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Policies and Guidance

Stewardship and Oversight Agreement

Between the Pennsylvania Department of Transportation
and the Federal Highway Administration

August 2012

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  1. Introduction
  2. Statutory Basis
  3. Intent and Purpose
  4. Other Public Agencies
  5. Standards, Specifications and Policies
  6. PennDOT Assumption of Certain FHWA Responsibilities
  7. Stewardship and Oversight Activities
  8. Oversight Designation and Project Categories
  9. Business Service Standards
  10. Implementation
  1. Introduction

    The Federal Highway Administration (FHWA) and the Pennsylvania Department of Transportation (Penn DOT) hereby enter into this Stewardship & Oversight Agreement (hereafter referred to as "Agreement") for the purpose of administering the Federal-aid Highway Program (FAHP) in Pennsylvania. This Agreement clarifies the stewardship and oversight roles and responsibilities of both the FHWA and Penn DOT in implementing the FAHP. The Agreement is intended to result in the efficient and effective management of public funds and to ensure that the FAHP is delivered consistent with laws, regulations, policies, and good business practice in Pennsylvania. This Agreement defines select stewardship and approval roles for Federal-aid design and construction projects in Pennsylvania. It includes PennDOT's assumption of certain FHWA oversight roles and approval responsibilities on specific categories of projects.

    This Agreement categorizes Federal-aid design and construction projects as FederalOversight (FO), Penn DOT-Oversight (PO)- National Highway System (NHS), or PennDOTOversight (PO)- Non-NHS on the basis of highway system, cost and level of risk. Further, it delegates to Penn DOT certain non-project approval actions that would otherwise be taken by FHWA.

    This Agreement provides for a risk-based approach where PennDOT and FHWA agree on how the FAHP will be administered in Pennsylvania, with specific actions to be taken by one or both parties. This Agreement is the documentation of the delegations, under 23 U.S.C. Section 106, from direct Federal-Oversight that are desired and accepted by Penn DOT and recognized by FHWA. The delegation options of 23 U.S.C. Section 106 are desirable for Penn DOT for the streamlining of processes. Delegations are desirable for FHWA because reduced project-level involvement allows for more effective application of resources. Notwithstanding the Agreement, FHWA retains overall responsibility for all aspects of Federal-aid programs and an Agreement does not preclude FHWA's access to and review of a Federal-aid project at any time and does not replace the provisions of Title 23, U.S.C. While Federal law allows a State DOT to assume certain project approvals and authorities, FHWA is ultimately accountable for ensuring that the FAHP is delivered consistent with established Federal requirements and FHWA is ultimately accountable for all Federal-aid highway projects.

    On the broader program level, FHWA will continue to provide stewardship and oversight of the FAHP through general actions and concurrences in its day-to-day activities, including improvements to program procedures, training, technical assistance, and development and deployment of new technologies, as well as routine program/project approval. Each of these activities contributes to the intent that the FAHP operates with integrity and for the public's maximum benefit.

  2. Statutory Basis

    The principal statutory and regulatory basis for development, administration, and oversight of Federal-aid projects are Title 23, United States Code (U.S.C.)- Highways, and Code of Federal Regulations {CFR), in particular 23 CFR. The specific statutory basis for this agreement is Title 23 U.S.C., Section 106, Project Approval and Oversight.

    It is recognized that the NHS (which includes the Interstate System) is of primary importance to the FHWA. Federal legislation relative to Interstate commerce and defense needs require that design standards, connectivity between States, and consistency for the motoring public be maintained on the NHS. FHWA retains overall oversight responsibility for all aspects of Federal-aid programs in Pennsylvania.

  3. Intent and Purpose

    The intent of this Agreement is to delegate FHWA's approval authority for preliminary engineering, construction contract administration, and right-of-way activities on or related to Federal-aid projects, consistent with enabling statutes and regulations, with specified exceptions for special interest project categories.

    PennDOT will assume certain FHWA Title 23 oversight roles and approval responsibilities on PO projects, including locally administered projects. This includes responsibility for ensuring that staff has appropriate training and knowledge to make sure that programs and projects are developed in full conformance with Federal requirements and that necessary corrective action is taken when actions and approvals are found to be in non-compliance with applicable Federal requirements. FHWA is available for consultation in such matters or may unilaterally become involved in determining corrective action.

  4. Other Public Agencies

    1. Eligible public agencies (city, county) or other State agencies may be permitted by Penn DOT to take project approval actions and administer Federal-aid design and construction projects if they have jurisdiction over the roadway in accordance with 23 CFR 635- Construction and Maintenance. Penn DOT is responsible for administration of all Federal-aid projects, and will assure local public agency knowledge of and compliance with State and Federal requirements. The requesting public agency may develop procedures which modify and/or supplement the procedures contained in this Agreement or otherwise published by Penn DOT, as long as the public agency procedures are approved by Penn DOT and FHWA, and the agency certifies that it will operate in compliance with them. Penn DOT is responsible for providing FHWA with documentation of the results of their quality assurance program relative to oversight activities of other public agencies.

    2. For projects Involving the Pennsylvania Turnpike Commission (PTCL project approval authority is delegated to Penn DOT for all type projects shown as PO in Table 1.

  5. Standards, Specifications and Policies

    PennDOT will comply with the provisions of Title 23 U.S.C, 23 CFR - Highways and all appropriate Federal and State laws, regulations, standards, and directives. Penn DOT will develop Federal-aid projects in accordance with the standards and guides identified in 23 U.S.C. 109, 23 CFR 625- Design Standards for Highways (as well as other FHWA policies identified in the Federal Register, the Federal-aid Policy Guide and elsewhere) and/or Penn DOT standards or manuals approved by FHWA.PennDOT manuals and guides are identified in Appendix A. Additions to Appendix A will occur as additional policies and guidance are developed, approved by FHWA, and implemented by PennDOT.

    PennDOT agrees that any revisions or additions to policy and procedure statements, design manuals, letters containing policy, rules and regulations, specifications and standards affecting the development or administration of Federally funded projects will be submitted, with a formal transmittal letter, to the FHWA Division Office for approval and/or concurrence. Design standards for non-NHS projects do not require FHWA approval.

  6. PennDOT Assumption of Certain FHWA Responsibilities

    It is agreed that PennDOT's assumption of certain responsibilities does not preclude FHWA access to and review of Federal-aid projects at any time, and that it does not replace the provisions of Title 23, U.S.C. with respect to the basic structure of the FAHP.

    Nothing in this Agreement shall affect or discharge any responsibility or obligation of the FHWA under any Federal law other than Title 23, U.S.C. Such other Federal requirements include, but are not limited to, the National Environmental Policy Act (NEPA), Section 4(f) of the Department of Transportation Act of 1966, the Clean Air Act, the Clean Water Act, the Civil Rights Act of 1964, NHPA Section 106, Davis Bacon Act (40 U.S.C.), Brooks Act, Disadvantaged Business Enterprise (DBE) (49 CFR 26), and the Uniform Relocation Assistance and Acquisition Policies Act of 1970 as Amended (i.e., Uniform Act) (49 CFR 24).

    At the time of FHWA's approval of funds for PennDOT-Oversight projects, it is understood that PennDOT has certified that eligibility and appropriate Federal requirements have been met or identified steps to be taken to ensure that requirements will be met. Notwithstanding this determination, FHWA continues to retain overall responsibility for all aspects of Federal-aid programs and, as such, shall be granted full access to review any aspect or record of a Federal-aid project at any time. In matters concerning questionable eligibility for Federal participation in the programming, development, and construction of Federal-aid projects, PennDOT will consult with FHWA or FHWA may choose to become involved in determining eligibility.

  7. Stewardship and Oversight Activities

    In carrying out their roles and responsibilities, FHWA and PennDOT will perform several program or project oversight activities including, but not limited to, those described in this Agreement. The FHWA's stewardship and oversight activities will be documented in an annual "Program of Oversight Initiatives" (POl) report, developed by FHWA, which will be shared annually with PennDOT. This document provides details of how the Stewardship and Oversight activities are being implemented by FHWA.

    Project Oversight- Project oversight refers to the activities performed at a project level by FHWA and PennDOT to ensure that projects are being designed and constructed in accordance with Federal and State requirements. The process for project oversight designations is described in Section VIII of this Agreement. FHWA oversight activities are included in Section VIII, and Appendices A and B. In addition to projects designated in Table 1 as FO, FHWA also performs Program Assessment Reviews (PARs). PARs are periodic "spot checks" of PennDOT-Oversight design and construction projects and may include participation from PennDOT District Office staff. FHWA identifies these projects at random in coordination with PennDOT's District Offices. PARs are designed to focus on evaluating and improving current activities, and following-up on unresolved issues from previous reviews. PARs also give FHWA a general understanding of individual PennDOT Districts' oversight. In addition, project reviews help feed the selection process for future program reviews. FHWA may also utilize various other project review techniques, including participation in project-related meetings, participation in value engineering teams, partnering activities, and telephone contacts.

    As determined by FHWA, PARs occur throughout the year in each PennDOT District. Findings of PARs are shared with PennDOT Central Office and the respective District as a means to monitor PennDOT's overall quality control and quality assurance processes.

    Program Oversight - Program oversight refers to the activities performed at a program level by FHWA and PennDOT to assess the performance of the FAHP to ensure that Federal and State requirements are being followed. Program assessments include, but are not limited to, joint risk assessments, certifications, the Financial Integrity Review and Evaluation (FIRE) Program, self-assessments, Right-of-Way spot check reviews, and the Independent Oversight Program (lOP). These tools are based on the common concepts of identifying strengths, areas for improvement, opportunities, and sharing "best" practices. These assessments may be triggered by National strategies or initiatives to address specific program areas, as well as the desire to strive for continuous improvement of the FAHP.

    The following is a detailed description of some techniques used in conducting program level stewardship and oversight of the FAHP:

    1. Risk Assessment- FHWA and PennDOT will tri-annually perform joint risk assessments of various program areas for the purpose of prioritizing its program level oversight activities. This assessment will be jointly reviewed in the other years to determine if the risks identified have been addressed and no additional action is needed. The risk assessment will include identification of risk responses that FHWA and PennDOT will undertake either individually or jointly. The risk response strategies will include identification of program reviews of Federal-aid projects and PennDOT processes. These program reviews will be captured in the Independent Oversight Program.

    2. Financial Integrity Review and Evaluation (FIRE)- The FIRE Program is an oversight program to ensure that Federal-aid funds are properly managed and effectively used in accordance with Federal policies, and that safeguards are in place to minimize fraud, waste, and abuse. The FIRE program includes Funds Management, Federal-aid billing, Major projects, Project authorization, Modification and Voucher, and Locally Administered Projects. The FIRE program is a consistent process for identification and prioritization of risk events, and identification of strategies for risk mitigation.

    3. Performance Indicators/Measures- Performance indicators will be established for the program areas within twelve months of the execution of this agreement. These performance indicators will be documented in Appendix B. The measures help assess performance in administering FAHP requirements and assist in determining whether funds are being effectively utilized to improve the transportation system. The indicators/measures also serve as a tool in conducting annual risk assessments.

      PennDOT provides status reports on these measures to FHWA for review twice per year; mid-performance year (December) and end of performance year (June). In addition, the measures will be revised within 30 days after the beginning of the FHWA Performance Year. Maintaining, updating, and improving the performance indicators/measures are the continuous responsibility of FHWA and PennDOT. The responsibility for tracking each individual measure will be assigned during joint meetings and can be subject to modification or change, if both parties agree. Measures can be evaluated at any time by FHWA and PennDOT.

    4. The Independent Oversight Program (lOP) -The lOP includes program reviews that are triggered by the joint risk assessment and/or by the performance indicators/measures that suggest a need for improvement, or by general recurring reviews of programs. In general, FHWA will use the lOP process to assess the capability and capacity of PennDOT in those areas where PennDOT has assumed FHWA's responsibilities. The lOP includes formal procedures for conducting reviews, developing reports, and tracking resolution of findings and recommendations. The reviews are conducted to:

      • Assess compliance with Federal requirements.
      • Identify opportunities for greater efficiencies and improvements to the program.
      • Identify exemplary best practices.
      • Identify areas that need attention and make recommendations for improvement.

      The number of reviews and the review topics are jointly established annually by FHWA and PennDOT and are based on the results and recommendations of the program assessment which includes a risk assessment analysis. Reviews may be initiated by both FHWA and PennDOT and are designed to include a multidisciplinary team from both agencies. Based on the outcome of the lOP, an action plan may be required to address the recommendations or corrective actions identified in the reviews. The action plan will be jointly monitored until the recommendations and corrective actions have been satisfactorily addressed. At the beginning of each FHWA performance year, FHWA will develop its schedule of reviews for the forthcoming year in coordination with PennDOT.

    PennDOT-Oversight Responsibilities - PennDOT is committed to improving quality in all facets of its operations to ensure that highway programs and projects adequately meet the existing and future transportation needs and conditions in a manner conducive to safety, environmental requirements, durability, and economy of maintenance. Projects will be designed and constructed in accordance with standards best suited to accomplish this objective and to conform to the particular needs of each locality.

    PennDOT's Quality Management Program provides guidelines for Quality Control and Quality Assurance that identifies project team responsibilities, including consultants, District Office, and Central Office, for overseeing production of quality products to accomplish project objectives and to conform to the particular needs of each locality.

    1. Quality Control (QC) is the process performed by PennDOT (and/or its consultants and contractors) that ensure developed products comply with Federal and State requirements and standards. QC is the responsibility of the party producing the product or service. For example, a document (calculations, drawings, reports, etc.) produced by a designer is thoroughly checked by another qualified person to ensure utilization of accepted logics, practices, and correctness of all information.

    2. Quality Assurance (QA) is the planned and systematic action performed by a party not involved in QC to provide adequate confidence that delegated approvals comply with Federal and State requirements and standards. An example is the performance of a limited, high-level review of each product to confirm quality, economy, and compliance with laws, regulations, and policies prior to final acceptance by PennDOT or prior to submission to external agencies for approval.

    Quality assurance and quality control are assured through the Program Oversight activities described above. PennDOT Central Office has delegated project development and delivery activities to District Engineering Offices and committed to performing Quality Assurance Reviews. The results of the reviews are to be shared with FHWA on an annual basis. FHWA and PennDOT will jointly identify which QA reviews to include in the annual report within twelve months of the execution of this Agreement. The agreed upon reviews will be documented in Appendix A. Quality assurances relative to Financial Management are described in Appendix A, Federal-aid Financial Procedures.

  8. Oversight Designation and Project Categories

    1. General Information -As provided for in Federal legislation, certain categories of Federal-aid projects are delegated to PennDOT for oversight responsibility. On PennDOT-Oversight projects, PennDOT will act on behalf of the U.S. Secretary of Transportation and FHWA in the development and approval of projects in accordance with the provisions in this Agreement and applicable Federal regulations, with the expectation that it exercises similar judgment based on Federal laws, regulations, and FHWA policies.

      Non-Title 23 requirements such as the NEPA, and Section 4{f) apply to both NHS and Non-NHS Federal-aid projects, and FHWA will review and approve the applicable actions for all FO and PO projects, except for those programmatically delegated to PennDOT. FHWA will also approve Right-of-Way (ROW) actions related to hardship and protective buying requests under the provisions of 23 CFR. Other Title 23 requirements (e.g., Metropolitan and Statewide Planning) apply to both NHS and Non-NHS projects. In addition,Title 23 requirements pertaining to contracts (for example, bid proposal content, including Davis Bacon, and DBE) and procurement procedures (competitive bidding, Brooks Act) apply regardless of whether the project is on or off the NHS.

    2. Risk-based Oversight Designations- Upon Statewide Transportation Improvement Program {STIP) approval, PennDOT will provide FHWA with a list of projects programmed for the upcoming three years based on the criteria included in Table 1. Immediately after, a project oversight meeting will be held with each PennDOT District, with FHWA, PennDOT Central Office, and District staff in attendance. The purpose of the meeting is for FHWA and PennDOT to specifically review the list of projects for each District and jointly make an oversight designation. FHWA, in consultation with PennDOT, will make risk-based oversight designation changes to meet FHWA and PennDOT goals, objectives, and identified risk areas, while at the same time considering FHWA workload. This may include changing projects deemed to be low-risk from Federal-Oversight to PennDOT-Oversight, and changing other projects not typically designated as Federal-Oversight to be designated as such because they meet the criteria in Table 1, Part B.

      On interim years of the STIP, preferably at the beginning of the Federal fiscal year, a modified project oversight meeting will be conducted in each District with representatives from FHWA, PennDOT Central Office, and the PennDOT District. The focus of the meeting will be to review the most current list of projects that will advance to design or construction and make changes to the oversight designations based on modifications in project scope or cost. The meeting will also be used to assess and determine the oversight designation of projects that were added to the STIP after it was approved. Within two weeks of the project oversight meetings, PennDOT will submit meeting minutes and the agreed upon list of full oversight projects to the FHWA Division for final approval. Any changes to oversight designation that occur outside of the project oversight meetings must be documented in writing and formally approved by FHWA.

      Federal-Oversight generally occurs from the beginning of preliminary engineering through construction of a project. In rare cases, a project may warrant Federal­ Oversight of a specific phase where there exists a Federal interest specific to that phase. For example, FHWA may determine that a project warrants Federal-Oversight up to bid award, but not during the construction phase of the project. Phase-specific Federal­ Oversight will be designated on a case-by-case basis at the time of the annual project oversight meeting or as a project progresses through the phases of design to construction. On projects that are not initially FO, FHWA will only be involved in approval actions that occur within the duration of the phase that is being subject to Federal-Oversight. There may be cases when project conditions, costs, or risks increase or decrease prompting reconsideration of the oversight designation.

      Table 1 identifies the general parameters for identifying those projects that will be designated FO and those that will be designated PO. The costs thresholds shown in Table 1 are based on the estimated cost of construction (regardless of funding source, unless 100% State, and excluding construction engineering and right-of-way costs) as reported on the STIP. If the project scope or cost is modified as a result of the Design Field View of a project, FHWA will be consulted regarding any potential changes in the oversight designation. Any changes to oversight designation must be documented in writing and formally approved by FHWA.

      -Table 1-
      A. General Parameters for Project Oversight Designation (l)
      Oversight (FO)
      Oversight (PO)
      3R (Resurfacing, Restoration &Rehabilitation that meets AASHTO Design Criteria)   X
      < $1 Million (2)   X
      $1 to $10 Million (Inherently Low Risk Projects, see definition Section VIII, Part D)   X
      > $10 Million {new or reconstruction) X  
      Interstate Completion (Appropriation 042) (3R projects that do not meet AASHTO Design Criteria) X  
      NHS (except Interstate)
      < $20 million   X
      ≥ $20 million X  
      Appalachian Development Highway System (ADHS) Corridors Completion Projects X  
      Non-NHS   X
      Discretionary Funding Source (3) (regardless of cost or system, ex. TIGER) X  
      Locally Administered Projects   X (5)(6)
      Major or unusual structures X  
      Other Non-Standard Structures- See DM-4 Table 1.9-1 X  
      Impact on identified freight corridors and facilities X  
      Extremely high ADT X  
      Bi-state projects X  
      Requiring an EIS or complex EA X  
      Complex traffic control X  
      Complex utility relocations and ROW X  
      New Alignment X  
      Innovative contracting methods X  
      Time to Construct > 2 construction seasons X  
      New or innovative construction methods X  
      Projects with earmarks X  
      High risk or complex ITS, e.g., involving software or standards development, new or emerging technologies or innovation X  

      (1) Dollar thresholds correspond to construction amount.
      (2) 23 USC 106(c)(4); includes 3R, construction and reconstruction.
      (3) Projects with discretionary funding will follow statutory law requirements.
      (4) Definitions of Risk-Based parameters is contained in Appendix C.
      (5) LPA projects require PO except where FO has been identified.
      (6) FHWA may elect to select at least one LPA per District for Federal Oversight.

    3. Project Categories- General agency responsibilities pertaining to the categories of Federal-aid projects are described below. A detailed list of program and project approvals related to oversight activities is provided in Appendix D.

      1. Federal-Oversight (FO)
        FHWA will retain approval authority for major actions on this category of projects.

      2. PennDOT-Oversight (PO) NHS
        PennDOT operates under the authority of Pennsylvania Act 120 of 1970, and will administer Federal-aid PO projects on the NHS in compliance with all applicable Federal statutes, regulations, and Executive Orders. In addition, PennDOT agrees to accomplish the policies and objectives contained in or issued pursuant to Title 23, U.S.C.

        PennDOT will assume the responsibilities assigned to the FHWA under Title 23 for Federal-aid projects as permitted by the ISTEA, TEA-21, SAFETEA-LU, and MAP-21, and as indicated in this agreement.

      3. PennDOT- Oversight Non-NHS
        PO - Non-NHS projects are those not located on the National Highway System. Procedures for PO- Non-NHS projects are similar to those for PO- NHS projects in the sense that delegation removes FHWA from approval of design and construction activities and contract administration actions. PennDOT is responsible for ensuring compliance with applicable Federal and State requirements regarding design and construction of Non-NHS projects.

    4. Oversight Designation for Special Types of Projects- Projects characterized by the parameters described below are defined as Special Types. Oversight varies depending on the cost threshold, risk, and facility.

      1. Inherently Low Risk Interstate Projects
        Interstate projects less than $10 million are designated as inherently low risk oversight projects and designated as PO NHS projects. This category includes those that are routine, low risk projects and that are generally non-controversial in with which PennDOT has a high-level of experience and documented procedures and processes in place for ensuring compliance with federal requirements. These projects would not include complex or unique engineering features, would not traditionally involve major changes in scope or cost, would satisfy design standards, and would not jeopardize the safety or operation of the Interstate System. Complex projects that are classified as "major projects," or involve new partners (public/private partnerships), or involve new, innovative contracting methods, or are viewed as high risk, are not considered inherently low risk oversight projects. In addition, certain other Interstate projects greater than $10 million may be designated as inherently low risk oversight projects on a case by case basis. The designation of these other Interstate projects as inherently low risk must be agreed upon by FHWA and PennDOT in writing and supported with agreed upon scopes of work.

      2. Major Projects and Projects with Costs Between $100 and $500 Million
        All Major Projects and projects with costs between $100 and $500 million will be designated as FO projects, regardless of the oversight designation criteria included in Table 1. In accordance with Section 1904 of SAFETEA-LU, all projects with costs greater than $100 million require a financial plan. A financial plan should be consistent with FHWA guidance. Projects with costs greater than $500 million are designated as Major Projects. In addition to the financial plan, a Major Project requires a Project Management Plan, and cost validations. The FHWA Division Office must be consulted when a Major Project is being considered.

      3. Intelligent Transportation Systems (ITS) Projects
        Normally ITS projects follow the same oversight designation criteria as depicted inTable 1. However, Non-facility specific ITS/operations projects, such as Traffic Management Center (TMC) projects, require a joint determination by FHWA and PennDOT of oversight responsibilities. Projects must conform to system engineering requirements in 23 CFR Part 940 -Intelligent Transportation System Architecture and Standards and 49 CFR- Transportation, as appropriate.

      4. Local Public Agency (LPA) Administered Projects
        LPA administered projects will follow the oversight designation criteria as depicted in Table 1. During the project oversight meetings, FHWA may elect to select at least one LPA project in each District to be designated as a FO project, if practicable, using the risk-based parameters in Table 1. The LPA FO project(s) will be identified and selected by FHWA during the project oversight meetings with the Districts. All Federal-aid projects on the NHS are subject to quality assurance procedures (23 CFR 637- Construction Inspection and Approval) including LPA administered projects. For projects off the NHS, PennDOT and the LPAs should use established procedures approved by PennDOT and FHWA. PennDOT's LPA procedures used for Federally Funded NHS projects must comply with applicable Federal requirements.

    Business Service Standards (BSS) provide an expectation for how long it will take to provide reports and findings along with the expectation of a response concerning corrective actions from PennDOT. FHWA and PennDOT will jointly develop BSS within twelve months of the execution of this Agreement. The BSS will be documented in Appendix E. These standards may be revisited annually. BSS will be developed relative to action on responses to audit findings, processing financial instruments, approval of PS&E packages, agreement on Risk Response Strategies, and quality assurance documentation of the LPA program.

    The pertinent PennDOT policies and procedures for accomplishing the intent of the requirements of the FO, PO-NHS, and PO- Non-NHS projects are listed in the Appendices to this Agreement.

    This Agreement supersedes all previously executed Stewardship and Oversight Agreements between the FHWA and PennDOT. This Agreement will take effect upon execution and will apply immediately to all new Federal-aid projects and all existing Federal-aid projects under design. Federal-aid projects under construction will retain their current oversight designation through completion, unless FHWA and PennDOT mutually agree to change that designation.

    The parties agree that there shall be periodic revisions of this Agreement to reflect changes in Federal and State laws, regulations, policies, and requirements.

Barry J. Schoch
Barry J. Schoch, P.E.
Pennsylvannia Department of Transportation
Harrisburg, Pennsylvania
B. Renee Sigel
B. Renee Sigel
Division Administrator
Federal Highway Administration
Harrisburg, Pennsylvania

Appendix A

Page last modified on April 1, 2013.
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