FFGAs also define a project’s scope, 

including the length of the system and the number of stations; its schedule, 

including the date when the system is expected to open for service; and its 

cost. For projects to obtain FFGAs, they must emerge from a regional, 

multimodal transportation planning process. 

Background 

The early stages of the New Starts project development process—

alternatives analysis and much of preliminary engineering—are carried out 

in concert with the metropolitan planning process specified by SAFETEALU and the environmental review processes required by the National 

 

5

For information on issues related to the New Starts evaluation measures, see GAO-08-844, 

Public Transportation: Improvements Are Needed to More Fully Assess Predicted 

Impacts of New Starts Projects (Washington, D.C.: July 25, 2008). 

6

49 U.S.C. § 5309(g)(2). 

Page 3 GAO-09-784 Public Transportation
 

Environmental Policy Act of 1969 (NEPA).7 Alternatives analysis studies 

are a corridor-level analysis of a range of alternatives designed to address 

locally-identified mobility and other problems in a specific transportation 

corridor. The alternatives analysis phase culminates in the selection of a 

locally preferred alternative (LPA), which is the New Starts project that 

FTA evaluates for funding. 

After a locally preferred alternative is selected, the project sponsor 

submits an application to FTA for the project to enter the preliminary 

engineering phase.8

 During the preliminary engineering phase, project 

sponsors refine the design of the locally preferred alternative, taking into 

consideration all reasonable design alternatives and estimating each 

alternative’s costs, benefits, and impacts (e.g., financial or environmental). 

Further, project sponsors are required to complete the NEPA 

environmental review process in order to receive federal funding. 

Specifically, FTA interprets NEPA to require, as part of the NEPA process 

for evaluation of the alternatives,9

 an environmental review document 

with information on each alternative’s benefits and costs relating to the 

New Starts evaluation. When the preliminary engineering phase is 

completed and federal environmental requirements are satisfied, FTA ma

approve the project’s advancement into final design, after which F

recommend the project for a FFGA and proceed to construction.

y 

TA may 

 

10 FTA 

oversees grantees’ management of projects from the preliminary 

engineering phase through the construction phase (see fig. 1). This project 

management oversight is conducted by FTA staff, working closely with its 

project management oversight contractors (PMOC), to provide continual 

7

42 U.S.C. § 4321 et seq. FTA requires projects to have progressed beyond the NEPA 

scoping phase before it will approve entry into New Starts preliminary engineering. The 

scoping phase of a project is a requirement of the NEPA process focused on identifying 

significant issues related to a proposed action. Additionally, the scoping phase may include 

a determination of the range of alternatives to be addressed in NEPA documents. 

8

To gain approval for entry into preliminary engineering, a project must (1) be identified 

through the alternatives analysis process, (2) be included in the region’s long-term 

transportation plan, (3) meet the statutorily defined project justification and financial 

criteria, and (4) demonstrate that the sponsors have the technical capability to manage the 

project during the preliminary engineering phase. Some federal New Starts funding is 

available to projects for preliminary engineering activities, if so appropriated by Congress. 

9

42 U.S.C. § 4332(c)(iii) and implementing regulation 40 C.F.R. § 1501.2(c) requires the 

study and development of alternatives to a proposed action. 

10Final design is the last phase of project development before construction and may include 

right-of-way acquisition, utility relocation, and the preparation of final construction plans 

and cost estimates. 

Page 4 GAO-09-784 Public Transportation
 

monitoring and assessment of projects’ scope, schedule, and budget, and 

of its sponsor’s technical capacity. 

Figure 1: New Starts Project Planning and Development Process 

Planning

Preliminary

engineering

Final design

Final design

Systems

planning

Alternatives

analysis

Select LPA

FTA decision 

on entry into preliminary

engineering

FTA decision

on entry into final

design

FFGA

Preliminary engineering

Construction

Project 

management 

oversight

Construction

Source: FTA.

Decision point Major development stage

FFGA = full funding grant agreement

FTA = Federal Transit Administration

LPA = locally preferred alternative

Legend

Page 5 GAO-09-784 Public Transportation
 

Note: Projects are rated at several points during project development, including as part of the 

evaluation for entry into the preliminary engineering and final design phases, and yearly for inclusion 

in the New Starts Annual Report. Additionally, the administration uses the FTA evaluation and rating 

process, along with the phase of development of New Starts projects, to decide which projects to 

recommend to Congress for funding. 

To help inform administration and congressional decisions about which 

projects should receive federal funds, FTA currently distinguishes among 

proposed projects by evaluating and assigning ratings to various statutory 

evaluation criteria—including both project justification and local financial 

commitment criteria—and then assigning an overall project rating.11 (See 

fig. 2.) These evaluation criteria reflect a broad range of benefits and 

effects of the proposed project, such as cost-effectiveness, as well as the 

ability of the project sponsor to fund the project and finance the continued 

operation of its transit system. FTA has developed specific measures for 

each of the criteria outlined in statute. However, FTA currently assigns a 

50 percent weight to both the cost-effectiveness and the land use criteria 

when developing the project justification summary rating. The other 

project justification criteria are not weighted, although the mobility 

improvements criterion is used as a “tiebreaker.”12 On the basis of their 

evaluation measures, FTA assigns proposed projects a rating for each 

criterion and then assigns a summary rating for local financial 

commitment and project justification. These two ratings are averaged 

together, and FTA assigns each project a “high,” “medium-high,” 

“medium,” “medium-low,” or “low” overall rating, which is used to rank 

projects and determine which projects to recommend for funding. 

 

11The exceptions to the evaluation process are statutorily exempt projects, which are those 

with requests for less than $25 million in New Starts funding. Sponsors of these projects 

are not required to submit project justification information (although FTA encourages the 

sponsors to do so). These projects are exempt until such time as a final regulation 

implementing certain provisions of SAFETEA-LU is complete. FTA does not rate these 

projects. As a result, the number of projects in the preliminary engineering or final design 

phases may be greater than the number of projects evaluated and rated by FTA. 

12In May 2009, FTA took steps to address concerns about the exclusion of some project 

justification criteria from the evaluation process. In a “Notice of Availability of Proposed 

Guidance for New Starts/Small Starts Policies and Procedures” and “Request for 

Comments” in the Federal Register, FTA proposed changing the weights assigned for the 

project justification criteria for New Starts projects. Specifically, FTA proposes to set the 

weights at 20 percent each for the mobility, cost-effectiveness, land use, and economic 

development criteria, and 10 percent each for operating efficiencies and environmental 

benefits. 74 Fed. Reg. 23776 (May 20, 2009). 

Page 6 GAO-09-784 Public Transportation
 

Figure 2: FTA’s Current New Starts Evaluation Process 

a

These criteria are not assigned a weight in the evaluation framework. 

Source: GAO analysis of FTA data.

Overall project

rating

Local financial

commitment

summary rating

Project

justification

summary rating

Mobility

improvements

(0% weight)a

Operating

efficiencies

(0% weight)a

Environmental

benefits

(0% weight)a

Costeffectiveness

(50% weight)

Land

use

(50% weight)

Weight

0% 50%

Other

factors

(0% weight)a

Non-New

Starts share

(20% weight)

Capital

finance plan

(50% weight)

Operating

finance plan

(30% weight)

Projects are rated at several points during the New Starts process, 

including as part of the evaluation for entry into the preliminary 

engineering and final design phases, and they are rated yearly for inclusion 

in the New Starts Annual Report. The administration uses the FTA 

evaluation and rating process, along with the phase of development of 

New Starts projects, to decide which projects to recommend to Congress 

for funding.13 Although many projects receive a summary rating that would 

 

13The administration’s funding recommendations are made in the President’s budget 

request and are included in FTA’s annual New Starts report to Congress, which is released 

each February in conjunction with the President’s budget request. See appendix I for a 

summary of the annual report for fiscal year 2010. 

Page 7 GAO-09-784 Public Transportation
 

make them eligible for a FFGA, generally only a few are proposed for a 

FFGA in a given fiscal year. FTA proposes FFGAs for those projects that

are projected to meet the following conditions during the fiscal year for 

which funding is proposed: 

deral project funding must be committed and available for the 

roject. 

ssed 

fits, and impacts (e.g., 

nancial or environmental) to be minimized. 

o remaining cost, project scope, or local 

nancial commitment issues. 

ogram, 

count 

A 

e 

rts 

requirements imposed for those seeking funding for lower cost projects 

 

• All nonfe

p

• The project must be in or near the final design phase and have progre

far enough for uncertainties about costs, bene

fi

• The project must meet FTA’s tests for readiness and technical capacity,

which confirm that there are n

fi

SAFETEA-LU introduced a number of changes to the New Starts pr

including some that affect the evaluation and rating process.14 For 

example, given past concerns that the evaluation process did not ac

for a project’s impact on economic development and FTA’s lack of 

communication to sponsors about upcoming changes, the statute added 

economic development to the list of project justification criteria that FT

must use to evaluate and rate New Starts projects, and requires FTA to 

issue notice and guidance each time significant changes are made to th

process and criteria.15 SAFETEA-LU also established the Small Sta

program, a new capital investment grant program, simplifying the 

14For more information on the changes SAFETEA-LU made to the New Starts program and 

the status of their implementation, see GAO-06-819, Public Transportation: New Starts 

Program in a Period of Transition (Washington, D.C.: Aug. 30, 2006) and GAO-07-917. 

15The legislation also requires that projects be funded only if they are justified based on a 

“comprehensive review” of its (1) mobility improvements, (2) environmental benefits, 

(3) cost-effectiveness, (4) operating efficiencies, (5) economic development effects, and 

(6) public transportation supportive land use policies and future patterns. The legislation 

also lists a number of factors to be analyzed, evaluated, and considered, including 

congestion relief, improved mobility, air and noise pollution, and energy consumption. 

Page 8 GAO-09-784 Public Transportation
 

such as bus rapid transit, streetcar, and commuter rail projects.16 This 

program is intended to advance smaller-scale projects through an 

expedited and streamlined evaluation and rating process. FTA also 

subsequently introduced a separate eligibility category within the Small 

Starts program called Very Small Starts, which is for projects with a 

capital cost of less than $50 million.17 Very Small Starts projects qualify for 

an even simpler and more expedited evaluation and rating process than 

other Small Starts projects. 

FTA, like most federal agencies, must document its activities, including 

work related to the New Starts program, in accordance with the Federal 

Records Act of 1950, as amended. Each federal agency must maintain a 

records management program and must preserve records that (1) 

document the organization, functions, policies, decisions, procedures, and 

essential transactions of the agency and (2) provide the information 

necessary to protect the legal and financial rights of the government and of 

persons directly affected by the agency’s activities.18 The National 

Archives and Records Administration (NARA) is given general o

responsibilities for records management programs and practices. The 

activities of an agency records management program include, among other 

things, the development of a records schedule—that is, for all records 

created and received by the agency, where and how long records need to 

be retained and their final disposition (destruction or preservation) based 

on time, or event, or a combination of time and event—subject to the 

approval of NARA. No record may be destroyed unless it has been 

scheduled and, for temporary records, the schedule is of critical 

versight 

 

16Small Starts projects are defined as those that are requesting less than $75 million in 

federal funding and have a total estimated net capital cost of less than $250 million. Transit 

projects that qualify for the Small Starts program are referred to as “Small Starts projects” 

in this report as well as in FTA’s guidance and reports. Transit projects that do not qualify 

for the Small Starts program because they request more federal funding, or are larger in 

scope, than is permitted by 49 U.S.C. § 5309(e) are referred to as “New Starts projects.” 

Thus, in this report, we use the term “New Starts” in two contexts: (1) to identify projects 

that are larger in scope than is permitted by 49 U.S.C. § 5309(e) and (2) as a reference to 

the entire capital investment grants program that is subject to 49 U.S.C. § 5309(d) or (e). 

17Very Small Starts projects must meet the same eligibility requirements as Small Starts 

projects and be located in corridors with more than 3,000 existing riders per average 

weekday who will benefit from the proposed project. In addition, the projects must have a 

total capital cost of less than $50 million (for all project elements) and a per-mile cost of 

less than $3 million, excluding rolling stock (e.g., train cars). 

18As relevant here, 44 U.S.C. chapters 21, 29, 31, and 33, and 36 C.F.R. Part 1222. 

Page 9 GAO-09-784 Public Transportation
 

importance because it provides the authority to dispose of the record after 

a specified time period. 

There is insufficient data available to determine the time it takes for a 

project to move through the New Starts process. Nevertheless, 9 of the 40 

projects that have received a FFGA since 1997, and with complete data 

available, had milestone dates that ranged from about 4.5 to 14 years to 

complete the project development phases. However, the data from these 9 

projects are not generalizeable to the 40 New Starts projects. FTA has not 

historically retained all milestone data for the 40 projects, such as the 

dates project sponsors apply to enter a project development phase, in a 

consistent manner. However, FTA has retained some milestone data from 

some projects and is taking steps to improve its New Starts data retention 

and collection. In addition, we found that project sponsors do not 

systematically retain milestone data for projects that have completed the 

New Starts process. Congress and FTA have taken action to expedite 

projects through the New Starts process through Penta-P and training 

workshops for project sponsors. 

Insufficient Data 

Prevent Complete 

Assessment of the 

Time It Takes Projects 

to Move through the 

Process, but Congress 

and FTA Have Taken 

Action to Expedite 

the Process 

Limited Milestone Data on 

Projects Available through 

FTA or Project Sponsors 

FTA has not historically retained all milestone data, such as the dates that 

project sponsors apply to enter a project development phase, and FTA’s 

subsequent approval, in a consistent or comprehensive manner. According 

to FTA, its record schedule requires that FTA retain documents related to 

milestone approvals for 2 years after the close of the project and FTA 

meets this requirement. For example, FTA retains documents that notify 

project sponsors of their approval to enter preliminary engineering and 

final design. Although not required, FTA has also retained milestone data 

from some, but not all, projects longer than 2 years. 

We were unable to obtain complete and reliable project milestone data 

from FTA. FTA has historically retained milestone data from some 

projects using a variety of techniques, such as maintaining hard copies of 

milestone approval letters or internal memos in binders and saving 

electronic copies of some documents in a computer filing system. Using 

these sources, FTA provided us with milestone approval dates—

preliminary engineering, final design, and FFGA—for the 40 projects that 

received a FFGA since 1997. However, when we attempted to verify the 

milestone approval dates from a random sample of 10 projects, we found 

that the data were unreliable and, in some cases, inaccurate. For example, 

the approval dates for some projects did not match the dates contained in 

the source documents (e.g., letters from FTA approving a project’s 

Page 10 GAO-09-784 Public Transportation
 

advancement into preliminary engineering); in other cases the source 

documents for some projects were missing from the project files. In 

addition to milestone approval dates, we asked FTA to provide the dates 

that these 40 projects began alternatives analysis and submitted 

applications for preliminary engineering, final design, and FFGA. Because 

FTA is not required by its record schedule to retain these dates, FTA was 

unable to provide these dates. In addition, FTA officials cited several 

challenges to collecting this information. First, FTA told us that it does not 

have records on when a project begins alternatives analysis because this 

phase is conducted at the local level, generally without FTA involvement. 

Second, FTA told us that it does not record when a project sponsor 

submits an application for preliminary engineering, final design, and FFGA 

because project sponsors almost never submit complete applications. 

According to FTA officials, they begin to review applications while 

simultaneously working with project sponsors to submit additional 

documentation to complete the application. However, according to FTA 

officials, because the application process is iterative, they have not 

historically assigned a date when the application was fully submitted. 

We have previously reported that federal agencies can use performance 

information to make various types of management decisions to improve 

programs and results.19 In particular, managers can use performance 

information to identify problems in existing programs, to try to identify the 

causes of problems, or to develop corrective actions. Further, GAO’s 

Standards for Internal Control in the Federal Government states that 

internal control activities include, among other activities, appropriate 

documentation of records.20 More specifically, internal control and all 

transactions and other significant events need to be clearly documented, 

and the documentation should be readily available for examination. The 

documentation should appear in management directives, administrative 

policies, or operating manuals and may be in paper or electronic form. All 

documentation and records should be properly managed and maintained. 

 

19GAO, Managing For Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005). 

20GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: November 1999). An internal control is an integral component of an 

organization’s management that provides reasonable assurance that the following 

objectives are being achieved: (1) effectiveness and efficiency of operations, (2) reliability 

of financial reporting, and (3) compliance with applicable laws and regulations. 

Page 11 GAO-09-784 Public Transportation
 

FTA officials acknowledged that while not historically perfect; the agency 

has retained sufficient milestone data to help manage the New Starts 

program. For example, FTA officials noted that they have used the data to 

help identify “pain points” in the process and options to streamline the 

process. Furthermore, FTA officials stated that even with the most 

comprehensive information on the time it takes for New Starts projects to 

complete the project development process, each project represents a 

unique set of challenges from local decision making, funding availability, 

and local legal structure that will impact the time it takes to pass through 

the FTA decision phases. 

Nevertheless, recognizing the importance of having complete milestone 

data to better understand and improve the project development process, 

FTA has taken several steps in recent years to more consistently collect 

and retain such data. For example, FTA officials told us that, since late 

2006, they now retain all letters that contain preliminary engineering and 

final design approval dates and electronically document the date a project 

sponsor’s application to enter preliminary engineering is received in 

internal memos. Also, according to FTA, the agency has begun to 

document the date when it considers project sponsors’ preliminary 

engineering applications complete. In addition, in 2008, FTA officials said 

that they began requiring project sponsors to submit a copy of their 

alternatives analysis initiations packages for FTA review and comment. 

Finally, FTA officials said they were in the process of developing a 

spreadsheet to record various project approval dates—including 

statutorily required approval dates and internal FTA review dates—and 

just completed a year long pilot project of an electronic case management 

system. 

Project sponsors also do not consistently retain milestone data for 

projects that have completed the New Starts process. Because of the 

limitations of FTA’s data, we attempted to collect data from project 

sponsors that have received a FFGA since 1997, on the time it takes for a 

project to move through the New Starts evaluation and rating process. We 

queried the project sponsors for several New Starts milestone dates. 

However, we found that some of the project sponsors do not consistently 

maintain records on completed projects. In addition, some projects had 

multiple project sponsors during the New Starts evaluation and rating 

process, which complicated record keeping. Nonetheless, we were able to 

gather some milestone dates for 30 of the 40 projects, but these data were 

not complete due to missing milestone dates and therefore we were not 

able to calculate valid timelines for all projects. (See app. III for more 

information on these data.) 

Page 12 GAO-09-784 Public Transportation
 

However, of the 30 project sponsors that provided information to us, only 

9 had complete sets of New Starts milestone dates. Figure 3 shows the 

time it took for each of these projects with complete data to move from 

the beginning of alternatives analysis to the approval for a FFGA, ranging 

from about 4.5 years for 3 projects to over 14 years for 2 projects.21 Due to 

the number of projects with complete data, the data from these 9 projects 

are not generalizeable to the 40 New Starts projects. The small sample size 

also makes it difficult to determine whether mode (i.e., heavy rail, light 

rail, or bus), cost, or the year that the completed projects entered the New 

Starts evaluation and rating process impacts the time each project spends 

in each phase. Furthermore, FTA officials told us that each New Start 

project’s experience in the evaluation and rating process is unique, making 

it difficult to identify trends or patterns. 

 

21Alternatives analysis is conducted at the local level, with limited FTA involvement. Thus, 

according to FTA officials, FTA has limited influence on the amount of time projects spend 

in the alternatives analysis phase. 

Page 13 GAO-09-784 Public Transportation
 

Figure 3: New Starts Planning and Project Development Durations for the Nine Projects with Complete Data 

Source: GAO analysis of project sponsor data.

Begin alternatives analysis to approval into preliminary engineering

Approval into preliminary engineering to approval into final design

Approval into final design to approved for full funding grant agreement

University Link LRT, Seattle, Wash.

South Corridor I-205 /

Portland Mall Light Rail Project,

Portland, Ore.

Norfolk Light Rail Transit Project,

Norfolk, Va.

West Corridor Light Rail,

Denver, Colo.

Eastside Corridor LRT Project,

Los Angeles, Calif.

Metra North Central

Service (NCS) Improvements,

Chicago, Ill.

Metra Union Pacific West Line

Extension/Central Kane,

Chicago, Ill.

Metra South West Service

Improvements and Extension,

Chicago, Ill.

Southeast Corridor Light Rail

(T-Rex), Denver, Colo.

Projecta

5 years and

7 months

4 years and

7 months

4 years and

7 months

4 years and

7 months

7 years and

9 months

13 years and

9 months

14 years and

1 month

14 years and

2 months

5 years

1

Year

2

Years

3

Years

4

Years

5

Years

6

Years

7

Years

8

Years

9

Years

10

Years

11

Years

12

Years

13

Years

14

Years

15

Years

a

Projects arrayed in chronological order by the date FTA approved them to enter preliminary 

engineering. 

Note: This figure includes the time each of the nine projects spent in the alternatives analysis phase. 

This phase is conducted at the local level, with limited FTA involvement. According to FTA officials, 

the time spent in alternatives analysis reflects local decision making and activities, not the New Starts 

process. 

Some project sponsors, transit consultants, and a transportation industry 

association official told us that, over the years, the New Starts process has 

become too time consuming. Specifically, several project sponsors told us 

that the amount of time it takes for FTA to determine whether a project 

can advance into the next phase can be significant and causes additional 

Page 14 GAO-09-784 Public Transportation
 

costs. In addition, a 2007 Deloitte study on the New Starts program found 

that the New Starts process is perceived by project sponsors as intensive, 

lengthy, and burdensome.22 For example, one project sponsor believes that 

FTA reviews prolonged its project development by approximately 1 year, 

which they estimate cost an additional $24 million. 

FTA officials have acknowledged that the requirements of the New Starts 

process could add time to project development and have acted to 

streamline the process. For example, FTA has allowed projects to conduct 

additional engineering while FTA reviews applications for final design. 

FTA has also maintained that thorough reviews of project information can 

identify issues and challenges with proposed investments that may later 

prolong project development. However, FTA officials also noted that not 

all project delays can be attributed to FTA or the New Starts process. FTA 

officials cited a number of reasons that a project could be delayed during 

preliminary engineering or final design that are outside FTA’s control such 

as changes to a project’s scope, changes in local political leadership, or the 

loss of local financial commitment. For example, according to FTA 

officials, the Northern Virginia (Dulles Corridor Metrorail Project—

Extension to Wiehle Avenue) project was about to receive FTA approval 

to enter the final design phase when the Governor of Virginia requested a 

period of 6 months to evaluate a potential change in the project’s scope—

digging a large-bore 4-mile tunnel for a portion of the project—that the 

project sponsor eventually discarded in favor of the original design. 

The lack of reliable comprehensive data makes it difficult to develop a 

complete understanding of the time it takes projects to move through the 

New Starts process. The limited information available and anecdotal 

examples suggest that the process can be lengthy. But, without complete 

and accurate data, it is difficult to know whether and to what extent the 

process has become more time consuming over the years or the addition 

of new requirements add to the length of the process. Without such 

information, Congress and FTA cannot reliably identify the location, 

causes, or extent of the pain points and which options would be an 

appropriate response to expedite this process. Moreover, as we have 

previously reported, having such information can help agencies identify 

 

22In June 2006, FTA commissioned Deloitte Development LLC to review the New Starts 

project development process and identify opportunities for streamlining or simplifying the 

process. See Deloitte Development LLC, New Starts Program Assessment (Feb. 12, 2007). 

Page 15 GAO-09-784 Public Transportation
 

weaknesses in programs, assess factors causing the problems, and modify 

processes.23

Legislative and FTA 

Actions Have Been Taken 

to Expedite the Process 

SAFETEA-LU created what is commonly called the Small Starts program, 

a new capital investment grant program, simplifying the requirements 

imposed for those seeking funding for lower cost projects, such as bus 

rapid transit, streetcar, and commuter rail projects. This program is 

intended to advance smaller scale projects through an expedited and 

streamlined evaluation and rating process. In July 2007, FTA established 

the eligibility parameters for the Small Starts program. FTA created a 

separate eligibility category within the Small Starts program called Very 

Small Starts, which is for projects with a total capital cost of less than $50 

million. According to FTA, as of June 2009, one Small Starts project has 

been awarded a project construction grant agreement (PCGA), and 

another is currently being processed.24 In addition, two projects have 

received construction funding through standard grants rather than PCGAs. 

SAFETEA-LU also established the Public-Private Partnership Pilot 

Program (Penta-P) to demonstrate the advantages and disadvantages of 

public-private partnerships for certain new fixed guideway capital projects 

funded by FTA. In January 2007, FTA published the terms of Penta-P in the 

Federal Register.

25 Penta-P projects may be eligible for a simplified and 

accelerated New Starts review process that is intended to reduce the time 

and cost to project sponsors. For example, under Penta-P, the projects are 

eligible for consideration, on a case-by-case basis, for accelerated design 

approvals. Specifically, FTA could issue concurrent approvals for 

preliminary engineering and final design to commence, thus allowing the 

project to proceed with final design immediately upon completion of 

preliminary engineering without requiring additional approval. To date, 

FTA has not issued such concurrent approvals. In 2007, FTA executed 

memorandums of understanding for three pilot Penta-P projects that are 

candidates for New Starts funding: Houston, Texas; Denver, Colorado; and 

 

23GAO-05-927. 

24A project construction grant agreement, like a FFGA, is a multiyear binding agreement 

that formally establishes the maximum level of federal financial assistance and outlines the 

terms and conditions of federal financial participation. A project construction grant 

agreement is used for projects requiring less than $75 million in New Starts funding with a 

total project cost of less than $250 million. 

2572 Fed. Reg. 2583 (January 2007). 

Page 16 GAO-09-784 Public Transportation
 

Oakland, California. According to FTA officials, as of July 2009, FTA has 

not issued concurrent approvals of the type described above as the 

Penta-P projects have not yet demonstrated the distribution of risk among 

the private and public sectors that would enable FTA to relax its normal 

due diligence for approvals into preliminary engineering or final design. 

FTA has also implemented administrative changes designed to expedite 

the New Starts process. Examples of these changes include the following: 

• Regular training workshops: FTA has developed and offered regular 

training workshops for project sponsors and offered information to 

project sponsors to end misconceptions about the New Starts process. For 

example, in March 2009, FTA offered two New Starts workshops in 

Phoenix, Arizona, and Tampa, Florida, on travel forecasting and provided 

the materials from these workshops on its Web site. In addition, in June 

2009, FTA offered a course on alternatives analysis in Los Angeles. FTA 

also offers New Start roundtables that are usually 2-day meetings between 

FTA staff and project sponsors of projects in preliminary engineering and 

final design seeking New Starts funding. They consist of presentations by 

FTA staff and local project sponsors on topics related to New Starts 

planning, project development, and the evaluation and rating process. 

• Project delivery tools: In addition to training, FTA has introduced project 

delivery tools to assist project sponsors with the New Starts evaluation 

and rating process. FTA now requires the submittal of an alternatives 

analysis initiation package summarizing corridor problems, conceptual 

alternatives, and preliminary evaluation measures to be used, which, 

according to FTA, can help to foster coordination among local 

participating agencies and FTA. FTA has also developed checklists for 

project sponsors to improve their understanding of the requirements of 

each phase of the New Starts process. Lastly, FTA has begun to use road 

maps with some project sponsors that include schedules and roles for 

both FTA and the sponsor. 

Page 17 GAO-09-784 Public Transportation
 

Project sponsors, transit consultants, transit industry associations, and 

academics we contacted identified several options for streamlining the 

New Starts project development process, including combining project 

development phases, using nonbinding or binding agreements, adopting a 

more risk-based approach, and promoting project development tools.26

Although each of these options could streamline the New Starts evaluation 

and rating process, each option has advantages and disadvantages to 

consider.27

Options Exist That 

Could Expedite the 

New Starts Project 

Development Process 

Combining Project 

Development Phases 

Project sponsors and transit consultants cited combining project 

development phases, such as preliminary engineering and final design, as 

an option for expediting the New Starts project development process. 

Project sponsors and transit consultants told us that waiting for FTA’s 

approval to enter preliminary engineering, final design, and construction 

can prolong project development. According to project sponsors, while 

FTA determines whether a project can advance to the next project 

development phase, work on the project essentially stops. Project 

sponsors can advance the project at their own risk, meaning they could 

have to redo the work if FTA does not subsequently approve an aspect of 

the project. The amount of time it takes for FTA to determine whether a 

project can advance can be significant. For example, one project sponsor 

told us that FTA’s review of its application to advance from alternatives 

analysis to preliminary engineering took 8 months, about the same amount 

of time it took the project sponsor to complete alternatives analysis. FTA 

officials told us the length of time for reviews depends on a number of 

factors, most importantly the completeness and accuracy of the project 

sponsor’s submissions. 

To reduce the “start/stop” phenomena project sponsors described, a 

legislative change would be necessary to eliminate the requirement that 

 

26The options that we identify in this section of the report are based on information we 

obtained from our interviews with New Starts project sponsors, transit industry 

associations, transit consultants, and academics. Not all of these officials identified each of 

these as options for streamlining the New Starts evaluation and rating process. Therefore, 

our intent is not to focus on the frequency with which the officials identified each option, 

but to inform the reader about the various options that could streamline the New Starts 

process in the future. 

27As of the issuance date of this report, DOT officials were in the process of formulating its 

reauthorization proposal for the New Starts process. Therefore, DOT officials did not 

comment on the options project sponsors and industry stakeholders told us would 

expedite project development within the New Starts program. 

Page 18 GAO-09-784 Public Transportation
 

FTA approve advancement of a project into final design, which would 

effectively combine the preliminary engineering and final design phases 

into one “project development” phase, as was done in SAFETEA-LU when 

creating a more streamlined version of the process under the Small Starts 

program. Furthermore, another option for legislative change would be to 

replace the requirement that FTA approve the advancement of a project 

into the preliminary engineering phase with a requirement that FTA 

approve a project into the overall New Starts program, which would 

streamline and simplify the process. In addition, the Deloitte study 

recommended combining preliminary engineering and final design, while 

simultaneously adjusting the FFGA review date to occur in the middle of 

this expanded phase, rather than after final design, where it traditionally 

happened. In this regard, the Deloitte study reflected the sentiments of 

project sponsors and consultants we interviewed, who said that combining 

phases and/or creating a programmatic approval28 would allow FTA to 

signal its intent to recommend a project for funding at an earlier point than 

the current project development process allows. This would give sponsors 

more opportunity to pursue private financing arrangements and 

alternative project delivery methods, such as those being carried out under 

Penta-P, as this federal funding provides the certainty needed to 

encourage private sector participation. In addition to combining phases, 

the Deloitte study also recommended that FTA redefine or more clearly 

define the project phases to more accurately reflect FTA’s current 

requirements and to better accommodate alternative delivery methods. 

There are limitations to combining phases of the New Starts project 

development process. One limitation to combining phases and clarifying 

them is that a legislative change would be necessary. Another limitation is 

that, depending on how it is accomplished, combining phases could 

impact how FTA integrates NEPA requirements into the project 

development process. Finally, combining phases would reduce the 

opportunities for FTA to monitor and evaluate high-value projects at 

important interim phases; therefore, increasing the potential for issues or 

problems to go undetected. 

 

28Approval to enter the New Starts program would convey FTA’s intent to recommend a 

project for funding so long as the project continued to meet certain broad criteria and 

satisfy NEPA and other project development conditions. 

Page 19 GAO-09-784 Public Transportation
 

The linear, phased evaluation process of the New Starts program has 

historically hampered project sponsors’ ability to utilize alternative project 

delivery methods, such as design-build, according to project sponsors.29

These alternative project delivery methods have the potential to develop a 

project cheaper and quicker than traditional project delivery methods can. 

However, project sponsors told us it is difficult to attract private sector 

interest early enough in the project development process to use alternative 

project delivery methods because there is no guarantee that the project 

will ultimately receive federal funding through the New Starts program. 

The Deloitte study also noted that New Starts project sponsors miss the 

opportunity to use alternative project delivery methods because of the 

lack of early commitment of federal funding for the projects. To encourage 

the private sector involvement needed, project sponsors, consultants, and 

experts we interviewed suggested that FTA use letters of intent, which are 

nonbinding agreements, or early system work agreements, which are 

binding agreements. Through a letter of intent, FTA announces its 

intention to obligate an amount from future available budget authority to a 

project. According to private sector entities we interviewed, such an 

intended obligation sends a signal of federal support for a project and, 

therefore, attaches more certainty to the project. A challenge of using 

letters of intent is that they can be misinterpreted as an obligation of 

federal funds, when in fact they only signal FTA’s intention to obligate 

future funds should the project meet all New Starts criteria and 

requirements, and budget authority is available. In addition, because FTA 

reserves, or sets aside, commitment authority, or contract authority,30

when it issues letters of intent, issuing more such letters would reduce the 

availability of this authority at a faster pace than issuing more early 

systems work agreements. Letters of intent cover the project’s full federal 

share and, while early systems work agreements actually obligate federal 

funds, they obligate only a portion of a project’s federal share. As such, it 

Consider Greater Use of 

Letters of Intent and Early 

Systems Work Agreements 

 

29Design-build is a project delivery approach where, in contrast to the design-bid-build 

approach that FTA’s project evaluation process is aligned with, the design and construction 

are contracted out to a single entity. This approach is used to minimize the project risk for 

an owner and to reduce the delivery schedule by overlapping the design phase and 

construction phase of a project. Design-bid-build is a project delivery approach in which 

the agency or owner (e.g., transit operator) contracts with separate entities for the design 

and construction of a project. 

30Contract authority is budget authority that permits an agency to incur obligations in 

advance of appropriations, including collections sufficient to liquidate the obligation or 

receipts. Contract authority is unfunded, and a subsequent appropriation or offsetting 

collection is needed to liquidate the obligations. GAO, A Glossary of Terms Used in the 

Federal Budget Process, GAO-05-734SP (Washington, D.C.: September 2005). 

Page 20 GAO-09-784 Public Transportation
 

is possible that, with more frequent use of letters of intent, FTA’s 

commitment authority could be depleted earlier than expected, which 

could affect the anticipated funding stream for future projects. Finally, 

another challenge of using an early systems work agreement is that the 

law specifies that FTA can only enter into this type of agreement with a 

project if a Record of Decision under NEPA has been issued, and the 

Secretary finds that a FFGA for the project will be made and the terms of 

the agreement will promote ultimate completion of the project more 

rapidly and at less cost, thus limiting FTA’s ability to use these 

agreements. 

Tailor the New Starts 

Evaluation Process to 

Risks Posed by the 

Projects 

Project sponsors, consultants, and experts we interviewed suggested that 

FTA adopt a more risk-based evaluation process for New Starts projects 

based on a project’s cost or complexity, the federal share of the project’s 

cost, or the project sponsor’s New Starts experience. For example, FTA 

could align the level of oversight with the proposed federal share of the 

project—that is, the greater the financial exposure for the federal 

government, the greater the level of oversight. This was employed with the 

creation of the Small Starts program, which is intended to provide a more 

streamlined process for smaller and less costly projects. Similarly, FTA 

could reduce or eliminate certain reviews for project sponsors who have 

successfully developed New Starts projects in the past, while applying 

greater oversight to project sponsors who have no experience with the 

New Starts project development process. We have noted the value in using 

risk-based approaches to oversight. For example, we have previously 

reported that assessing risks can help agencies allocate finite resources 

and help policymakers make informed decisions.31 By adopting a more 

risk-based approach, based on, for example, project sponsor experience, 

project scope, total project cost, or federal share of the cost, FTA could 

allow select projects to move more quickly through the New Starts project 

development process and more efficiently use its scarce resources. 

However, a trade-off of not applying all evaluation measures to every 

project is that FTA could miss the opportunity to detect problems early in 

the project’s development. Further, this practice may move FTA away 

from their stated management objective of treating “all projects equitably 

across the U.S.” 

 

31GAO, Highlights of a Forum Convened by the Comptroller General of the United States: 

Strengthening the Use of Risk Management Principles in Homeland Security, 

GAO-08-627SP (Washington, D.C.: April 2008). 

Page 21 GAO-09-784 Public Transportation
 

Project sponsors said that FTA should more consistently use road maps or 

similar tools to define the project sponsor’s and FTA’s expectations and 

responsibilities for moving the project forward. Without establishing these 

expectations, project sponsors have historically had little information 

about how long it will take FTA to review, for example, their request to 

move from alternatives analysis to preliminary engineering. This lack of 

information makes it difficult for the project sponsor to effectively manage 

the project. Additionally, FTA previously identified an “adequate schedule” 

as a key factor of successful project implementation. Given the benefits of 

clearly setting these expectations, Deloitte recommended that FTA use 

road maps for all projects. The Deloitte study also observed that project 

sponsors would like to see FTA use more project development 

agreements, or similar vehicles, early in the development process because 

they help clarify expectations on both sides.32

Consistently Use Project 

Development Tools 

The following project development tools could increase the transparency 

of and help project sponsors navigate the New Starts project development 

process: 

• Road maps or similar project schedules: FTA has used road maps for 

select projects, but the agency does not consistently use them for all 

projects. According to FTA, the agency is currently working with project 

sponsors to establish road maps for all projects. However, according to 

some project sponsors, a limitation of using road maps is that expected 

time frames are subject to change—that is, project schedules often change 

as a project evolves throughout the development process. Furthermore, 

every project is unique, making it difficult to set a realistic time frame for 

each phase of development. Consequently, the road maps can provide only 

rough estimates of expected time frames. 

• Project development agreements (PDA): FTA has used project 

development agreements, on a limited basis, to help streamline the New 

 

32FTA included a provision for project development agreements in its Notice of Proposed 

Rulemaking issued in August, 2007, which proposed mandatory execution of project 

development agreements before projects could be accepted into preliminary engineering. 

However, the notice was withdrawn in February, 2009 after FTA determined withdrawal 

was “warranted due to an intervening statutory change.” That change was the June 2008 

SAFETEA-LU Technical Corrections Act, which required FTA to “give comparable, but not 

necessarily equal, numerical weight to each project justification criteria in calculating the 

overall project rating” for both New Starts and Small Starts projects. In withdrawing the 

notice, FTA wrote that those revisions would require such a fundamental change to how 

FTA weighs the criteria that a new approach to rulemaking for the New Starts and Small 

Starts programs was required. 

Page 22 GAO-09-784 Public Transportation
 

Starts project development process. PDAs require project sponsors and 

FTA to agree on three components: a delivery schedule, a review of key 

project development deliverables, and clear expectations from both sides 

for demonstrating project development progress, so that each would be 

held accountable for the advancement of a project. However, an FTA 

official stated that there are differences of opinion inside FTA as to the 

relative efficacy of road maps versus project development agreements. In 

addition, FTA told us that, as legal documents, PDAs take so long to 

negotiate with project sponsors that they may not offer a streamlining 

advantage. Because of that, some FTA staff members have stated a 

preference for road maps over PDAs and, as an alternative to PDAs, are 

currently using the informal road maps described above to establish 

milestones and timelines. 

Apply Policy and Guidance 

Changes Only to Future 

Projects 

Project sponsors told us that the frequent policy and guidance changes to 

the New Starts program can result in additional costs and delays as project 

sponsors are required to redo analyses to reflect the changes. In May 2006, 

FTA modified its policy so that a project that has been approved for entry 

into final design would no longer be subject to changes in New Starts 

policy and guidance.33 However, this policy change does not apply to 

projects approved for entry into preliminary engineering, which is the New 

Starts project development phase that has the most requirements for 

project sponsors and the phase where project sponsors told us that 

frequent changes result in additional costs and delays. For example, 

sponsor officials for one project told us that shortly after they submitted 

their preliminary engineering approval materials to FTA, FTA established 

a new, internal rule that required a risk assessment to take place prior to 

FTA’s approval to enter preliminary engineering, instead of during 

preliminary engineering. To protect the development schedule, the 

officials asked for, but were denied, approval for the project to proceed 

under the existing guidance that placed risk assessment activities during 

preliminary engineering, or at least to perform the risk assessment 

concurrently with preliminary engineering approval to maintain the 

schedule. The sponsor said the overall effect of the change was a delay of 

the preliminary engineering approval by about 4 months. According to 

FTA officials, FTA typically allows “grace periods” when implementing 

major policy changes to provide sponsors stability and time to adapt to 

 

33This policy would not exempt a project from new statutory or regulatory guidelines, as it 

is outside FTA’s authority to do so. 

Page 23 GAO-09-784 Public Transportation
 

those changes. Furthermore, another project sponsor noted that new 

requirements can prolong project development because each element of a 

proposed project is interrelated, so changing one requirement can stop 

momentum on a project. To avoid this rework, some project sponsors, 

consultants, and experts we interviewed suggested that FTA apply 

changes only to future projects, not projects currently in preliminary 

engineering. However, by not applying changes to projects in preliminary 

engineering, FTA could miss the opportunity to enhance its oversight of 

these projects. Also, applying changes to some projects but not to others 

would require FTA staff to create and apply multiple sets of rules to the 

project management process, which could create an administrative burden 

and move away from a consistent evaluation process. 

Revise the Internal Review 

Process and the Use of 

Project Management 

Oversight Contractors 

Project sponsors told us that FTA could minimize delays due to the 

stop/start nature of the development process by an adjustment to FTA 

staffing or contractor support levels to allow for multiple, simultaneous 

reviews of sponsors’ projects, and could reduce uncertainty by changing 

the way the agency selects and trains oversight contractors. Consultants 

and sponsors told us that FTA’s “first-in, first-out” approach to the review 

process, while not agency policy, sometimes can result in FTA reviewing 

only one project at a time, in the order they arrive. FTA told us this 

happens occasionally because of overlapping demands placed on 

oversight contractors, who are not able to perform simultaneous reviews. 

As a result, the development of low-risk projects is often prolonged if they 

happen to sit in the queue behind more complex projects that were 

submitted earlier. The Deloitte study recommended, and consultants and a 

sponsor we interviewed agreed, that FTA could adjust its process or 

staffing, as needed, to enable multiple reviews to be conducted in parallel. 

In addition, sponsors and consultants we interviewed told us some of 

FTA’s PMOCs have little experience with New Starts or Small Starts 

projects, leaving them uncertain about FTA requirements. As a 

consequence, inexperienced PMOCs sometimes provide inconsistent 

guidance, resulting in sponsors having to re-do work, adding time to the 

development process. To reduce the PMOC’s uncertainties about FTA’s 

requirements, FTA could provide them with additional training, especially 

when regulatory and administrative requirements change. FTA could also 

streamline the process by using staff, instead of contractors, to oversee 

project sponsors. Since staff possesses more institutional knowledge, they 

would provide sponsors more certain guidance. However, shifting more 

oversight work inside FTA would add to the scope and complexity of 

FTA’s work and could, therefore, create staffing challenges. 

Page 24 GAO-09-784 Public Transportation
 

FTA’s New Starts program is often cited as a model for other federal 

transportation programs. FTA’s recommendations for funding are based 

on a rigorous examination of proposed projects, and Congress has 

generally followed FTA’s funding recommendations. However, there is 

concern among some Members of Congress and the transit industry about 

the project development process, namely that it has become too time 

consuming, costly, and complex. 

Despite congressional and FTA actions to streamline the New Starts 

project development process, it continues to be viewed as time consuming 

and lengthy. However, the specific areas of concern that lead to delays, are 

difficult to determine because of a paucity of information about the time it 

has taken projects to move through the New Starts process. Moreover, this 

lack of adequate data makes it difficult for Congress and FTA to assess the 

extent to which federal efforts designed to expedite the New Starts 

process are succeeding. Although each project is unique, providing this 

information could also help set general expectations about the length of 

the process for potential project sponsors. While FTA has taken some 

steps to improve its data collection and retention, additional work is 

needed. As stewards of the New Starts program, which provides millions 

of dollars to local communities for transit projects each year, it is FTA’s 

responsibility to ensure that program changes are based on accurate and 

reliable information. 

Through our interviews with project sponsors, transit industry 

consultants, and transportation experts, as well as our review of existing 

research, we identified a number of potential options to expedite project 

development within the New Starts program. However, FTA must also 

strike the appropriate balance between expediting project development 

and maintaining the rigor and accountability of the New Starts program. 

As FTA works to develop its proposal for the New Starts program for the 

upcoming surface transportation reauthorization, considering the 

advantages and disadvantages of these options, including any potential 

trade-offs, could help FTA select any options that expedite the process 

while maintaining the rigorous oversight of the process. It is important 

that the length of project development within New Starts program does 

not serve as a deterrent as more communities turn to transit to solve their 

transportation challenges. 

To improve the New Starts program, we recommend that the Secretary of 

Transportation direct the FTA Administrator to take the following two 

actions: 

Conclusions 

Recommendations for 

Executive Action 

Page 25 GAO-09-784 Public Transportation
 

• continue to improve data collection and retention for statutorily defined 

milestones and determine if additional data would help to better describe 

the time it takes for a project to move through the New Starts process. In 

doing so, FTA should establish mechanisms to ensure the accuracy of the 

data and routinely analyze the data in order to identify the length of time it 

takes projects to move through each phase, potential causes for perceived 

delays, and potential solutions. FTA should make its analysis available to 

Congress and other interested parties. 

• analyze the streamlining options identified in this report, along with any 

additional options, to determine which options, if any, to implement—

seeking legislative change if necessary—to expedite the project 

development within the New Starts program. 

We provided the DOT, including FTA, with a draft copy of this report for 

review and comment. In e-mail comments, DOT agreed with our 

recommendation to consider options to expedite project development, 

noting that the options we identified to help expedite project development 

within the New Starts program are consistent with the options that FTA 

has been discussing with transit stakeholders and congressional staff. 

However, DOT disagreed with our recommendation on data, as originally 

drafted, because it did not recognize FTA’s ongoing efforts to improve its 

data collection. In addition, in its comments, FTA acknowledged that there 

are always opportunities to improve various aspects of the program, 

including some of the data collection efforts discussed in this report, but 

noted that the agency has maintained, and has access to, the information 

necessary to effectively track active projects and review progress through 

milestones for past projects. Furthermore, FTA expressed concern that 

the report uses a standard for data management that is neither intended 

nor necessary for effective project management. FTA officials also stated 

that, even with the most comprehensive milestone data, each project 

represents a unique set of challenges that will impact the time it takes for a 

project to pass through the New Starts process. More broadly, FTA 

officials stated that they use milestone data to manage the program and 

make changes to improve the program. 

Agency Comments 

and Our Evaluation 

To address these comments, we incorporated additional information about 

FTA’s ongoing efforts to strengthen its data management process in the 

report. We also revised in the report the recommendation on data 

collection to reflect FTA’s ongoing work while still emphasizing the need 

to improve the agency’s milestone data collection and retention, including 

the reliability and accuracy of the data. In addition, we agree that each 

Page 26 GAO-09-784 Public Transportation
 

New Starts project represents a unique set of circumstances that will 

affect the time it takes to pass through FTA decision phases and further 

recognized this fact in the report. However, we disagree with the assertion 

that we hold this information to a standard neither intended nor necessary 

for effective program management. An effective system of internal 

controls requires that managers have relevant and reliable information to 

better achieve agencies’ missions and program results. As we note in the 

report, FTA project milestone data are unreliable and, in some cases, 

inaccurate, which can jeopardize effective program management. We and 

others have recognized FTA’s New Starts process as providing a sound, 

rigorous and systematic process for identifying projects worthy of federal 

discretionary funding for major transit investments, and analysis based on 

reliable data will only help strengthen FTA’s management of the program. 

We, therefore, believe that this recommendation, as revised, is valid. 

DOT also provided technical clarifications, which we incorporated as 

appropriate. 

We are sending copies of this report to appropriate congressional 

committees and DOT. The report also is available at no charge on the GAO 

Web site at http://www.gao.gov. 

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

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

Congressional Relations and Public Affairs may be found on the last page 

Susan A. Fleming 

of this report. Key contributors to this report are listed in appendix IV. 

Director, Physical Infrastructure Issues 

Page 27 GAO-09-784 Public Transportation
Appendix I: Ad

Billi

Starts, Small St

Projects 

ministration Requests $1.83 

on in Fiscal Year 2010 Funding for New 

arts, and Very Small Starts 

Page 28 GAO-09-784 

Appendix I: Administration Requests $1.83 

Billion in Fiscal Year 2010 Funding for New 

Starts, Small Starts, and Very Small Starts 

Projects 

FTA Evaluated and Rated 

14 New Starts Projects and 

Recommended 5 New 

Projects for Funding in 

Fiscal Year 2010 

The Federal Transit Administration evaluated and rated 14 New Starts 

projects in preliminary engineering and final design during the fiscal year 

2010 cycle. FTA also reviewed the progress but did not rate 5 projects that 

are statutorily exempt from being rated.1

 (See table 4 for a full list of these 

projects.) 

Table 1: New Starts Projects Evaluated and Rated for Fiscal Year 2010 by Phase of New Starts Process 

Dollars in millions 

Project name Location Total capital cost

Federal share of 

capital cost 

Overall project 

rating 

Final design 

New Britain—Hartford Busway Hartford, Conn. $569.3 48% Medium 

Urban Transitway 

Phase II 

Stamford, Conn. $48.3 51% Exempt 

Wilmington to Newark Commuter 

Rail Improvements 

Wilmington, Del. $78.4 32% Exempt 

Central Florida Commuter Rail 

Transit—Initial Operating Segmenta

Orlando, Fla. $357.2 50% Medium 

Access to the Region’s CorebNorthern New Jersey $8,700.0 34% Medium-high 

South County Commuter Rail Providence, R.I. $49.2 51% Exempt 

Preliminary engineering 

Modern StreetcarcTucson, Ariz. $150.1 17% Exempt 

South Corridor Phase 2a Sacramento, Calif. $270.0 50% Medium 

Central Subway LRT San Francisco, Calif. $1,298.0 59% Medium-high 

East CorridorcDenver, Colo. $2,043.8 39% Medium 

Gold LinecDenver, Colo. $859.5 28% Medium 

Orange Line Phase 2: North Corridor 

Metrorail Extension 

Miami, Fla. $1,504.7 47% Medium-low 

Assembly Square StationcBoston, Mass. $47.7 52% Exempt 

Silver Line Phase III Boston, Mass. $2,106.5 60% Medium-low 

Central Corridor LRT St. Paul-Minneapolis, 

Minn. 

$914.9 50% Medium-high 

Northeast Corridor Light Rail Project Charlotte, N.C. $749 50% Medium-high 

 

1

Projects requesting less than $25 million in New Starts funding were not evaluated and 

rated during the fiscal year 2010 cycle because under 49 U.S.C. §5309(e)(1)(B) they are 

exempt from the New Starts evaluation and rating process until such time as a final 

regulation implementing certain provisions of SAFETEA-LU is completed. 

Public Transportation 
Appendix I: Administration Requests $1.83 

Billion in Fiscal Year 2010 Funding for New 

Starts, Small Starts, and Very Small Starts 

Projects 

Dollars in millions 

Project name Location Total capital cost

Federal share of 

capital cost 

 Overall project 

rating 

Milwaukee LRTc

Portland, Ore. $1,471.7 50% Medium-high 

North Corridor LRTa, c Houston, Tex. $677.0 49% Medium 

Southeast Corridor LRTa, c Houston, Tex. $680.6 49% Medium 

Source: GAO summary of New Starts Annual Report on Funding Recommendations for Fiscal Year 2010. 

Note: Projects in this table are listed in alphabetic order by state. 

a

These projects have been recommended for full funding grant agreements and are in final design or 

expected to be approved into final design before the end of summer 2009, the environmental process 

has been completed, and any needed railroad agreements have been negotiated and are at or near 

completion. 

b

This project has been recommended for an early system work agreement. 

c

These projects have been approved into New Starts preliminary engineering since the publication of 

the fiscal year 2009 annual report. 

Of the 14 New Starts projects evaluated and rated during the fiscal year 

2010 cycle, FTA recommended five new projects for funding through full 

funding grant agreements (FFGA) or early system work agreements 

(ESWA) this year. In its annual report, FTA states that these projects 

recommended for funding are in final design or expected to be approved 

into final design before the end of summer 2009, the environmental 

process has been completed, and any needed railroad agreements have 

been negotiated and are at or near completion. For these projects, FTA 

recommends a total of $430 million in New Starts funding in fiscal year 

2010. The total capital cost of these projects is estimated to be 

approximately $11.14 billion. 

FTA also recommended, as part of the President’s budget request, 

reserving $81.79 million in New Starts funding for projects that may attain 

the FFGA milestone in the budget year but have not sufficiently 

progressed in project development for FTA to recommend them in the 

budget request. FTA has not specified which projects will be eligible for 

this funding or allocated a particular amount for any given project. 

According to the annual report and officials we spoke with at FTA, this 

approach will allow the agency to make “real time” funding 

recommendations as project uncertainties are mitigated, and Congress 

makes final appropriations decisions. FTA does not expect that all of the 

projects in preliminary engineering will advance to final design in fiscal 

year 2010. 

Page 29 GAO-09-784 Public Transportation
Appendix I: Administration Requests $1.83 

Billion in Fiscal Year 2010 Funding for New 

Starts, Small Starts, and Very Small Starts 

Projects 

FTA evaluated and rated 21 eligible Small Starts and Very Small Starts 

projects for the fiscal year 2010 cycle. These include 1 project with a 

pending project construction grant agreement,2

 16 projects that have 

demonstrated sufficient readiness to be considered for funding in the 

fiscal year 2010 President’s budget request, and 4 projects that have not 

yet demonstrated readiness to be considered for funding.3

 (See table 5 for 

a full list of these projects.) FTA recommends a total of $174.27 million in 

funding for Small Starts, including Very Small Starts, projects. The total 

capital cost of the 16 projects that FTA recommended for funding is 

estimated to be $895.11 million. Most of these projects are proposed to be 

funded under a multiyear PCGA. However, if a project requests less than 

$25 million in Small Starts funding or has received its full appropriations, 

FTA will award funds in a single-year capital grant rather than a PCGA. 

FTA Evaluated and Rated 

21 Small Starts and Very 

Small Starts Projects and 

Recommended Funding 

for 16 Projects 

Table 2: Small Starts and Very Small Starts Projects Evaluated and Rated for Fiscal Year 2010 

Dollars in millions 

Project name Location Total capital cost

Federal share 

of capital cost

Overall project 

rating 

Type of 

project 

Mountain Links BRTaFlagstaff, Ariz. $10.4 60% Medium Very Small 

Starts 

Livermore-Amador Route 10 

BRTa

Livermore, Calif. $21.7 50% Medium Very Small 

Starts 

Metro Rapid Bus System Gap 

Closurea

Los Angeles, Calif. $34.5 48% Medium-high Very Small 

Starts 

Wilshire Boulevard Bus-Only 

Lanea

Los Angeles, Calif. $31.5 74% Medium Very Small 

Starts 

Monterey Bay Rapid Transita, bMonterey, Calif. $3.5 80% Medium Very Small 

Starts 

East Bay BRTb Oakland, Calif. $234.6 32% High Small Starts 

Perris Valley Linea Riverside, Calif. $168.9 44% Medium-high Small Starts 

 

2

Financial assistance for construction of Small Starts projected is provided through a 

PCGA, which are similar to FFGAs and are negotiated during project development. 

3

In the fiscal year 2010 New Starts annual report, FTA recommends a Small Starts project, 

Portland Streetcar Loop, for a PCGA even though it received a low cost-effectiveness 

rating. According to an FTA official we spoke with, FTA is advancing the project for 

funding because it meets all the statutory criteria. The official also noted that the policy 

instituted in 2005 that all projects receive a medium cost-effectiveness rating before they 

are recommended for funding was an “administrative requirement” of the previous 

administration, and the new administration believes that the Portland project is worth 

funding given its other predicted benefits. 

Page 30 GAO-09-784 Public Transportation
Appendix I: Administration Requests $1.83 

Billion in Fiscal Year 2010 Funding for New 

Starts, Small Starts, and Very Small Starts 

Projects 

Dollars in millions 

Project name Location Total capital cost

Federal share 

of capital cost

Overall project 

rating 

Type of 

project 

E Street Corridor sbX BRTa

San Bernardino, Calif. $163.4 46% Medium Small Starts 

Mid-City RapidaSan Diego, Calif. $43.3 50% Medium-high Very Small 

Starts 

Van Ness Avenue BRT San Francisco, Calif. $118.2 63% Medium-high Small Starts 

Metro Express—Airport Way 

Corridor BRTa, b

San Joaquin, Calif. $9.7 29% Medium-high Very Small 

Starts 

Mason Corridor BRTaFort Collins, Colo. $82.0 80% Medium Small Starts 

BRT Projectab Roaring Fork Valley, 

Colo. 

$46.4 56% Medium-high Very Small 

Starts 

Commuter Rail ImprovementsaFitchburg, Mass. $150.0 50% Medium-high Small Starts 

Division Avenue BRT Grand Rapids, Mich. $36.7 80% Medium Very Small 

Starts 

Troost Corridor BRTaKansas City, Mo. $30.7 80% Medium Very Small 

Starts 

Nostrand Avenue BRTbNew York City, N.Y. $88.3 21% High Small Starts 

Streetcar LoopcPortland, Ore. $126.9 59% Medium Small Starts 

MetroRapid BRTa, b Austin, Tex. $47.0 80% Medium Very Small 

Starts 

Bellevue-Redmond BRTa King County, Wash. $27.0 75% Medium Very Small 

Starts 

Pacific Highway South BRTa King County, Wash. $25.1 56% Medium Very Small 

Starts 

Source: GAO summary of New Starts Annual Report on Funding Recommendations for Fiscal Year 2010. 

Note: Projects in this table are listed in alphabetic order by state. 

a

These projects have been recommended for funding in fiscal year 2010. 

b

These projects have been approved into Small Starts Project Development since the publication of 

the fiscal year 2009 report. 

c

This project has a pending PCGA. The fiscal year 2009 annual report recommended the Portland 

Streetcar Loop project for funding but noted that while it did receive an overall rating of medium it did 

not achieve a Medium rating for cost effectiveness. As the project meets all the statutory criteria, FTA 

is advancing the project for funding. 

FTA’s Fiscal Year 2010 

Budget Proposal 

Recommends $1.83 Billion 

for the New Starts 

Program 

The administration’s fiscal year 2010 budget proposal recommends that 

$1.83 billion be made available for the New Starts program. This amount is 

$81.093 million more than the program’s fiscal year 2009 appropriation. 

Figure 4 illustrates the planned uses of the administration’s proposed 

request for the New Starts fiscal year 2010 budget, including the following: 

• $1,123.03 million would be allocated among the 19 projects with existing 

FFGAs, 

Page 31 GAO-09-784 Public Transportation
Appendix I: Administration Requests $1.83 

Billion in Fiscal Year 2010 Funding for New 

Starts, Small Starts, and Very Small Starts 

Projects 

• $430.0 million would be allocated among the 5 projects newly 

recommended for funding through FFGAs or ESWAs, 

• $81.79 million would be allocated to projects that may attain the FFGA 

milestone in the budget year but have not sufficiently progressed for FTA 

to recommend them in the budget request, 

• $174.25 million would be allocated among the 16 Small Starts projects 

newly recommended for funding, and 

• $18.27 million for management and oversight activities. 

Figure 4: Allocation of FTA’s Recommended Fiscal Year 2010 Budget for New Starts 

Note: FTA is authorized to use up to 1 percent of amounts made available for the New Starts program 

for project management and oversight activities. 

5%

23%

10%

61%

Source: GAO analysis of FTA data.

1%

Management and oversight activities,

$18.27 million

Small Starts projects,

$174.25 million 

Possible FFGAs,

$81.79 million 

New FFGA and ESWA,

$430.0 million

Existing FFGAs,

$1,123.03 million

Recovery Act Funding 

Allowed FTA to Accelerate 

Payments to Projects with 

FFGAs 

The American Recovery and Reinvestment Act (Recovery Act) provided 

FTA with over $740 million in funding for the New Starts program. This 

funding for surface transportation projects allowed FTA to accelerate 

payments to transit projects with existing FFGAs and PCGAs. FTA 

distributed Recovery Act funding to 11 projects in construction with fiscal 

Page 32 GAO-09-784 Public Transportation
Appendix I: Administration Requests $1.83 

Billion in Fiscal Year 2010 Funding for New 

Starts, Small Starts, and Very Small Starts 

Projects 

year 2010 commitments. More specifically, FTA distributed at least 40 

percent of each project’s scheduled fiscal year 2010 payment in Recovery 

Act funding. According to FTA, 5 projects with demonstrated cash flow 

needs that exceeded this distribution received additional funding. This 

funding will not require amendments or significant changes to any FFGAs 

because the overall federal share of the total project costs did not change. 

FTA Has About $879 

Million Remaining in 

SAFETEA-LU Contingent 

Commitment Authority 

The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A 

Legacy for Users Act (SAFETEA-LU), like the Transportation Equity Act 

for the 21st Century, allowed FTA to make contingent commitments for 

funding to projects beyond what is authorized in law, subject to future 

authorizations and appropriations.4

 According to FTA, SAFETEA-LU and 

the Recovery Act gave FTA a total contingent commitment authority of 

$14.37 billion, of which $12.684 billion has been committed through FFGAs 

and preliminary engineering and final design activities for projects through 

fiscal year 2009. 

FTA officials said that the agency has approximately $879 million 

remaining in contingent commitment authority after consideration of fiscal 

year 2010 funding recommendations. FTA officials also told us that they 

need additional authority for commitment beyond fiscal year 2010 because 

FTA is not permitted to spend money beyond its authorized level. FTA 

officials noted that the available level of contingent commitment authority 

did not influence their fiscal year 2010 recommendations. Further, they 

stated that they were able to recommend all of the projects deemed ready 

for funding because of the additional Recovery Act funding. 

 

4

See Pub. L. No. 109-59, § 3011(g)(2)(B)(i), 119 Stat. 1144, 1580 (2005), codified at 49 U.S.C. 

§ 5309(g)(2)(B)(ii). This contingent commitment authority is designed to allow FTA to 

execute grant agreements that extend beyond SAFETEA-LU’s 5-year period. 

Page 33 GAO-09-784 Public Transportation
Appendix II: Scope and Methodology Appendix II: Scope and Methodology 

To evaluate the time it has generally taken for projects to move through 

the New Starts process we collected and attempted to verify FTA data on 

New Starts projects that have advanced through the New Starts process 

and received FFGAs after June 1997 to determine the length of time each 

project spent in each stage of the process. However, we found this data to 

be unreliable based on our reviews of FTA files on a random sample of 10 

projects’ milestone dates. We also attempted to collect data from project 

sponsors to establish how long it has taken projects to move through the 

New Starts process. We contacted each project sponsor and requested 

seven milestone dates from alternatives analysis through FFGA. We 

received verifiable data for 30 of the 40 projects approved into a FFGA 

since June 1997. However, of the 30 projects, we received complete sets of 

milestone data for 9 projects. Due to the number of projects with complete 

data, the data from these 9 projects are not generalizeable to the 40 New 

Starts projects. The verifiable data included the dated letters the project 

sponsors sent to or received from FTA. The data for the beginning of 

alternatives analysis are based on several documents, including local 

government board meeting minutes that record a decision for the locality 

to begin alternatives analysis. We also examined the 2007 Deloitte 

Development, LLC, report on FTA’s New Starts process and interviewed 

the project leader for this study to obtain information on the time it takes 

for New Starts projects to move through the process. 

To determine the steps Congress and FTA have taken to expedite the New 

Starts process, we reviewed documents including our reports on the New 

Starts program, federal legislation such as SAFETEA-LU, as well as other 

applicable New Starts requirements, and FTA New Starts policy guidance. 

In addition, we interviewed FTA officials and attended the American 

Public Transportation Association’s March 11, 2009, legislative conference, 

at which FTA gave a presentation on the New Starts and Small Starts 

programs, to obtain information on steps taken by Congress and FTA to 

expedite the New Starts process. 

To assess the options that exist to expedite the process, we collected and 

analyzed information from relevant reports. In particular, we examined the 

recommendations from the 2007 Deloitte Development, LLC, report on 

FTA’s New Starts process and the American Pubic Transportation 

Association’s October 2008 report on transportation authorizing law. We 

interviewed FTA officials, transportation experts and consultants, industry 

groups, and project sponsors that chose not to enter the New Starts 

pipeline to identify factors contributing to New Starts project timeline 

challenges, as well as actions FTA and Congress have taken to expedite 

the New Starts process. We also interviewed these officials to identify 

Page 34 GAO-09-784 Public Transportation 
Appendix II: Scope and Methodology 

additional changes that could streamline the project development process, 

as well as the advantages and disadvantages. 

Additionally, we interviewed 9 project sponsors about 10 projects, 

including those currently in the New Starts pipeline and those under a 

FFGA, about their experiences with and perceptions of the New Starts 

process. For each of these projects we interviewed the relevant project 

sponsor or contractor, as well as FTA officials with experience evaluating 

and overseeing the project. We selected these projects based on the 

following criteria: (1) timing (i.e., when projects received a FFGA); 

(2) mode (e.g., rail, light rail, or bus); (3) scope (i.e., the total cost of the 

project); and (4) projects from different geographic areas. Because the 

projects were selected as a nonprobability sample, the results cannot be 

generalized to all projects.1

 Table 3 lists the New Starts and Small Starts 

project sponsors we interviewed for our review. 

Table 3: New Starts and Small Starts Project Sponsors Interviewed 

Name of project sponsor Location Project type 

AC Transit Oakland, Calif. Small Starts 

Charlotte Area Transit System Charlotte, N.C. New Starts 

City of Fort Collins Fort Collins, Colo. Small Starts 

Connecticut Department of Transportation Hartford, Conn. New Starts 

Metropolitan Council St. Paul, Minn. New Starts 

Metropolitan Transportation Authority New York City, N.Y. New Starts 

Metropolitan Washington Airports Authority Northern Virginia New Starts 

Tri-County Metropolitan Transportation 

District of Oregon 

Portland, Ore. New Starts 

Utah Transit Authority Salt Lake City, Utah New Starts 

Source: GAO. 

To describe the New Starts and Small Starts projects evaluated, rated, and 

recommended for funding in fiscal year 2010 by FTA, we reviewed FTA’s 

Annual Report on New Starts for Fiscal Year 2010 and interviewed FTA 

officials. We spoke to the FTA officials about the number of projects 

evaluated, rated, and recommended for funding, the amount of funding 

 

1

Results from nonprobability samples cannot be used to make inferences about a 

population because in a nonprobability sample some elements of the population being 

studied have no chance or an unknown chance of being selected as part of the sample. 

Page 35 GAO-09-784 Public Transportation
Appendix II: Scope and Methodology 

requested for these projects, the total costs of proposed projects, as well 

as how FTA allocated its Recovery Act funding.2

 

2

American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, title XII, 123 Stat. 

115, 209-211. 

Page 36 GAO-09-784 Public Transportation
Appendix III: Timeline Data on New Starts 

Projects That We Collected from Project 

Sponsors, by Mode 

Beginning 

alternatives 

analysis 

Request 

entry 

preliminary 

engineering 

Approval 

into 

preliminary 

engineering 

Request 

entry final 

design 

Approval 

into final 

design 

Request full 

funding 

grant 

agreement 

Approval 

funding 

grant 

agreement Mode 

Central Light rail 

Double Track Project 

(Md.) 

Jan. 1999 Aug. 2000 July 2001 Light rail 

CTA Ravenswood 

Line Extension (Ill.) 

Apr. 2002 Aug. 2002 Jan. 2003 Jan. 2004 Heavy rail 

Dulles Corridor 

Metrorail Project—

Extension to Wiehle 

Ave. (Va.)a

Aug. 2003 June 2004 Sept. 2007 May 2008 Oct. 2008 Mar. 2009 Heavy rail 

Eastside Corridor 

LRT Project (Calif.) 

June 1999 July 2000 Oct. 2000 May 2002 Oct. 2002 May 2003 June 2004 Light rail 

Euclid Corridor 

Transportation 

Project (Ohio) 

Mar. 1993 Sept. 1996 Dec. 2001 July 2002 Sept. 2002 Oct. 2004 Bus 

Hiawatha Avenue 

Corridor (Minn.) 

Sept. 1999 Apr. 2000 June 2000 Nov. 2000 Light rail 

Hudson Bergen 

Light rail Transit 

System (N.J.) 

Oct. 2000 Light rail 

Interstate Max 

Project: North/South 

Corridor (Ore.)a

Apr. 1993 Oct. 1999 Feb. 2000 Sept. 2000 Light rail 

Largo Town Center 

Metrorail Extension 

(D.C.) 

July 1997 July 2000 May 2000 Dec. 2000 Heavy rail 

Medical Center Rail 

Extension (Tenn.) 

Oct. 1997 Apr. 1998 Dec. 1999 May 2000 Dec. 2000 Light rail 

Metra North Central 

Service 

Improvements (Ill.) 

Apr. 1997 Dec. 1997 Jan. 1999 May 2000 Oct. 2000 Mar. 2001 Nov. 2001 Commuter 

rail 

Metra South West 

Service 

Improvements and 

Extension (Ill.) 

Apr. 1997 Dec. 1997 Jan. 1999 Oct. 2000 Jan. 2001 Mar. 2001 Nov. 2001 Commuter 

rail 

Metra Union Pacific 

West Line 

Extension/Central 

Kane (Ill.) 

Apr. 1997 Dec. 1997 Jan. 1999 Aug. 2000 Jan. 2001 Mar. 2001 Nov. 2001 Commuter 

rail 

MTA Long Island rail 

Road East Side 

Access (N.Y.)a

Feb. 2002 June 2006 Commuter 

rail 

Appendix III: Timeline Data on New Starts 

Projects That We Collected from Project 

Sponsors, by Mode 

Page 37 GAO-09-784 Public Transportation 
Appendix III: Timeline Data on New Starts 

Projects That We Collected from Project 

Sponsors, by Mode 

Beginning 

alternatives 

analysis 

Request 

entry 

preliminary 

engineering 

Approval 

into 

preliminary 

engineering 

Request 

entry final 

design 

Approval 

into final 

design 

Request full 

funding 

grant 

agreement 

Approval 

funding 

grant 

agreement Mode 

Newark Elizabeth 

rail Link (N.J.) 

Aug. 2000 Light rail 

North Shore Light 

rail Transit 

Connector (Pa.) 

Jan. 1999 Sept. 2000 Sept. 2002 Apr. 2003 Jan. 2006 Sept. 2006 Light rail 

Norfolk Light rail 

Transit Project (Va.) 

Sept. 1993 Aug. 2002 Nov. 2002 Nov. 2005 Sept. 2006 Feb. 2007 Oct. 2007 Light rail 

Northstar Corridor 

rail Project (Minn.)a

Mar. 2000 June 2000 June 2001 Sept. 2006 June 2007 Dec. 2007 Commuter 

rail 

Oceanside 

Escondido rail 

Project (Calif.) 

June 1997 Jan. 1998 Nov. 1999 Mar. 2000 Apr. 2002 Feb. 2003 Light rail 

Rehabilitate CTA 

Douglas Branch (Ill.) 

Feb. 2000 June 2000 Dec. 2000 Jan. 2001 Heavy rail 

San Francisco 

Airport Extension 

(Calif.) 

June 1990 Aug. 1992 Oct. 1992 Mar. 1996 June 1997 Heavy rail 

Second Avenue 

Subway (N.Y.)a

Dec. 2001 Mar. 2006 Apr. 2006 Nov. 2007 Heavy rail 

South Corridor I-205/ 

Portland Mall Light 

rail Project (Ore.)a

Apr. 1993 Aug. 2003 Mar. 2004 Apr. 2005 Oct. 2005 Mar. 2006 June 2007 Light rail 

South Corridor LRT, 

(N.C.)a

Dec. 1997 June 2000 Sept. 2000 May 2003 Light rail 

Southeast Corridor 

Light rail (T-Rex) 

(Colo.) 

Apr. 1995 Nov. 1997 Feb. 1998 Apr. 2000 May 2000 Oct. 2000 Nov. 2000 Light rail 

South Florida 

Double Track 

Corridor 

Improvement 

Program (Fla.) 

Nov. 1999 Apr. 2004 Commuter 

rail 

Stage II LRT (Pa.) Dec. 1995 Feb. 1996 Apr. 2000 Jan. 2001 Light rail 

University Link LRT 

(Wash.) 

Apr. 2001 Aug. 2005 Dec. 2005 May 2006 Dec. 2006 Jan. 2008 Jan. 2009 Light rail 

Wilsonville to 

Beaverton 

Commuter rail 

Project (Ore.)a

May 2002 May 2004 Oct. 2006 Commuter 

rail 

West Corridor Light 

rail (Colo.) 

Apr. 1995 Dec. 2000 Mar. 2001 June 2005 Aug. 2005 June 2008 Jan. 2009 Light rail 

Source: GAO analysis of project sponsor documents. 

Page 38 GAO-09-784 Public Transportation
Appendix III: Timeline Data on New Starts 

Projects That We Collected from Project 

Sponsors, by Mode 

a

Designates projects whose sponsors we interviewed, and from whom we collected data. 

Note: The data in this table are based on dated letters the project sponsors sent to or received from 

FTA. The data for the beginning of alternatives analysis is based on several different kinds of 

documents, including Environmental Impact Statements and local government board meeting minutes 

that record a decision for the locality to begin alternatives analysis or major investment study. 

Page 39 GAO-09-784 Public Transportation
Appendix IV: 

A

GAO Contact and Staff 

cknowledgments 

Page 40 GAO-09-784 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

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

In addition to the individual named above, A. Nicole Clowers, Acting 

Director; Kyle Browning; Lauren Calhoun; Gary Guggolz; Brandon Haller; 

and Carrie Wilks made key contributions to this report. 

Public Transportation 

GAO Contact 

Staff 

Acknowledgments 

(541051) 
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