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Metropolitan Planning Organization Responsibilities for the Transit Asset Management Rule FAQs

Prepared March 13, 2017

Learn more about performance-based planning for transit.

1. My MPO serves the role of a transit provider (or Group Plan sponsor), and I have questions about the TAM requirements pertaining to transit providers (or Group Plan sponsors).

See a detailed list of TAM FAQs for answers about TAM performance measures, target setting and TAM plan requirements for transit providers and group plan sponsors. This FAQ focuses on the MPO responsibilities to set targets and incorporate TAM-related performance based planning in the Metropolitan Transportation Plan (MTP) and Transportation Improvement Program (TIP) process.

2. Transit providers are required to set annual targets:  their initial targets for fiscal year 2017 were required to be set by January 1, 2017.  How will the MPO be able to use annual targets to support the performance management provisions of the MTP and TIP, which cover a much longer time period?

Under the joint FHWA-FTA final rule on planning (Statewide and Nonmetropolitan Transportation Planning; Metropolitan Transportation Planning), MPOs, state DOTs, and transit providers are required to coordinate to the maximum extent practical when setting transit performance targets. The MPO should work with the state DOT and transit providers to develop specific written provisions to define how they will coordinate with the transit providers in their metropolitan area to implement a performance based planning process, including how they will establish performance targets within their MTP and TIP. 

Transit providers are required to prepare their initial TAM Plan by October 1, 2018, update it every four years, and share it with their MPO.  The TAM Plan has multiple elements including the transit provider’s prioritized list of investments to improve the state of good repair of their capital assets over a four-year period.  The MPO should integrate the TAM plan(s) into their planning process and coordinate with the transit providers to implement a performance based planning process that prioritizes investments that meet regional performance targets for State of Good Repair.

3. For my MPO to establish initial TAM performance targets by July 1, 2017, each transit provider in our metropolitan area must provide their targets for State of Good Repair (SGR) for each asset class. However, several of them are developing their TAM plans and are not finished. What should my MPO do if all of the transit providers have not provided their performance targets?

FTA recognizes that some transit providers may not have had complete data available to set their initial targets by January 1, 2017, which in some cases may be leading to ongoing delays for the transit providers to share with the MPO. In these cases, once the transit agency(s) submits their performance targets to the MPO, it should coordinate with all transit providers in the metropolitan area to set the MPO’s initial targets within 180 days. FTA will not require deviation from normal planning cycles, as per 23 U.S.C 134(l): The Secretary shall not require a state to deviate from its established planning update cycle to implement changes made by this section.

4. A transit provider operates within more than one MPO boundary, so is the provider required to share their TAM targets and TAM Plans with all the MPOs where it operates?  What if the transit provider’s service within an MPO boundary is only a small part of their service, as may exist with 5311-funded rural transit operators?

The transit provider (or Group Plan sponsor) must provide their TAM targets to each MPO in the metropolitan area in which the transit provider’s projects and services are programmed in the MPO’s TIP.

5. My MPO has coordinated with each transit provider in our region, and we would like to incorporate each provider’s individual targets for their different asset types as the MPO’s set of targets, rather than one regional target per asset type that includes all providers. Is this allowed?

While setting regional SGR performance targets is a local decision, FTA suggests MPOs identify one region-wide State of Good Repair performance target for each asset type for all transit providers in that region.  This will enable the MPO to assess progress towards region-wide attainment of transit state of good repair performance and better determine how funding decisions support regional targets for SGR.  In order to track progress towards attainment SGR performance targets, it is FTA’s expectation that an MPO shall select performance targets for its metropolitan planning area in coordination, to the maximum extent practical, with the providers of public transportation.

6. Each transit provider sets targets based on their own fiscal year, which is sometimes different from what my MPO uses as their fiscal year. How should the MPO address this issue?

FTA is relying on the local coordination process, as documented in updated metropolitan planning agreements between the MPO, transit providers, and State, to define the approach for how the MPO will integrate the information obtained from multiple transit providers into the MPO’s target setting and MTP and TIP planning process.

7. FTA guidance states that transit providers are required to set targets for the specific asset classes in each of the four asset management categories, for which the provider has an asset type in their inventory. (Please see the NTD Asset Inventory Module (AIM) for more information on asset data).  But to support performance based planning in the MTP and TIP planning process, there may be a local need for an even more refined breakdown (e.g., targets for buses that are separately-tracked for 30-foot and 40-foot buses).  Are the MPO’s targets supposed to be limited to just the asset types used for NTD (National Transit Database) reporting?

This is a local decision. The MPO may use additional breakdowns of the NTD-reported asset types, if this is useful to the MTP and TIP planning process and performance reporting. The performance reports should be clear on how all of the MPO’s targets were developed. Please note that 49 CFR 625 requires transit providers to report their SGR targets in terms of NTD’s asset types. 

8. As the MPO, where do we send the TAM targets we are required to establish within 180 days of receiving the transit agency’s targets, and how are they approved?  How is the subsequent TAM-related work that is done to support the MTP and TIP planning process reviewed and approved?

While the transit providers (or Group Plan sponsors) are required to provide their TAM targets and TAM plans to the MPO, and the MPO provides their targets and performance reports to the state DOT (or multiple state DOTs if the MPO is in more than one state), the MPO’s targets are not sent to FTA for review and approval.  The MPO sets their targets in coordination with the transit providers, and the MPO’s system performance reports measure progress toward achieving those targets with each update of the MTP.  In the TIP, MPO’s must describe how implementation of the TIP is anticipated to make progress toward achievement of targets.  Every four years FTA and FHWA undertake a planning certification review of each MPO in a transportation management area (TMA), where we will be looking at how the MPO to demonstrates how they are implementing a performance based planning process that is consistent with the FHWA-FTA Final Rule on planning (Statewide and Nonmetropolitan Transportation Planning; Metropolitan Transportation Planning) and the Transit Asset Management Final Rule. 

9.  Will my MPO receive a corrective action during a certification review if we cannot meet our regional performance targets for transit State of Good Repair?

No, there are no penalties, or incentives, for meeting or missing a TAM performance measures target. FTA and FHWA will review the MPO’s planning process to determine if the MPO and local planning partners have referenced the performance based plans and incorporated performance targets into the MPO’s MTP and TIP. However, FTA will not provide a corrective action if transit targets are not met.

10. As the MPO, are we required to update an MTP and TIP that was approved prior to October 1, 2018, to reference the TAM targets?

No. For plans adopted before October 1, 2018, there is no requirement to include TAM performance measures or performance targets as part of your plans and programs.  Please note, however, that any amendment of your MTP or TIP after October 1, 2018, will trigger the requirement to incorporate transit performance management components into the planning process.  NOTE:  Other Performance Management targets (Highway Safety, Bridge, Pavements, etc.) will each have their own implementation dates.

11. The transit provider’s targets will be updated annually, so does this mean the MPO must do the same?

No.  The transit providers (or Group Plan sponsors) will share their targets annually with their respective MPO or MPOs.  The MPO’s targets are not required to be updated annually, but must be revisited when the MPO updates its MTP and/or TIP.

12. The transit provider’s performance metric calculations do not incorporate any weighting for value of asset or level of use.  As the MPO, are we allowed to incorporate weighting strategies, if it is useful to the MPO planning process?

Yes. These are local decisions. For national consistency in reporting the SGR performance measures, the performance metric calculations prepared by each transit provider (or Group Plan sponsor) to satisfy the TAM rule do not allow any weighting strategies. However, MPOs and their metropolitan planning partners routinely utilize weights for the various rating criteria as they are used in setting priorities for MTP and TIP inclusion. FTA recognizes that each transit provider and MPO has the prerogative to develop and implement a unique analytical approach or decision support tool to prioritize its asset investments. FTA also recognizes that the statute and regulation provide that an MPO must integrate the transit agencies’ asset management plans into the MPO planning process. The MPO must also select SGR performance targets in coordination, to the maximum extent practicable, with the transit agencies.  So if it is useful to the local MTP and TIP planning process, the MPO may consider different weighting strategies to prioritize investments. However, the MPO’s performance reports should be clear on the impacts of a selected strategy, when compared to non-weighted calculations.

Updated: Monday, April 10, 2017
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