Metropolitan and Statewide Transportation Planning
JUSTIFICATION STATEMENT
Background/Definitions:
The Unified Planning Work Program (UPWP) and State Planning and Research (SP&R) program contain information describing transportation and transportation related planning activities anticipated to be undertaken in metropolitan and non-metropolitan areas. The UPWP details the planning work to be performed in metropolitan areas with Federal planning assistance and serves as the Metropolitan Planning Organization (MPO)’s planning grant application for Federal Highway Administration (FHWA) metropolitan planning funds and as the basis of the Federal Transit Administration (FTA) grant application for funding to support metropolitan planning. The UPWP describes:
a. Task objectives.
b. Tangible products expected.
c. Previous work towards these objectives.
d. Relationship to other activities.
e. Agency responsible for work.
f. Cost and funding source.
The UPWP is required of all MPOs in Transportation Management Areas (TMAs), i.e., all urbanized areas of over 200,000 population and other areas designated by the FHWA and FTA at the request of the MPO and State Governor. MPOs in non-TMAs may also develop UPWPs, although FTA and FHWA may accept more simplified statements of work for these urbanized areas.
Similarly, the State submits planning activities for funding under the FHWA and FTA SP&R program, describing the proposed planning work to be carried out throughout the State. UPWPs and applications for funding under the SP&R program are reviewed and approved by FHWA and FTA for their separate funding programs.
The Metropolitan Transportation Plan (Metropolitan Plan) describes the policies, strategies, and facilities, or changes in facilities, comprised of both capital investment and operational/management strategies, as proposed by State and local officials for future implementation. It is a dynamic document which addresses at least a twenty-year planning horizon, but is reviewed and updated every five years in areas that are in attainment of national ambient air quality standards, and every four years in areas designated as non attainment or maintenance of those standards. The joint FTA/FHWA planning regulations require that the metropolitan plan be multimodal in nature. It must include a discussion of types of environmental mitigation activities and potential areas for applying them, in consultation with federal, State, and tribal wildlife, land management, and regulatory agencies. The plan also must include a financial plan identifying known and reasonable projected revenues to support implementation of projects and strategies included in the plan. In TMAs, the plan must reflect consideration of congestion management strategies and performance measures as defined through their Congestion Management Process. Development of the plan must also allow for an adequate opportunity for public participation. The metropolitan plan ensures that projects proposed for implementation are based on a continuing, comprehensive, and cooperative planning process.
The Statewide Transportation Plan (Statewide Plan). The requirements of the statewide plan are similar to those of the metropolitan plan, with the exception that project-level detail in plan recommendations, and a supporting financial plan, are optional. Also, the Statewide Plan has no legislatively required update cycles.
The Metropolitan Transportation Improvement Program (TIP) is a management tool for prioritizing and programming projects and strategies for funding by FTA and FHWA for near-term implementation in metropolitan planning areas, covering a minimum four-year period. Updated at least every four years, the TIP must be consistent with the metropolitan plan and reflect the overall transportation goals while identifying the realistic local and federal financial resources that are used to fund infrastructure improvements. Associated with the TIP, a list must be prepared annually of projects from the TIP for which funding was obligated in the previous year, including investments in pedestrian walkways and bicycle transportation facilities.
The Statewide Transportation Improvement Program (STIP) is the management tool for prioritizing and programming projects and strategies for funding by FTA and FHWA for near-term implementation throughout the State. As with the TIP, the STIP must cover a minimum four-year period and be updated at least every four years. The portion of the STIP in a metropolitan planning area is developed in cooperation with the MPO, with metropolitan TIPs included without change, directly or by reference, in the STIP after their approval by the MPO and the State’s Governor. The STIP is jointly approved by FTA and FHWA and serves as the basis for funding awards under Title 23 and Title 49, Chapter 53, for the individual projects and strategies included.
In summary, the UPWP identifies transportation planning activities in metropolitan areas and supports the request for funding to support the work under both FTA and FHWA planning programs in metropolitan areas. A similar listing of planning activities is prepared on a statewide level as the basis for FTA and FHWA SP&R funding. The metropolitan plan and statewide plan reflect the long-range goals and objectives determined through the metropolitan and statewide transportation planning processes respectively. The TIP and STIP are short-range multi-year listings of highway and transit improvement projects which are consistent with those plans and which support the request for, and receipt of, federal transportation funding under Title 23 U.S.C. and Chapter 53 of Title 49 U.S.C.
1. Explain the circumstances that make information collection necessary.
FTA and FHWA jointly carry out the federal mandate to improve metropolitan and statewide transportation under authority of Title 49, Chapter 53, and Title 23 of the United States Code. Sections 5305(g) of Title 49 and 104(f) of Title 23 authorize funds to support transportation planning at metropolitan and statewide levels. As a condition to receive Title 49, Chapter 53, and Title 23 funding, requirements are established for metropolitan and statewide transportation planning under Sections 5303 and 5304 of Title 49 and Sections 134 and 135 of Title 23 that call for development of transportation plans and transportation improvement programs in all States and metropolitan areas. The information collection activities necessary to prepare federally required plans and programs, and the supporting planning studies proposed for funding in UPWPs and under the SP&R work programs are necessary to monitor and evaluate current and projected usage and performance of transportation systems nationwide - in each urbanized area and throughout every State.
The metropolitan plan and TIP are required by Sections 49 U.S.C. 5303 and 23 U.S.C. 134, which state that "metropolitan planning organizations, in cooperation with the State, shall develop transportation plans and programs for urbanized areas of the State." 49 U.S.C. 5304 and 23 U.S.C 135 require that each "State shall develop transportation plans and programs for all areas of the State." Both statutory sections require that "the process for developing such plans and programs shall provide for consideration of all modes of transportation and shall be continuing, cooperative, and comprehensive.” MPOs and States use metropolitan and statewide plans, TIPs, and STIPs as the basis for investing federal and non-federal capital funds for transportation infrastructure investments. (Note: Paperwork Reduction Act requirements for preparation of the STIP are covered by OMB control number 2125-0039.)
23 CFR Part 450 implements these statutory requirements. (Note: 23 CFR Part 450 is identical to, and cross-referenced by, the equivalent regulation in Title 49, 49 CFR Part 613.) The MPO, together with the State and public transportation operators, prepares plans for each urbanized area, while the State develops a statewide plan, which, in metropolitan areas, is developed in cooperation with affected MPOs. Additionally, metropolitan plans developed under the statutory and regulatory requirements cited above in nonattainment and maintenance areas must be found by FTA/FHWA to be in conformity with State Implementation Plans (SIPs)) for attaining Environmental Protection Agency ambient air quality standards. These plans form the basis for development of TIPs and STIPs, the short-range programming documents for federally-funded transportation capital investments.
A UPWP is required by 23 CFR 450.308 for all MPOs in TMAs. MPOs in urbanized areas of less than 200,000 population, with prior approval by the State, FTA, and FHWA, may use a simplified statement of work as their planning grant application instead of developing a full UPWP. Details of the required planning processes supported by FTA and FHWA metropolitan planning funds, as required by Section 5303 of Title 49 U.S.C. and 23 U.S.C. 134, are set out in 23 CFR 450. The planning grant application is based upon a cooperative State and locally developed and endorsed UPWP and is the mechanism by which grantees request federal funding. The information contained in the UPWP is necessary to establish the eligibility of the activities for which funding is being requested.
On August 10, 2005, the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU) was signed by the President, which made a number of changes to Statewide and Metropolitan Planning law, involving both an expansion of the range of stakeholders and topics to be considered in transportation decision-making, as well as a reduction in the frequency of reporting requirements that are reflected in this document. A final rule published in the Federal Register, on February 14, 2007, entitled “Statewide Transportation Planning; Metropolitan Transportation Planning,” implements the changes enacted by SAFETEA-LU.
2. Indicate how, by whom, and for what purpose the information is to be used.
Preparation of UPWPs, project listing for SP&R funding, metropolitan and statewide plans, TIPs, and STIPs are essential components of decision-making by State and local officials for planning and programming federal transportation dollars to support the priority transportation investment needs of their areas. In addition to serving as the grant application by States for FHWA and FTA planning funds in metropolitan areas, UPWPs are used by FTA and FHWA on a national scale to establish national out year budgets and regional program plans, develop policy on using funds, monitor State and local consistency with national technical emphasis areas, respond to Congressional inquiries, prepare congressional testimony, and ensure efficiency in the use and expenditure of federal funds by determining that planning proposals are reasonable, cost-effective, and supportive of full compliance with all applicable federal law and regulations.
When reviewing UPWPs, FTA and FHWA evaluate:
the grantee's ability to carry out the work program;
the eligibility of each work task for funding;
c. the ability of the collective work tasks to ensure full compliance with all applicable federal laws and regulations; and
d. the inclusion of tasks reflecting areas of national policy emphasis.
Sections 5303 and 5304 of 49 U.S.C. and Sections 134 and 135 of 23 U.S.C. require the development of plans and programs in all urbanized areas and entire States respectively. After approval by the Governor and MPO, metropolitan TIPs in attainment areas are to be incorporated directly into the STIP. For nonattainment areas, as required by the Clean Air Act Amendments of 1990 (CAAA), FTA/FHWA must make a conformity finding on these areas' plans and TIPs before TIPs are incorporated within STIPs.
The complete STIP is then jointly reviewed and approved (or disapproved) by FTA and FHWA. With that action comes a joint determination, or finding, by FTA and FHWA that metropolitan and statewide planning processes are in compliance with all applicable federal laws and regulations. These planning “findings,” conformity determinations, and approval actions constitute the determination that State and metropolitan area transportation planning processes are complying with federal law and regulatory requirements - as a condition of eligibility for receiving federal-aid. Without the supporting documents, these “findings” and planning approvals cannot be made as the basis for making project-level grant awards.
Requirements of the TIP and STIP as described by 23 CFR Part 450 are:
Identification of projects - since a STIP/TIP is made up of various types of capital projects, from equipment acquisition to major highway and transitway construction, it is essential that these projects be identified and described.
Estimated cost - since the STIP/TIP is the basis for subsequent programming and obligation of both Federal Aid Highway and FTA capital funds, there must be an indication of project cost and federal funds required.
Source of federal funds - The STIP/TIP is an integrated FTA/FHWA program. Because both agencies have several statutory sources of funds, each with different eligibility requirements, it is necessary to know what projects are proposed to be funded from which fund.
Identification of the recipient - Because the STIP/TIP is an integrated program of highway and transit improvements, many potential capital grant recipients have projects included in the document. For FTA funding, it is necessary that each individual project be identified as to the likely capital grant applicant.
In nonattainment areas, the TIP must also identify and give priority to Transportation Control Measures (TCM) included in an approved State Implementation Plan (as required by the Clean Air Act) for air quality attainment and must describe how these TCMs are to be implemented. Projects included in nonattainment area TIPs must be described in sufficient detail to permit air quality analysis for the purpose of making a conformity determination.
In addition to the air quality analysis for nonattainment areas, FTA and FHWA's review of all areas must ensure that:
a. Programmed projects are consistent with long range plans.
b. Projects reflect the areas’ priorities and are consistent with the anticipated availability of funds.
c. The MPO and State Governor approve the metropolitan TIP and it is incorporated, without change, into the STIP.
d. An opportunity for public comment was provided during the development of the STIP/TIP.
The STIP/TIP requirement reduces the burden to potential capital grant applicants by imposing the programming requirements at one point and setting one response to these requirements.
Describe to what extent the collection of information involves the use of automated
or other technological collection techniques and any consideration of using information
technology to reduce burden.
The SP&R program, UPWP, metropolitan and statewide plan, TIP, and STIP are adaptable to computer generation and revision. Both FTA and FHWA have extensive technical assistance programs encouraging application of computer techniques. These programs reduce burden by achieving time-savings in technical analysis, report revisions, and clerical activities through automation.
4. Describe efforts to identify duplication. Show specifically why similar information
already available cannot be used or modified for use for the purposes described.
While the transit and highway funding programs for planning and project implementation are unique to FTA and FHWA, FTA and FHWA cooperate to avoid duplication of effort. Most visible is consolidating FTA and FHWA statutory requirements for planning through the issuance of joint planning regulations. MPOs and States prepare a single set of UPWPs, plans, TIPs, and STIPs to satisfy both FTA and FHWA requirements.
The information contained in projects proposed for funding under the SP&R programs, UPWPs, metropolitan and state plans, TIPs, and STIPs are not contained in any other federally required document. However, where this information is already contained in State and local planning documents, that can be accepted, provided all FTA and FHWA requirements are met, thus further reducing any duplication and unnecessary burden.
5. Describe methods used to minimize burden on small businesses or other small entities.
The SP&R programs, UPWPs, transportation plans, STIP/TIPs, and associated data collection does not involve small businesses. However, FTA and FHWA have eliminated several significant technical and administrative requirements which permit small urbanized areas to develop work activities which meet their own needs. The burden has been further minimized in the over 226 non-TMAs (urbanized areas under 200,000 population) in that a UPWP does not need to be developed; rather, the planning tasks for these areas may be documented elsewhere by the State and MPO. 23 CFR 450.308 also provides for simplified procedures and a five year update cycle for the development of plans in metropolitan areas which are in attainment of transportation air quality standards.
6. Describe the consequences to federal program or policy activities if collection were
conducted less frequently.
Less frequent data collection is not possible since it would not allow sufficiently current and accurate work descriptions and budget estimates. Furthermore, the schedules for planning documents set forth in the proposed regulations are identical to provisions set forth in SAFETEA-LU.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with 5 CFR 1320.6.
The information collected is consistent with the guidelines in 5 CFR 1320.6. Previous SP&R programs, UPWPs, plans, and STIP/TIPs need not be retained after revisions are made. Consequently, retention falls within the four-year requirement. The 20-year plan horizon cited in the joint planning regulations refers to an analysis period and not a record retention period.
8. Describe efforts to consult with persons outside the agency to obtain their views.
SP&R programs, UPWPs, metropolitan plans and TIPs have been submitted to FTA and FHWA for many years to support funding of the transportation planning and capital improvement programs for urbanized and non-urbanized areas. Continuing contact between each of FTA's grantees and FTA regional staff as well as FHWA's division office staff and State DOTs and MPOs provide opportunity for grantees to seek changes. No major problems have developed regarding this requirement. 49 CFR 106.31 provides that anyone may petition to establish, amend, or repeal a regulation. No petition has been received relative to this requirement.
While FTA and FHWA have taken every measure to lessen the burden of the statutory transportation planning requirements on MPOs and State DOTs without compromising the intent of a continuing, comprehensive, and coordinated planning process, it is clear that the development of statewide plans and STIPs and the added requirements to metropolitan plans and TIPs has resulted in some additional work for State DOTs and MPOs. FTA and FHWA have consulted (and will continue to do so) with these agencies in the development of supplemental guidance to the joint planning regulations to further lessen the burden of the statutory requirements.
A Final Rule focused on the requirement for consultation with non-metropolitan local officials in the development of statewide plans and programs was published on January 23, 2003. A Final Rule outlining the planning requirements set forth in SAFETEA-LU was published in the Federal Register on February 14, 2007. This regulation was prepared following an extensive process of stakeholder engagement which included listening sessions with effected stakeholders and publication of a Notice of Proposed Rulemaking that solicited comment from State DOTs, MPOs, and the general public on the proposed approaches for implementing the changes in SAFETEA-LU. The Final Rule documented and incorporated all comments received.
A 60-day Federal Register Notice was published on April 27, 2009 (page 19112) soliciting comments prior to submission to the Office of Management and Budget. No comments were received. A 30-day Federal Register notice was published on August 6, 2009 (page 39375).
9. Explain any decision to provide any payment or gift to respondents.
No payment or gift is made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in the statute, regulation or agency policy.
There is no assurance of confidentiality given regarding submission of the information collected. The data is used for determining eligibility for receipt of grant funds and compliance with statutory requirements.
Provide any additional information for questions of a sensitive nature.
The documents do not require any information of a sensitive nature. None of the information required is of a personal nature.
Provide an estimate of the hour burden of the collection of information and
annualized cost to respondents.
The following summarizes in tabular form the estimated burden hours for the collection of information for the purposes of developing and completing UPWPs, metropolitan and statewide transportation plans, and TIPs/STIPs and an explanation of the methodology used to calculate the number of hours required per submission.
Unified Planning Work Programs (UPWPs) – current Regulation
Total Burden Total Annual
Number of Annual Hours per Burden
Urbanized Area (UZA) Pop. Entities Submissions Submission Hours
Over 200,000 156 156 300 46,800
TOTAL 384 384 -- 92,400
Total Avg. Total
of States Annual Hours per Annual
& MPOs Submissions Submission Hours
Areas
MPOs in Nonattainment and
Maintenance Areas 237 59 550 32,450
State DOTs 52 13 275 3,575
Transportation Plans – current Regulation
Number Total Burden
of Annual Hours per Total Annual
Entities Submission Submission Burden Hours
Maintenance Areas 237 47 1,440 67,680
State DOTs 52 10 720 7,200
TOTAL 436 86 -- 100,980
TOTAL ANNUAL BURDEN HOURS
Burden Hours (2009)
UPWPs1 92,400
TIP/STIPs2 46,750
Plans3 100,980
TOTAL 240,130
Burden Cost (2009)
UPWPs $ 2,932,642
TIPs 1,352,111
Metropolitan Plans 3,540,072
STIPs 113,220
Statewide Plans 237,145
TOTAL $ 8,175,190
Estimated cost to the respondents: UPWP
The respondent's cost is the cost of the MPOs’ and State agencies’ staff time required to compile and produce the UPWP. UPWPs must be developed identifying work activities over the next one or two-year period. Given the complex nature of the planning requirements, we estimate that an average of 300 hours per respondent will be required by MPOs to prepare UPWPs in TMAs and 200 hours per respondent in non-TMAs.
Using a staff salary of $31.67 (based on annual staff salary of $65,880) per hour total respondent cost is estimated at $3,666,960. This figure was computed as follows:
158 TMA submissions x 300 hours x $31.67 = $1,501,158
226 Non-TMA submissions x 200 hours x $31.67 = $1,431,484
Note that although 23 CFR 450.308 allows MPOs in the 226 non-TMAs to prepare simplified statements of work, FTA and FHWA know of no MPOs that are developing such simplified statements.
Estimating 25 percent overhead, total annual cost to respondents = ($1,501,158 + $1,431,484 = $2,932,642) x 1.25 = $3,665,802.
OMB has previously approved the burden on respondents to develop State (SPR) work programs under FHWA control number 2125-0039.
Estimated cost to the respondents: TIP/STIP
Metropolitan TIPs are prepared by MPOs in cooperation with the State and local public transportation operators. TIPs are required every four years; plans in nonattainment and maintenance areas must be updated and submitted to FTA/FHWA every four years and in attainment areas every five years. Although the requirements for metropolitan TIPs and plans, particularly in nonattainment areas, are complex, current burden estimates have been generated from past experiences, informal discussion with both FTA/FHWA field staff and respondents, and a comparison of recent trends in the allocation of resources by respondents to meet the requirements. For example, given the increased level of detail required to comply with SAFETEA-LU, we estimate that MPOs in attainment areas will consume approximately 275 person hours in the development of the TIP document. Furthermore, considering the more stringent requirements relating to the implementation of Transportation Control Measures in nonattainment areas and the fact that most of these areas are in the Nation's largest metropolitan areas with the most projects to program, we estimate that an average of 550 person hours per submission are required for these TIPs.
The development by States of a STIP draws heavily on the work cooperatively done by MPOs and States in the preparation of metropolitan TIPs. This work burden has already been calculated in this section; however, to the extent that STIPs must reflect the programming of transportation projects in nonmetropolitan areas, there exists some marginal burden in the development of the overall statewide program. We estimate that burden at 275 person hours is required for each STIP.
Using a staff salary of $31.67 per hour, total respondent cost is estimated at $1,831,664 for TIP/STIP development. These figures were computed as follows:
TIPs/STIPs
147 submissions for attainment areas x 275 hours per submission x $31.67 divided by 4 years = $320,065
52 submissions for State DOTs x 275 hours per submission x $31.67 divided by 4 years = $113,220
237 submissions for nonattainment and maintenance areas x 550 hours per submission x $31.67 divided by 4 years = $1,032,046
Estimating 25 percent overhead total annualized cost =
($320,065 + $113,220 + $1,032,046 = $1,465,331) x 1.25 = $1,831,664
Transportation Plans
The Joint Planning Regulations require that plans in nonattainment and maintenance areas be updated and submitted to FTA/FHWA every four years and that plans in attainment areas be updated every five years. The development by States of a statewide plan draws heavily on the work cooperatively done by MPOs and States in the preparation of metropolitan TIPs and plans. This work burden has already been calculated in this section; however, to the extent that statewide plans must reflect the planning of transportation projects in nonmetropolitan areas, there exists some marginal burden in the development of the overall plan. We estimate that burden at 720 person hours are required for the preparation of the plan. These plans are updated every five years. Assuming an average rate of $31.67/ hour we estimate that the respondent cost for the metropolitan plan is $3,540,072 and for the statewide plan is $237,145. These amounts are calculated below:
147 submissions for attainment areas x 900 hours per year x $31.67 divided by 5 years = $837,988
237
submissions for nonattainment and maintenance areas x 1440 hours per
year x $31.67 divided by 4 years = $2,702,084
52 Plan submissions x 720 hours x $31.67 divided by 5 years = $237,145
Estimating 25 percent overhead, total annualized cost (837,988 + 2,702,084 + 237,145 =
$3,777,217) x 1.25 = $4,721,521
Provide estimate of annualized cost to respondents or recordkeepers resulting
from the collection of information (not including the cost of any hour burden
shown in Items 12 and 14).
There are no capital or start-up costs associated directly with the collection of information required by the UPWPs, TIPs/STIPs, and plans. Any capital equipment used to provide this information in most cases would have been purchased to carry out general transportation and air quality planning activities.
14. Provide estimates of annualized cost to the federal government.
a. Cost to the federal government: UPWP
The UPWP is a required statement of proposed planning activities to be undertaken by MPOs, in cooperation with States and public transportation operators, which forms the basis for FTA and FHWA to make funds available to State DOTs for financing the proposed work.
MPOs submit a UPWP at least biennially (although in practice most MPOs submit UPWPs annually). The federal government's cost is limited to the cost of FTA and FHWA staff time required in consultation with the MPOs and State DOTs during preparation of the UPWP and in reviewing the document or negotiating any revisions that may be necessary. This effort is done by FTA and FHWA field staff and is estimated to require about 10 hours to review each UPWP per year. At an average hourly rate of $38.44 for GS-13 staff, the annual federal cost of reviewing UPWPs for TMAs is estimated to be approximately $184,513 and is calculated as follows:
384 submissions x 10 hours per submission = 3,840 hours
3,840 hours x $38.44 hour = $147,610
Estimating 25% percent overhead, total annualized cost to the federal government is:
$147,610 x 1.25 = $184,513
Please note that each State DOT also submits a statewide planning work program, which serves as the basis of the State's application for federal financial assistance for planning activities. Typically, a State's work program incorporates UPWPs with less detailed work plans developed by MPOs in urbanized areas below 200,000 population in cooperation with the State and local public transportation operators. The statewide work program also describes the planning activities to be undertaken in rural areas and other activities.
The information collection requirements of the State work program have been
previously approved by the Office of Management and Budget under FHWA control
number 2125-0039.
b. Cost to the federal government: Metropolitan TIPs/Plans
In nonattainment areas each of the nation's 237 MPOs submits to FTA/FHWA their plans and TIPs for conformity determinations. Plans and TIPs in other areas are submitted for informational purposes. We estimate that the reviews of these documents in the 147 attainment areas consume a minimum of 20 hours per submission. Furthermore, FTA and FHWA must make a joint conformity finding for any new or amended TIP and for new or updated plans in the approximately 237 nonattainment and maintenance areas nationally for ozone, carbon monoxide, and PM10. We estimate that this conformity determination will take an additional 20 hours per finding.
Transportation Improvement Programs (TIPs)
TIPs are required to be submitted at least every four years; however, they may be amended at any time. We estimate that each amendment requires 5 person hours of FTA and FHWA staff time. FTA and FHWA may also be required to make new conformity findings for nonattainment area TIP amendments. We estimate that perhaps 50 percent of all TIPs will
be amended, and that, consequently, 50 percent of nonattainment area TIPs may be subject to more than one conformity finding every four years.
Given the above, we estimate that with an average grade of GS-13 ($38.44 per hour), the annual federal cost is $182,110 for TIP reviews and amendments as determined by the following:
384 TIP submissions every four years = 96 submissions/year
96 submissions x 20 hours x $38.44 = $73,805
50 percent TIP amendments every year = 48 submissions/year
48 amendments x 5 hours x $38.44 = $9,226
237 conformity findings every four years = 59 findings/year
59 findings x 20 hours x $38.44 = $45,359
50 percent conformity findings for TIP amendments in nonattainment areas every year
= 30 additional conformity findings/year.
30 findings x 15 hours x $38.44 = $17,298
Estimating 25 percent overhead, total annualized cost = (73,805 + 9,226 + 45,359 + 17,298 = 145,688) x1.25 = $182,110
Metropolitan Plans
Plans in the 237 nonattainment areas must be updated and reviewed every four years and in the 147 attainment areas every five years. The annual federal cost for reviewing metropolitan plans is $142,228 and is determined by the following:
147 plan submissions every five years = 30 submissions/year
30 submissions x 20 hours x $38.44 = $23,064
237 nonattainment area plan submissions every four years = 59 submissions/year
59 submissions x 40* hours x $38.44 = $90,718
Estimating 25 percent overhead, total annualized cost =
(23,064 + 90,718 = 113,782) x 1. 25 = $142,228
*20 hours for basic review and 20 hours for conformity finding = 40 hours
c. STIP/State Plan
Statewide Transportation Improvement Programs (STIPs)
The STIP is the financially constrained program of an entire State's FTA- and FHWA-funded (and other significant) transportation projects. It includes, either directly or by reference, TIPs prepared by MPOs for metropolitan areas. When included directly, the review of a TIP may occur within the context of a STIP submission, although FTA and FHWA must make a separate conformity determination on all TIPs in nonattainment areas before these TIPs can be included in the STIP (see 14b). Review and approval of the STIP, then, basically consists of the sum total of metropolitan TIP reviews (as described in 14b) plus reviews of programmed projects in rural areas and the statewide public participation process.
The FTA/FHWA review of the STIP is estimated at 20 person hours and of STIP amendments at 5 person hours. Although STIPs must be submitted a minimum of every four years, they may be amended at any time. Estimating that 50 percent of STIPs will be amended, the federal cost of STIP approvals is $14,054, and is computed as follows:
52 STIP submissions every four years = 13 submissions/year.
13 submissions x 20 hours x $38.44 = $9,994
50 percent STIP amendments every four years = 6.5 additional findings/year
6.5 findings x 5 hours x $38.44 = $1,249
Estimating 25 percent overhead, total annualized cost = ($11,243) x 1.25 = $14,054
Statewide Plan
The statewide plan requirement was continued under SAFETEA-LU. The plan is a required product of each of the 50 States, Puerto Rico, and the District of Columbia. The portion of the plan in metropolitan areas is to be developed in cooperation with MPOs. The review of this portion of the statewide plan occurs during the review of the metropolitan plan (see 14b for burden estimates). Review of the overall statewide plan is estimated at 10 hours.
23 CFR 450, Section 214 requires that statewide plans be “periodically updated.” Assuming a reasonable update cycle of 5 years, the cost of the federal government of statewide plan review is estimated at $9,610.
52 plan submissions every five years = 10 submissions/year
10 submissions x 20 hours x $38.44 = $7,688
Estimating 25 percent overhead, total annualized cost = $7,688 x 1.25 = $9,610
15. Explain the reasons for any program changes or adjustments reported to the
OMB.
The number of states and urbanized areas remained the same. The burden decreased by
10,165 hours due to changes caused by reclassification of counties and TMAs. The changes in the cost calculations reflect wage inflation5 and a shift of 45 counties from air quality attainment to non attainment status.6
16. Outline plans for tabulation and publication and address any complex
analytical techniques that will be used.
There are no plans for publishing the results or contents of the UPWPs, plans, or TIPs
submitted or for any tabulation or statistical analysis.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
Not applicable.
Explain each exception to the certification for Paperwork Reduction Act
submissions of OMB Form 83-I.
Not applicable.
1 Change in Burden Hours represents a reclassification of two TMAs as nonTMAs
2 Change in Burden Hours represents a reclassification of 45 counties previously in attainment of air quality standards to non attainment status
3 Change in Burden Hours represents a reclassification of 45 counties previously in attainment of air quality standards to non attainment status
4 These costs do not include 25 percent overhead expenses, which are in addition to any hour burden shown here
5 For reference, see http://www.usinflationcalculator.com/inflation/current-inflation-rates/ using published BLS CPI data
6 From the EPA Green Book of Nonattainment Areas at http://www.epa.gov/airprogm/oar/oaqps/greenbk/index.html
| File Type | application/msword |
| File Title | Justification of Burden Hours |
| Author | Peter Noyes |
| Last Modified By | DOT User |
| File Modified | 2009-08-13 |
| File Created | 2009-08-13 |