Public Transportation: Better Data Needed to Assess Length of New Starts Process, and Options Exist to Expedite Project Development
Published: 2009-08-06T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The New Starts program is an important source of new capital investment in mass transportation. To be eligible for federal funding, a project must advance through the different project development phases of the New Starts program, including alternatives analysis, preliminary engineering, and final design. The Federal Transit Administration (FTA) evaluates projects as a condition for advancement into each project development phase of the program. FTA has acted recently to streamline the process. This report discusses the (1) time it has generally taken for projects to move through the New Starts process and what Congress and FTA have done to expedite the process and (2) options that exist to expedite the process. In response to a legislative mandate, GAO reviewed statutes, FTA guidance and regulations, and project data. GAO also interviewed Department of Transportation (DOT) officials, projects sponsors, and industry stakeholders.
section_title: What GAO Found
paragraphs: Insufficient data are available to describe the time it has taken for all projects to move through the New Starts process. Nevertheless, 9 of 40 projects that have received full funding grant agreements since 1997, and had complete data available, had milestone dates that ranged from about 4 to 14 years to complete the project development phases. However, the data from these 9 projects are not generalizeable to the 40 New Starts projects. FTA has not historically retained all milestone data for every project, such as the dates that project sponsors apply to enter preliminary engineering and FTA's subsequent approval. Although not required by its records retention policy, FTA has retained milestone data from some projects longer than 2 years. However, GAO was unable to obtain complete and reliable project milestone data from FTA. FTA officials acknowledged that, while not historically perfect, the agency has retained sufficient milestone data to help manage the New Starts program. Nevertheless, recognizing the importance of having complete milestone data, FTA has taken several steps in recent years to more consistently collect and retain such data. In addition, GAO found that project sponsors do not consistently retain milestone data for projects that have completed the New Starts process. Congress and FTA have taken action to expedite projects through the New Starts process. For example, legislative action created the Public-Private Partnership Pilot Program (Penta-P) to study the benefits of using public-private partnerships for certain new fixed-guideway capital projects, such as accelerating project delivery. In addition, FTA has implemented administrative changes to expedite the New Starts process. For example, FTA has developed and offered training workshops for project sponsors and has introduced project delivery tools. These tools include checklists for project sponsors to improve their understanding of the requirements of each phase of the New Starts process. Project sponsors and industry stakeholders GAO interviewed identified options to help expedite project development within the New Starts program. These options include tailoring the New Starts evaluation process to risks posed by the projects, using letters of intent more frequently, and applying policy and guidance changes only to future projects. Each option has advantages and disadvantages to consider. In addition, FTA must also strike the appropriate balance between expediting project delivery and maintaining the accountability of the program. For example, by signaling early federal support of projects, letters of intent could help project sponsors use potentially less costly and time-consuming alternative project delivery methods, such as design-build. However, such early support poses some risk. It is possible that with more frequent use of letters of intent, FTA's commitment authority could be depleted earlier than expected, which could affect the anticipated funding stream for future projects. Furthermore, some options, like combining one or more statutorily required project development phases, would require legislative action.

section_title: Letter
paragraphs: Since the early 1970s, much of the federal government’s share of new  capital investment in mass transportation has come through the Federal  Transit Administration’s (FTA) New Starts program. Through this  program, FTA identifies and recommends new fixed-guideway transit  projects for grants, typically through full funding grant agreements  (FFGA). Over the last decade, the New Starts program has provided state  and local agencies with over $10 billion to help design and construct  transit projects nationwide.
The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A  Legacy for Users (SAFETEA-LU), which authorized the New Starts  program through fiscal year 2009, identifies criteria for how FTA evaluates  and rates projects. FTA must prioritize projects for funding by evaluating,  rating, and recommending potential projects on the basis of specific  financial commitment and project justification criteria—including mobility  improvements, cost-effectiveness, economic development effects, land  use, environmental benefits, and operating efficiencies. Using these  statutorily identified criteria, FTA evaluates potential projects annually  and as a condition for advancement into each phase of the New Starts  process, including preliminary engineering, final design, and construction.  FTA refers to projects in the preliminary engineering or final design  phases as being in the “pipeline” through which successful projects  advance to receive funding.
We have previously identified FTA’s use of a rigorous and systematic  evaluation process to distinguish among proposed New Starts investments  as a model for other transportation programs. However, we and other  stakeholders and policymakers have also identified challenges facing the  New Starts program. For example, our past reviews found that many  program stakeholders thought that FTA’s process for evaluating New  Starts projects was too time consuming, costly, and complex. These issues  and the upcoming reauthorization of all surface transportation programs,  including the New Starts program, have led stakeholders and  policymakers to examine the existing evaluation and rating process and  consider potential modifications and other options to reduce the  complexity, cost, and time it takes for a New Starts project to go through  the pipeline.
We are required by SAFETEA-LU to report each year on FTA’s processes  and procedures for evaluating, rating, and recommending New Starts  projects for federal funding and on FTA’s implementation of these  processes and procedures. This report discusses the (1) time it has  generally taken for proposed projects to move through the New Starts  process, and what Congress and FTA have done to expedite the process,  and (2) options that exist to expedite the process. In addition, appendix I  contains an overview of FTA’s fiscal year 2010 New Starts Annual Report  and budget request. To address these objectives, we reviewed SAFETEA- LU and other New Starts statutory requirements, FTA guidance and  regulations governing the New Starts program and other FTA documents,  including the annual New Starts report, and interviewed transportation  experts, transit consultants, transit industry associations, and Department  of Transportation (DOT) officials about the time it takes for a New Starts  project to move through the New Starts process, as well as the options  that exist to expedite the process. We also interviewed 9 project sponsors  about 10 projects. We selected these projects based on a range of  characteristics, including: (1) timing (i.e., when projects received a FFGA);  (2) mode (i.e., heavy rail, light rail, or bus); (3) scope (i.e., the total cost of  the project); and (4) geographic area. In addition, we gathered, and took  steps to verify, FTA data on project milestone approval dates to determine  how long the 40 projects that received a FFGA after June 1997 took to  complete the New Starts process. We also attempted to gather data  directly from project sponsors on project milestone approval and  application dates for these 40 projects to determine how long it took  projects to complete the New Starts process. Appendix II contains  additional information about our scope and methodology. For this report,  we did not consider how projects are rated or examine the efficacy of  FTA’s evaluation measures. We conducted this performance audit from  January 2009 to August 2009, in accordance with generally accepted  government auditing standards. Those standards require that we plan and  perform the audit to obtain sufficient, appropriate evidence to provide a  reasonable basis for our findings and conclusions based on our audit  objectives. We believe that the evidence obtained provides a reasonable  basis for our findings and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: FTA generally funds New Starts projects through FFGAs, which are  required by statute to establish the terms and conditions for federal  participation in a New Starts project. FFGAs also define a project’s scope,  including the length of the system and the number of stations; its schedule,  including the date when the system is expected to open for service; and its  cost. For projects to obtain FFGAs, they must emerge from a regional,  multimodal transportation planning process.
The early stages of the New Starts project development process— alternatives analysis and much of preliminary engineering—are carried out  in concert with the metropolitan planning process specified by SAFETEA- LU and the environmental review processes required by the National  Environmental Policy Act of 1969 (NEPA). Alternatives analysis studies  are a corridor-level analysis of a range of alternatives designed to address  locally-identified mobility and other problems in a specific transportation  corridor. The alternatives analysis phase culminates in the selection of a  locally preferred alternative (LPA), which is the New Starts project that  FTA evaluates for funding.
After a locally preferred alternative is selected, the project sponsor  submits an application to FTA for the project to enter the preliminary  engineering phase. During the preliminary engineering phase, project  sponsors refine the design of the locally preferred alternative, taking into  consideration all reasonable design alternatives and estimating each  alternative’s costs, benefits, and impacts (e.g., financial or environmental).  Further, project sponsors are required to complete the NEPA  environmental review process in order to receive federal funding.  Specifically, FTA interprets NEPA to require, as part of the NEPA process  for evaluation of the alternatives, an environmental review document  with information on each alternative’s benefits and costs relating to the  New Starts evaluation. When the preliminary engineering phase is  completed and federal environmental requirements are satisfied, FTA may  approve the project’s advancement into final design, after which FTA may  recommend the project for a FFGA and proceed to construction. FTA  oversees grantees’ management of projects from the preliminary  engineering phase through the construction phase (see fig. 1). This project  management oversight is conducted by FTA staff, working closely with its  project management oversight contractors (PMOC), to provide continual  monitoring and assessment of projects’ scope, schedule, and budget, and  of its sponsor’s technical capacity.
To help inform administration and congressional decisions about which  projects should receive federal funds, FTA currently distinguishes among  proposed projects by evaluating and assigning ratings to various statutory  evaluation criteria—including both project justification and local financial  commitment criteria—and then assigning an overall project rating. (See  fig. 2.) These evaluation criteria reflect a broad range of benefits and  effects of the proposed project, such as cost-effectiveness, as well as the  ability of the project sponsor to fund the project and finance the continued  operation of its transit system. FTA has developed specific measures for  each of the criteria outlined in statute. However, FTA currently assigns a  50 percent weight to both the cost-effectiveness and the land use criteria  when developing the project justification summary rating. The other  project justification criteria are not weighted, although the mobility  improvements criterion is used as a “tiebreaker.” On the basis of their  evaluation measures, FTA assigns proposed projects a rating for each  criterion and then assigns a summary rating for local financial  commitment and project justification. These two ratings are averaged  together, and FTA assigns each project a “high,” “medium-high,”  “medium,” “medium-low,” or “low” overall rating, which is used to rank  projects and determine which projects to recommend for funding.
Projects are rated at several points during the New Starts process,  including as part of the evaluation for entry into the preliminary  engineering and final design phases, and they are rated yearly for inclusion  in the New Starts Annual Report. The administration uses the FTA  evaluation and rating process, along with the phase of development of  New Starts projects, to decide which projects to recommend to Congress  for funding. Although many projects receive a summary rating that would  make them eligible for a FFGA, generally only a few are proposed for a  FFGA in a given fiscal year. FTA proposes FFGAs for those projects that are projected to meet the fol lowing conditions during the fiscal year for  which funding is proposed:  deral project funding must be committed and available for the  roject.
The project must be in or near the final design phase and have progre far enough for uncertainties about costs, bene financial or environmental) to be minimized. fits, and impacts (e.g.,    The project must meet FTA’s tests for readiness and technical capacity, o remaining cost, project scope, or local  which confirm that there are n financial commitment issues.
SAFETEA-LU introduced a number of changes to the New Starts pr including some that affect the evaluation and rating process. For  example, given past concerns that the evaluation process did not ac for a project’s impact on economic development and FTA’s lack of  communication to sponsors about upcoming changes, the statute added  economic development to the list of project justification criteria that FT must use to evaluate and rate New Starts projects, and requires FTA to  issue notice and guidance each time significant changes are made to th process and criteria. SAFETEA-LU also established the Small Starts  program, a new capital investment grant program, simplifying the  requirements imposed for those seeking funding for lower cost projects  e  such as bus rapid transit, streetcar, and commuter rail projects. This  program is intended to advance smaller-scale projects through an  expedited and streamlined evaluation and rating process. FTA also  subsequently introduced a separate eligibility category within the Small  Starts program called Very Small Starts, which is for projects with a  capital cost of less than $50 million. Very Small Starts projects qualify for  an even simpler and more expedited evaluation and rating process than  other Small Starts projects.
FTA, like most federal agencies, must document its activities, including  work related to the New Starts program, in accordance with the Federal  Records Act of 1950, as amended. Each federal agency must maintain a  records management program and must preserve records that (1)  document the organization, functions, policies, decisions, procedures, and  essential transactions of the agency and (2) provide the information  necessary to protect the legal and financial rights of the government and of  persons directly affected by the agency’s activities. The National  Archives and Records Administration (NARA) is given general oversight  responsibilities for records management programs and practices. The  activities of an agency records management program include, among other  things, the development of a records schedule—that is, for all records  created and received by the agency, where and how long records need to  be retained and their final disposition (destruction or preservation) based  on time, or event, or a combination of time and event—subject to the  approval of NARA. No record may be destroyed unless it has been  scheduled and, for temporary records, the schedule is of critical  importance because it provides the authority to dispose of the record after  a specified time period.
section_title: Insufficient Data Prevent Complete Assessment of the Time It Takes Projects to Move through the Process, but Congress and FTA Have Taken Action to Expedite the Process
paragraphs: There is insufficient data available to determine the time it takes for a  project to move through the New Starts process. Nevertheless, 9 of the 40  projects that have received a FFGA since 1997, and with complete data  available, had milestone dates that ranged from about 4.5 to 14 years to  complete the project development phases. However, the data from these 9  projects are not generalizeable to the 40 New Starts projects. FTA has not  historically retained all milestone data for the 40 projects, such as the  dates project sponsors apply to enter a project development phase, in a  consistent manner. However, FTA has retained some milestone data from  some projects and is taking steps to improve its New Starts data retention  and collection. In addition, we found that project sponsors do not  systematically retain milestone data for projects that have completed the  New Starts process. Congress and FTA have taken action to expedite  projects through the New Starts process through Penta-P and training  workshops for project sponsors.
subsections: section_title: Limited Milestone Data on Projects Available through FTA or Project Sponsors
paragraphs: FTA has not historically retained all milestone data, such as the dates that  project sponsors apply to enter a project development phase, and FTA’s  subsequent approval, in a consistent or comprehensive manner. According  to FTA, its record schedule requires that FTA retain documents related to  milestone approvals for 2 years after the close of the project and FTA  meets this requirement. For example, FTA retains documents that notify  project sponsors of their approval to enter preliminary engineering and  final design. Although not required, FTA has also retained milestone data  from some, but not all, projects longer than 2 years.
We were unable to obtain complete and reliable project milestone data  from FTA. FTA has historically retained milestone data from some  projects using a variety of techniques, such as maintaining hard copies of  milestone approval letters or internal memos in binders and saving  electronic copies of some documents in a computer filing system. Using  these sources, FTA provided us with milestone approval dates— preliminary engineering, final design, and FFGA—for the 40 projects that  received a FFGA since 1997. However, when we attempted to verify the  milestone approval dates from a random sample of 10 projects, we found  that the data were unreliable and, in some cases, inaccurate. For example,  the approval dates for some projects did not match the dates contained in  the source documents (e.g., letters from FTA approving a project’s  advancement into preliminary engineering); in other cases the source  documents for some projects were missing from the project files. In  addition to milestone approval dates, we asked FTA to provide the dates  that these 40 projects began alternatives analysis and submitted  applications for preliminary engineering, final design, and FFGA. Because  FTA is not required by its record schedule to retain these dates, FTA was  unable to provide these dates. In addition, FTA officials cited several  challenges to collecting this information. First, FTA told us that it does not  have records on when a project begins alternatives analysis because this  phase is conducted at the local level, generally without FTA involvement.  Second, FTA told us that it does not record when a project sponsor  submits an application for preliminary engineering, final design, and FFGA  because project sponsors almost never submit complete applications.  According to FTA officials, they begin to review applications while  simultaneously working with project sponsors to submit additional  documentation to complete the application. However, according to FTA  officials, because the application process is iterative, they have not  historically assigned a date when the application was fully submitted.
We have previously reported that federal agencies can use performance  information to make various types of management decisions to improve  programs and results. In particular, managers can use performance  information to identify problems in existing programs, to try to identify the  causes of problems, or to develop corrective actions. Further, GAO’s  Standards for Internal Control in the Federal Government states that  internal control activities include, among other activities, appropriate  documentation of records. More specifically, internal control and all  transactions and other significant events need to be clearly documented,  and the documentation should be readily available for examination. The  documentation should appear in management directives, administrative  policies, or operating manuals and may be in paper or electronic form. All  documentation and records should be properly managed and maintained.
FTA officials acknowledged that while not historically perfect; the agency  has retained sufficient milestone data to help manage the New Starts  program. For example, FTA officials noted that they have used the data to  help identify “pain points” in the process and options to streamline the  process. Furthermore, FTA officials stated that even with the most  comprehensive information on the time it takes for New Starts projects to  complete the project development process, each project represents a  unique set of challenges from local decision making, funding availability,  and local legal structure that will impact the time it takes to pass through  the FTA decision phases.
Nevertheless, recognizing the importance of having complete milestone  data to better understand and improve the project development process,  FTA has taken several steps in recent years to more consistently collect  and retain such data. For example, FTA officials told us that, since late  2006, they now retain all letters that contain preliminary engineering and  final design approval dates and electronically document the date a project  sponsor’s application to enter preliminary engineering is received in  internal memos. Also, according to FTA, the agency has begun to  document the date when it considers project sponsors’ preliminary  engineering applications complete. In addition, in 2008, FTA officials said  that they began requiring project sponsors to submit a copy of their  alternatives analysis initiations packages for FTA review and comment.  Finally, FTA officials said they were in the process of developing a  spreadsheet to record various project approval dates—including  statutorily required approval dates and internal FTA review dates—and  just completed a year long pilot project of an electronic case management  system.
Project sponsors also do not consistently retain milestone data for  projects that have completed the New Starts process. Because of the  limitations of FTA’s data, we attempted to collect data from project  sponsors that have received a FFGA since 1997, on the time it takes for a  project to move through the New Starts evaluation and rating process. We  queried the project sponsors for several New Starts milestone dates.  However, we found that some of the project sponsors do not consistently  maintain records on completed projects. In addition, some projects had  multiple project sponsors during the New Starts evaluation and rating  process, which complicated record keeping. Nonetheless, we were able to  gather some milestone dates for 30 of the 40 projects, but these data were  not complete due to missing milestone dates and therefore we were not  able to calculate valid timelines for all projects. (See app. III for more  information on these data.)
However, of the 30 project sponsors that provided information to us, only  9 had complete sets of New Starts milestone dates. Figure 3 shows the  time it took for each of these projects with complete data to move from  the beginning of alternatives analysis to the approval for a FFGA, ranging  from about 4.5 years for 3 projects to over 14 years for 2 projects. Due to  the number of projects with complete data, the data from these 9 projects  are not generalizeable to the 40 New Starts projects. The small sample size  also makes it difficult to determine whether mode (i.e., heavy rail, light  rail, or bus), cost, or the year that the completed projects entered the New  Starts evaluation and rating process impacts the time each project spends  in each phase. Furthermore, FTA officials told us that each New Start  project’s experience in the evaluation and rating process is unique, making  it difficult to identify trends or patterns.
Some project sponsors, transit consultants, and a transportation industry  association official told us that, over the years, the New Starts process has  become too time consuming. Specifically, several project sponsors told us  that the amount of time it takes for FTA to determine whether a project  can advance into the next phase can be significant and causes additional  costs. In addition, a 2007 Deloitte study on the New Starts program found  that the New Starts process is perceived by project sponsors as intensive,  lengthy, and burdensome. For example, one project sponsor believes that  FTA reviews prolonged its project development by approximately 1 year,  which they estimate cost an additional $24 million.
FTA officials have acknowledged that the requirements of the New Starts  process could add time to project development and have acted to  streamline the process. For example, FTA has allowed projects to conduct  additional engineering while FTA reviews applications for final design.  FTA has also maintained that thorough reviews of project information can  identify issues and challenges with proposed investments that may later  prolong project development. However, FTA officials also noted that not  all project delays can be attributed to FTA or the New Starts process. FTA  officials cited a number of reasons that a project could be delayed during  preliminary engineering or final design that are outside FTA’s control such  as changes to a project’s scope, changes in local political leadership, or the  loss of local financial commitment. For example, according to FTA  officials, the Northern Virginia (Dulles Corridor Metrorail Project— Extension to Wiehle Avenue) project was about to receive FTA approval  to enter the final design phase when the Governor of Virginia requested a  period of 6 months to evaluate a potential change in the project’s scope— digging a large-bore 4-mile tunnel for a portion of the project—that the  project sponsor eventually discarded in favor of the original design.
The lack of reliable comprehensive data makes it difficult to develop a  complete understanding of the time it takes projects to move through the  New Starts process. The limited information available and anecdotal  examples suggest that the process can be lengthy. But, without complete  and accurate data, it is difficult to know whether and to what extent the  process has become more time consuming over the years or the addition  of new requirements add to the length of the process. Without such  information, Congress and FTA cannot reliably identify the location,  causes, or extent of the pain points and which options would be an  appropriate response to expedite this process. Moreover, as we have  previously reported, having such information can help agencies identify  weaknesses in programs, assess factors causing the problems, and modify  processes.
section_title: Legislative and FTA Actions Have Been Taken to Expedite the Process
paragraphs: SAFETEA-LU created what is commonly called the Small Starts program,  a new capital investment grant program, simplifying the requirements  imposed for those seeking funding for lower cost projects, such as bus  rapid transit, streetcar, and commuter rail projects. This program is  intended to advance smaller scale projects through an expedited and  streamlined evaluation and rating process. In July 2007, FTA established  the eligibility parameters for the Small Starts program. FTA created a  separate eligibility category within the Small Starts program called Very  Small Starts, which is for projects with a total capital cost of less than $50  million. According to FTA, as of June 2009, one Small Starts project has  been awarded a project construction grant agreement (PCGA), and  another is currently being processed. In addition, two projects have  received construction funding through standard grants rather than PCGAs.
SAFETEA-LU also established the Public-Private Partnership Pilot  Program (Penta-P) to demonstrate the advantages and disadvantages of  public-private partnerships for certain new fixed guideway capital projects  funded by FTA. In January 2007, FTA published the terms of Penta-P in the  Federal Register. Penta-P projects may be eligible for a simplified and  accelerated New Starts review process that is intended to reduce the time  and cost to project sponsors. For example, under Penta-P, the projects are  eligible for consideration, on a case-by-case basis, for accelerated design  approvals. Specifically, FTA could issue concurrent approvals for  preliminary engineering and final design to commence, thus allowing the  project to proceed with final design immediately upon completion of  preliminary engineering without requiring additional approval. To date,  FTA has not issued such concurrent approvals. In 2007, FTA executed  memorandums of understanding for three pilot Penta-P projects that are  candidates for New Starts funding: Houston, Texas; Denver, Colorado; and  Oakland, California. According to FTA officials, as of July 2009, FTA has  not issued concurrent approvals of the type described above as the   Penta-P projects have not yet demonstrated the distribution of risk among  the private and public sectors that would enable FTA to relax its normal  due diligence for approvals into preliminary engineering or final design.
FTA has also implemented administrative changes designed to expedite  the New Starts process. Examples of these changes include the following:    Regular training workshops: FTA has developed and offered regular  training workshops for project sponsors and offered information to  project sponsors to end misconceptions about the New Starts process. For  example, in March 2009, FTA offered two New Starts workshops in  Phoenix, Arizona, and Tampa, Florida, on travel forecasting and provided  the materials from these workshops on its Web site. In addition, in June  2009, FTA offered a course on alternatives analysis in Los Angeles. FTA  also offers New Start roundtables that are usually 2-day meetings between  FTA staff and project sponsors of projects in preliminary engineering and  final design seeking New Starts funding. They consist of presentations by  FTA staff and local project sponsors on topics related to New Starts  planning, project development, and the evaluation and rating process.
Project delivery tools: In addition to training, FTA has introduced project  delivery tools to assist project sponsors with the New Starts evaluation  and rating process. FTA now requires the submittal of an alternatives  analysis initiation package summarizing corridor problems, conceptual  alternatives, and preliminary evaluation measures to be used, which,  according to FTA, can help to foster coordination among local  participating agencies and FTA. FTA has also developed checklists for  project sponsors to improve their understanding of the requirements of  each phase of the New Starts process. Lastly, FTA has begun to use road  maps with some project sponsors that include schedules and roles for  both FTA and the sponsor.
section_title: Options Exist That Could Expedite the New Starts Project Development Process
paragraphs: Project sponsors, transit consultants, transit industry associations, and  academics we contacted identified several options for streamlining the  New Starts project development process, including combining project  development phases, using nonbinding or binding agreements, adopting a  more risk-based approach, and promoting project development tools.  Although each of these options could streamline the New Starts evaluation  and rating process, each option has advantages and disadvantages to  consider.
subsections: section_title: Combining Project Development Phases
paragraphs: Project sponsors and transit consultants cited combining project  development phases, such as preliminary engineering and final design, as  an option for expediting the New Starts project development process.  Project sponsors and transit consultants told us that waiting for FTA’s  approval to enter preliminary engineering, final design, and construction  can prolong project development. According to project sponsors, while  FTA determines whether a project can advance to the next project  development phase, work on the project essentially stops. Project  sponsors can advance the project at their own risk, meaning they could  have to redo the work if FTA does not subsequently approve an aspect of  the project. The amount of time it takes for FTA to determine whether a  project can advance can be significant. For example, one project sponsor  told us that FTA’s review of its application to advance from alternatives  analysis to preliminary engineering took 8 months, about the same amount  of time it took the project sponsor to complete alternatives analysis. FTA  officials told us the length of time for reviews depends on a number of  factors, most importantly the completeness and accuracy of the project  sponsor’s submissions.
To reduce the “start/stop” phenomena project sponsors described, a  legislative change would be necessary to eliminate the requirement that  FTA approve advancement of a project into final design, which would  effectively combine the preliminary engineering and final design phases  into one “project development” phase, as was done in SAFETEA-LU when  creating a more streamlined version of the process under the Small Starts  program. Furthermore, another option for legislative change would be to  replace the requirement that FTA approve the advancement of a project  into the preliminary engineering phase with a requirement that FTA  approve a project into the overall New Starts program, which would  streamline and simplify the process. In addition, the Deloitte study  recommended combining preliminary engineering and final design, while  simultaneously adjusting the FFGA review date to occur in the middle of  this expanded phase, rather than after final design, where it traditionally  happened. In this regard, the Deloitte study reflected the sentiments of  project sponsors and consultants we interviewed, who said that combining  phases and/or creating a programmatic approval would allow FTA to  signal its intent to recommend a project for funding at an earlier point than  the current project development process allows. This would give sponsors  more opportunity to pursue private financing arrangements and  alternative project delivery methods, such as those being carried out under  Penta-P, as this federal funding provides the certainty needed to  encourage private sector participation. In addition to combining phases,  the Deloitte study also recommended that FTA redefine or more clearly  define the project phases to more accurately reflect FTA’s current  requirements and to better accommodate alternative delivery methods.
There are limitations to combining phases of the New Starts project  development process. One limitation to combining phases and clarifying  them is that a legislative change would be necessary. Another limitation is  that, depending on how it is accomplished, combining phases could  impact how FTA integrates NEPA requirements into the project  development process. Finally, combining phases would reduce the  opportunities for FTA to monitor and evaluate high-value projects at  important interim phases; therefore, increasing the potential for issues or  problems to go undetected.
section_title: Consider Greater Use of Letters of Intent and Early Systems Work Agreements
paragraphs: The linear, phased evaluation process of the New Starts program has  historically hampered project sponsors’ ability to utilize alternative project  delivery methods, such as design-build, according to project sponsors.  These alternative project delivery methods have the potential to develop a  project cheaper and quicker than traditional project delivery methods can.  However, project sponsors told us it is difficult to attract private sector  interest early enough in the project development process to use alternative  project delivery methods because there is no guarantee that the project  will ultimately receive federal funding through the New Starts program.  The Deloitte study also noted that New Starts project sponsors miss the  opportunity to use alternative project delivery methods because of the  lack of early commitment of federal funding for the projects. To encourage  the private sector involvement needed, project sponsors, consultants, and  experts we interviewed suggested that FTA use letters of intent, which are  nonbinding agreements, or early system work agreements, which are  binding agreements. Through a letter of intent, FTA announces its  intention to obligate an amount from future available budget authority to a  project. According to private sector entities we interviewed, such an  intended obligation sends a signal of federal support for a project and,  therefore, attaches more certainty to the project. A challenge of using  letters of intent is that they can be misinterpreted as an obligation of  federal funds, when in fact they only signal FTA’s intention to obligate  future funds should the project meet all New Starts criteria and  requirements, and budget authority is available. In addition, because FTA  reserves, or sets aside, commitment authority, or contract authority,  when it issues letters of intent, issuing more such letters would reduce the  availability of this authority at a faster pace than issuing more early  systems work agreements. Letters of intent cover the project’s full federal  share and, while early systems work agreements actually obligate federal  funds, they obligate only a portion of a project’s federal share. As such, it  is possible that, with more frequent use of letters of intent, FTA’s  commitment authority could be depleted earlier than expected, which  could affect the anticipated funding stream for future projects. Finally,  another challenge of using an early systems work agreement is that the  law specifies that FTA can only enter into this type of agreement with a  project if a Record of Decision under NEPA has been issued, and the  Secretary finds that a FFGA for the project will be made and the terms of  the agreement will promote ultimate completion of the project more  rapidly and at less cost, thus limiting FTA’s ability to use these  agreements.
section_title: Tailor the New Starts Evaluation Process to Risks Posed by the Projects
paragraphs: Project sponsors, consultants, and experts we interviewed suggested that  FTA adopt a more risk-based evaluation process for New Starts projects  based on a project’s cost or complexity, the federal share of the project’s  cost, or the project sponsor’s New Starts experience. For example, FTA  could align the level of oversight with the proposed federal share of the  project—that is, the greater the financial exposure for the federal  government, the greater the level of oversight. This was employed with the  creation of the Small Starts program, which is intended to provide a more  streamlined process for smaller and less costly projects. Similarly, FTA  could reduce or eliminate certain reviews for project sponsors who have  successfully developed New Starts projects in the past, while applying  greater oversight to project sponsors who have no experience with the  New Starts project development process. We have noted the value in using  risk-based approaches to oversight. For example, we have previously  reported that assessing risks can help agencies allocate finite resources  and help policymakers make informed decisions. By adopting a more  risk-based approach, based on, for example, project sponsor experience,  project scope, total project cost, or federal share of the cost, FTA could  allow select projects to move more quickly through the New Starts project  development process and more efficiently use its scarce resources.  However, a trade-off of not applying all evaluation measures to every  project is that FTA could miss the opportunity to detect problems early in  the project’s development. Further, this practice may move FTA away  from their stated management objective of treating “all projects equitably  across the U.S.”
section_title: Consistently Use Project Development Tools
paragraphs: Project sponsors said that FTA should more consistently use road maps or  similar tools to define the project sponsor’s and FTA’s expectations and  responsibilities for moving the project forward. Without establishing these  expectations, project sponsors have historically had little information  about how long it will take FTA to review, for example, their request to  move from alternatives analysis to preliminary engineering. This lack of  information makes it difficult for the project sponsor to effectively manage  the project. Additionally, FTA previously identified an “adequate schedule”  as a key factor of successful project implementation. Given the benefits of  clearly setting these expectations, Deloitte recommended that FTA use  road maps for all projects. The Deloitte study also observed that project  sponsors would like to see FTA use more project development  agreements, or similar vehicles, early in the development process because  they help clarify expectations on both sides.
The following project development tools could increase the transparency  of and help project sponsors navigate the New Starts project development  process:    Road maps or similar project schedules: FTA has used road maps for  select projects, but the agency does not consistently use them for all  projects. According to FTA, the agency is currently working with project  sponsors to establish road maps for all projects. However, according to  some project sponsors, a limitation of using road maps is that expected  time frames are subject to change—that is, project schedules often change  as a project evolves throughout the development process. Furthermore,  every project is unique, making it difficult to set a realistic time frame for  each phase of development. Consequently, the road maps can provide only  rough estimates of expected time frames.
Project development agreements (PDA): FTA has used project  development agreements, on a limited basis, to help streamline the New  Starts project development process. PDAs require project sponsors and  FTA to agree on three components: a delivery schedule, a review of key  project development deliverables, and clear expectations from both sides  for demonstrating project development progress, so that each would be  held accountable for the advancement of a project. However, an FTA  official stated that there are differences of opinion inside FTA as to the  relative efficacy of road maps versus project development agreements. In  addition, FTA told us that, as legal documents, PDAs take so long to  negotiate with project sponsors that they may not offer a streamlining  advantage. Because of that, some FTA staff members have stated a  preference for road maps over PDAs and, as an alternative to PDAs, are  currently using the informal road maps described above to establish  milestones and timelines.
section_title: Apply Policy and Guidance Changes Only to Future Projects
paragraphs: Project sponsors told us that the frequent policy and guidance changes to  the New Starts program can result in additional costs and delays as project  sponsors are required to redo analyses to reflect the changes. In May 2006,  FTA modified its policy so that a project that has been approved for entry  into final design would no longer be subject to changes in New Starts  policy and guidance. However, this policy change does not apply to  projects approved for entry into preliminary engineering, which is the New  Starts project development phase that has the most requirements for  project sponsors and the phase where project sponsors told us that  frequent changes result in additional costs and delays. For example,  sponsor officials for one project told us that shortly after they submitted  their preliminary engineering approval materials to FTA, FTA established  a new, internal rule that required a risk assessment to take place prior to  FTA’s approval to enter preliminary engineering, instead of during  preliminary engineering. To protect the development schedule, the  officials asked for, but were denied, approval for the project to proceed  under the existing guidance that placed risk assessment activities during  preliminary engineering, or at least to perform the risk assessment  concurrently with preliminary engineering approval to maintain the  schedule. The sponsor said the overall effect of the change was a delay of  the preliminary engineering approval by about 4 months. According to  FTA officials, FTA typically allows “grace periods” when implementing  major policy changes to provide sponsors stability and time to adapt to  those changes. Furthermore, another project sponsor noted that new  requirements can prolong project development because each element of a  proposed project is interrelated, so changing one requirement can stop  momentum on a project. To avoid this rework, some project sponsors,  consultants, and experts we interviewed suggested that FTA apply  changes only to future projects, not projects currently in preliminary  engineering. However, by not applying changes to projects in preliminary  engineering, FTA could miss the opportunity to enhance its oversight of  these projects. Also, applying changes to some projects but not to others  would require FTA staff to create and apply multiple sets of rules to the  project management process, which could create an administrative burden  and move away from a consistent evaluation process.
section_title: Revise the Internal Review Process and the Use of Project Management Oversight Contractors
paragraphs: Project sponsors told us that FTA could minimize delays due to the  stop/start nature of the development process by an adjustment to FTA  staffing or contractor support levels to allow for multiple, simultaneous  reviews of sponsors’ projects, and could reduce uncertainty by changing  the way the agency selects and trains oversight contractors. Consultants  and sponsors told us that FTA’s “first-in, first-out” approach to the review  process, while not agency policy, sometimes can result in FTA reviewing  only one project at a time, in the order they arrive. FTA told us this  happens occasionally because of overlapping demands placed on  oversight contractors, who are not able to perform simultaneous reviews.  As a result, the development of low-risk projects is often prolonged if they  happen to sit in the queue behind more complex projects that were  submitted earlier. The Deloitte study recommended, and consultants and a  sponsor we interviewed agreed, that FTA could adjust its process or  staffing, as needed, to enable multiple reviews to be conducted in parallel.  In addition, sponsors and consultants we interviewed told us some of  FTA’s PMOCs have little experience with New Starts or Small Starts  projects, leaving them uncertain about FTA requirements. As a  consequence, inexperienced PMOCs sometimes provide inconsistent  guidance, resulting in sponsors having to re-do work, adding time to the  development process. To reduce the PMOC’s uncertainties about FTA’s  requirements, FTA could provide them with additional training, especially  when regulatory and administrative requirements change. FTA could also  streamline the process by using staff, instead of contractors, to oversee  project sponsors. Since staff possesses more institutional knowledge, they  would provide sponsors more certain guidance. However, shifting more  oversight work inside FTA would add to the scope and complexity of  FTA’s work and could, therefore, create staffing challenges.
section_title: Conclusions
paragraphs: FTA’s New Starts program is often cited as a model for other federal  transportation programs. FTA’s recommendations for funding are based  on a rigorous examination of proposed projects, and Congress has  generally followed FTA’s funding recommendations. However, there is  concern among some Members of Congress and the transit industry about  the project development process, namely that it has become too time  consuming, costly, and complex.
Despite congressional and FTA actions to streamline the New Starts  project development process, it continues to be viewed as time consuming  and lengthy. However, the specific areas of concern that lead to delays, are  difficult to determine because of a paucity of information about the time it  has taken projects to move through the New Starts process. Moreover, this  lack of adequate data makes it difficult for Congress and FTA to assess the  extent to which federal efforts designed to expedite the New Starts  process are succeeding. Although each project is unique, providing this  information could also help set general expectations about the length of  the process for potential project sponsors. While FTA has taken some  steps to improve its data collection and retention, additional work is  needed. As stewards of the New Starts program, which provides millions  of dollars to local communities for transit projects each year, it is FTA’s  responsibility to ensure that program changes are based on accurate and  reliable information.
Through our interviews with project sponsors, transit industry  consultants, and transportation experts, as well as our review of existing  research, we identified a number of potential options to expedite project  development within the New Starts program. However, FTA must also  strike the appropriate balance between expediting project development  and maintaining the rigor and accountability of the New Starts program.  As FTA works to develop its proposal for the New Starts program for the  upcoming surface transportation reauthorization, considering the  advantages and disadvantages of these options, including any potential  trade-offs, could help FTA select any options that expedite the process  while maintaining the rigorous oversight of the process. It is important  that the length of project development within New Starts program does  not serve as a deterrent as more communities turn to transit to solve their  transportation challenges.
section_title: Recommendations for Executive Action
paragraphs: To improve the New Starts program, we recommend that the Secretary of  Transportation direct the FTA Administrator to take the following two  actions:    continue to improve data collection and retention for statutorily defined  milestones and determine if additional data would help to better describe  the time it takes for a project to move through the New Starts process. In  doing so, FTA should establish mechanisms to ensure the accuracy of the  data and routinely analyze the data in order to identify the length of time it  takes projects to move through each phase, potential causes for perceived  delays, and potential solutions. FTA should make its analysis available to  Congress and other interested parties.   analyze the streamlining options identified in this report, along with any  additional options, to determine which options, if any, to implement— seeking legislative change if necessary—to expedite the project  development within the New Starts program.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided the DOT, including FTA, with a draft copy of this report for  review and comment. In e-mail comments, DOT agreed with our  recommendation to consider options to expedite project development,  noting that the options we identified to help expedite project development  within the New Starts program are consistent with the options that FTA  has been discussing with transit stakeholders and congressional staff.  However, DOT disagreed with our recommendation on data, as originally  drafted, because it did not recognize FTA’s ongoing efforts to improve its  data collection. In addition, in its comments, FTA acknowledged that there  are always opportunities to improve various aspects of the program,  including some of the data collection efforts discussed in this report, but  noted that the agency has maintained, and has access to, the information  necessary to effectively track active projects and review progress through  milestones for past projects. Furthermore, FTA expressed concern that  the report uses a standard for data management that is neither intended  nor necessary for effective project management. FTA officials also stated  that, even with the most comprehensive milestone data, each project  represents a unique set of challenges that will impact the time it takes for a  project to pass through the New Starts process. More broadly, FTA  officials stated that they use milestone data to manage the program and  make changes to improve the program.
To address these comments, we incorporated additional information about  FTA’s ongoing efforts to strengthen its data management process in the  report. We also revised in the report the recommendation on data  collection to reflect FTA’s ongoing work while still emphasizing the need  to improve the agency’s milestone data collection and retention, including  the reliability and accuracy of the data. In addition, we agree that each  New Starts project represents a unique set of circumstances that will  affect the time it takes to pass through FTA decision phases and further  recognized this fact in the report. However, we disagree with the assertion  that we hold this information to a standard neither intended nor necessary  for effective program management. An effective system of internal  controls requires that managers have relevant and reliable information to  better achieve agencies’ missions and program results. As we note in the  report, FTA project milestone data are unreliable and, in some cases,  inaccurate, which can jeopardize effective program management. We and  others have recognized FTA’s New Starts process as providing a sound,  rigorous and systematic process for identifying projects worthy of federal  discretionary funding for major transit investments, and analysis based on  reliable data will only help strengthen FTA’s management of the program.  We, therefore, believe that this recommendation, as revised, is valid.
DOT also provided technical clarifications, which we incorporated as  appropriate.
We are sending copies of this report to appropriate congressional  committees and DOT. The report also is available at no charge on the GAO  Web site at http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at flemings@gao.gov or (202) 512-2834. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix IV.
section_title: Appendix I: Administration Requests $1.83 Billion in Fiscal Year 2010 Funding for New Starts, Small Starts, and Very Small Starts Projects
subsections: section_title: FTA Evaluated and Rated 14 New Starts Projects and Recommended 5 New Projects for Funding in Fiscal Year 2010
paragraphs: The Federal Transit Administration evaluated and rated 14 New Starts  projects in preliminary engineering and final design during the fiscal year  2010 cycle. FTA also reviewed the progress but did not rate 5 projects that  are statutorily exempt from being rated. (See table 4 for a full list of these  projects.)
Of the 14 New Starts projects evaluated and rated during the fiscal year  2010 cycle, FTA recommended five new projects for funding through full  funding grant agreements (FFGA) or early system work agreements  (ESWA) this year. In its annual report, FTA states that these projects  recommended for funding are in final design or expected to be approved  into final design before the end of summer 2009, the environmental  process has been completed, and any needed railroad agreements have  been negotiated and are at or near completion. For these projects, FTA  recommends a total of $430 million in New Starts funding in fiscal year  2010. The total capital cost of these projects is estimated to be  approximately $11.14 billion.
FTA also recommended, as part of the President’s budget request,  reserving $81.79 million in New Starts funding for projects that may attain  the FFGA milestone in the budget year but have not sufficiently  progressed in project development for FTA to recommend them in the  budget request. FTA has not specified which projects will be eligible for  this funding or allocated a particular amount for any given project.  According to the annual report and officials we spoke with at FTA, this  approach will allow the agency to make “real time” funding  recommendations as project uncertainties are mitigated, and Congress  makes final appropriations decisions. FTA does not expect that all of the  projects in preliminary engineering will advance to final design in fiscal  year 2010.
section_title: FTA Evaluated and Rated 21 Small Starts and Very Small Starts Projects and Recommended Funding for 16 Projects
paragraphs: FTA evaluated and rated 21 eligible Small Starts and Very Small Starts  projects for the fiscal year 2010 cycle. These include 1 project with a  pending project construction grant agreement, 16 projects that have  demonstrated sufficient readiness to be considered for funding in the  fiscal year 2010 President’s budget request, and 4 projects that have not  yet demonstrated readiness to be considered for funding. (See table 5 for  a full list of these projects.) FTA recommends a total of $174.27 million in  funding for Small Starts, including Very Small Starts, projects. The total  capital cost of the 16 projects that FTA recommended for funding is  estimated to be $895.11 million. Most of these projects are proposed to be  funded under a multiyear PCGA. However, if a project requests less than  $25 million in Small Starts funding or has received its full appropriations,  FTA will award funds in a single-year capital grant rather than a PCGA.
section_title: FTA’s Fiscal Year 2010 Budget Proposal Recommends $1.83 Billion for the New Starts Program
paragraphs: The administration’s fiscal year 2010 budget proposal recommends that  $1.83 billion be made available for the New Starts program. This amount is  $81.093 million more than the program’s fiscal year 2009 appropriation.  Figure 4 illustrates the planned uses of the administration’s proposed  request for the New Starts fiscal year 2010 budget, including the following:    $1,123.03 million would be allocated among the 19 projects with existing  FFGAs,    $430.0 million would be allocated among the 5 projects newly  recommended for funding through FFGAs or ESWAs,   $81.79 million would be allocated to projects that may attain the FFGA  milestone in the budget year but have not sufficiently progressed for FTA  to recommend them in the budget request,   $174.25 million would be allocated among the 16 Small Starts projects  newly recommended for funding, and    $18.27 million for management and oversight activities.
section_title: Recovery Act Funding Allowed FTA to Accelerate Payments to Projects with FFGAs
paragraphs: The American Recovery and Reinvestment Act (Recovery Act) provided  FTA with over $740 million in funding for the New Starts program. This  funding for surface transportation projects allowed FTA to accelerate  payments to transit projects with existing FFGAs and PCGAs. FTA  distributed Recovery Act funding to 11 projects in construction with fiscal  year 2010 commitments. More specifically, FTA distributed at least 40  percent of each project’s scheduled fiscal year 2010 payment in Recovery  Act funding. According to FTA, 5 projects with demonstrated cash flow  needs that exceeded this distribution received additional funding. This  funding will not require amendments or significant changes to any FFGAs  because the overall federal share of the total project costs did not change.
section_title: FTA Has About $879 Million Remaining in SAFETEA-LU Contingent Commitment Authority
paragraphs: The Safe, Accountable, Flexible, Efficient Transportation Equity Act: A  Legacy for Users Act (SAFETEA-LU), like the Transportation Equity Act  for the 21st Century, allowed FTA to make contingent commitments for  funding to projects beyond what is authorized in law, subject to future  authorizations and appropriations. According to FTA, SAFETEA-LU and  the Recovery Act gave FTA a total contingent commitment authority of  $14.37 billion, of which $12.684 billion has been committed through FFGAs  and preliminary engineering and final design activities for projects through  fiscal year 2009.
FTA officials said that the agency has approximately $879 million  remaining in contingent commitment authority after consideration of fiscal  year 2010 funding recommendations. FTA officials also told us that they  need additional authority for commitment beyond fiscal year 2010 because  FTA is not permitted to spend money beyond its authorized level. FTA  officials noted that the available level of contingent commitment authority  did not influence their fiscal year 2010 recommendations. Further, they  stated that they were able to recommend all of the projects deemed ready  for funding because of the additional Recovery Act funding.
section_title: Appendix II: Scope and Methodology
paragraphs: To evaluate the time it has generally taken for projects to move through  the New Starts process we collected and attempted to verify FTA data on  New Starts projects that have advanced through the New Starts process  and received FFGAs after June 1997 to determine the length of time each  project spent in each stage of the process. However, we found this data to  be unreliable based on our reviews of FTA files on a random sample of 10  projects’ milestone dates. We also attempted to collect data from project  sponsors to establish how long it has taken projects to move through the  New Starts process. We contacted each project sponsor and requested  seven milestone dates from alternatives analysis through FFGA. We  received verifiable data for 30 of the 40 projects approved into a FFGA  since June 1997. However, of the 30 projects, we received complete sets of  milestone data for 9 projects. Due to the number of projects with complete  data, the data from these 9 projects are not generalizeable to the 40 New  Starts projects. The verifiable data included the dated letters the project  sponsors sent to or received from FTA. The data for the beginning of  alternatives analysis are based on several documents, including local  government board meeting minutes that record a decision for the locality  to begin alternatives analysis. We also examined the 2007 Deloitte  Development, LLC, report on FTA’s New Starts process and interviewed  the project leader for this study to obtain information on the time it takes  for New Starts projects to move through the process.
To determine the steps Congress and FTA have taken to expedite the New  Starts process, we reviewed documents including our reports on the New  Starts program, federal legislation such as SAFETEA-LU, as well as other  applicable New Starts requirements, and FTA New Starts policy guidance.  In addition, we interviewed FTA officials and attended the American  Public Transportation Association’s March 11, 2009, legislative conference,  at which FTA gave a presentation on the New Starts and Small Starts  programs, to obtain information on steps taken by Congress and FTA to  expedite the New Starts process.
To assess the options that exist to expedite the process, we collected and  analyzed information from relevant reports. In particular, we examined the  recommendations from the 2007 Deloitte Development, LLC, report on  FTA’s New Starts process and the American Pubic Transportation  Association’s October 2008 report on transportation authorizing law. We  interviewed FTA officials, transportation experts and consultants, industry  groups, and project sponsors that chose not to enter the New Starts  pipeline to identify factors contributing to New Starts project timeline  challenges, as well as actions FTA and Congress have taken to expedite  the New Starts process. We also interviewed these officials to identify  additional changes that could streamline the project development process,  as well as the advantages and disadvantages.
Additionally, we interviewed 9 project sponsors about 10 projects,  including those currently in the New Starts pipeline and those under a  FFGA, about their experiences with and perceptions of the New Starts  process. For each of these projects we interviewed the relevant project  sponsor or contractor, as well as FTA officials with experience evaluating  and overseeing the project. We selected these projects based on the  following criteria: (1) timing (i.e., when projects received a FFGA);   (2) mode (e.g., rail, light rail, or bus); (3) scope (i.e., the total cost of the  project); and (4) projects from different geographic areas. Because the  projects were selected as a nonprobability sample, the results cannot be  generalized to all projects. Table 3 lists the New Starts and Small Starts  project sponsors we interviewed for our review.
To describe the New Starts and Small Starts projects evaluated, rated, and  recommended for funding in fiscal year 2010 by FTA, we reviewed FTA’s  Annual Report on New Starts for Fiscal Year 2010 and interviewed FTA  officials. We spoke to the FTA officials about the number of projects  evaluated, rated, and recommended for funding, the amount of funding  requested for these projects, the total costs of proposed projects, as well  as how FTA allocated its Recovery Act funding.
section_title: Appendix III: Timeline Data on New Starts Projects That We Collected from Project Sponsors, by Mode
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, A. Nicole Clowers, Acting  Director; Kyle Browning; Lauren Calhoun; Gary Guggolz; Brandon Haller;  and Carrie Wilks made key contributions to this report.