Federal Transit Administration: Progress and Challenges in Implementing and Evaluating the Job Access and Reverse Commute Program
Published: 2009-05-21T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Established in 1998, the Job Access and Reverse Commute Program (JARC)-administered by the Federal Transit Administration (FTA)--awards grants to states and localities to provide transportation to help low-income individuals access jobs. In 2005, the Safe, Accountable, Flexible, Efficient Transportation Equity Act--A Legacy for Users (SAFETEA-LU) reauthorized the program and made changes, such as allocating funds by formula to large and small urban and rural areas through designated recipients, usually transit agencies and states. SAFETEA-LU also required GAO to periodically review the program. This second report under the mandate examines (1) the extent to which FTA has awarded JARC funds for fiscal years 2006 through 2008, and how recipients are using the funds; (2) challenges faced by recipients in implementing the program; and (3) FTA's plans to evaluate the program. For this work, GAO analyzed data and interviewed officials from FTA, nine states, and selected localities.
section_title: What GAO Found
paragraphs: FTA is making progress in awarding funds and has awarded about 48 percent of the $436.6 million in JARC funds apportioned for fiscal years 2006 through 2008 to 49 states and 131 of 152 large urbanized areas. Recipients plan to use the funds primarily to operate transit services. However, about 14 percent of fiscal year 2006 funds lapsed. According to FTA officials, these funds lapsed for several reasons. For example, some applicants did not meet administrative requirements in time to apply for funds. FTA officials are working with states and localities to reduce the amount of funds that lapse in the future. Recipients plan to use 65 percent of fiscal year 2006 funds to operate transit services, 28 percent for capital projects, and 7 percent for administrative costs. States and local authorities GAO interviewed cited multiple challenges in implementing the JARC program; a common concern is that, overall, the effort required to obtain JARC funds is disproportionate to the relatively small amount of funding available. One challenge cited by recipients was that FTA's delay in issuing final guidance and the process to identify designated recipients reduced the time available to secure funds before the funds expired. In addition, although recipients considered the coordinated planning process beneficial, many cited factors that hindered coordination, including lack of resources and the reluctance of some stakeholders to participate. Moreover, although the JARC program requires human service providers to be included as stakeholders, other transportation planning requirements do not, complicating the coordinated planning process. Some designated recipients also expressed concerns about identifying stable sources of matching funds and duplicative efforts in administering JARC with other FTA programs. These challenges have delayed applications for funds and project implementation, and contributed to the lapse in fiscal year 2006 funds. Although FTA has not completed an evaluation of the JARC program under SAFETEA-LU, recipients we spoke with indicated that projects have benefited low-income individuals by providing a means to get to work. Since 2000, FTA has refined its approach for evaluating the program and currently has two studies under way to evaluate the JARC program under SAFETEA-LU. However, both studies may have limitations that could affect FTA's assessment of the program. One of these studies--due in September 2009--will evaluate projects using FTA's performance measures; specifically, the number of rides provided and number of jobs accessed. However, collecting reliable data for these measures is problematic, particularly for the number of jobs accessed. The other study--due in the spring of 2010--will include results of a survey of JARC recipients and individuals using JARC services and will focus on the program's impact on those using the services. However, this study will use a methodology similar to that used in a prior study which had limitations in the survey instrument design and data analysis. FTA does not have a comprehensive process in place to assess whether its researchers use generally accepted survey design and data analysis methodologies.

section_title: Letter
paragraphs: Access to adequate transportation is critical to enabling low-income  individuals to find and retain employment. To address this issue, Congress  established the Job Access and Reverse Commute (JARC) program in  1998. Administered by the Federal Transit Administration (FTA), JARC  provides grants to states and localities to fill gaps in transportation  services for low-income individuals needing access to jobs and related  services, such as child care and training. In 2005, Congress reauthorized  JARC through the Safe, Accountable, Flexible, Efficient Transportation  Equity Act—A Legacy for Users (SAFETEA-LU), and authorized $727  million for the program for fiscal years 2005 through 2009. SAFETEA-LU  made a number of changes, the most significant of which changed JARC  from a discretionary to a formula program. JARC funding may be spent on  operating projects, such as new or expanded transit services that could  include bus routes, van pool services, and commuter rail services, or on  capital projects, which include mobility management services and  equipment purchases. SAFETEA-LU required that the Department of  Transportation (DOT) evaluate the effectiveness of the JARC program and  report the results to the House Committee on Transportation and  Infrastructure and the Senate Committee on Banking, Housing, and Urban  Affairs by August 2008. FTA submitted a report to Congress on the JARC  program in January 2009.
SAFETEA-LU also requires GAO to study the JARC program 1 year after  the legislation took effect and every 2 years thereafter. This report—the  second in response to the mandate-—analyzes FTA’s progress in  implementing changes to the JARC program. Our specific reporting  objectives were to determine:    The extent to which FTA has awarded available funds for fiscal  years 2006 through 2008, and how recipients are using these funds  since SAFETEA-LU went into effect.
The challenges recipients have faced in implementing the JARC  program.
How FTA plans to evaluate the program.
To address these objectives, we reviewed relevant laws and regulations  and interviewed FTA officials, JARC recipients, and stakeholders. We  obtained and analyzed data from FTA’s Transportation Electronic Awards  Management (TEAM) System to determine the extent to which FTA  awarded JARC funds, and assessed the reliability of these data. We  determined that the data were sufficiently reliable for the purposes of our  report. To examine how recipients have used JARC funds since SAFETEA- LU went into effect and challenges recipients have encountered in  implementing the program, we interviewed 26 designated recipients and  16 subrecipients. We selected the designated recipients based on criteria  that included states and large urbanized areas receiving an increase or a  decrease in JARC funds as a result of changing to the formula program,  states we interviewed for our November 2006 report, and states FTA and  industry association officials suggested. We selected subrecipients that  covered the three areas that were apportioned JARC funding under  SAFETEA-LU—large and small urbanized as well as rural areas—as well  as those that designated recipients recommended. Since we used a  nongeneralizable sampling approach, the results of these interviews  cannot be used to make inferences about all designated recipients and  subrecipients. We also interviewed local stakeholders and officials from  industry associations, including the American Association of State  Highway and Transportation Officials (AASHTO), the American Public  Transportation Association (APTA), the Community Transportation  Association of America, and the National Association of Regional Councils  to obtain their views on challenges associated with implementing the  JARC program. Furthermore, to identify challenges faced by human  services agencies associated with the coordinated human services  transportation planning process, we interviewed officials from the U.S.  Department of Labor and U.S. Department of Health and Human Services,  and associations representing elderly and disabled persons, including  Easter Seals, the Association of Programs for Rural Independent Living,  and AARP. To determine how FTA plans to evaluate the JARC program,  we reviewed previous evaluations and interviewed officials from FTA and  two contractors that are evaluating the program. For each evaluation, we  assessed the contractor’s scope and methodology using standard survey  and economic principles and practices as criteria. We also interviewed  designated recipients, subrecipients, and other state and local officials to  obtain their perspectives on FTA’s JARC performance measures. See  appendix I for additional information on our scope and methodology.
We conducted this performance audit from May 2008 to May 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  provides a reasonable basis for our findings and conclusions based on our  audit objectives.
subsections: section_title: Background
paragraphs: The Personal Responsibility and Work Opportunity Reconciliation Act of  1996 significantly changed the system for providing assistance to low- income families with children by replacing the existing entitlement  program with fixed block grants to states to provide Temporary Assistance  for Needy Families (TANF). TANF provides about $16.5 billion annually  to states to help families become self-sufficient, imposes work  requirements for adults, and limits the time individuals can receive federal  assistance.
However, accessing entry-level jobs to meet TANF work requirements can  be challenging for low-income individuals, many of whom do not ow n cars  or have poorly maintained cars that are not equipped to drive long  distances. As we reported in 2004, many rural TANF recipients cannot  afford to own and operate a reliable vehicle and public transportation to and from employment-related services and work is often not available.   Existing public transportation systems cannot always bridge the gap  between the location of individuals’ homes and jobs for which they not to mention child care and other domestic responsibilities and  employment-related services. These systems were originally established to allow urban residents to travel within cities and bring suburban residents  to central-city work locations. According to 2007 U.S. Census Bureau data,  a higher proportion of people in metropolitan areas who are below  poverty level live in cities in those areas than in the corresponding  suburbs. Furthermore, employees at many entry-level jobs must work  shifts in the evenings or on we ekends, when public transit services are  either unavailable or limited.
As a result, Congress created the JARC program in the Transportation  Equity Act for the 21st Century (TEA-21) to support the nation’s welfare- reform goals. The purpose of the program was to improve the mobility of  low-income individuals by awarding grants that states and localities cou use to provide additional or expanded transportation services and thus  provide more opportunities for individuals to get to work. JARC funds  ld  were awarded to grantees designated for project funding in the conference  reports that accompanied appropriations acts.
TEA-21 also required GAO to review the JARC program every 6 months. In  a series of reports from December 1998 to August 2004, GAO found,  among other things, that JARC had increased coordination among transit  and human service agencies, but that FTA was slow in evaluating the  program. These reports included recommendations to assist FTA in  improving its evaluation process. In response to these recommendations,  FTA developed specific objectives, performance criteria, goals, and  performance measures for the JARC program, although GAO noted  limitations in the performance measures and recognized that FTA planned  to continue to develop more comprehensive and relevant performance  measures.
SAFETEA-LU made several changes to the JARC program that affected  recipients. Most notably, SAFETEA-LU created a formula to distribute  funds beginning with fiscal year 2006: SAFETEA-LU requires that 40  percent of JARC funds each year be apportioned among states for projects  in small urbanized and rural areas—those with populations of 50,000 to  199,999 and less than 50,000, respectively. It also required that the  remaining 60 percent be apportioned among large urbanized areas—those  with populations of 200,000 or more. As a result, rural and small  urbanized areas were each apportioned a total of $27.3 million in fiscal  year 2006, while large urbanized areas were apportioned a total of $82  million (see table 1). The change to a formula grant program significantly  altered the allocation of JARC funds because some states and large  urbanized areas that did not formerly receive funds now receive them, and  others receive different amounts than they received in the past. For  example, total funds available in Florida and Virginia increased by more  than 1,200 percent from fiscal years 2005 to 2006 (from $594,708 to $8.3  million and from $84,249 to $2.5 million, respectively). Similarly, the funds  available for the large urbanized area of Tampa/St. Petersburg increased  64 percent from 2005 to 2006 (from $594,708 to $978,029). However, the  total funds available to Alaska and Vermont decreased by more than 80  percent (from $1.7 million to $207,503 and from $991,182 to $186,885,  respectively), and the funds available to the Birmingham, Alabama, area  decreased 88 percent from 2005 to 2006 (from $3 million to $356,107). In  addition, 18 states were apportioned JARC funds for fiscal year 2006 that  did not receive funds in fiscal year 2005.
Recipients have up to 3 years in which to apply for funds for each fiscal  year. For example, recipients could apply for fiscal year 2006 funds until  September 30, 2008. Any funds not applied for by then lapsed and would  have been reapportioned among all recipients for fiscal year 2009.  Similarly, fiscal year 2007 funds are available until September 30, 2009 and  fiscal year 2008 funds will be available until September 30, 2010.
The amount of available JARC funds is relatively small compared to FTA’s  primary grant programs. For example, FTA’s Urbanized Area Formula  Grant program (Section 5307), which provides transit funding for large and  small urbanized areas, was apportioned $3.9 billion for fiscal year 2008,  while FTA’s Rural Area Formula Grant program (Section 5311) was  apportioned about $416 million in fiscal year 2008. In contrast, the total  amount of JARC funds available for the 3 fiscal years 2006 through 2008 is  $436.6 million.
SAFETEA-LU also requires JARC recipients to fulfill specific requirements  and follow specific processes (see fig. 1):    SAFETEA-LU required that a recipient be designated to award JARC  funds. This recipient is responsible for distributing funds to other  agencies. The governor of each state designated a recipient—almost  always the state department of transportation—for JARC funds at  the state level for small urbanized and rural areas. For large  urbanized areas, the governor, local officials, and public  transportation operators selected designated recipients, often a  major transit agency or metropolitan planning organization (MPO).
SAFETEA-LU required that designated recipients certify that JARC  projects are derived from locally developed coordinated public  transit-human services transportation plans. The coordinated  planning process must include representatives of public, private,  and nonprofit transportation and human services providers and  participation by the general public. In general, among the states we  contacted, either the designated recipient or MPO has taken the lead  in developing coordinated plans in large urbanized areas. For small  urbanized and rural areas, some designated recipients at the state  level have generally delegated responsibility to develop plans to  agencies at the local level, while in others the designated recipients  have taken the lead. Local officials must ensure that appropriate  transportation and human services providers participate in the  process.
Under SAFETEA-LU, designated recipients at the state level must  develop a solicitation process for small urbanized and rural areas to  apply for funds. States must use a competitive selection process to  select projects for these areas. Large urbanized areas must also  develop and conduct a competitive selection process for their  projects. After projects are selected, states and large urbanized  areas must apply to FTA to fund the projects and certify that  selected projects were derived from a locally developed,  coordinated public transit-human services transportation plan.
SAFETEA-LU allows states and large urbanized areas to use 10  percent of JARC funds for administrative activities, including  planning and coordination activities. Under TEA-21, the use of JARC  funds for planning and coordination activities was prohibited.
To ensure designated recipients fulfill their stewardship roles, FTA  requires designated recipients to submit a management plan  describing how they plan to administer the JARC program.  Designated recipients for large urbanized areas submit program  management plans, while state agencies that are designated  recipients for small urbanized and rural areas submit state  management plans. States have submitted management plans in the  past for other transit programs. FTA allows states to amend  existing management plans to include the JARC program.
SAFETEA-LU increased the federal government’s share of capital  costs to no more than 80 percent. Under TEA-21, the federal match  for capital projects was 50 percent, which was inconsistent with the  federal share for capital projects in other FTA programs. As under  TEA-21, JARC recipients must identify and raise 50 percent of the  funds for operating projects. Matching funds may come from other  federal programs that are not administered by DOT, such as TANF  block grants, as well as from non-cash sources, such as in-kind  contributions, employer contributions, and volunteer services.
SAFETEA-LU also requires that two other FTA programs that provide  funding for transportation-disadvantaged populations certify that  projects be derived from a locally developed coordinated human services  transportation plan. One of these, the New Freedom program, was created  by SAFETEA-LU to support new public transportation services and  public transportation alternatives beyond those required by the Americans  with Disabilities Act. According to FTA, the program is intended to fill  gaps between human service and public transportation services and to  facilitate integrating individuals with disabilities into the workforce as well  as full participation in the community. The program provides alternatives  to assist individuals with disabilities with transportation, including  transportation to and from jobs and employment support services. The  second program, the Elderly Individuals and Individuals with Disabilities  program (commonly referred to as the Section 5310 program), has existed  since 1975. The Section 5310 program originally provided formula funding  for capital projects to help meet the transportation needs of elderly  individuals and persons with disabilities. However, in 1991, Congress  expanded the Section 5310 program to allow funds to be used to acquire  services to promote the use of private-sector providers and to coordinate  with other human service agencies and public transit providers. These  purchases are also considered to be capital expenses.
As indicated in tables 2 and 3, Congress apportioned $283.3 million and  $408 million for the New Freedom and the Section 5310 programs,  respectively, from fiscal years 2006 through 2009. Similar to the JARC  program, the New Freedom and Section 5310 programs are relatively small  in comparison with FTA’s regular transit formula programs. Recipients  apply separately for funds for each of these programs.
In our last evaluation of FTA’s progress—our first report under SAFETEA- LU, issued in November 2006—we noted that, in response to our previous  concerns over performance evaluation, FTA was taking steps to further  improve its evaluation process, such as revising the JARC performance  measures. We also noted that FTA was developing its strategies to  evaluate and oversee the program and had not yet issued final guidance to  implement JARC, and states were still working to meet the new  requirements. At that time, 3 states and 9 out of 152 large urbanized areas  had received fiscal year 2006 funds as of the end of that fiscal year; these  funds represented less than 4 percent of the fiscal year 2006 JARC funds  apportioned to states and large urbanized areas. In our report, we  recommended that FTA update its existing oversight processes to include  the JARC program and specify how often it will monitor recipients that are  not subject to its existing oversight processes. FTA agreed to consider  our recommendations and has incorporated oversight provisions for the  JARC program into its review processes. FTA also issued final guidance  implementing the changes to JARC in May 2007. As part of that guidance,  FTA established policies and procedures for agencies to implement the  program and established two performance measures to evaluate the  performance of JARC projects: number of rides and number of jobs  accessed.
section_title: FTA Is Making Progress in Awarding JARC Funds, and Recipients Are Using the Funds Primarily for Operating Services
paragraphs: FTA has awarded 48 percent (about $198.0 million) of JARC funds for  fiscal years 2006 through 2008 to 49 states and 131 of 152 large urbanized  areas. However, about 14 percent of fiscal year 2006 funds lapsed— primarily in small urbanized areas—for various reasons, including delays  in fulfilling administrative requirements under SAFETEA-LU. According to  FTA data, recipients plan to use the funds awarded thus far primarily to  operate transit services as opposed to capital and other projects.
subsections: section_title: FTA Is Making Progress in Awarding Fiscal Year 2006 through 2008 Funds, Although Some Fiscal Year 2006 Funds Lapsed
paragraphs: Overall, FTA has awarded almost half of the apportioned $436.6 million  available for fiscal years 2006 through 2008 (about 48 percent) to 49 states  and 131 of 152 large urbanized areas, as of March 2009. This level  represents significant improvement since GAO’s last evaluation of FTA’s  progress in 2006, when 3 states and 9 large urbanized areas had received  fiscal year 2006 funds. As shown in figure 2, FTA has awarded about $118  million (around 86 percent) of fiscal year 2006 JARC funds, approximately  $56.7 million (around 39 percent) of fiscal year 2007, and around $23.2  million (about 15 percent) of fiscal year 2008. The majority of the fiscal  year 2006 JARC funds (about 64 percent) were awarded in fiscal year 2008  before the September 30, 2008, deadline. Recipients we spoke with who  did not apply for these funds until fiscal year 2008 said they delayed  applying partly because of FTA’s delay in issuing guidance and other  challenges discussed later in the report.
However, about $18.6 million (roughly 14 percent) of fiscal year 2006  funds lapsed and will be reapportioned to all recipients with the fiscal year  2009 JARC funds apportionments. While the largest amount of funds that  lapsed were for large urbanized areas (about $10.9 million, or about 13  percent of the amount allocated for those areas), a greater proportion  lapsed in small urbanized areas (about $5.2 million, or 19 percent of the  amount allocated for those areas). Thirty-three out of 152 large urbanized  areas (about 22 percent) allowed a portion of the fiscal year 2006 JARC  funds to lapse. While 5 out of the 33 large urbanized areas allowed less  than 1 percent of their allocated funds to lapse, about 64 percent of those  recipients allowed all of the allocated funds to lapse. For instance, Miami,  Florida, allowed all of its appropriated JARC funding—almost $2.8  million—to lapse. For small urbanized areas, 11 states and one U.S.  territory had about $5.2 million funds lapse, with 6 states and U.S.  territories having the entire allocated funds lapse. Finally, for rural areas,  five states and one U.S. territory had about 9 percent (about $2.5 million)  lapse. (See app. II for a complete list of areas that allowed fiscal year  2006 funds to lapse.)
According to FTA officials, fiscal year 2006 JARC funds lapsed for various  reasons. Some areas encountered delays in developing the coordinated  public transit human service transportation plan, and did not complete the  plans in time to apply to FTA for fiscal year 2006 funds. (The next section  of the report discusses these challenges in more detail.)
Despite the lapse of fiscal year 2006 funds, FTA is making progress to  award the funds remaining for fiscal years 2007 and 2008 before the  deadlines at the end of fiscal years 2009 and 2010, respectively. According  to FTA, regional and headquarters staff have contacted stakeholders in  areas where funds lapsed to explore ways for these communities to use  the remaining funds. For example, in March 2009, FTA headquarters and  Region 4 staff in Atlanta, Georgia., conducted a conference call with Miami  transit providers and MPOs to discuss strategies for the large urbanized  area to use its remaining JARC funds. During the call participants agreed  to select a designated recipient, finalize coordinated plans, and conduct a  competitive selection in time to apply for the area’s fiscal year 2007 JARC  funds. As of May 2009, the Governor of Florida has selected a designated  recipient and the competitive selection process for JARC projects within  the Miami area is underway.
As a result of such efforts, FTA has awarded more fiscal year 2007 and  2008 JARC funds, relative to the rate at which it awarded fiscal year 2006  funds. For example, FTA awarded about 3.9 percent of fiscal year 2006  funds in the first year of availability, compared with approximately 5.0  percent and 14.3 percent awarded in the first year of available fiscal years  2007 and 2008 funds, respectively. FTA officials and designated recipients  we interviewed attributed the increase in the rate of awarding funds to  various factors, including availability of and improvements to the final  guidance, overcoming the initial learning curve in implementing the  program, and awarding projects on a 2-year funding cycle. FTA expects to  award more than 90 percent of fiscal year 2007 funds—slightly more than  the 86 percent for fiscal year 2006—before the September 30, 2009,  deadline.
section_title: Recipients Plan to Use Awarded Funds Primarily to Operate Existing Transit Services
paragraphs: Recipients have used or plan to use JARC funds primarily to operate or  expand existing transit routes in an effort to target low-income  populations. Recipients have the discretion to use JARC funds for three  types of expenditures: (1) operating assistance to subsidize the cost of  operating new or existing transit services, such as staffing, advertising  costs, insurance and fuel; (2) capital assistance, such as purchasing  vehicles and equipment; and (3) administrative costs. Designated  recipients can use up to 10 percent of allocated JARC funds for  administrative costs, such as the cost to conduct coordinated planning and  competitive selection processes, but have discretion on how to use the  remaining allocated amount—whether for operating assistance or capital  projects. As shown in figure 3, recipients have used or plan to use about  65.3 percent of fiscal year 2006 funds primarily for operating assistance,  compared to about 27.5 percent for capital expenses and 7.2 percent for  administrative costs.
Many recipients we interviewed are using funds to help cover the cost to  operate existing transit routes, or to expand transit services targeted at  low-income populations. For example, the Rochester-Genesee Regional  Transportation Authority, a designated recipient in a large urbanized area  in upstate New York, plans to use JARC funds to operate an existing  reverse commute, fixed route service during evenings and on weekends  from the city of Rochester to employment locations in outlying suburban  areas. Similarly, New Jersey Transit awarded the North Jersey  Transportation Planning Authority funds to offset operating costs for its  demand response transit service in Bergen County, New Jersey  Recipients also plan to use funds to operate other types of transit projects  eligible under JARC, such as bicycle loan or auto repair programs. For  instance, the Southwestern Wisconsin Community Action Program is  currently using JARC funds to operate an auto loan program to assist low- income workers in rural areas in purchasing vehicles for shared rides to  work, while the Kenosha Achievement Center in the Kenosha, Wisconsin,  small urbanized area is using JARC funds to operate a bike loan program  that would provide transportation to jobs for low-income job seekers.
Fewer JARC recipients we interviewed plan to use the funds for capital  assistance. Although JARC provides up to 80 percent of federal funds for  recipients’ capital assistance and 50 percent for operating assistance,  recipients noted that the available funding is not generally sufficient to  start new services and/or purchase vehicles and equipment—both of  which can be costly—and continue operating services after receiving  JARC funds. For instance, representatives of a designated recipient in  Georgia told us that they would like to establish and operate new bus  routes to transport low income workers to a new employment center  being developed. The designated recipient was allocated about $192,000  for fiscal year 2006, but officials indicated that this amount would only  allow them to purchase one transit bus, which typically costs about  $300,000 to purchase and $200,000 per year to operate. The funding would  not cover additional buses or sustain operations beyond 1 year. The  designated recipient may apply for fiscal year 2007 and 2008 funds but  would still have difficulty continuing the routes under current budget  constraints in the region.
Nevertheless, other recipients we contacted do plan to use JARC funds for  capital expenses, such as purchasing a van for a vanpool or a global  positioning system to assist in operating a mobility management program.  For instance, the Coastal Georgia Regional Development Center plans to  use its fiscal years 2006 and 2007 JARC funds to operate 12 regional  vanpools that will serve eight passengers per vehicle and provide two trips  per day in the southern rural areas of Georgia, while the Lower Savannah  Council of Governments plans to use some of its funds to defray the cost  of operating a new mobility management program in its rural and small  urbanized regions. A few designated recipients also indicated that they  plan to use some of their JARC funds to implement such a program.  Finally, many designated recipients chose not to use the funds for  administrative purposes because they wanted to use the funds for  transportation rather than support services.
section_title: JARC Recipients Report Multiple Challenges in Implementing the Program
paragraphs: Recipients and local authorities we interviewed cited multiple challenges  throughout the process for implementing JARC-funded projects. Although  many of these recipients and local authorities have addressed these  challenges and have received JARC funding, a common concern we heard  is that, overall, the amount of effort required to obtain JARC funds is  disproportionate to the relatively small amount of funding available  compared to other transit programs. FTA officials are taking steps to  address these challenges, and noted that some challenges—such as the  amount of funding and flexibility in using JARC funds—are rooted in  statute and would need to be addressed by Congress in the next surface  transportation reauthorization.
subsections: section_title: Initial Delay in Issuing Final Guidance Hindered Implementation
paragraphs: Although many designated recipients we interviewed commented that FTA  has made progress in implementing JARC, some noted that issues with  FTA’s guidance hindered implementation. First, FTA did not issue its final  guidance until May 2007, almost 2 years after SAFETEA-LU was enacted in  August 2005 and 2 months after FTA initially planned to issue it. As we  previously reported, FTA used an extensive public participation process  to develop the guidance and received a large volume of public input,  partially in response to requests from transit agencies and stakeholders.
While this process helped FTA develop the final guidance, it also delayed  its issuance. Consequently, FTA’s interim guidance included a “hold  harmless” provision stating that the final guidance requirements would not  apply retroactively to grants awarded before FTA issued the final  guidance.  Some designated recipients chose to implement JARC programs  using FTA’s interim guidance. Others, however, were hesitant to do so  because of uncertainties in interpreting policies and procedures and chose  to wait for the final guidance. This ultimately reduced the time available  for these recipients to apply for JARC funds appropriated in fiscal year  2006.
Second, some JARC recipients found FTA’s interim and final guidance  vague and overly broad. Designated recipients noted that the guidance did  not provide sufficient specific information on whether a project was  eligible for JARC funds or the standards of oversight for subrecipients.  Specifically, designated recipients in Arizona, California, and Pennsylvania  commented that FTA’s guidance does not provide enough information on  overseeing and managing subrecipents. For example, one recipient was  unsure of the parameters for funding and monitoring JARC auto loan  projects. Recipients were also unsure how to oversee and manage  projects that cross boundaries throughout the region, such as large and  small urbanized and rural areas. For example, a recipient and subrecipient  in Arizona were unsure about how to develop a cost-allocation method for  demand response and fixed route projects that operate across large and  small urbanized and rural boundaries. An FTA official stated that the  guidance was intended to provide a broad framework for implementation  and allow states and large urbanized areas flexibility to administer  programs that best meet local and regional needs without being overly  prescriptive. FTA also noted that the final JARC circular includes  examples and detailed lists to supplement the guidance.
In addition, some designated recipients and an industry association  representative commented that FTA provided inconsistent information.  For instance, one FTA regional office required all designated recipients in  its jurisdiction to submit locally developed, coordinated public transit- human services transportation plans to verify that project applications for  JARC funds were derived from the plans. However, this practice was not  consistent with other FTA regions. FTA subsequently directed regional  offices to instead rely on JARC applicants’ certification that projects were  derived from the plans. They also directed regional offices to confirm that  the individual applicants and projects submitted are included in the  program of projects required to receive JARC funds. An FTA official  acknowledged inconsistent information and interpretation of its guidance  among some regional offices and stated that FTA has been using a  document entitled “Questions and Answers on the Section 5310, JARC,  and New Freedom Programs” posted on its Web site to reduce  inconsistencies among regional offices. An FTA official also noted that the  agency has periodically taken advantage of its regularly scheduled bi- weekly meetings between headquarters and regional staff to clarify JARC  program guidance and to provide additional guidance to regional staff.
section_title: Delays in Identifying Designated Recipients in Some Large Urbanized Areas Contributed to Delays in Awarding Funds
paragraphs: Some recipients commented that delays in identifying designated  recipients in large urbanized areas contributed to delays in awarding fiscal  year 2006 funds and implementing transit projects. Some states and large  urbanized areas did not identify designated recipients until fiscal year  2008. Moreover, although the majority of designated recipients have been  identified, as of September 2009, 5 out of 152 large urbanized areas had not  yet identified a designated recipient; these 5 areas allowed fiscal year 2006  funds to lapse. This may be because prospective designated recipients are  reluctant to take on the role. Officials with the New York Metropolitan  Transportation Authority reported that they did not want to be the  designated recipient primarily because they were not sure they could  fulfill the requirements with the limited amount of funds available to  administer and manage the program. Specifically, SAFETEA-LU allows  non-profit agencies to receive JARC funding and FTA requires that  designated recipients ensure that subrecipients, which could include non- profit agencies, comply with federal requirements. Some non-profit  agencies have not received FTA funds in the past and local officials were  not confident these agencies had the financial capability to manage JARC  funds and comply with FTA’s requirements. These agency officials  expressed concern that they would be held liable if non-profit agencies  ultimately did not comply with those requirements. In particular, many  New York City transit agencies had these concerns and, as a result, the  New York State DOT agreed to become the designated recipient for the  New York City portion of the New York-Newark large urbanized area.
Concerns about taking on the designated recipient role were not limited to  areas without designated recipients. For instance, the Port Authority of  Allegheny County, the major transit agency in the Pittsburgh large  urbanized area, plans to transfer the designated recipient role to the area’s  MPO—the Southwestern Pennsylvania Commission—because the  administrative requirements exceeded its capacity and regional  jurisdiction. Additionally, 8 states—4 of which we contacted—took on  the role of designated recipient for 16 large urbanized areas. According to  officials in New York and Wisconsin, the state departments of  transportation took on the responsibility primarily because they did not  want funds to lapse and local authorities did not want to take on the  responsibilities, respectively. For instance, officials with the MPOs in  Madison and Milwaukee told us they asked the Wisconsin DOT to be the  designated recipient for those large urbanized areas because the state had  experience with administering the program under TEA-21 and the MPOs  had insufficient resources to take on the responsibilities.
Because the process of identifying designated recipients in some areas  took more than 2 years after SAFETEA-LU was enacted, it reduced the  time available for those areas to conduct a coordinated planning process,  develop a coordinated human services transportation plan, conduct a  competitive selection process, and apply to FTA for funds before the  September 30, 2008, deadline to award fiscal year 2006 funds. Designated  recipients that were not identified until fiscal year 2008 were at a  particular disadvantage because they had less time to apply for JARC  funds. Designated recipients in large urbanized areas in California and  Georgia and a subrecipient in Chicago all commented that the process for  identifying and selecting designated recipients ultimately delayed  applications to FTA for fiscal year 2006 funds and hindered implementing  projects.
section_title: Multiple Designated Recipients in Some Areas Led to Additional Steps to Administer Funds and Limited Funding Flexibility
paragraphs: Some recipients indicated that assigning multiple designated recipients to  administer and manage JARC funds has resulted in additional steps to  administer JARC. Under SAFETEA-LU, state agencies must be the  designated recipients for small urbanized and rural areas, while local  agencies, such as a major transit agency or MPO, can serve as designated  recipients in large urbanized areas. However, the jurisdiction of some local  agencies that were selected as designated recipients in large urbanized  areas may include small urbanized and rural areas. Specifically, officials in  Sacramento, Los Angeles, and San Francisco/Oakland in California, and  Phoenix, Arizona, indicated that this infrastructure is disjointed and  confusing because states are responsible for rural and small urbanized  areas that may also be under the jurisdiction of designated recipients for  other FTA programs in large urbanized areas.
For example, the Sacramento Area Council of Governments—the MPO  and designated recipient for Sacramento—has jurisdiction over the large  urbanized area as well as the small urbanized and rural areas in the  region for the federally required Transportation Improvement Program.  Subrecipients that provide transit services for the large urbanized area as  well as rural areas need to apply to both the state and the designated  recipient in a large urbanized area to receive funds for the urbanized and  rural areas as well as report to both the MPO and state.
To facilitate coordination and share resources, some states, such as  Arizona and California, have delegated the administration of JARC  projects in small urbanized areas to designated recipients in large  urbanized areas, while retaining jurisdiction over rural areas. For instance,  California delegated the responsibility for conducting a competitive  selection process to the Metropolitan Transportation Commission in the  San Francisco-Oakland area and the Sacramento Area Council of  Governments in Sacramento for small urbanized areas under those  agencies’ jurisdiction.
While delegating administration of JARC projects in small urbanized areas  to designated recipients in large urbanized areas may facilitate  coordination, it also results in additional work for designated recipients  for both the state and large urbanized areas. As the designated recipient  for small urbanized areas, the state is ultimately responsible for all aspects  of funding distribution and oversight of subrecipients in those areas. Thus,  it must ensure and certify that the statewide competitive selection process  resulted in a fair and equitable distribution of funds. Consequently, states  may want to review and assess projects for small urbanized areas that  were selected as part of the large urbanized area’s competitive selection  process to ensure that they were derived from the locally developed,  coordinated public transit-human services transportation plan. Some  states may want designated recipients for large urbanized areas to apply  for small urbanized area funds through the state’s designated recipient,  rather than directly to FTA. For instance, a designated recipient for a large  urbanized area in California that was delegated responsibility to oversee  the competitive selection process for small urbanized areas instructed the  agency to send its selected JARC projects to the state for additional review  and competition with other small urbanized areas in the state. The state  then applied to FTA for funding. This process increased the time and effort  to award funds for small urbanized areas. As previously mentioned, a  greater proportion of funds lapsed in small urbanized areas, compared to  funds allocated to large urbanized and rural areas. Some designated  recipients suggested allowing states discretion to select designated  recipients for small urbanized and rural areas, rather than requiring the  state to take on that role. However, SAFETEA-LU requires that the state be  the designated recipient for small urbanized and rural areas.
Moreover, although SAFETEA-LU’s formula allocating funds by large and  small urbanized and rural area classifications provides funds to areas that  had not previously received JARC funds, some designated recipients  indicated that the funding allocations between urban and rural areas  limited them from distributing funds where they are most needed. Some  recipients we contacted would like discretion to use funds where they are  most needed in the state and the region. Currently, large urbanized areas  receive more funding than small urbanized and rural areas, since the  funding formula is based on the population and number of eligible low- income residents. In some cases this may meet needs, but officials from  New Jersey Transit commented that transportation needs of New Jersey’s  small urbanized and rural areas have been disproportionately affected by  the formula, making it difficult to meet the transit needs of small  urbanized and rural areas because allocated funds cannot be transferred  from large urbanized areas. Additionally, officials from the Oregon  Department of Transportation indicated that the state could not transfer  funds from its small urbanized areas to its rural areas, even if the state  received more applications from rural areas than from small urbanized  areas. In another case, officials from the Metropolitan Transportation  Commission indicated that they had difficulties awarding JARC funds to  potential recipients in Petaluma, California—a relatively wealthy, small  urbanized area in northern California—because the area did not have a  large concentration of low-income residents and did not qualify for the  funds that were allocated to the area. As mentioned earlier, California was  one of the states in which funds lapsed for small urbanized and rural  areas. Designated recipients in California, New Jersey, and Wisconsin  suggested eliminating the urbanized area classifications established in  SAFETEA-LU and giving local agencies discretion to allocate funds where  they are most needed in the region. According to officials, this would give  designated recipients flexibility to transfer funds to areas that may need  more funds, such as rural areas with fewer resources than large urbanized  areas.
Furthermore, designated recipients in large urbanized areas that cross  state lines—such as New York City, New York and Newark, New Jersey— had to take additional steps to administer the program. Industry  associations noted concerns about how large urbanized areas that crossed  state lines would implement changes to JARC. Although the designated  recipients in multi-state jurisdictions we interviewed indicated that  awarding JARC funds was not as much of an issue as expected, the  process did require additional administrative and coordination efforts. For  instance, in several multi-state large urbanized areas—like Chicago,  Illinois - Northwestern Indiana; Augusta, Georgia -Aiken, South Carolina;  and New York City, New York - Newark, New Jersey—the cities in one of  the states decided not to apply for or use all of the allocated JARC funding.  Specifically, officials in northwestern Indiana, Augusta, and New York City  decided not to apply for or use all of the allocated JARC funding. Each of  these cities transferred JARC funding to the city in the other state to  ensure that the funds would be used. For example, the New York City  Metropolitan Transportation Authority decided not to apply because it  already provides extensive transit services 24 hours a day, 7 days a week  and did not need the relatively small amount of JARC funds available.   However, to accomplish this transfer, the designated recipients had to  agree on how to split the apportionment and notify FTA annually of the  split and the geographic area each recipient would manage. For example,  when New York transferred some of the New York City portion of the  JARC funds to New Jersey so that it could be used for a project in Newark,  officials had to negotiate the formula to use to determine the amount of  the funds to transfer to New Jersey for Newark’s use. These negotiations  took some time, which subsequently delayed New Jersey Transit’s efforts  to award JARC funds in the Philadelphia, Pennsylvania.-Camden, New  Jersey area. In another instance, northwestern Indiana was not able to  use its JARC funding during the summer of 2008 and transferred the funds  to Illinois for Chicago to use. Officials with Chicago’s Regional  Transportation Authority stated that they had to quickly identify projects  to include in its application so that the funds would not lapse.
section_title: Although Recipients Considered Coordination Beneficial, Multiple Factors Make It Difficult
paragraphs: Many state and designated recipient officials we interviewed considered  the coordinated planning process beneficial and worthwhile. Recipients  noted that including stakeholders from transit and planning agencies as  well as human services agencies provided different perspectives and  resources and brought together agencies that traditionally do not work  together. As a result, the coordination process helped identify transit  service needs and gaps. One planning agency stated that the coordinated  planning requirement helped build on efforts it previously had in place  because it compelled agencies to work together to receive federal funds  and forced them to plan more strategically.
However, designated recipients cited multiple factors that challenged  coordination efforts:  Lack of sufficient funds, resources, and expertise  Many designated recipients noted that the limited amount of funds, lack of  resources and, in some cases, lack of planning expertise, made  coordination difficult:    Some designated recipients that used the 10 percent of JARC funds  SAFETEA-LU allows for administration and planning commented  that the amount is insufficient to cover the cost of planning. For  instance, a designated recipient in a large urbanized area in Georgia  hired a consultant to conduct the coordinated planning process and  develop a plan, but the allowance did not cover the cost of the  consultant. In another case, Oregon can use about $59,800—the  allowed amount for fiscal year 2006—for administrative purposes.  However, officials noted that, in total, the state spent about $400,000  to develop coordinated plans for its 46 local and tribal agencies.  Similarly, Arizona obtained a grant from the United We Ride  initiative to help defray—but not entirely cover—the cost to develop  a coordinated public transit-human services transportation plan for  small urbanized and rural areas. Although FTA allows designated  recipients to also combine JARC funds with 10 percent of the funds  from the New Freedom and the Elderly Individuals and Individuals  with Disabilities (commonly referred to as Section 5310) programs,  some designated recipients decided not to use the funds for  administrative activities because they wanted to use the relatively  small amount of allocated funds for transportation services rather  than support services.
Six of the nine state-level designated recipients we spoke with  indicated that rural areas, in particular, have fewer resources and  thus find JARC’s coordinated planning requirements more  challenging than do large and small urbanized areas. One state  official stated that while some rural areas have used Section 5311  rural formula program funds to pay for planning and coordination  costs, others that do not receive other FTA funds have no funds  available for planning and coordination. In other areas, state budget  issues may limit how funds can be used. For instance, Georgia  applied to use JARC funds for administrative purposes, but current  state budget problems have prohibited funds from being used to hire  additional staff to coordinate and develop plans for rural areas.
Rural areas in some states do not have a regional planning infrastructure  or staff with planning expertise to conduct and develop coordinated public  transit-human services transportation plans. For instance, Wisconsin  officials indicated that their state does not have a regional rural planning  infrastructure because the state develops rural area policies and derives  projects from that process. An Illinois official commented that rural areas  had never developed public transportation plans before SAFETEA-LU. The  state hired planning coordinators to help develop coordinated plans in  rural areas because those areas lacked staff with planning expertise.  Nevertheless, recipients in other rural areas indicated that the planning  process did not present challenges in rural areas, and coordinated  planning in rural areas is critical because these areas are isolated and  coordination is critical to providing transit services.
Despite these concerns, many recipients have developed coordinated  public transit-human services transportation plans. These plans will need  to be periodically updated. Recipients noted that challenges in  coordinating and periodically updating plans will continue, particularly if  stakeholders are asked to meet regularly but are not guaranteed to receive  funds, given the limited amount of JARC funding available. Recipients  indicated that the amount of effort required to coordinate and develop a  plan, along with conducting a competitive selection process, is  disproportionate to the small amount of JARC funds available.
Difficulties in engaging human services agencies  Another coordination challenge cited was convincing other organizations,  such as human service agencies, to consistently participate in the planning  process. While designated recipients encourage stakeholders from human  services agencies to participate in the coordination effort, these agencies  are not necessarily required to coordinate. Some designated recipients  have required these agencies to participate in the coordinated planning  process in order to receive funds. However, according to a designated  recipient, the relatively small amount of JARC funds does not offer  sufficient incentive for some agencies to participate. Some designated  recipients suggested that federal agencies, such as the Department of  Health and Human Services, that provide and allow funds to be used for  transportation services should require grantees to participate in  coordinated planning efforts.
According to Department of Health and Human Services officials, federal  officials are making efforts to increase participation by other  organizations, but ultimately, local human services agencies decide  whether or not to participate in the coordinated planning process. Officials  with FTA and other federal agencies, including the Department of Health  and Human Services and the Department of Labor, reported that they have  been working through the Federal Interagency Coordinating Council on  Access and Mobility to encourage federal grantees to participate in  coordinated transportation planning efforts. In 2003, we recommended  that federal agencies develop and distribute additional guidance to states  and other grantees to encourage coordinated transportation by clearly  defining allowable uses of funds, explaining how to develop cost-sharing  arrangements for transporting common clientele, and clarifying whether  funds can be used to serve individuals other than a program’s target  population. While the respective federal agencies have since issued  guidance encouraging grant recipients to share resources with local  transit and planning agencies through the Federal Interagency  Coordinating Council on Access and Mobility, the agencies are still  developing a cost sharing policy. However, officials from the departments  of Labor and Health and Human Services indicated that local human  services agencies may have other competing priorities that limit their  ability to coordinate with transit agencies.
Difficulties integrating JARC planning requirements with existing  planning requirements  Additionally, the different requirements between JARC’s coordinated  public transit-human services transportation plan and the state and  metropolitan transportation plans can result in additional work for  designated recipients. For instance, under SAFETEA-LU, states and MPOs  are not required to include human services providers as stakeholders in  the transportation planning process; states and MPOs are only required to  provide stakeholders a reasonable opportunity to comment on the state  and metropolitan transportation plans. JARC, on the other hand, requires  designated recipients to include human services agencies in the planning  process and have a role in developing the coordinated public transit- human services transportation plan. Some designated recipients indicated  that integrating human services agency coordination for JARC into  existing transportation planning process would help streamline efforts.
section_title: Some Recipients Indicated Challenge in Identifying and Raising Matching Funds
paragraphs: Designated recipients in four states and four large urbanized areas  commented that identifying and generating matching funds has been  challenging, particularly for small urbanized and rural areas. Although the  state and local match for capital projects—20 percent—is less than the  match for operating projects—50 percent—many recipients use JARC  funds for operating projects and thus must identify and raise 50 percent of  the cost of these projects. Some states, such as California and  Pennsylvania, and large urbanized areas such as Chicago, have a dedicated  source of funds, such as state or local sales taxes, to match federal transit  programs, but other states, such as Georgia, and large urbanized areas— such as Milwaukee and Madison in Wisconsin and Savannah and Augusta  in Georgia—do not.
Recipients in locations with dedicated sources of matching funds also  noted that those sources are not always stable. For example, a designated  recipient and subrecipient relying on sales tax revenues dedicated to  transit noted decreased sales tax revenues due to the current economic  slowdown. Moreover, dedicated sources of matching funds are not always  sufficient to cover program costs. For instance, designated recipients in  New York urbanized areas have a dedicated tax that can be used for  capital expenditures but not for operating projects. In addition, two  recipients noted that funds from other federal agencies, such as TANF  funds, are increasingly being used for purposes other than transportation,  reducing the amount available for use as matching funds for JARC  projects.
section_title: Lack of Competition Raises Concern
paragraphs: Although some recipients we contacted indicated that the competitive  process has been fair and transparent, regional FTA officials and a few  designated recipients expressed concern over the lack of competitive  JARC projects in some geographic areas. For instance, the designated  recipient for the Phoenix large urbanized area noted that it received only  one project application for the competitive selection process for fiscal  years 2006 and 2007 funds.
Some designated recipients noted that competition does not exist in  certain areas because some potential subrecipients, particularly nonprofit  organizations, cannot meet federal requirements, limiting the number of  candidates that can apply for JARC funds. Several designated recipients  indicated that nonprofit organizations may not have the capacity to meet  federal mandates, such as FTA’s procurement requirements for purchasing  vehicles, and/or manage FTA funded projects. Additionally, large transit  agencies that had previously received JARC funds are in a better  competitive position, which might discourage smaller transit agencies or  nonprofit agencies from applying. For instance, Maricopa County’s Special  Transportation Services in Phoenix, Arizona, has experience applying for  federal funds, as it has historically received JARC funding since 1999, and  is in a good position to compete. The agency has the resources available,  such as a fleet of shuttle vans that are already in compliance with federal  regulations and requirements. On the other hand, according to the  designated recipient, a nonprofit agency in Phoenix that was new to the  JARC program withdrew its application for funds after determining that it  could not comply with federal regulations and the administrative  requirements for purchasing vehicles.
section_title: Some Recipients Reported That Requirements to Administer and Manage JARC Duplicate Other FTA Program Requirements
paragraphs: Several states and designated recipients in large urbanized areas noted  that the requirements to manage and administer JARC duplicate those of  FTA’s two other relatively small transit programs, New Freedom and  Section 5310. Although some designated recipients voiced concerns about  consolidating the programs because they serve populations with different  needs, others suggested streamlining or consolidating them because they  have similar administrative requirements, such as coordinating with  human services agencies and developing a coordinated plan. FTA allows  designated recipients to streamline and consolidate planning efforts for all  three programs. However, some recipients commented that applying for  the funds separately for these programs is redundant and time consuming.  For instance, a subrecipient in Arizona submitted two identical  applications—one for JARC and one for New Freedom—to the designated  recipient, which in turn submitted similar applications to FTA for both  JARC and New Freedom funds. Designated recipients noted that  consolidating JARC with related FTA programs, such as the New Freedom  and Section 5310 programs, would lessen the amount of administrative  effort required to receive and manage the programs.
Transit industry associations have proposed consolidating JARC with  other federal transit programs to streamline and eliminate the  administrative burden of coordinating and managing various FTA transit  programs. AASHTO proposed consolidating JARC with FTA’s urbanized  area and rural area formula grants programs and combining the New  Freedom program with Section 5310. The American Public Transportation  Association proposed consolidating JARC with New Freedom and Section  5310. Both associations indicated that the intent of the proposals is to  reduce the programs’ administrative requirements while still maintaining  the programs’ intent to provide transportation services to disadvantaged  populations. Nevertheless, associations representing elderly and disabled  persons, such as the Easter Seals, AARP, and Association of Programs for  Rural Independent Living expressed concern that consolidating these  programs would jeopardize advances in providing transportation to these  populations. Officials from all of the associations—those representing the  transportation agencies as well as those representing elderly and disabled  persons—agreed that any changes to the JARC, New Freedom, and  Section 5310 programs need to ensure that the programs’ intent remains  intact.
section_title: JARC Program Recipients Cite Benefits, but FTA’s Plans for Current Evaluations May Have Limitations
paragraphs: Although FTA has not completed an evaluation of the JARC program  under SAFETEA-LU, recipients we spoke with indicated that projects have  benefited low-income individuals by providing a means to get to work.  FTA has improved its approach for evaluating the program since 2000 and  currently has two studies under way to evaluate the JARC program under  SAFETEA-LU. However, both studies—one on performance measures and  another on the program’s economic impacts—may have limitations that  could affect FTA’s assessment of the program.
subsections: section_title: Program Recipients Cite Positive Benefits
paragraphs: Although FTA’s evaluations of the JARC program are not yet complete,  many designated recipients and subrecipients believe that the program is  beneficial because it has helped people access and maintain jobs. State  and local officials that we interviewed cited numerous examples in which  projects benefited individuals because they provided a means for them to  get to work. Officials noted that, without the transportation that JARC  services provided, these individuals would not have been able to obtain  and maintain jobs. For example, officials in Milwaukee, Wisconsin, noted  that JARC bus routes provided 96,000 rides during a 6-month period,  suggesting that many people were using the routes to get to jobs or job  training. Similarly, in New Jersey, surveys of individuals who use JARC  services indicated that 70 percent of them could not get to work without  the transportation services being provided. Despite these individual  experiences, however, designated recipients and other state and local  officials agreed that JARC projects funded under SAFETEA-LU have not  been in effect long enough to determine the projects’ impact. Any  evaluation of the projects would also have to consider program costs, such  as the time and effort designated recipients and others invest to implement  the program and comply with its requirements.
section_title: Collecting Data for JARC Performance Measures Could Be Difficult
paragraphs: FTA has contracted with CES and TranSystems—which have been  evaluating the JARC program since 2003—to further develop and improve  the performance measures established in FTA’s final JARC guidance in  May 2007. The current performance measures include the number of rides  on JARC-funded projects and the number of jobs accessed. Designated  recipients will report data on JARC projects to CES and TranSystems in  May 2009. These data will likely include projects funded under SAFETEA- LU, as most of the projects implemented under SAFETEA-LU were  awarded in fiscal year 2008. FTA officials anticipate a report in September  2009.
However, limitations inherent in the performance measures could affect  the usefulness of this evaluation:    Actual or estimated number of rides (as measured by one-way trips):  According to designated recipients and other state and local agency  officials we spoke with, determining the number of rides to access  jobs presents challenges because individuals use fixed route  services for many reasons in addition to traveling to work, including  shopping and medical appointments. For example, for projects that  provide bus service to shopping malls, determining whether people  are traveling to reach jobs at the malls, shop, or go to restaurants is  difficult. In addition, CES and TranSystems noted that anyone can  use these services, not just low-income populations. Although  transit agency officials noted that people are not comfortable  providing information on their income, FTA officials noted that they  are not asking designated recipients to report the number of riders  served or the incomes of these riders. FTA officials also noted that  because SAFETEA-LU requires that JARC projects be derived from a  coordinated plan identifying priorities to meet the transportation  needs of low-income individuals traveling to employment or related  activities, they believe they can presume that projects serve  predominantly low-income populations. Nevertheless, because  anyone can use JARC services, FTA will not know with certainty  whether the targeted population is using the services to find work or  better paying jobs.
Number of jobs accessed: Although FTA does not plan to have  designated recipients provide information on the number of jobs  accessed, CES and TranSystems representatives, designated  recipients, and other local officials we spoke with expressed  concerns about determining the number of jobs accessed. They  noted that assessing this performance measure is difficult because  many designated recipients and local agencies do not have the  information necessary to determine the number of jobs accessed in  a given area by people using JARC services. Even if agencies could  determine the number of jobs accessed, agencies would likely  calculate it differently, resulting in inconsistent information. For  example, while one official indicated his agency could survey riders,  others indicated they would estimate the number of jobs accessed  based on employment data or the number of businesses in the area.
FTA officials and CES and TranSystems representatives explained that,  rather than ask designated recipients to provide the number of jobs  accessed, they intend to request that designated recipients provide data on  the geographical areas in which they provide JARC services. For fixed  route projects, designated recipients will provide information on the  geographic area surrounding the length of the route. For demand response  services, designated recipients will provide the geographic area—such as  the state or county—in which the service is provided. CES and  TranSystems will use this information to estimate the number of jobs  accessed. CES and TranSystems officials noted that, in some cases, the  actual number of jobs accessed is known. For example, a subrecipient in  Ohio provides transportation that only serves temporary employees  traveling to jobs in a manufacturing plant. Consequently, the provider  knows the number of jobs being accessed and can report that number  rather than information on the geographical area.
In addition to limitations in the performance measures, the method to  estimate the number of jobs accessed has limitations. CES and  TranSystems plan to use the geographic data to calculate a very rough  estimate of the number of jobs accessed. CES and TranSystems will use a  Census Bureau program, the Longitudinal Employer-Household Dynamic  (LEHD), to estimate the number of jobs accessed by calculating the  number of jobs in a given geographical area. For example, for fixed route  services, CES and TranSystems will estimate the number of jobs within a  ½-mile “zone” along the route, i.e., ¼-mile on either side of the route. For  demand response services, CES and TranSystems will estimate the  number of jobs within a geographical unit, such as the county in which a  service is provided. According to CES and TranSystems officials, this  approach only estimates the number of jobs accessed at a national level  and cannot be used to estimate the number of jobs at a state or local level.  This approach has other limitations:    The LEHD program does not include information from all 50 states.
As of September 2008, 47 states supplied data. Of those, 42 were  included in the program.
For demand response services, CES and TranSystems can estimate  the total number of jobs and low-wage jobs within specific  geographic boundaries, such as a county or state. However, if the  demand response service area does not correspond directly to  specific geographic units, job information is not available.
FTA officials acknowledged these limitations and noted that CES and  TranSystems have been working with FTA to improve the quality of the  jobs accessed measure. Specifically, CES and TranSystems noted that this  performance measure actually estimates the potential number of jobs,  which overstates the number of jobs accessed. Consequently, CES and  TranSystems developed two alternatives:  translating ridership into jobs reached by assuming that individuals  make round trips when traveling for work-related purposes, and  dividing the number of trips by two; and    comparing theoretical capacity to jobs accessed by determining the  number of individuals who could be served and dividing by two  (again assuming round trips).
CES and TranSystems noted that each of these approaches have  advantages and disadvantages. For example, while the first alternative  directly translates ridership into jobs, it also assumes that all riders are  traveling to jobs, which is not realistic. Moreover, it does not consider that  different people use services on different days. As a result, the estimates  could misstate the number of jobs accessed. The second approach, which  compares theoretical capacity to jobs accessed, considers the transit  system’s capacity. However, CES and TranSystems acknowledge that this  approach may not be realistic as services are not necessarily filled to  capacity while in operation. Although these approaches attempt to address  the weaknesses of the current efforts to estimate jobs accessed, they could  still misstate the extent to which the target population benefits from the  JARC program.
CES and TranSystems have also developed measures for other JARC  services allowed under SAFETEA-LU that cannot be measured using the  number of riders and number of jobs accessed, such as informational  services and capital projects. CES and TranSystems are using a matrix to  capture key information regarding the projects such as the number of  requests for information services mobility managers received or the  number of additional vehicles purchased.
section_title: Evaluation of Economic Outcomes of JARC Programs Has Limitations in Survey and Analysis Design
paragraphs: The second study, conducted under contract with the University of Illinois  at Chicago (UIC), will focus on analyzing the economic impact of the  JARC program using data from a survey of JARC service users, program  managers, and coordinated human services transportation plan  participants. As of May 2009, researchers were in the process of finalizing  the survey instruments for this study. FTA expects UIC to issue a report in  the spring of 2010.
According to FTA officials and UIC researchers, the survey design and  analysis for the planned 2010 report will use a methodology similar to a  June 2008 survey-based economic analysis that UIC conducted on JARC  outcomes under TEA-21. In the 2008 study, the researchers estimated the  benefits and costs associated with the program. Potential benefits of the  JARC program include higher paying jobs that participants may gain as a  result of being able to travel to areas with better paying jobs. Potential  costs include those associated with operating the program.
However, we noted several limitations in the 2008 study, including  weaknesses in the design of the survey as well as the analysis of data  obtained from the survey. Although all surveys are potentially subject to  sources of error, the researchers did not use standard practices that would  help minimize these sources of error when developing and implementing  the survey used in the 2008 report. This limitation could affect the  reliability of the survey data used to estimate the economic impacts.
Specifically, the researchers may have overstated the benefits to the target  population.
For example, the survey estimates were reported as if they were based on  a probability sample and were generalizable to the population that the  JARC program targets. However, the estimates were not based on a  probability sample and, therefore, should not be generalized. In addition,  they did not disclose this fact or take it into account when developing  overall economic impacts. According to FTA officials, the researchers  were careful to not generalize the results of their survey research. While  the report does note that generalizing the results is difficult, the report  made several conclusions that, as written, appear to apply to the  population of JARC users as opposed to the survey sample. For example,  the report concluded that employment transportation services are  providing valuable services to users and that those services are being  appropriately targeted. In addition, the report indicates that the individuals  using the services are greatly dependent on them, and that the benefits to  the users are high and likely to persist over time. However, the report does  not qualify the results to clarify that they apply only to the users surveyed.   Without this qualification, the report appears to extend the results to all  users, which would be inappropriate because the users surveyed were not  selected as part of a probability sample. The absence of this qualification  thus limits the usefulness of their assessment. In addition, the researchers  did not consider the need to qualify the results when developing overall  economic impacts.
In addition, the survey used in the 2008 study is subject to nonsampling  errors, including coverage error, non-response error, and measurement  error:    The 2008 survey is subject to coverage error, which results when all  members of the survey population do not have an equal or known  chance of being sampled for participation. Standard practice is to  note to whom and when the surveys are disseminated. For example,  if the transportation system providing JARC services operates 24  hours a day, researchers would have to survey across all days and  time frames. Otherwise, individuals using the service on days and  times that researchers do not survey would have a zero chance of  being selected. The researchers indicated that they rode the selected  services for 6 to 12 hours so they could cover at least one if not both  rush-hour periods and, where appropriate, they also rode during off- peak hours including late night and early morning. In addition,  researchers said that in a few cases they administered surveys over  multiple days to ensure that they surveyed a sufficient number of  respondents. However, the researchers did not include in the study a  detailed sampling plan that would fully explain how coverage issues  were addressed. As a result, the extent of coverage error is  unknown, and the 2008 survey results should not be generalized to  all JARC users.
The 2008 survey also suffers from nonresponse error, which results  when people responding to a survey differ from sampled individuals  who did not respond, in a way that is relevant to the study. Standard  practice to minimize this type of error includes using a systematic  sampling approach when disseminating surveys and noting, to the  extent possible, who is not participating, to see if non-respondents  differ from respondents. For the June 2008 study, UIC researchers  indicated that they boarded buses and developed a rapport with  some riders. However, the researchers acknowledged that not all  riders were willing to complete the survey. In addition, the study  does not identify the survey response rate and did not consider  potential differences between respondents and nonrespondents.  Without this information, the extent to which the estimates are  biased is unknown.
Finally, the wording for the questions used in the 2008 survey may  have resulted in inaccurate or uninterpretable responses. In general,  standard practice includes pretesting and technical review of the  instrument before administering to help minimize measurement  error. Although the researchers indicated that they pretested the  survey instrument and made changes based on the pretests and  believed that the pretest was thorough, we found obvious  weaknesses in the survey instrument. For example, we found that  some response categories in the survey were not mutually exclusive  or exhaustive, questions appeared ambiguous, and instructions for  responding were not clear.
Collectively, we believe that these potential sources of error raise  questions about the validity of the survey data as it was used to estimate  the economic effect of the JARC program in the 2008 study. We found  similar limitations in the draft survey instrument that the researchers have  proposed to use for the 2010 study and provided specific technical review  feedback to FTA and the researchers regarding these limitations.  FTA  officials indicated that the researchers had made numerous changes that  incorporated our comments as well as the results of pretests and their own  internal reviews.
We also identified limitations in the economic analysis used to estimate  the benefits and costs of the JARC program in the June 2008 study. For  example, the researchers used a before-and-after approach to analyze the  benefits and costs. That is, the program was analyzed in terms of its  effect on individuals (for example, on changes in earnings) before and  after using the service. However, this approach does not indicate what  would have happened without the program. For example, an individual’s  earnings may have increased over time even without the program. The  researchers said that because they implemented the survey just after the  JARC service started, they believe they primarily captured the program’s  effects. The researchers also indicated that they plan to refine the survey  questions for the next study to more precisely capture the program’s effect  and exclude significant life events that might also affect an individual’s  earnings.
In addition, the researchers found that, overall, the net benefits of the  program are positive. However, when analyzing more specific aspects of  the program, such as the benefits and costs of fixed route and demand  response services, the researchers reported that the program’s net benefits  are negative. The researchers attribute this conflicting result to their use  of averages in computing net benefits and indicated that they used  averages to smooth out irregularities in the survey responses. For  example, the study indicates that the survey data had a wide distribution  with some large positive and negative values (for example, some survey  respondents may have lost higher-paying jobs before using the JARC  service and took a lower-paying job after using the service.) However, the  extent to which the reported irregularities in the survey data are  reasonable differences in responses between riders or are due to the  survey limitations discussed above is not clear. In addition, the reported  economic results make it difficult to ascertain whether the program is  generating positive net benefits and whether it is an efficient use of  society’s resources.
The researchers acknowledged some of these limitations and indicated  they have taken steps to improve their research design for the current  study, such as incorporating changes into their survey instrument. They  also indicated that they plan to make other improvements.  We believe that  changes to address the limitations could improve the usefulness of the  results in assessing the economic effect of the JARC program.
Nevertheless, FTA does not have a comprehensive process in place to  ensure that evaluations of the impact of the JARC program use generally  accepted survey design and data analysis methodologies. Although FTA  officials indicated that an FTA economist reviewed the researchers’  proposed data collection and evaluation methodology at the beginning of  the project, FTA did not review the draft report. FTA officials indicated  that they did not have the expertise to do so and noted that another  entity—such as the Bureau of Transportation Statistics within DOT’s  Research and Innovative Technology Administration—would need to  assist with this type of evaluation. Since the study was published in 2008,  FTA officials said that the results did not inform FTA’s decisions about  how to implement the JARC program. However, FTA indicated that the  results of the study as well as other evaluations contribute to discussions  on the program’s future.
section_title: Conclusions
paragraphs: FTA has made progress in awarding JARC funds since Congress passed  SAFETEA-LU in 2005, although FTA’s delay in issuing final guidance and  other challenges contributed to a lapse in some fiscal year 2006 funds.  Now that the final guidance has been issued and recipients have had  experience implementing the program, the expectation is that more fiscal  year 2007 and 2008 funds will be awarded to implement more projects, and  accordingly, less funds will lapse in the future.
Recipients have faced several challenges in implementing JARC. A  message we consistently heard from designated recipients and  subrecipients is that the requirements for the current program are  extensive considering the relatively small amount of funding available.  Although FTA and recipients are becoming accustomed to the new  formula program and its requirements—which could lessen the severity of  these challenges in the future—recipients told us that they continue to  face challenges in a number of circumstances, such as when:    designated recipients for large urbanized areas have jurisdiction  over small urbanized and/or rural areas and when the service  provided by an individual transit provider overlaps two or more of  these areas;    designated recipients are responsible for ensuring that organizations  that do not traditionally receive FTA funding comply with FTA  requirements;  local agencies, particularly those in rural areas, have limited staff,  funding, and/or expertise needed to update coordinated public  transit-human services transportation plans; and    JARC requirements duplicate the requirements for other programs,  such as New Freedom and Section 5310.
The results of FTA’s evaluations of the JARC programs under SAFETEA- LU may have limitations that could affect FTA’s assessment of the  program. FTA’s current performance measures—number of rides and  number of jobs accessed—have limitations that could misstate the  program’s performance. FTA’s ongoing study of JARC’s economic  outcomes, conducted by UIC, may also have limitations if it utilizes the  same survey design and data analysis methodology used in UIC’s June  2008 study of the JARC program under TEA-21. While FTA does not have  the expertise to review the methodologies used in these studies, other  entities, such as the Bureau of Transportation Statistics within DOT’s  Research and Innovative Technology Administration, could assist with this  review. Recognizing that FTA has improved its evaluation approach over  time and that the JARC program is relatively small compared with FTA’s  regular transit formula programs, drawing on this expertise within DOT  could provide additional assurances that the methodologies used in the  evaluations follow generally accepted survey design and data analysis  practices without expending significant additional resources.
section_title: Recommendations
paragraphs: We recommend that the Secretary of DOT direct the FTA to:    Determine what actions FTA or Congress could take to address the  challenges agencies have encountered. For example, these actions  could include providing more specific guidance to assist large  urbanized areas with jurisdiction over small urbanized or rural  areas, or suggesting that Congress consider consolidating the  application processes for JARC and other programs with similar  requirements.
Ensure that program evaluations use generally accepted survey  design and data analysis methodologies by conducting a peer review  of current and future program evaluations, including UIC’s current  study of the JARC program. This review could be conducted with  the assistance of another agency within DOT, such as the Bureau of  Transportation Statistics within DOT’s Research and Innovative  Technology Administration.
section_title: Agency Comments
paragraphs: DOT reviewed a draft of this report and provided comments by e-mail  requesting that we incorporate information providing additional  perspective on FTA’s progress in implementing the JARC program,  including its evaluations of the program, which we have done. For  example, DOT officials noted that FTA’s current evaluation framework  responds to prior GAO concerns by using an access to jobs measure rather  than an access to employment sites measure. We agree that FTA’s current  methodology for evaluating the JARC program—although still limited in  some respects—represents an improvement over the agency’s previous  approaches and that the agency has been responsive to GAO’s prior  concerns.  DOT also provided technical corrections, which we have  incorporated as appropriate.
We are sending copies of this report to congressional committees with  responsibility for transit issues; the Secretary of Transportation; the  Administrator, Federal Transit Administration; and the Director, Office of  Management and Budget. In addition, the report will be available at no  charge on the GAO Web site at http://www.gao.gov.
If you have any questions regarding this report, please contact me at (202)  512-2834 or at wised@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 III.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: We are mandated to evaluate the Job Access and Reverse Commute  (JARC) program every 2 years under the Safe, Accountable, Flexible,  Efficient Transportation Equity Act-A Legacy for Users (SAFETEA-LU).   This report addresses (1) the extent to which FTA has awarded available  JARC funds for fiscal years 2006 through 2008 and how recipients are  using the funds since the changes went into effect under SAFETEA-LU, (2)  the challenges recipients have faced in implementing the program, and (3)  how FTA plans to evaluate the JARC program.
To determine the extent to which FTA awarded available JARC funds, we  collected and analyzed JARC grants award data from FTA’s Transportation  Electronic Awards Management (TEAM) System. To assess the reliability  of TEAM data, we (1) reviewed existing documentation related to the data  source and (2) obtained information from the system manager on FTA’s  data reliability procedures. We also brought discrepancies we found in the  data to FTA officials’ attention so they could resolve them before we  conducted our analyses. We determined that the data were sufficiently  reliable for the purposes of our report. To examine how recipients have  used JARC funds since SAFETEA-LU went into effect, we interviewed 26  designated recipients—9 states and 17 agencies representing large  urbanized areas—and 16 subrecipients that were selected from a  nonprobability sample. Table 4 lists the 26 designated recipients and table  5 lists the 16 subrecipients we interviewed.
We collected and reviewed information from these recipients on the  different types of JARC projects being planned or implemented, including  demand response and fixed route transit services, auto loan projects,  mobility management services, and vanpool services. We selected the  designated recipients based on a diverse range of criteria that included  states and large urbanized areas that:  received an increase or a decrease in JARC funds as a result of  changing to the formula program;    were previously interviewed for our November 2006 report;    had awarded all or portions of fiscal year 2006 funds, as of May 2008;    had not identified a designated recipient as of May 2008; and    FTA and industry association officials suggested.
We also chose large urbanized areas that crossed multiple states and  considered the geographic locations of states and large urbanized areas to  obtain a wider range of geographic coverage and dispersion. We selected  subrecipients that covered the three types of areas that were apportioned  JARC funding under SAFETEA-LU—large and small urbanized as well as  rural areas—and were based on recommendations from designated  recipients. These interviews cannot be generalized to the entire JARC  recipient and stakeholder population because they were selected from a  non-probability sample.
To identify the challenges recipients have encountered in implementing  the program, we interviewed officials from our selected non-probability  sample of designated recipients and subrecipients as well as 19  stakeholders, such as metropolitan planning organizations and local public  transit agencies, to obtain their views on challenges associated with  implementing the JARC program. Table 6 lists the 19 stakeholders we  interviewed.
In addition, we interviewed the applicable FTA regions responsible for the  states and large urbanized areas we visited to obtain their perspective on  challenges identified in the region. We also interviewed officials from  industry associations, including the American Association of State  Highway and Transportation Officials (AASHTO), the American Public  Transportation Association, the Community Transportation Association of  America, and the National Association of Regional Councils to identify  challenges faced by the agencies these associations represent. Our  interviews with AASHTO included discussions with officials from state  departments of transportation from California, Illinois, Iowa, New York,  North Dakota, Oregon, and Texas. We summarized our interview  responses to identify common challenges in implementing the program.  We also reviewed relevant laws and regulations, including SAFETEA-LU  and FTA’s final guidance on administering JARC, and other FTA  information, such as the Frequently Asked Questions document posted on  FTA’s Website, to clarify the guidance. To identify challenges faced by  human services agencies associated with the coordinated human services  transportation planning process, we interviewed officials from the U.S.  Department of Labor and U.S. Department of Health and Human Services.  Additionally, we interviewed officials of associations representing the  elderly and disabled, including Easter Seals, AARP, the Association of  Programs for Rural Independent Living, and North Country Independent  Living to obtain their perspectives on consolidating JARC with other FTA  transit programs, such as the New Freedom, Elderly Individuals and  Individuals with Disabilities, and urbanized and rural area programs.
To determine how FTA plans to evaluate the JARC program, we reviewed  previous evaluations and interviewed officials from FTA and two  contractors, TranSystems/CES and the University of Illinois at Chicago  (UIC), that are evaluating the JARC program. For each evaluation, we  assessed the contractors’ scope and methodology. Specifically, for the  TranSystems/CES evaluation, which focuses on JARC performance  measures, we determined the contractor’s plans to collect and analyze  data on JARC projects. We also interviewed designated recipients,  subrecipients and other state and local officials to obtain their  perspectives on FTA’s JARC performance measures. For the UIC  evaluation, which focuses on JARC’s economic impact and outcomes, we  reviewed UIC’s June 2008 evaluation of the JARC program under TEA-21  using standard survey and economic principles and practices as criteria,  and interviewed UIC researchers to identify similarities and differences  between UIC’s methodologies for the prior and current studies and the  implications those methodologies could have on UIC’s current evaluation.  We also reviewed and assessed the survey document UIC used on the prior  evaluation as well as the survey documents UIC plans to use in the current  study and provided feedback to the researchers.
section_title: Appendix II: Summary of Areas with Lapsed Fiscal Year 2006 JARC Funds
paragraphs: Lapsed Amount (percent)
Aguadilla-Isabela-San Sebastian, Puerto Rico  $ 530,843 (100%)
Daytona Beach-Port Orange, Florida  Philadelphia, Pennsylvania-New Jersey-Delaware- Maryland   406,084 (100%)  238,265 ( 74.9%)  14,105 (18.8%)  191,671 (100%)  149,168 (30.6%)  136,539 (100%)  18,975 (12.4%)  152,079 (100%)  154,803 (100%)  116,718 (100%)  118,352 (100%)  296,056 (100%)  188,181 (100%)  125,080 (100%) 2,798,658 (100%)  307,613 (52.5%)  110,760 (100%)  162,591 ( 100%)  156,161 (7.2%)
Port St. Lucie, Florida   134,102 (100%)  138,244 (100%)
Lapsed Amount (percent)  108,520 (100%)  292,557 (90.0%)  347,894 (33.9%)  3,175,710 (100%)  178,704 (100%)  130,784 (100%) $10,879,217 (76.8%) $10,879,217 (13.3%)
Small urbanized areas in the state  $1,050,607 (36.9%)  47,028 (100%)  51,652 (100%)  18,627 (2.8%)
Total allocated to small urbanized areas   250,000 (31.5%)  142,431 (100%)  37,708 (100%) 426,704 ( 83.1%)  550,122 (63.1%)  2,571,505 (100%) 1,535 (1.2%) 97,515 (100%) $5,245,434 (59.8%) $5,245,434 (19.2%)
Lapsed Amount (percent)
Non-urbanized, rural areas in the state  880,209 (63.2%)
Total allocated to non-urbanized rural areas  60,739 (100%) 312,252 (57.1%) 862,267 (62.6%) 354,265 (100%) $2,469,732 (66.2%) $2,469,732 (9.0%)
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: Other key contributors to this report were Sara Vermillion (Assistant  Director), Lynn Filla-Clark, Kathleen Gilhooly, Timothy Guinane, Jennifer  Kim, Heather May, Jaclyn Nelson, Karen O’Conor, Lisa Reynolds, Terry  Richardson, and Amy Rosewarne.