Metropolitan Planning Organization Responsibilities for the Transit Asset Management Rule FAQs
Updated June 25, 2019
Learn more about performance-based planning for transit.
Questions
- 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).
- Transit providers are required to set annual targets: their initial targets for fiscal year 2017 were required to be set by January 1, 2017. Yet, transit providers are not required to complete their TAM Plans until October 1, 2018. How can my MPO comply with the statutory and regulatory requirement to establish its initial State of Good Repair (SGR) performance targets (TAM targets) no later than 180 days after the transit providers establish their initial targets, i.e., by July 1, 2017?
- Several of the transit providers in my MPO’s metropolitan planning area are still assessing the condition of their assets and have not yet established their TAM targets. What should my MPO do if all the transit providers have not provided information on the condition of their transit assets and their initial TAM targets?
- If a transit provider operates within more than one MPO boundary, is it required to share its asset conditions, 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?
- 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 TAM targets, rather than one regional target per asset type that includes all providers. Is this allowed?
- 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 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 limited to the asset types used for NTD (National Transit Database) reporting?
- 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?
- Will my MPO receive a corrective action during a certification review if we cannot meet our TAM targets?
- 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?
- When my MPO amends or updates its 4-year TIP after October 1, 2018, is it required to demonstrate how the projects programmed in the TIP help meet our adopted TAM targets?
- If the transit provider requests an amendment to the TIP after October 1, 2018, must the MPO’s MTP be amended to reflect TAM targets?
- A transit agency that provides service in my metropolitan planning area has not provided its TAM targets to my MPO, and does not plan to do so until September 2018. Can my MPO amend or adopt a new TIP and/or MTP after October 1, even though the transit provider has not provided its targets?
- If a transit agency updates its TAM targets annually, and reports them to the National Transit Database, is the MPO required to adopt new targets within 180 days?
- My State Department of Transportation is preparing a Tier II group plan for its Section 5310 and 5311 subrecipients. Is the State DOT required to share the Tier II plan with the MPOs in the State?
- If the State DOT is the Tier II group plan sponsor and establishes TAM targets and shares it with the MPOs, are the MPOs required to establish those targets within 180 days?
- 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?
- To confirm, transit operators will set Public Transit Safety targets for the first time in July 2020 and MPOs will set targets for the first time 180 days after (in January 2021)?
- To confirm, targets will be set annually?
- Will targets be quantified as an annual number, or as a 5-year average as the road safety targets are quantified?
- Are MPOs required to set transit safety targets within 180 days after each time a public transportation provider sets transit safety targets, or set targets within 180 days of when initial transit safety targets are set, and then for subsequent transit safety targets, when the MPO updates its MTP (or sooner if they choose)?
- If the 180-day timeline applies only to initial targets, is there a regulatory/statutory/policy citation for this?
Questions and Answers
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. Yet, transit providers are not required to complete their TAM Plans until October 1, 2018. How can my MPO comply with the statutory and regulatory requirement to establish its initial State of Good Repair (SGR) performance targets (TAM targets) no later than 180 days after the transit providers establish their initial targets, i.e., by July 1, 2017?
You are correct that the statute and the joint FHWA-FTA final rule on planning (Statewide and Nonmetropolitan Transportation Planning; Metropolitan Transportation Planning) require an MPO to establish its initial TAM targets no later than 180 days after the transit providers establish their initial targets. Subsequent MPO targets must be set when updating the MTP. The final rule also provides that the MPO, state DOT, and transit providers that serve the metropolitan planning area coordinate, to the maximum extent practicable, when setting TAM targets.
How the MPO, state DOT and transit providers coordinate when setting TAM targets is based on the specific written provisions in which they jointly define how they will implement a performance based planning process. This includes cooperatively developing and sharing information related to transportation performance data, the selection of performance targets, the reporting of performance targets, the reporting of performance to be used in tracking progress toward attainment of critical outcomes for the region of the MPO. The final joint planning rule requires that the MPO adopt these jointly written provisions by October 1, 2018.
3. Several of the transit providers in my MPO’s metropolitan planning area are still assessing the condition of their assets and have not yet established their TAM targets. What should my MPO do if all the transit providers have not provided information on the condition of their transit assets and their initial TAM targets?
FTA recognizes that some transit providers may not have had complete data available to set their initial targets by January 1, 2017, which would delay the sharing of that information with the MPO. In these cases, once the transit agency(s) submits their asset condition information and their initial TAM targets to the MPO, it should coordinate with all transit providers in the metropolitan planning area to set the MPO’s initial targets within 180 days, according to the written procedures developed in coordination with the transit providers and state DOT(s).
4. If a transit provider operates within more than one MPO boundary, is it required to share its asset conditions, 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 asset conditions and TAM targets to each MPO in which the transit provider’s (or any Group plan participant’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 TAM targets, rather than one regional target per asset type that includes all providers. Is this allowed?
While setting regional TAM targets is a local decision, FTA suggests MPOs identify one region-wide 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 SGR and better determine how funding decisions support regional targets. To track progress towards attaining TAM targets, it is FTA’s expectation that an MPO shall select targets for its metropolitan planning area in coordination, to the maximum extent practicable, 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?
The MPO should rely upon the written procedures it developed with the transit providers that serve its metropolitan planning area and the state DOT(s). These written procedures should define the approach that the MPO will use to integrate the information, including the condition of the transit agency’s assets and established targets, 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 limited to the asset types used for NTD (National Transit Database) reporting?
If the MPO, transit agencies that provide service in the metropolitan planning area and state DOT(s) determine that it would be useful to the MTP and TIP planning process and performance reporting for a more refined breakdown of asset types than used for NTD, this would be included in the agreed upon written procedures to implement the performance-based planning process.
Please note that 49 CFR 625 requires transit providers to report their asset performance and targets to the NTD. The NTD will produce a report on asset performance and targets by MPO area. FTA anticipates the report will be published in late 2019 in conjunction with the publication of verified 2018 data.
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?
The MPO does not send its’ established TAM targets to FTA for review and approval. However, through the certification review of MPOs in the transportation management areas undertaken every four years, FHWA and FTA will review whether the MPO is 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.
This review will focus on the development and implementation of written procedures by the MPO in coordination with the transit agencies that provide service in its metropolitan planning area and the state DOTs. With respect to the performance-based planning requirements, the review will examine whether the MPO’s metropolitan planning process integrates (directly or by reference) the goals, objectives, performance measures, and targets described in the Transit Asset Management Plan, and that the system performance report measures progress toward achieving selected targets with each update of the MTP and whether the TIP includes a description of how the program of projects contributes to achieving the MPO’s performance targets in the MTP, linking investment priorities to those targets.
9. Will my MPO receive a corrective action during a certification review if we cannot meet our TAM targets?
No, the MPO will not receive a corrective action during a certification review if it does not meet its TAM targets. There are no penalties, or incentives, for meeting or missing established targets.
During the certification review, FTA and FHWA will examine whether the MPO’s metropolitan planning process integrates (directly or by reference) the goals, objectives, performance measures, and targets described in the Transit Asset Management Plan, and that the system performance report measures progress toward achieving selected targets with each update of the MTP and whether the TIP includes a description of how the program of projects contributes to achieving the MPO’s targets.
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, MPOs, are not required to update an MTP and TIP that was approved prior to October 1, 2018, to reference the TAM targets unless the MPO takes an action to amend the MTP and/or TIP. Any amendment of the 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. When my MPO amends or updates its 4-year TIP after October 1, 2018, is it required to demonstrate how the projects programmed in the TIP help meet our adopted TAM targets?
Yes, in order for an MPO to amend or update its 4-year TIP after October 1, 2018, the MPO must include a description of the anticipated effect of the TIP toward achieving the TAM targets set by the MPO.
12. If the transit provider requests an amendment to the TIP after October 1, 2018, must the MPO’s MTP be amended to reflect TAM targets?
No. If an MPO acts to amend its TIP after October 1, 2018, it does not have to amend its MTP to include the TAM targets if the programmed projects are consistent with the current MTP.
13. A transit agency that provides service in my metropolitan planning area has not provided its TAM targets to my MPO, and does not plan to do so until September 2018. Can my MPO amend or adopt a new TIP and/or MTP after October 1, even though the transit provider has not provided its targets?
No, FTA and FHWA will not approve an amended MTP, TIP or STIP after October 1, 2018 unless the planning products to be amended reflect the performance based planning process.
An MPO cannot amend or adopt its TIP after October 1, 2018 unless it describes the anticipated effect of the TIP toward achieving the TAM targets set by the MPO. It cannot adopt or amend its MTP unless the MTP includes a description of the performance measures and targets used to assess the performance and condition of the transportation system. It must also include the performance system report that evaluates the performance and condition of the transportation system with respect to these performance measures and targets. The TAM and Joint Planning Final Rules require transit providers to provide their TAM targets to the MPO.
FTA and FHWA encourage MPOs to work with the transit agencies in their metropolitan planning area to develop written procedures on how they will collect, share and report TAM data and how they will cooperatively set SGR targets.
14. If a transit agency updates its TAM targets annually, and reports them to the National Transit Database, is the MPO required to adopt new targets within 180 days?
No. The MPO may adopt new TAM targets when it updates it TIP and MTP on its four-year cycle. This process should be documented in a written agreement between the transit providers, the MPOs, and the State DOT.
15. My State Department of Transportation is preparing a Tier II group plan for its Section 5310 and 5311 subrecipients. Is the State DOT required to share the Tier II plan with the MPOs in the State?
Yes, the State DOT must share its Tier II group plan with those MPOs whose TIPs program funding for the Section 5311 or 5310 sub-recipients’ projects or services.
16. If the State DOT is the Tier II group plan sponsor and establishes TAM targets and shares it with the MPOs, are the MPOs required to establish those targets within 180 days?
No. The MPO may establish new TAM targets when it updates it TIP and MTP on its four-year cycle. This process should be documented in an agreement between the transit providers, the MPOs and the State DOT.
17. 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. The process to establish TAM targets is decided locally among the MPO, the transit agencies that serve the metropolitan planning area, and the State DOT(s). For national consistency in reporting, 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 TAM targets in coordination, to the maximum extent practicable, with the transit agencies. 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.
Public Transportation Agency Safety Planning
18. To confirm, transit operators will set Public Transit Safety targets for the first time in July 2020 and MPOs will set targets for the first time 180 days after (in January 2021)?
The PTASP rule requires transit providers to have their certified agency safety plans in place, which includes the first set of required safety performance targets, and share these targets with the MPO no later than July 20, 2020. The MPOs then have 180 days from receipt of the agency performance targets to prepare their initial public transportation safety performance targets. (23 C.F.R. § 450.306d (3)) MPOs with multiple transit providers should work with the transit providers to identify appropriate targets for that metropolitan area.
19. To confirm, targets will be set annually?
Each transit provider is required to review its agency safety plan, annually and update the plan, including the safety performance targets, as necessary.
The MPO is not required to set new transit safety targets each year, but can choose to revisit the MPO’s safety targets based on the schedule for preparation of its system performance report that is part of the Metropolitan Transportation Plan (MTP). The first MPO MTP update or amendment to be approved on or after July 20, 2021, must include the adopted transit safety targets for the region. The next MTP update, but not each MTP amendment, also includes an updated system performance report that contains the adopted transit safety targets.
20. Will targets be quantified as an annual number, or as a 5-year average as the road safety targets are quantified?
FTA has defined a specific methodology for target setting. Each transit agency and MPO may establish the process and methodology for setting transit targets. FTA’s National Public Transportation Plan includes guidance that agencies and MPOs may consider when setting transit targets.
21. Are MPOs required to set transit safety targets within 180 days after each time a public transportation provider sets transit safety targets, or set targets within 180 days of when initial transit safety targets are set, and then for subsequent transit safety targets, when the MPO updates its MTP (or sooner if they choose)?
The MPO’s initial transit safety targets are set within 180 days of receipt of the transit safety targets from the transit agencies. The MPO then revisits the its targets based on the schedule for preparation of its system performance report that is part of the Metropolitan Transportation Plan (MTP). The first MTP update or amendment to be approved on or after July 20, 2021 is required to include the MPO’s transit safety targets. The next MTP update, but not each MTP amendment, also includes an updated system performance report that contains the MPO’s transit safety targets. MPOs may choose to update their transit targets more frequently, but the second federally-required system performance report must reference the information contained in the first federally-required system performance report.
22. If the 180-day timeline applies only to initial targets, is there a regulatory/statutory/policy citation for this?
The process for setting performance targets for safety and transit asset management, sharing data and the public transit agency safety plans and transit asset management plans, frequency for updating the targets, and tracking progress towards meeting the performance targets, must be defined within the metropolitan planning agreements or other written provisions between the MPO, the State DOT, and transit providers. The decision on how often the MPO will adopt new targets (when a transit provider updates their Safety targets) is up to the MPO and transit provider.