GAO 

United States Government Accountability Office

Report to the Ranking Member,

Committee on Environment and Public 

Works, U.S. Senate 

METROPOLITAN 

PLANNING 

ORGANIZATIONS 

Options Exist to 

Enhance 

Transportation 

Planning Capacity and 

Federal Oversight 

September 2009 

GAO-09-868 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

September 2009

METROPOLITAN PLANNING ORGANIZATIONS

Options Exist to Enhance Transportation Planning

Capacity and Federal Oversight 

Highlights of GAO-09-868, a report to the 

Ranking Member, Committee on 

Environment and Public Works, U.S. 

Senate 

Metropolitan planning 

organizations (MPO) are 

responsible for transportation 

planning in metropolitan areas; 

however, little is known about 

what has been achieved by the 

planning efforts. This 

congressionally requested report 

describes (1) the characteristics 

and responsibilities of MPOs, (2) 

the challenges that MPOs face in 

carrying out their responsibilities, 

(3) how the U.S. Department of 

Transportation (DOT) provides 

oversight for MPOs and the extent 

to which this improves 

transportation planning, and (4) the 

options that have been proposed to 

enhance transportation planning. 

To address these objectives, GAO 

surveyed all 381 MPOs (with an 86 

percent response rate) and 

conducted case studies of eight 

metropolitan areas and conducted 

a survey of program managers. 

What GAO Recommends

GAO suggests that Congress 

consider making MPO 

transportation planning more 

performance based by, for example, 

identifying specific transportation 

outcomes for transportation 

planning and charging DOT with 

assessing MPOs’ progress in 

achieving these outcomes in the 

certification review process. GAO 

also recommends, among other 

things, that DOT develop a strategy 

to improve data gathering and 

modeling at the MPO level. DOT 

agreed to consider the report’s 

recommendations. 

MPOs vary greatly in terms of capacity and responsibilities. Some MPOs are 

supported by one or two staff, while others have over 100 staff. While half of 

MPOs represent populations of less than 200,000, some represent millions. 

MPOs are typically housed within a regional planning council or a city or 

county government agency, but also may operate as independent agencies. 

Most MPOs receive the majority of their planning funds from federal sources, 

but also receive funds from other sources such as states or localities. The 

technical capacity of MPOs also varies significantly, both in terms of the type 

of model used to develop travel demand forecasts and the number of staff 

available to perform such forecasts. Some MPOs have acquired additional 

responsibilities, such as project implementation, beyond federal requirements.

MPOs cited many challenges in our survey and interviews, primarily related to 

funding and staffing, authority, and technical capacity. About 85 percent of all 

MPOs responding to our survey cited the lack of transportation planning 

funding as a challenge to transportation planning. About half of our survey 

respondents stated that the lack of flexibility for using federal planning funds 

inhibits them from conducting comprehensive transportation planning. 

Staffing constraints, such as limited number of staff and lack of trained staff, 

also impact MPOs’ ability to conduct transportation planning. Finally, 

according to our survey and interviews, some MPOs lack the technical 

capacity and data necessary to conduct the type of complex transportation 

modeling required to meet their planning needs. 

DOT’s Federal Transit Administration (FTA) and Federal Highway 

Administration (FHWA) work together to oversee MPOs, but given the 

process-oriented approach of the oversight, it is difficult to determine whether 

their oversight is improving transportation planning. MPOs representing more 

than 200,000 in population are subject to federal certification reviews. The 

certification reviews focus on procedural compliance with planning 

requirements, not transportation outcomes. MPOs generally view this federal 

process as pro forma in nature and place a greater value on informal 

assistance provided by both federal and state governments. 

Several proposals have been developed by government and industry 

associations that could address some of the resource, authority, and technical 

challenges facing MPOs. For example, 

• allowing the use of transportation planning funds for more activities could 

better meet the needs of some metropolitan areas; 

• varying MPOs’ planning requirements and authority or changing the legal 

definition of MPOs could address varying capacity and planning needs; 

• increasing federal investment in modeling and data gathering could 

improve the technical capability of MPOs and bring a greater degree of 

reliability and consistency across MPOs to travel demand forecasting; and

• making the planning process more performance-based could allow FTA 

and FHWA to better assess MPOs’ progress in achieving specific results.

View GAO-09-868 or key components.

For more information, contact Phillip R. Herr 

at (202) 512-2834 or herrp@gao.gov. To view 

the e-supplement online, click on 

GAO-09-867SP. 
Page i GAO-09-868 

Contents 

Letter 1

Background 3 

MPOs Vary Considerably in Terms of Capacity, Responsibilities, 

and Range of Activities 11 

MPOs Face Resource, Authority, and Technical Challenges That 

Impact Their Ability to Conduct Transportation Planning 16 

The Extent to Which MPO Oversight Mechanisms Improve 

Transportation Planning Is Unclear 22 

MPO, Government, and Industry Officials Have Developed Options 

to Enhance Transportation Planning 24 

Conclusions 29 

Matter for Congressional Consideration 30 

Recommendations 30 

Agency Comments 31 

Appendix I Scope and Methodology 32 

Appendix II GAO Contact and Staff Acknowledgments 35 

Tables 

Table 1: Mean and Median Number of Staff at MPOs 12 

Table 2: Metropolitan Regions Selected for Case Study 34 

Figures 

Figure 1: Number of MPOs by Population Represented 5 

Figure 2: Transportation Planning Processes 7 

Figure 3: Apportionments of FHWA and FTA Metropolitan 

Planning Funds, Fiscal Year 1996 through Fiscal Year 2009 10 

 Metropolitan Planning Organizations 
Abbreviations 

3-C continuing, cooperative, and comprehensive 

AASHTO American Association of State Highway and 

 Transportation Officials 

AMPO Association of Metropolitan Planning Organizations 

APTA American Public Transportation Association 

CMAQ Congestion Mitigation and Air Quality Improvement 

 Program 

CMP Congestion Management Process 

DOT Department of Transportation 

FHWA Federal Highway Administration 

FTA Federal Transit Administration 

MPO Metropolitan Planning Organization 

SAFETEA-LU Safe, Accountable, Flexible, Efficient 

 Transportation Equity Act: A Legacy for Users 

STIP Statewide Transportation Improvement Program 

TIP Transportation Improvement Program 

TMA Transportation Management Area 

TRB Transportation Research Board 

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Page ii GAO-09-868 Metropolitan Planning Organizations
Page 1 GAO-09-868 

 

United States Government Accountability Office

Washington, DC 20548 

 

September 9, 2009 

The Honorable James Inhofe 

Ranking Member 

Committee on Environment and Public Works 

United States Senate 

Dear Senator Inhofe: 

Metropolitan areas are the centers of much social and economic activity in 

the United States. The largest 100 of these areas house more than 65 

percent of our population and produce 75 percent of our national 

economic output. They are also where most seaport tonnage arrives and 

departs, transit miles are ridden, and rail and air passengers board. 

However, the productivity of these economic centers, and as a result the 

economic vitality of the United States, is being threatened by a number of 

transportation challenges, such as increasing levels of congestion. These 

challenges are significantly affected by decisions on how federal 

transportation funds are invested and these decisions are shaped by the 

transportation planning efforts undertaken by the 381 metropolitan 

planning organizations (MPO). 

To encourage the development of efficient and effective transportation 

systems, the Federal-Aid Highway Act of 1962 required urban 

transportation planning as a condition for receiving federal-aid 

transportation funds in urban areas. The act also provided funding for 

regional transportation planning. To reflect the growing sense that local 

elected officials and citizens should be given a larger role in this regional 

transportation decision-making process, the Federal-Aid Highway Act of 

1973 required the designation of MPOs in urban areas with populations of 

more than 50,000 people to carry out a continuing, cooperative, and 

comprehensive (3-C) planning process. Recognizing the importance of 

metropolitan areas and the need to fully integrate these areas into 

transportation investment decisions, the Intermodal Surface 

Transportation Efficiency Act of 19911

 devolved greater responsibility for 

planning and implementation of transportation projects to MPOs. 

Subsequently, in 2005, the Safe, Accountable, Flexible, Efficient 

Transportation Equity Act: A Legacy for Users (SAFETEA-LU), the current 

1

Pub. L. No. 102-240. 

 Metropolitan Planning Organizations 
 

surface transportation program authorization act, added additional 

transportation planning requirements to MPOs’ responsibilities, while also 

providing additional time for MPOs to make updates to their plans and 

programs and increasing federal funding to MPOs to respond to such 

responsibilities.2

 Little is known, though, about what has been achieved by 

the federal government’s investment in metropolitan transportation 

planning. As the September 2009 expiration of SAFETEA-LU approaches, 

more complete information on the effectiveness of MPOs’ transportation 

planning activities is needed, especially in light of government and 

industry associations’ proposals for increasing or modifying MPOs’ 

authority, responsibilities, and funding. Accordingly, you asked us to 

examine (1) the characteristics and responsibilities of MPOs; (2) the 

challenges that MPOs face in carrying out their responsibilities; (3) how 

the U.S. Department of Transportation (DOT) provides oversight for MPOs 

and the extent to which this improves transportation planning; and (4) the 

options that have been proposed to enhance transportation planning. 

To address these objectives, we reviewed existing legislation, regulations, 

and program guidance concerning MPOs’ transportation planning 

responsibilities and the federal certification process; reviewed proposals 

to change or reform current MPO planning responsibilities; interviewed 

Federal Transit Administration (FTA) and Federal Highway 

Administration (FHWA) officials and representatives from industry 

associations such as the Association of Metropolitan Planning 

Organizations and the Transportation Research Board (TRB), as well as 

state departments of transportation, to obtain their perspectives on MPOs’ 

planning activities, variations among MPOs, the federal certification 

process, and proposals to improve the current planning process. We also 

conducted case studies of eight MPOs in four states that we selected based 

on population and structure, among other things, which included 

reviewing the MPOs’ transportation plans and interviewing MPO officials, 

the state departments of transportation, the relevant FHWA division office 

and FTA regional office, transit agencies, and other regional associations. 

In addition, we observed an FHWA-FTA MPO certification review; and 

surveyed all 381 legally designated MPOs to gain information on their 

varying roles, responsibilities, capacity, the challenges they face in 

meeting their planning responsibilities, and options to improve the 

 

2

Pub. L. No. 109-59. 

Page 2 GAO-09-868 Metropolitan Planning Organizations
 

transportation planning process.3 The results of our survey can be found at 

GAO-09-867SP. To determine the various options to address MPOs’ 

challenges, we reviewed proposals from the Association of Metropolitan 

Planning Organizations (AMPO), the American Association of State 

Highway and Transportation officials (AASHTO), the American Public 

Transportation Association (APTA), the Brookings Institution, the 

previous and current DOT administrations, and the June 2009 House 

Transportation and Infrastructure Committee blueprint for the surface 

transportation reauthorization. We also discussed suggestions for 

improving the planning process with federal and state officials, as well as 

the eight MPOs we interviewed. 

For the purposes of this report, we refer to MPOs representing populations 

of less than 200,000 as “small MPOs,” MPOs representing populations 

between 200,000 and 1 million as “medium MPOs,” and MPOs representing 

populations above 1 million as “large MPOs.” Appendix I contains 

additional information about our scope and methodology. We conducted 

this performance audit from September 2008 to September 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. 

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

DOT agreed to consider our recommendations and provided technical 

comments which we incorporated into the report, as appropriate. 

MPOs, representing local governments and working in coordination with 

state departments of transportation and major providers of transportation 

services, have responsibility for the regional transportation planning 

Background 

 

3

To establish this list of MPOs, we obtained contact information from the U.S. Department 

of Transportation and the Association of Metropolitan Planning Organizations. Any 

inconsistencies between the two lists were reconciled with phone calls to the relevant MPO 

in January 2009. We received completed questionnaires from 328 (86 percent) of the MPOs. 

Nonresponding MPOs were distributed among different states and sizes of MPOs in a way 

that did not show evidence of bias. 

Page 3 GAO-09-868 Metropolitan Planning Organizations
 

processes in urbanized areas.4 (See figure 2 for a summary of these 

processes.) A core function of MPOs is to establish and manage a fair and 

impartial setting for effective transportation decision making in an 

urbanized area. To receive federal transportation funding, any project in 

an urbanized area must emerge from the relevant MPO and state 

department of transportation planning process. MPOs, which generally 

have a governing policy board consisting of local elected officials and 

appropriate state and public transportation officials, facilitate decision 

making on regional transportation issues including major capital 

investment projects and priorities. MPOs also generally have a technical 

advisory committee (including engineers, planners, and other local staff); 

citizen’s advisory committee; and additional committees, such as a bicycle 

and pedestrian committee or a freight advisory committee. MPO staff 

assist the MPO board by preparing documents, fostering interagency 

coordination, facilitating public input and feedback, and managing the 

planning process. Staff may also provide committees with technical 

assessments and evaluations of proposed transportation initiatives. 

Created to carry out a federally mandated transportation planning process, 

MPOs’ core membership is spelled out in law, but the organizational 

structure and staff arrangements were designed to be determined by 

agreement between local officials and the state. 

The size of the populations represented by individual MPOs varies. For 

instance, about 52 percent of the 381 MPOs represent populations of fewer 

than 200,000 people; 36 percent of MPOs represent populations of 200,000 

to 999,999 people; and 11 percent of MPOs represent populations of 1 

million or more people. However, the largest MPOs—those representing 

more than 1 million people—represent about 49 percent of the country. 

(See figure 1 for a summary of MPO sizes.) 

 

4

Planning organizations are not required for rural areas. As part of the statewide planning 

process, the state department of transportation consults with local officials in nonurban 

areas and determines the projects in those areas to which the state will direct resources. 

However, some states have Rural Planning Organizations to plan for the expenditure of 

federal and state transportation funds in their area. 

Page 4 GAO-09-868 Metropolitan Planning Organizations
 

Figure 1: Number of MPOs by Population Represented 

Note: Percentages do not add to 100 due to rounding. 

11%

52% 36%

Source: GAO analysis of Census data.

Small (population of 50,000-199,999)

199 MPOs

Medium (population of 200,000-999,999)

139 MPOs

Large (population of 1 million and above)

43 MPOs

All MPOs have the same basic planning requirements. Specifically, all 

MPOs are required to produce the following: 

• long-range (20-year) transportation plans;5

• short-range (4-year) Transportation Improvement Programs; 

• annual statements of planning priorities and activities (generally called a 

Unified Planning Work Program or UPWP); and 

• public participation plans.6

Transportation improvement programs (TIP), based on the long-range 

plan, should be designed to achieve the area’s transportation goals using 

spending, operating, management, and financial tools. The area’s 

transportation goals are determined by the MPO’s policy board, including 

 

5

These long-range plans are generally called metropolitan transportation plans. 

6

In providing interested parties “a reasonable opportunity to comment on the 

transportation plan,” 23 U.S.C. § 134(i)(5)(C) and 49 U.S.C. § 5303 (i)(5)(C) require an MPO 

“to the maximum extent practicable...hold any public meetings at convenient and 

accessible locations and times.” 

Page 5 GAO-09-868 Metropolitan Planning Organizations
 

representatives from relevant jurisdictions and transportation operators, 

through interactions between stakeholders and the public for the purpose 

of identifying visions for the community’s future. This process allows the 

region as a whole to determine how it should allocate its limited 

transportation resources among the various capital and operating needs of 

the area, based on local and regional priorities. Both the TIP and the longrange plan must be fiscally constrained—that is, the total estimated cost of 

the planned transportation improvements cannot exceed anticipated levels 

of funding.7

 MPOs must develop these plans and programs in cooperation 

with their state department of transportation as well as local transit 

operators, land-use entities, and environmental resource agencies.8

 Where 

they exist in their region, MPOs also consult with tribal governments, 

airports, Amtrak, or freight rail interests during the planning process. (See 

figure 2 for a summary of the role of the MPO, state, and federal 

government in developing the long-range plan and TIP.) 

 

7

The long-range plan and TIP must include information on how the MPO reasonably 

expects to fund the projects included in the plan, including anticipated revenues from 

FHWA and FTA, state government, regional or local sources, the private sector, and user 

charges. The long-range plan must also demonstrate that there is a balance between the 

expected revenue sources for transportation investments and the estimated costs of the 

projects and programs described in the plan. 

8

With respect to environmental resource agencies, SAFETEA-LU requires that long-range 

transportation plans be developed in consultation with state and local agencies responsible 

for land-use management, natural resources, environmental protection, conservation, and 

historic preservation, and that state conservation plans or maps and inventories of natural 

or historic resources be consulted, if available. 

Page 6 GAO-09-868 Metropolitan Planning Organizations
 

Figure 2: Transportation Planning Processes 

Long-range plansb

• Plan time frame: at least 20 years

• Updated every 4 years (MPOs) or 

as appropriate (states)

c

Metropolitan

planning

Statewide

planning

Federal Highway

Administration/

Federal Transit

Administration

Metropolitan transportation improvement program (TIP)

• Identifies proposed federally supported transportation 

projects or phases of a project 

• Financially constrained–includes a financial plan to 

demonstrate current and proposed revenue sources

• Identifies the criteria and process for prioritizing 

implementation of transportation plan elements

• MPOs and states approve the program

State transportation improvement program (STIP)

• Covers the MPO regions and all other state areas

• Contains descriptions of all capital and noncapital 

transportation projects, with some exceptions

• Financially constrained–demonstrates current and 

proposed federal, state, and local revenue sources

STIP approval

• Requires joint approval by FHWA/FTA at least 

once every 4 years

• Certifies that the transportation planning process

is carried out in accordance with applicable 

federal requirements

• MPO self-certification with each submission of the 

proposed TIP to FHWA/FTA as part of the STIP 

approval, at least once every 4 years

Metropolitan long-range transportation plan

• Identifies projected transportation demand and 

congestion management strategies

• Assesses capital investments and the existing 

transportation system 

• Reflects social, economic, environmental, and 

energy conservation goals and objectives

• Includes a financial plan to demonstrate revenue 

sources for transportation investments

Statewide long-range transportation plan

• Intermodal and statewide in scope

• Coordination with metropolitan long-range plans

• References planning studies and reports

significant to the development of the plan 

• Summarizes availability of financial and other 

resources needed to carry out the plan 

(optional)

MPO and state planning process certification

• State shall certify that the planning process is being 

carried out in accordance with all applicable 

requirements of 23 U.S.C. 134 and 135 at the time the 

entire proposed STIP is submitted to FHWA/FTA for 

approval, at least every 4 years

• FHWA/FTA conducts certification reviews for all MPOs

representing populations greater than 200,000 to 

ensure that the planning process is conducted in 

accordance with applicable federal requirements

Short-range programsa

 • Plan time frame: at least 4 years

 • Updated at least every 4 years

Source: GAO analysis of federal regulations governing metropolitan and statewide transportation planning.

a

Short-range programs, called Transportation Improvement Programs, are based on the long-range 

plan and are required to achieve the area’s transportation goals using spending, operating, 

management, and financial tools. 

b

Long-range plans, generally called Metropolitan Transportation Plans, are intended to foster mobility 

and access for people and goods, efficient transportation system performance and preservation, and 

good quality of life. 

Page 7 GAO-09-868 Metropolitan Planning Organizations
 

c

MPOs are required to review and update the transportation plan at least every 4 years in air quality 

nonattainment and maintenance areas and at least every 5 years in attainment areas. An air quality 

nonattainment area is a region that the Environmental Protection Agency has designated as not 

meeting federal air quality standards. An air quality maintenance area is a region previously 

designated nonattainment. 

Beyond the requirements common to all MPOs, some MPOs have 

additional planning requirements. For example, MPOs serving urbanized 

areas with populations of over 200,000 people, which are referred to as 

transportation management areas (TMA), are required to develop a 

Congestion Management Process (CMP) that identifies actions and 

strategies to reduce congestion.9

 In addition, MPOs containing areas that 

do not conform to federal air quality standards (i.e., nonattainment areas) 

or areas that have recently come into conformance with the standards 

(i.e., maintenance areas) are required to ensure that planned 

transportation improvements will not cause new air quality violations, 

worsen existing violations, or delay timely attainment of the standards. To 

ensure that such plans will not negatively affect regional air quality, MPOs 

must conduct what is termed “conformity analysis” for proposed 

transportation improvements.10

To create these transportation plans and programs, MPOs consider a 

variety of factors, including local travel forecasts and federal 

considerations. For example, MPOs forecast future travel with the 

assistance of computerized travel-demand models. These models provide 

information on how urban growth and proposed facility and operational 

investments will affect the operation of the transportation system. Such 

models are complex and require as inputs extensive current information 

on roadway and transit system characteristics and operations, as well as 

current and forecast demographic information. Creating and operating the 

 

9

The CMP is a process for monitoring transportation system performance that involves data 

collection, performance measurement and monitoring, and the identification of strategies 

and projects to manage congestion. 

10This transportation conformity analysis requires MPOs to use forecasts for their longrange plan to estimate traffic volumes and speeds, which become inputs to the 

Environmental Protection Agency’s (EPA) MOBILE model. That model, in turn, provides 

estimates of future motor vehicle source emissions. These emissions estimates are used to 

determine whether the proposed transportation plan and programs will result in motor 

vehicle emission levels that conform to those established in state air quality plans and 

approved by EPA. Under federal conformity requirements, if the estimated emissions that 

result from future vehicle travel exceed budgets established in the state implementation 

plan, which is required by EPA, and transportation conformity cannot be determined, 

projects and programs must be delayed, except for projects determined to be exempt from 

air quality conformity. 

Page 8 GAO-09-868 Metropolitan Planning Organizations
 

models requires a high degree of technical training and expertise. 

Additionally, when developing these plans and programs, MPOs must 

consider specific statutorily defined planning factors. These factors 

require that the metropolitan planning process provide for consideration 

of projects and strategies that will 

• support the economic vitality of the metropolitan area, especially by 

enabling global competitiveness, productivity, and efficiency; 

• increase the safety of the transportation system for motorized and 

nonmotorized users; 

• increase the security of the transportation system for motorized and 

nonmotorized users; 

• increase the accessibility and mobility of people and freight; 

• protect and enhance the environment, promote energy conservation, 

improve the quality of life, and promote consistency between 

transportation improvements and state and local planned growth and 

economic development patterns; 

• enhance the integration and connectivity of the transportation system, 

across and between modes, for people and freight; 

• promote efficient system management and operation; and 

• emphasize the preservation of the existing transportation system. 

To carry out this regional planning process, 1.25 percent of federal-aid 

highway funding from the Interstate Maintenance, National Highway 

System, Bridge, Surface Transportation Program, and Congestion 

Mitigation and Air Quality (CMAQ) programs is apportioned to the states 

as metropolitan planning funds. 

Federal legislation has maintained, and periodically increased, the funding 

for MPO activities over time. (See figure 3.) These federal funds are 

distributed to states based on population. Generally states then provide 

each of their MPOs with baseline funding and distribute any remaining 

balance according to a formula. While the states can use a range of factors 

in their formulas, such as congestion levels, they are required to take 

population into account. Federal planning dollars must also be matched by 

state and local governments. Specifically, state and local governments 

must provide at least 20 percent of metropolitan planning funds, although 

Page 9 GAO-09-868 Metropolitan Planning Organizations
 

some state and local governments have to provide more than 20 percent in 

funding to perform all of their necessary planning activities. 

Figure 3: Apportionments of FHWA and FTA Metropolitan Planning Funds, Fiscal Year 1996 through Fiscal Year 2009 

Dollars (in millions)

Fiscal year

FTA

FHWA

Source: U.S. Department of Transportation.

0

50

100

150

200

250

300

350

400

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Federal and state governments oversee this regional planning process. At 

the federal level, FTA and FHWA work together to perform federal 

certification reviews—certifying that each TMA has carried out its 

planning according to the applicable federal statutes. More specifically, 

the certification review requires that the federal government assess TMAs 

every 4 years to determine how well they are working with the 

transportation-related organizations, local governments, public 

transportation operators, and citizens in their area, as well as with the 

state departments of transportation, to meet the many statutory and 

regulatory requirements applicable to the planning process. Additionally, 

the certification review assesses the quality of the required planning 

documents. The certification review includes a desk review of the MPO’s 

plans and a site visit, among other things. Additionally, all MPOs, including 

both TMAs and non-TMAs, must also self-certify that their planning 

process meets the federal requirements. States also participate in the 

regional planning process by, for example, reviewing and approving the 

MPO’s TIP. If the state approves the TIP, the state must incorporate the 

Page 10 GAO-09-868 Metropolitan Planning Organizations
 

TIP, without change, into the statewide transportation improvement 

program (STIP).11 If the state does not approve the TIP, the MPO and the 

projects included in the TIP are not eligible for federal funding. This 

requirement compels states to coordinate with MPOs and vice versa. 

MPOs Vary 

Considerably in Terms 

of Capacity, 

Responsibilities, and 

Range of Activities 

The Staffing, Financial, 

and Technical Capacity of 

MPOs Varies Significantly 

The staff size and structure of MPOs vary significantly. Some MPOs are 

supported by one or two staff, while a few have over 100 full or part-time 

staff. Most MPOs have a relatively small staff, with a median of four fulltime staff per MPO, based on our survey. (See table 1 for a summary of the 

number of staff by size of MPO.) The type and structure of the 

organizations housing MPOs also vary across the country. The structure of 

an MPO is determined by agreement between relevant local governments 

and the state, and therefore the extent to which these local governments 

or other regional organizations support MPO activities varies. These 

organizations can support MPOs by housing staff within their organization, 

which can include providing the personnel and facilities necessary for 

MPO activities. Some MPOs are housed and staffed by a local jurisdiction 

(such as a city or county government) within its boundaries, others by a 

regional planning council, and still others operate independently. 

According to our survey respondents, 71 percent of MPOs are a part of 

agencies such as regional councils and city, county, or state governments. 

Eighteen percent of MPOs report that they operate independently.12

 

11The STIP is similar to the TIP in that it identifies 4 years of transportation project 

priorities and must be fiscally constrained. STIPs must be approved by both FHWA and 

FTA. 

12Eleven percent of survey respondents specified “other” as the MPO structure. 

Page 11 GAO-09-868 Metropolitan Planning Organizations
 

Table 1: Mean and Median Number of Staff at MPOs 

MPO size 

Mean 

number of 

full-time 

staff

Mean 

number of 

part-time 

staff 

Median 

number of 

full-time staff

Median 

number of 

part-time 

staff

Small 

(population of less than 

200,000) 3.19 1.43 2.00 1.00

Medium 

(population of 200,000-

999,999) 8.19 1.50 7.00 1.00

Large 

(population of 1 million and 

above) 49.27 3.90 31.00 1.00

All MPOs 10.96 1.77 4.00 1.00

Source: GAO analysis of MPO survey responses. 

Beyond their staff and structure, MPOs also vary in terms of their funding 

sources and amounts. Federal planning funds—FHWA PL funds and FTA 

Section 5303 funds—generally make up a large portion of the MPO budget 

for conducting necessary studies and developing transportation plans, 

programs, and other documents. According to our survey respondents, 

about 80 percent of MPOs receive a majority of their planning funds from 

these federal sources. The amount of matching funds provided by state 

and local sources also varies considerably by MPO. For example, officials 

from one state department of transportation we spoke to said that the 

small MPOs receive considerably more than the required 20 percent of 

state and local matching funds for transportation planning. Officials from 

another state told us that although they only receive the required 20 

percent match, they also provide technical support to some MPOs. In 

addition to federal planning funds and the required state and local match, 

some MPOs receive and use other funds, such as dedicated local taxes and 

transit fare box revenue. Finally, according to FTA, while most federal 

transit funds designated for urban areas are apportioned directly from 

FTA to the transit operator, some funds are apportioned to MPOs, which 

then allocate those funds themselves.13

The technical capacity of MPOs to develop travel demand forecasts—a 

crucial component of the long-range plans—also varies. Some MPOs—

about 45 percent of all our survey respondents—use their own models to 

 

13Transit funds for rural areas are administered by the state department of transportation. 

Page 12 GAO-09-868 Metropolitan Planning Organizations
 

develop most, if not all, of their forecasts, while 51 percent rely on 

consultants or their state department of transportation to conduct their 

modeling. Small MPOs are less likely to conduct their own travel demand 

forecasts, with only 30 percent reporting that they have their own 

modeling, according to our survey. Further, the federal government gives 

local transportation planning agencies, including MPOs, the flexibility to 

choose their own transportation models without being subject to 

minimum standards or guidelines. As a result, the type of model used by 

MPOs also varies. Of the MPOs that reported in our survey that they use a 

model to conduct their travel demand forecasts, a large majority said that 

they use a four-step model, which uses survey and other data to estimate 

future trips and assign those trips to different modes. Seven survey 

respondents indicated that they use activity-based models, which are tied 

more closely to household and traveler characteristics and behavior and 

therefore should, in concept, permit MPOs to address policy questions that 

cannot be treated with the conventional four-step models. For example, 

four-step models are not suited to estimating the emissions effects of small 

transportation projects or linking these effects to air quality; more 

advanced modeling techniques, such as activity-based models, are needed 

to estimate such effects. The Transportation Research Board (TRB) also 

noted that although the four-step process is common, there are 

considerable variations in the completeness and complexity of the models 

and data employed.14 Further, they reported that MPOs vary significantly 

in the number of staff devoted to travel forecasting. 

 

The Responsibilities and 

Activities of Some MPOs 

Have Expanded beyond 

Transportation Planning 

Through our survey and interviews, we also found that many MPOs have 

additional responsibilities that are not federally required, many of which 

extend beyond transportation planning. For some MPOs, these additional 

responsibilities and activities are required by their state, while other MPOs 

have taken on these responsibilities over time, based on regional needs. 

• Land-use planning. According to our survey respondents, many MPOs 

conduct all or a portion of their region’s land-use planning, and for some 

14TRB, Metropolitan Travel Forecasting: Current Practice and Future Direction, Special 

Report 288 (2007). TRB is one of six major divisions of the National Research Council— a 

private, nonprofit institution that is the principal operating agency of the National 

Academies in providing services to the government, the public, and the scientific and 

engineering communities. TRB provides leadership in transportation innovation and 

progress through research and information exchange, conducted within a setting that is 

objective, interdisciplinary, and multimodal. 

Page 13 GAO-09-868 Metropolitan Planning Organizations
 

this is a state requirement. Specifically, 70 percent of MPOs have some 

land-use planning responsibilities, with the larger MPOs generally 

reporting that they have more of these planning responsibilities than small 

MPOs. Eleven percent of survey respondents specifically said that their 

land-use responsibilities are required by their state. In practice, some 

MPOs integrate land-use planning into their transportation planning 

process by considering potential land-use scenarios along with proposed 

projects. Some MPOs have also led public processes to develop an 

integrated transportation and land-use “vision” for a region and to evaluate 

future transportation and land-use scenarios. Similarly, for a number of 

MPOs, various forms of land-use models are now part of the process for 

analyzing the growth of the region and studying the land-use impacts of 

alternative transportation investment programs. Generally, though, MPOs 

do not have authority to make land-use decisions. Rather, local 

jurisdictions typically have the authority to make such zoning and other 

decisions. 

• Project selection. By determining which projects are to be included in 

TIPs, all MPOs have a role in determining which projects will ultimately be 

funded. However, only certain MPOs have the authority to select—from a 

list of projects in an approved TIP—which projects are to be implemented 

in the most immediate time frame, using federal funds available to a 

metropolitan planning area. In areas designated as TMAs, the MPO, in 

consultation with the state and public transportation operators, selects 

from an approved TIP all projects that are to be implemented using 

funding under Title 23 or under Chapter 53 of Title 49 of the U.S. Code 

(excluding projects on the National Highway System and projects funded 

under the Bridge, Interstate Maintenance, and Federal Lands Highway 

programs). Furthermore, MPOs in air quality nonattainment areas also 

have the ability to use CMAQ funds.15 Additionally, in California, regional 

organizations have project selection authority for 75 percent of their 

region’s portion of the state’s TIP funds (which includes both federal and 

state highway money). 

 

15The CMAQ program, jointly administered by the FHWA and FTA, provides funds to state 

departments of transportation, MPOs, and transit agencies to invest in projects that reduce 

criteria air pollutants regulated from transportation-related sources over a period of 5 

years. Funding is available for areas that do not meet federal air quality standards 

(nonattainment areas), as well as former nonattainment areas that are now in compliance 

(maintenance areas). The formula for distribution of funds—which considers an area’s 

population by county and the severity of its ozone and carbon monoxide problems within 

the nonattainment or maintenance area, with greater weight given to areas that are both 

carbon monoxide and ozone nonattainment and maintenance areas—is continued. 

Page 14 GAO-09-868 Metropolitan Planning Organizations
 

• Project implementation. Some MPOs also have the responsibility for 

implementing transportation projects. Generally, MPOs do not take the 

lead in implementing transportation projects; rather, they play a 

coordinating role in planning and programming funds for projects and 

operations. Usually, local jurisdictions, transit operators, or state 

governments take the lead in implementing projects. However, 37 percent 

of survey respondents—representing MPOs of all sizes—said that they 

implement projects. For example, one large MPO we spoke with utilizes its 

local, state, and federal funds to implement projects by leveraging this 

money with regional partners to construct large-scale transportation 

projects. Toward this end, the MPO established a program aimed at 

quickly reducing congestion in particular areas. This initiative uses smallscale projects, such as traffic signal optimization, for congested 

corridors—which can be implemented within 2 years and are largely 

funded and carried out by the MPO. 

• Transit operations. Sixteen percent of MPOs responded in our survey 

that they have some responsibility for operating all or a portion of their 

regional transit system. For example, one western MPO is both the transit 

authority—providing mass transit that connects throughout the region—

and the transportation-planning agency for the greater metropolitan area. 

Another MPO noted in our survey that rather than operating the transit 

system, it serves as the planning staff for both the region’s MPO and the 

transit agency. 

• Environmental planning. Twenty-one percent of MPOs responding to 

our survey said that they conduct air quality or emissions analysis, beyond 

the federally required conformity process. Further, 32 percent of MPOs 

responding to our survey said that they conduct additional environmental 

or water quality planning. For example, one state we visited requires its 

MPOs to consider how their long-range transportation plan increases 

water and energy conservation and efficiency. 

Page 15 GAO-09-868 Metropolitan Planning Organizations
 

MPOs Face Resource, 

Authority, and 

Technical Challenges 

That Impact Their 

Ability to Conduct 

Transportation 

Planning 

MPOs Report Funding and 

Staffing Limitations 

MPOs we surveyed and interviewed cited several funding challenges that 

impact their ability to conduct transportation planning. About 85 percent 

of all MPOs responding to our survey cited the lack of transportation 

planning funding as a challenge to transportation planning.16 MPOs we 

surveyed and interviewed also cited challenges related to the lack of 

flexibility of transportation planning funds. Specifically, about half of all 

MPOs responding to our survey cited the lack of flexibility of funding as a 

challenge. While FTA allows planning funds to be used for a broad range 

of planning activities, FHWA is more prescriptive in how planning funds 

can be spent. For example, FHWA guidance precludes using planning 

funds for projects’ environmental analyses that definitively go beyond 

transportation planning.17 Furthermore, officials at a few MPOs we spoke 

with stated that it is unclear which activities can be undertaken with 

planning funds, particularly in terms of the FHWA planning funds, and that 

such definitions inhibit them from conducting comprehensive planning by 

not allowing them to use transportation planning dollars for other uses 

where necessary. DOT officials we spoke with agreed that the eligibility 

for FHWA planning funds is fairly narrow, but noted that Surface 

 

16For questions where we asked about the challenges that MPOs face, we used a five-point 

scale to measure the extent of the challenge: very great challenge, great challenge, 

moderate challenge, some or little challenge, and no challenge. For the purposes of this 

report, we combined the responses for moderate challenge, great challenge, and very great 

challenge to describe the challenges MPOs identified. 

17Specifically, under 23 CFR Part 420 FHWA funding programs, once a general travel 

corridor or specific project has progressed to a point in the preliminary/engineering 

National Environmental Policy Act phase that clearly extends beyond transportation 

planning, additional in-depth environmental studies must be funded through the program 

category for which the ultimate project qualifies (e.g., National Highway System, Interstate 

Maintenance, or Bridge Programs), rather than metropolitan planning or statewide 

planning and research funds. 

Page 16 GAO-09-868 Metropolitan Planning Organizations
 

Transportation Program funds can be used for metropolitan planning and 

are more flexible. 

MPOs also cited a few other funding-related challenges. First, many MPOs 

reported having difficulty securing local matching funds for federal 

transportation planning dollars. About 66 percent of survey respondents 

overall cited this as a challenge. For example, one MPO we spoke with has 

been unable to utilize all of the federal planning funds it has been allocated 

because the MPO cannot meet its local matching requirements. As a result, 

the MPO has not been able to hire needed staff. Second, MPOs also had 

mixed opinions regarding the fiscal constraint requirement—that MPOs 

develop plans that correspond to reliable revenue projections. About 84 

percent of survey respondents cited the fiscal constraint requirement as a 

challenge. One MPO official told us that this is a challenge because the 

MPO has to submit its TIP without full knowledge of the state’s available 

funding; this makes creating a realistic fiscally constrained TIP difficult. A 

previous GAO report found similar concerns. In particular, for MPOs in 

some urban areas, financially constraining the transportation 

improvement program meant abandoning proposed projects because of a 

lack of projected revenue.18 Although developing a fiscally constrained 

plan can be difficult, we have also previously reported that the fiscal 

constraint requirement has been largely beneficial to the planning process 

because it has led MPOs to obtain more reliable revenue projections from 

state departments of transportation and transit agencies and to exclude 

those projects that could not be financed within budget constraints. Third, 

beyond funding challenges related to planning, officials at a few small 

MPOs we spoke with often stated that their region had insufficient funding 

to keep pace with the transportation projects needed. In fact, at one small 

MPO, an official estimated that the region received about 10 percent of the 

funding needed to construct necessary projects. This lack of funding could 

potentially limit the effectiveness of MPO planning because fewer projects 

from the TIP can be implemented. 

MPOs also cited staffing constraints, to a lesser extent, as a challenge that 

impacts their ability to conduct transportation planning. Some MPOs 

stated that staffing affects their ability to fulfill its planning requirements. 

For example, one small MPO told us that with only one or two staff 

members, it is very difficult to satisfy all the federal requirements for 

 

18GAO, Urban Transportation: Metropolitan Planning Organizations’ Efforts to Meet 

Federal Planning Requirements, GAO/RCED-96-200 (Washington, D.C.: Sept. 17, 1996). 

Page 17 GAO-09-868 Metropolitan Planning Organizations
 

MPOs such as creating and updating the TIP and long-range plan and 

holding public meetings. MPOs also mentioned a lack of trained staff as a 

challenge to transportation planning. About half of the survey respondents 

cited lack of trained staff as a challenge in carrying out the federal 

requirements for transportation planning. Lack of trained staff is also a 

challenge for small MPOs, according to our survey. For example, officials 

from several MPOs stated that retaining staff trained to conduct the travel 

forecasting is difficult because there are few people with the expertise to 

conduct such technical analyses and consulting firms can often pay 

modelers a higher salary than an MPO. In addition, officials from one MPO 

told us that the challenges of having limited staff resources is compounded 

by requirements to ensure public participation, noting that much of their 

time is spent carrying out the public participation requirements for the 

planning process relative to other activities. Concerns about meeting the 

public participation requirements were consistent across most of the 

MPOs we surveyed. In particular, 79 percent of survey respondents stated 

that they have difficulty obtaining the public participation needed to meet 

their transportation planning requirements. A few MPOs we interviewed 

stated that it was difficult to generate public participation in the planning 

process, in part because few people actually understand what an MPO is 

or what it does. 

Most MPOs function as part of another planning or governing body, such 

as a council of governments. According to a few MPOs we interviewed, 

this arrangement can address staffing and funding limitations by allowing 

an MPO the ability to cut costs by sharing resources such as a space in 

which to operate and, in some cases, facilitates coordination between the 

MPO and other planners or transportation stakeholders. However, this 

arrangement can also create some challenges. In particular, a few MPOs 

housed within city governments or other entities connected with a specific 

jurisdiction said that this arrangement causes them to be viewed as less 

impartial than MPOs that are stand-alone entities, and that these 

perceptions can affect their consensus-building efforts. Additionally, 71 

percent of small MPO survey respondents cited competing priorities 

between transportation planning and other tasks related to the council of 

governments as a challenge. 

Most MPOs Report That 

Limitations to Their 

Authority Presents 

Challenges 

MPOs we surveyed and interviewed also cited the lack of authority as a 

challenge to effective transportation planning. About 80 percent of all 

MPOs responding to our survey indicated that the lack of authority to 

implement the plans they develop is a challenge. The majority of MPOs 

that responded to our survey do not implement any of the projects 

Page 18 GAO-09-868 Metropolitan Planning Organizations
 

contained in the plans that they create. Rather, they rely on other agents 

such as cities, counties, and state departments of transportation to carry 

out their plans. Similarly, although many survey respondents reported that 

they conduct land-use planning for their region, MPOs generally lack the 

authority to make land-use decisions. Instead, this authority generally 

rests with state and local jurisdictions. As a result, MPOs indicated that 

they have difficulty anticipating and integrating land-use decisions into 

their transportation planning.19 For example, in one region we visited, 

local jurisdictions are often reluctant to make land-use planning decision

in-line with the MPO’s regional transportation plan. In part, the official 

stated that this occurs because local jurisdictions have a difficult time 

making land-use decisions that benefit the region as a whole as opposed to 

their individual community. If land-use decisions do not correspond wit

an MPO’s plans, the MPO’s proposed transportation improvements may 

not be as effective. Our past work has documented that integrating landuse and transportation investments—including accurately modeling futu

land-use changes—is important but challenging.

s 

h 

re 

 

20

MPOs we interviewed also cited their lack of authority in determining 

which projects will be implemented as a challenge. Although MPOs help 

determine which projects are eligible for funding and which ones have 

priority through the development of the TIP, whether a project will be 

funded and the amount of funds made available for the project are 

determined by federal, state, and local policymakers. Moreover, according 

to our survey, the availability of funding and public support are more 

important drivers of transportation investment decisions than the analysis 

conducted by MPOs. This is consistent with our previous work regarding 

transportation decision making, which indicated that even when economic 

analyses are performed, the results are not necessarily the most important 

factor considered in terms of which projects to fund; rather, a number of 

factors, such as public support or the availability of funding, drive 

transportation investment decisions.21

19Current transportation demand models are also unable to predict the effect of a 

transportation investment on land-use patterns and development. 

20GAO, Highway and Transit Investments: Options for Improving Information on 

Projects’ Benefits and Costs and Increasing Accountability for Results, GAO-05-172

(Washington, D.C.: Jan. 24, 2005). 

21GAO-05-172. 

Page 19 GAO-09-868 Metropolitan Planning Organizations
 

Although MPOs in the survey cited lack of authority as a challenge, the 

MPOs we interviewed had mixed opinions regarding the extent to which 

they felt being granted additional authority would improve transportation 

planning. Some of the MPOs we spoke with emphasized that having 

project implementation and land-use decision-making authority would 

improve transportation planning. For example, one large MPO told us that 

although they have developed a close working relationship over the years 

with transit operators and other transportation stakeholders to make their 

planning processes successful, they need land-use authority to more 

comprehensively address critical transportation issues. Another MPO we 

interviewed, however, suggested that giving MPOs project implementation 

or land-use authority may not improve transportation planning. 

Specifically, one MPO official stated that such additional authorities may 

actually hamper MPOs’ ability to conduct transportation planning, since 

some of their current ability to generate consensus results from the fact 

that they do not have a stake in building or operating the transportation 

plans. 

Lack of Technical Capacity 

Makes It Difficult for 

MPOs to Meet Increasingly 

Complex Requirements 

MPOs also face technical challenges, in part because the travel demand 

modeling required to forecast future growth and needs has become more 

complicated. MPOs today face a much broader and more complex set of 

requirements and needs in their travel modeling than they did in the 1960s 

and 1970s, when the primary concern was evaluating highway and transit 

system capacity expansions.22 New requirements—such as determining 

motor vehicle emissions and changes in land use—have created additional 

data needs to account for the increasing complexity of the transportation 

system. For example, about half of our survey respondents indicated that 

their MPOs include a nonattainment or maintenance area and, thus, are 

required to conduct air quality conformity analyses. An even larger 

percentage of medium- and large-sized MPOs—66 percent and 76 percent, 

respectively—indicated that they have such areas within their MPO 

boundaries. As planning organizations, much of the value of MPOs lies in 

their ability to forecast and analyze an increasingly complex and growing 

set of transportation needs. If MPOs’ technical capabilities cannot account 

for the increasing complexities facing regional transportation systems, 

MPOs’ contributions to transportation planning may be compromised, 

which could lead to planning failures and poor investment decisions. 

 

22TRB, Metropolitan Travel Forecasting: Current Practice and Future Direction, Special 

Report 288 (2007). 

Page 20 GAO-09-868 Metropolitan Planning Organizations
 

Although some MPOs are taking steps to meet the challenges presented by 

the increasing complexity of the transportation system, MPOs still face 

modeling challenges. About half of MPOs report that they face challenges 

related to their limited modeling capacity. Some MPOs have had success 

updating their travel forecasting techniques to accommodate new 

requirements. For example, officials at one MPO told us the transit agency 

in their region is developing a travel demand model specifically for transit, 

though it has not yet been incorporated into the MPO’s travel models. 

Some MPOs we interviewed, however, told us that they lack the resources 

to improve their modeling capabilities. In fact, MPO officials expressed 

concern in interviews that current models, including the four-step models 

most MPOs use, do not necessarily produce forecasts that can adequately 

account for the increasing complexities of transportation planning, such 

as predicting future land-use patterns and transit’s effect on travel 

behavior. TRB also found similar challenges—that is, they found inherent 

weaknesses in current models that are generally unable to address new 

policy concerns raised by the growing complexity of the transportation 

system. TRB notes that when the detail required to address a 

transportation issue increases, the complexity of the analytical techniques 

should increase as well. For example, a small metropolitan area 

experiencing minimal growth, with little transit and no air quality 

problems, will likely be able to use a simple model to determine the area’s 

needs. Thus no single approach is appropriate for all MPOs. 

Although modeling presents challenges, according to our survey, the most 

predominant technical challenge was related to acquiring quality data to 

use in planning models. Over 70 percent of survey respondents cited data 

limitations as a challenge. Data reflecting current travel patterns in a 

metropolitan area are important because models that are supplied with 

inaccurate or out-of-date data may produce inadequate forecasts that 

contribute to poor planning. In addition, having robust data to support 

proposed transportation plans helps to keep planning more objective and 

lends credibility to the plans developed by MPOs. However, conducting a 

household travel survey—a survey of random households in a 

metropolitan area that gathers trip-related data, such as mode of 

transportation, duration, distance and purpose of trip—to collect updated 

Page 21 GAO-09-868 Metropolitan Planning Organizations
 

data is both expensive and time-consuming.23 For example, officials at one 

large MPO we interviewed stated that they need to update their household 

survey but are having difficulty finding the estimated $1.5 million needed 

to do so. As we mentioned earlier, funding shortages and the lack of staff 

trained with such technical expertise make increasing technical capacity a 

challenge for many MPOs, particularly small ones. TRB’s study also found 

that many MPOs had inadequate data to support their modeling processes. 

The federal certification review is an important mechanism that FTA and 

FHWA use to oversee the MPO planning process. Although all MPOs are 

required to self-certify that they have met the federal transportation 

planning requirements, SAFETEA-LU also requires DOT to certify the 

metropolitan planning process of the 155 TMAs every 4 years.24 To conduct 

a certification review, FTA and FHWA assemble a team which typically 

consists of FTA and FHWA field staff, but may also include FHWA or FTA 

headquarters community planners, EPA officials, other subject matter 

experts, or experts from DOT’s Volpe National Transportation Systems 

Center. FHWA division office personnel generally take the lead in these 

reviews, which typically take 6 to 9 months and include (1) an initial desk 

review, which includes verifying compliance with basic regulatory 

requirements, among other things; (2) an evaluation of the MPO’s written 

response to a series of questions; (3) a 2 to 4 day site visit during which the 

team gathers additional information; and (4) a meeting to inform the 

public about planning requirements and provide an opportunity for the 

public to express concerns about how the process is meeting the needs of 

the area. After the site visit, the team prepares a final report including 

review findings and recommendations, which incorporates public 

comments on the planning process. 

The Extent to Which 

MPO Oversight 

Mechanisms Improve 

Transportation 

Planning Is Unclear 

Consistent with federal law, the federal certification review is processoriented and conducted without regard to transportation planning 

outcomes. Specifically, through certification reviews, DOT ensures that 

the metropolitan planning process of an MPO serving a TMA is carried out 

 

23The National Household Travel Survey is a DOT effort sponsored by the Bureau of 

Transportation Statistics and FHWA to collect data on both long-distance and local travel 

by the American public. The joint survey gathers trip-related data, such as mode of 

transportation, duration, distance, and purpose of trip. MPOs also conduct household 

travel surveys to collect data on local travel in their respective metropolitan areas. 

24According to DOT’s MPO database, 155 MPOs have at least one part of their designated 

boundary within a TMA. 

Page 22 GAO-09-868 Metropolitan Planning Organizations
 

in accordance with applicable provisions of federal law—for example, by 

ascertaining whether or not the MPO has adhered to its public 

participation plan. Oversight also provides a mechanism through which 

the federal government can ensure that its funds are being used to achieve 

its intended goals. The current process-oriented approach toward 

certification generally focuses on procedural requirements as opposed to 

performance. FTA and FHWA can withhold apportioned federal highway 

and transit funds if they determine an MPO is in noncompliance with 

federal requirements. However, FTA and FHWA officials were unaware of 

any instance in which an MPO was not certified due to noncompliance 

during the last 10 years. Furthermore, FTA and FHWA officials noted that 

the process is meant to be collaborative in nature. Therefore, a finding of 

noncompliance is as much of a failure on the part of DOT as the MPO, 

according to a DOT official. 

Because the federal certification is focused on compliance, not outcomes, 

it is difficult to determine whether federal oversight is improving 

transportation planning. GAO has previously recommended25 to DOT, as 

well as to Congress, that adopting performance measures and goals for 

programs can aid in evaluating and measuring the success of the 

programs, which can lead to better decisions about transportation 

investments.26 The procedural focus of the federal certification, and the 

fact that, according to DOT officials’ knowledge, no MPO has failed to be 

certified as a result of a certification review also makes it difficult to use 

the certification results as a performance indicator for MPOs. According to 

FHWA and FTA officials, certification reviews examine the quality of the 

MPO planning process by, for example, identifying corrective actions 

where there is noncompliance with statute or regulations and 

recommendations for areas needing improvement. Corrective actions are 

set with milestone dates to rectify the noncompliance and require a status 

report and re-evaluation of the process. Commendations for the use of 

noteworthy practices are also identified. However, FTA and FHWA do not 

assess the progress of the MPO in achieving the goals outlined in the plans. 

According to FTA and FHWA officials, states may, but are not required to, 

 

25GAO, Rail Transit: Additional Federal Leadership Would Enhance FTA’s State Safety 

Oversight Program, GAO-06-821 (Washington, D.C.: July 26, 2006) and GAO, Surface 

Transportation: Restructured Federal Approach Needed for More Focused, PerformanceBased, and Sustainable Programs, GAO-08-400 (Washington, D.C.: Mar. 6, 2008). 

26DOT officials generally agreed with our recommendations and stated that, although they 

do have some performance measures in place for certain programs, additional performance 

measures could be beneficial. 

Page 23 GAO-09-868 Metropolitan Planning Organizations
 

monitor the progress of MPOs in meeting their goals. Furthermore, an 

FHWA official noted that the elements that are reviewed through 

certification serve as proxies for good planning—for example, the 

resulting plans will be better if the MPO is regularly soliciting and 

incorporating public input. 

Most MPOs we interviewed generally view the federal certification reviews 

as pro forma in nature and place a greater value on informal assistance 

from the federal government. Officials in one state said that the most 

important oversight is the “give and take” between agencies on the various 

transportation plans they create. This informal interaction allows the 

oversight agencies to identify issues prior to the formal reviews. Likewise, 

many federal officials with whom we spoke view informal interactions—

such as regular meetings, technical assistance, and review of air quality 

conformity analyses—as an important aspect of oversight. One FHWA 

division official we interviewed stated that the benefit of ongoing 

communication is that problems are identified as they arise and can be 

addressed well before the certification review or self certification is 

conducted. 

MPOs also reported that the assistance provided by their states is more 

important than the federal certification reviews. Although the level of 

participation of states in the planning process varies, MPOs reported in 

our survey that state department of transportation officials generally play 

a greater oversight role than DOT for certain activities. For example, 

around 80 percent of survey respondents reported that state department of 

transportation officials are involved in MPO boards and committees, while 

over 55 percent and 70 percent reported similar participation from federal 

officials on MPO boards and committees, respectively. This may be due, in 

part, to the limited number of staff at FHWA and FTA. 

With the pending expiration of the current surface transportation 

authorizing legislation, MPO, government, and industry officials have 

developed various formal and informal proposals to improve or change the 

current transportation planning process. We reviewed proposals from 

AMPO, AASHTO, APTA, the Brookings Institution, the previous and 

current DOT administrations, and the June 2009 House Transportation and 

Infrastructure Committee blueprint for the surface transportation 

reauthorization. We also discussed suggestions for improving 

transportation planning with MPO, federal, and state officials. In reviewing 

these proposals or suggestions, we identified several recurring changes, or 

options, that could address some of the resource, authority, and technical 

MPO, Government, 

and Industry Officials 

Have Developed 

Options to Enhance 

Transportation 

Planning 

Page 24 GAO-09-868 Metropolitan Planning Organizations
 

challenges facing MPOs. Most of the options have both advantages and 

disadvantages, and implementing any of the options will require policy 

trade-offs. 

Increasing Flexibility in 

Use of Federal Funds 

Creating an expanded or clarified definition of eligibility for the use of 

transportation planning funds could allow MPOs to utilize planning funds 

in ways that best meet the needs of the area. Most of the MPOs we 

surveyed and many of the MPOs we interviewed suggested that having 

additional flexibility regarding the types of activities that are eligible to be 

completed using planning funds would improve the planning process. 

Currently, FHWA guidance precludes using planning funds for projects’ 

environmental analyses that “clearly extends beyond transportation 

planning.” As we mentioned previously, officials at a few MPOs we spoke 

with stated that they are unclear about what environmental activities are 

eligible under that definition, which makes it difficult to conduct 

comprehensive transportation planning. According to many of the MPOs 

we interviewed and 90 percent of the MPOs responding to our survey, 

creating more flexibility in how the planning funds can be spent would 

improve the effectiveness of the planning process and allow MPOs to be 

more efficient by prioritizing their limited resources to the most critical 

planning activities. However, providing such flexibility in federal 

transportation funds could result in less transparency and accountability. 

In particular, when funds can be flexed across different activities, there is 

less ability to assess the impact of particular funding streams—such as 

transportation planning funds—on the achievement of key goals. 

Creating Greater Variation 

in Planning Requirements 

A number of the proposals for improving the MPO planning process 

include creating further variation—in addition to the TMA and non-TMA 

distinction—in MPOs’ planning requirements and authority to account for 

the wide variation in capacity of MPOs across the country. For example, 

creating additional variations in MPOs’ planning requirements could 

include the development of abbreviated planning requirements for MPOs. 

SAFETEA-LU allows that the Secretary of Transportation may permit 

MPOs that are not designated as TMAs or are not in nonattainment for 

ozone or carbon monoxide to develop abbreviated metropolitan 

transportation plans or TIPs. In so doing, the Secretary must take into 

account the complexity of transportation problems in the area.27 MPOs in 

 

27SAFETEA-LU 23 U.S.C. § 134(l); 49 U.S.C. § 5303(l). 

Page 25 GAO-09-868 Metropolitan Planning Organizations
 

small metropolitan areas—where transportation needs are often less 

complex—could benefit from abbreviated planning requirements. To date, 

no MPOs have applied for the abbreviated planning requirements, 

according to DOT officials. 

Other proposals suggest that MPOs that have exhibited increased 

capacity—e.g., those that are conducting additional activities beyond the 

current planning requirements—could be allowed additional 

implementation authority to oversee the development of certain projects. 

Likewise, an MPO could be granted expanded authority to plan and fund a 

metropolitan area’s transportation projects—focusing available 

transportation funds on projects that will benefit a region the most, 

regardless of mode. A large majority of the survey respondents—79 

percent—stated that additional project implementation authority would 

improve effectiveness of the MPO planning process.28

However, granting additional authorities to MPOs or reducing the 

requirements could result in some additional challenges for MPOs and 

DOT. Additional federal and state oversight may be needed for (1) MPOs 

that take on new, traditionally non-MPO responsibilities, such as project 

implementation or (2) MPOs that reduce their planning requirements in 

order to ensure that the abbreviated process adequately accounts for the 

transportation needs of the area. Additionally, over half of the survey 

respondents reported that they do not have the capacity to undertake 

additional project implementation authorities, despite the fact that a large 

majority of MPOs stated increased implementation authority would 

improve the effectiveness of their planning process. 

Other proposals include changing the legal definition of MPOs to realign 

the MPO planning process with current capacity and planning needs. In 

particular, one option calls for an increase in the population threshold for 

mandatory MPO creation. Requiring the formation of MPOs at a larger 

population threshold could ease the burden of the previously mentioned 

resource constraints affecting small MPOs, including funding and staffing 

shortages. Specifically, one of the state departments of transportation we 

 

28For questions where we asked about the options that would improve the effectiveness of 

the MPO planning process, we used a five-point scale to measure extent: very great extent, 

great extent, moderate extent, some or little extent, and no extent. For the purposes of this 

report, we combined the responses for moderate extent, great extent, and very great extent 

to report the percentage of responses that indicated an option would improve the 

effectiveness of the planning process. 

Page 26 GAO-09-868 Metropolitan Planning Organizations
 

interviewed—one that contains more rural areas—noted that the current 

population threshold of 50,000 can create a situation in which a relatively 

small, rural area with less complex transportation needs is given MPO 

responsibilities. In these situations, MPOs may have difficulty funding an 

adequate number of positions—or filling them with qualified individuals—

to do the work needed to meet federal and state requirements. Raising the 

population threshold could raise the likelihood that MPO efforts are 

limited to urban areas with more advanced transportation needs. 

However, about 73 percent of survey respondents from small MPOs 

reported that raising the threshold would not be an appropriate way to 

improve the planning process. An official from a small MPO we 

interviewed noted that any reduction in responsibilities for small MPOs 

must be a contextual decision based on the complexity of the 

transportation needs in the area, such as proximity to a large metropolitan 

area that is expected to grow in the future. 

Increasing Federal 

Investment in Modeling 

Efforts 

With regard to technical constraints, improving technical capabilities 

across MPOs will likely require additional investment in modeling, data 

gathering, or both. As noted previously, current models are not well suited 

to representing travelers’ responses to the complex range of policies such 

as freight movement and motor vehicle emissions. Of particular concern is 

that many MPOs have inadequate data to support their modeling 

processes, even for traditional travel demand forecasts. Eighty-seven 

percent of MPOs surveyed said that greater federal support for 

transportation research and data would improve their effectiveness. 

Moreover, many of the MPOs we interviewed agreed that federal 

government investment in modeling and data gathering is necessary to 

ensure greater reliability in travel demand forecasting across MPOs and to 

help account for the increasing complexity of transportation forecasting 

and data needs in urban areas. Furthermore, without such an investment, 

policymakers may lack the information needed to make informed 

decisions on investments related to the transportation system. 

Toward this end, TRB’s Special Report 288 recommended the 

development and implementation of new modeling approaches to travel 

demand forecasting that are better suited to providing reliable 

information. These new modeling approaches include such applications as 

multimodal investment analyses, environmental assessments, evaluations 

of a wide range of policy alternatives, and meeting federal and state 

regulatory requirements. TRB also made various recommendations for 

improvements, including increasing DOT support and funding for 

incremental improvements to models in settings appropriate for their use, 

Page 27 GAO-09-868 Metropolitan Planning Organizations
 

and the continued development, demonstration, and implementation of 

advanced modeling approaches.29 Additionally, TRB encouraged DOT 

collaboration with MPOs and states to examine data collection needs, 

including data requirements for validating current travel forecasting 

models and meeting regulatory requirements. Most recently, in July 2009, 

when DOT announced its principles for an 18-month extension of federal 

highway, transit, and highway and trucking safety programs, it called for 

an investment of $300 million to build state and MPO planning capacity for 

the collection and analysis of data on transportation goals. Additionally, 

DOT’s 18-month extension proposal suggests an investment of $10 million 

to build MPOs’ informational and analytic capacity to refine assessment 

tools at the federal level, among other things. 

Making the Planning 

Process More 

Performance-Based 

Currently there are no requirements to attain explicit performance 

thresholds, such as reducing congestion or improving highway safety, built 

into the federal planning requirements for MPOs.30 MPOs and industry 

representatives we interviewed recognized the value of making the 

planning process more performance-based, noting that focusing on 

outcomes could improve transportation investment decision making. In 

addition, DOT’s recently released principles for an 18-month extension of 

certain federal surface transportation programs also calls for stronger 

requirements for tracking and reporting on the projected and actual 

outcomes of transportation investments that use federal dollars. Using 

performance measures could help hold MPOs accountable for carrying out 

a 3-C transportation planning process that encourages and promotes a safe 

and efficient surface transportation system. According to our survey, most 

MPOs already report using performance measures to some extent to 

assess results achieved. However, MPOs generally reported using outputbased measures, such as compliance with state and federal transportation 

planning rules, rather than outcome-based measures, such as improved 

safety. Further, some DOT officials we spoke with maintained that the 

wide variety of needs and capacities among regions would make it difficult 

to establish national performance measures. To overcome the challenge of 

 

29Advanced travel models are based on a more comprehensive understanding of the 

activities of households; that is, they reflect the full range of trade-offs that affect whether 

to make a trip, what time a trip is made, the destinations visited, the modes used, and the 

paths selected. 

30The CMP requires that TMAs monitor congestion and consider potential congestion relief 

measures in formulating long-range plans. 

Page 28 GAO-09-868 Metropolitan Planning Organizations
 

creating such measures for all MPOs, some officials said that broader 

performance goals could be established at the national level, while more 

specific measures and targets could be left for states and regions to 

establish. 

Establishing outcome-based measures for all MPOs would also require 

DOT to expand its oversight so that it can assess the progress of MPOs in 

achieving specific results, rather than focusing on compliance with 

existing statutes and rules. However, a few MPOs and the DOT officials we 

spoke to noted that it would not be appropriate to hold MPOs accountable 

for specific outcomes because they do not have the authority to implement 

their plans. Indeed, it is often up to local jurisdictions and the state to 

carry out MPO plans, and they do not always have the same priorities and 

goals as the MPOs. Some MPO stakeholders we spoke to noted that 

reconciling the needs of the region with the priorities of individual 

jurisdictions is a significant challenge. Nevertheless, other officials we 

spoke to noted that the purpose of MPOs is to establish a consensus on a 

region’s long-term transportation goals and that it would be appropriate to 

link those goals with specific outcomes. 

Our survey shows a pattern of variations and challenges that could 

increasingly compromise the quality of regional transportation planning, 

potentially allowing transportation problems—such as increasing 

congestion—to inhibit economic activity in the United States. For 

example: 

Conclusions 

• MPOs’ roles and responsibilities are not commensurate with their 

requirements. Under the current system, a small MPO with a simple 

transportation mission and limited technical capacity is generally 

accountable to the same planning and program requirements and oversight 

as a large MPO with a complex, multimodal transportation system, raising 

questions as to whether the federal government is appropriately targeting 

its oversight resources. SAFETEA-LU allows MPOs to seek permission to 

use a more abbreviated planning process. MPOs may not be universally 

aware of this option since, to date, no MPOs have utilized it. 

• The quality of MPOs’ computerized travel demand models and the data 

used to support the process is often insufficient or unreliable. As planning 

organizations, one of the important functions of MPOs is the ability to 

forecast and analyze an increasingly complex and growing set of 

environmental, transportation, and social trends. Thus if MPOs are not 

able to keep pace with the increasing complexity of this task, their 

Page 29 GAO-09-868 Metropolitan Planning Organizations
 

contribution to transportation planning may be compromised. However, 

on a cautionary note, effective forecasting requires both quality computer 

models and accurate data, such that investing in one without improving 

the other may waste resources. DOT’s July 2009 18-month extension 

proposal calls for additional resources for the collection and analysis of 

data on transportation goals to help build transportation planning 

capacity. Adopting TRB’s modeling and data gathering recommendations 

is an example of how the additional resources could be invested. 

• Finally, because the oversight mechanisms for MPOs are focused on 

process, rather than outcomes, it is unclear what impact regional 

transportation planning is having on transportation outcomes. Despite 

over 30 years of a federally mandated and funded transportation planning 

process and billions spent on roads, bridges, and transit projects, there is 

not enough information for policymakers to determine whether the 

planning process is addressing critical transportation challenges facing the 

United States. However, shifting to a more performance-based oversight 

approach will require legislative changes. 

Addressing these variations and challenges is particularly important given 

some proposed reforms that would increase the ability of metropolitan 

and local governments to access additional federal transportation funds. 

The upcoming reauthorization of federal surface transportation programs 

provides Congress and DOT an opportunity to address these challenges 

and enhance regional transportation planning. For example, Congress and 

DOT could examine what is being invested in the federal oversight 

process, what the return for this investment is, and how it may be 

improved. 

Congress should consider making MPO transportation planning more 

performance-based—for example, by identifying specific transportation 

outcomes for transportation planning and charging the U.S. Department of 

Transportation with assessing MPOs’ progress in achieving these 

outcomes in the certification review process. 

Matter for 

Congressional 

Consideration 

To improve the transportation planning process, we are recommending 

that the Secretary of Transportation take the following two actions: Recommendations 

Page 30 GAO-09-868 Metropolitan Planning Organizations
 

1. Direct the Administrators of the Federal Highway Administration and 

the Federal Transit Administration to establish guidelines for MPOs to 

apply for, and implement, the abbreviated planning clause for small 

MPOs, and share these guidelines with existing MPOs. 

2. Develop a strategy to improve data gathering and modeling efforts 

among MPOs, including establishing a timeline for implementing the 

modeling and data recommendations for the federal government in the 

Transportation Research Board’s Special Report 288. 

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

agreed to consider the report’s recommendations. DOT also provided 

technical comments, which we incorporated as appropriate. 

Agency Comments 

We are sending copies of this report to interested congressional 

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

will be available at no charge on GAO’s Web site at http://www.gao.gov. 

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

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

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

of this report. GAO staff who made major contributions to this report are 

listed in appendix II. 

Sincerely yours, 

Phillip R. Herr 

Director 

Physical Infrastructure Issues 

Page 31 GAO-09-868 Metropolitan Planning Organizations
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To identify and assess the characteristics and responsibilities of 

metropolitan planning organizations (MPO) we reviewed current and 

previous federal statutes and regulations governing MPOs. We also 

reviewed relevant academic, industry association, GAO, and U.S. 

Department of Transportation (DOT) research and publications to 

understand MPOs’ transportation planning responsibilities, the ways MPOs 

vary, and the challenges MPOs face in carrying out their responsibilities. 

Additionally, we interviewed representatives from industry associations, 

as well as MPO, Federal Transit Administration (FTA), Federal Highway 

Administration (FHWA), and DOT officials to clarify MPO planning 

responsibilities, identify transportation planning challenges, and assess 

how DOT provides oversight for MPOs and the extent to which this 

improves transportation planning. To further examine the role of state 

departments of transportation in metropolitan planning and assess the 

potential impact of various changes to MPOs, we contacted 11 additional 

state departments of transportation by e-mail and received responses from 

6. We also attended and observed a DOT on-site certification review in 

Savannah, Georgia, to further understand the federal oversight of 

transportation management areas (TMA). 

To determine the various options for improving regional transportation 

planning, we reviewed federal surface transportation program 

reauthorization proposals from the Association of Metropolitan Planning 

Organizations (AMPO), American Association of State Highway and 

Transportation officials, American Public Transportation Association, 

Brookings Institution, the previous and current DOT administrations, and 

the current House Transportation and Infrastructure Committee blueprint 

for reauthorization. We also discussed informal proposals or suggestions 

for improving the planning process with MPO, federal, and state officials. 

To gather in-depth information on the roles and responsibilities of MPOs, 

the extent to which federal oversight improves transportation planning, 

and possible ways to improve regional transportation planning, we 

conducted a Web-based survey of all 381 MPOs. This survey was 

conducted from February 3 to April 1, 2009. To prepare the questionnaire, 

we pretested potential questions with MPOs of different sizes and from 

different FTA regions to ensure that (1) the questions and possible 

responses were clear and thorough, (2) terminology was used correctly, 

(3) questions did not place an undue burden on the respondents, (4) the 

information was feasible to obtain, and (5) the questionnaire was 

comprehensive and unbiased. On the basis of feedback from the seven 

pretests we conducted, we made changes to the content and format of 

Page 32 GAO-09-868 Metropolitan Planning Organizations 
Appendix I: Scope and Methodology 

some survey questions. The results of our survey can be found at 

GAO-09-867SP. 

To identify MPOs to survey, we obtained MPO contact information from 

DOT and AMPO; any inconsistencies between the two lists were 

reconciled with phone calls to the relevant MPO. We also contacted all of 

the MPOs in advance, by e-mail, to ensure that we had identified the 

correct respondents and to request their completion of the questionnaire. 

After the survey had been available for 2 weeks, and again after 4 and 6 

weeks, we used e-mail and telephone calls to contact MPOs who had not 

completed their questionnaires. Using these procedures, we obtained an 

86 percent response rate. Because this was not a sample survey, there are 

no sampling errors. However, the practical difficulties of conducting any 

survey may introduce errors, commonly referred to as nonsampling errors. 

For example, difficulties in how a particular question is interpreted, in the 

sources of information that are available to respondents, or in how the 

data are entered into a database or were analyzed can introduce unwanted 

variability into the survey results. We took steps in the development of the 

questionnaire, the data collection, and the data analysis to minimize these 

nonsampling errors. For instance, a survey specialist designed the 

questionnaire in collaboration with GAO staff who have subject-matter 

expertise. Further, the draft questionnaire was pretested with a number of 

MPOs to ensure that the questions were relevant, clearly stated, and easy 

to comprehend. When the data were analyzed, a second, independent 

analyst checked all computer programs. Finally, nonresponding MPOs 

were distributed among different states and sizes of MPOs in a way that 

did not show evidence of bias. 

To gather additional information on the roles and responsibilities of MPOs, 

the extent to which federal oversight improves transportation planning, 

and possible ways to improve regional transportation planning, we 

conducted case studies in eight metropolitan areas. Each case study 

involved interviews with the designated MPO for that metropolitan area, 

as well as the state department of transportation, transit operators, and 

other relevant regional organizations. We selected MPOs to visit and 

examine based on the following criteria: 

• population (based on whether or not the MPO is in a designated TMA); 

• location (based on the FTA region); 

Page 33 GAO-09-868 Metropolitan Planning Organizations
Appendix I: Scope and Methodology 

• air quality (based on whether the MPO is located in an air quality 

nonattainment area); 

• structure of the MPO (based on whether the MPO is an independent 

agency or housed within another organization or jurisdiction); and 

• recommendations from internal stakeholders, experts, associations, and 

federal DOT officials we consulted. 

Although using these criteria allowed us, in our view, to obtain 

information from a diverse mix of MPOs, the findings from our case 

studies cannot be generalized to all MPOs because they were selected as 

part of a nonprobability sample.1

 Table 2 lists the region and relevant 

MPOs where we conducted case studies. 

Table 2: Metropolitan Regions Selected for Case Study 

Metropolitan area Designated MPO 

Albuquerque, New Mexico Mid-Region Council of Governments 

Dallas-Ft. Worth, Texas North Central Texas Council of Governments 

Gainesville, Florida North Central Florida Regional Planning Council 

Jacksonville, Florida North Florida Transportation Planning Organization 

Sacramento, California Sacramento Area Council of Governments 

San Francisco, California Metropolitan Transportation Commission 

Santa Fe, New Mexico Santa Fe Metropolitan Planning Organization 

Sherman, Texas Sherman-Dennison Metropolitan Planning 

Organization 

Source: GAO. 

 

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 34 GAO-09-868 Metropolitan Planning Organizations
Appendix II: 

A

GAO Contact and Staff 

cknowledgments 

Page 35 GAO-09-868 

Appendix II: GAO Contact and Staff 

Acknowledgments 

Phillip R. Herr, (202) 512-2834 or herrp@gao.gov

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

Director; Kyle Browning; F. Chase Cook; Kathleen Gilhooly; Cathy Hurley; 

Stu Kaufman; Sara Ann Moessbaeur; Josh Ormond; Stephanie Purcell; Amy 

Rosewarne; Jay Smale; and Susan Zimmerman made key contributions to 

this report. 

 Metropolitan Planning Organizations 

GAO Contact 

Staff 

Acknowledgments 

(546008) 
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