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SAFETEA-LU 1808: CMAQ Evaluation and Assessment Phase II Final Report

3. Observations From The Field: Benefits, Challenges, and Opportunities

Report cover image: a parking lot of trucks, a BIKE sign, a towtruck behind a broken down car, and children getting on a school bus


All of the information presented in this report is intended to contribute to further discussions about the effectiveness of the CMAQ program, both as it currently stands and with an eye to the future. Rather than focusing solely on identifying effective practices themselves, some of the questions asked during site-visit interviews centered on better understanding the broader planning and funding context within which State DOTs and MPOs develop their CMAQ programs. This section presents the resulting observations in four categories:

Links to the Bigger Picture

The case studies indicated that CMAQ helps agencies to link more effectively to the "bigger picture" of regional planning by:

For many of the MPOs interviewed, the CMAQ program is one of the largest sources of Federal transportation discretionary funds available. As such, it is one of the few areas for which MPOs themselves, rather than State DOTs, take the lead in planning and programming. Direct decisionmaking authority for CMAQ has required MPO staff to engage their policy boards, subcommittees, and community stakeholders to develop methodologies to effectively evaluate and program CMAQ projects. The scrutiny to which CMAQ projects are subject in terms of eligibility requirements and calculating and reporting benefits forces MPOs to develop planning and programming processes that, in some ways, are more rigorous than for other Federal funding sources. This not only builds MPOs' internal capacity to program CMAQ funds but also improves metropolitan planning processes overall and positions MPOs to plan for other sources of transportation funding, whether local, State, or Federal.

Some MPOs explained that they have been able to use the CMAQ program as an incubator for testing new and innovative projects that might not otherwise qualify for Federal funds. Most agencies noted that they use CMAQ to support popular projects that might not be able to receive funding without it, such as diesel retrofits and transportation demand management (TDM) activities. For example, when CMAQ-funded projects have been able to demonstrate their value and success on a smaller scale, agencies have been able to justify greater resource allocation to them in subsequent programming rounds on a larger scale. The Birmingham MPO noted that "Birmingham is an example of a place where projects that were originally funded with CMAQ are now funded through other programs as well."

Though it is sometimes seen as a burden, the CMAQ program's additional requirement to estimate project benefits has a positive side in that it brings a higher degree of analytical rigor and justification into the planning and programming process. Both the Birmingham and Pittsburgh MPOs noted that projects passing the CMAQ eligibility test have an advantage in determining funding because they are better able to estimate their benefits than are most traditional projects, which are not subject to the same degree of analysis or evaluation. The CMAQ model of analysis may play an increasingly important role in determining funding in a future, more performance-based model of transportation planning.

Several of the larger MPOs interviewed reflected on the nearly 20-year history they now have of programming CMAQ funds over the years. These MPOs revealed how the CMAQ program's success on a smaller scale has led to shifts in their boards' policy goals at a broader level, enabling them to see the nexus between transportation planning and other quality-of-life issues ranging from public health to community livability and environmental stewardship.

The CMAQ program has also helped MPOs and State DOTs to expand their reach by opening the transportation planning and programming process to nontraditional partners such as trucking companies, school districts, and citizen groups. This builds awareness and understanding of the transportation planning process to a broader audience of stakeholders and also challenges MPOs to improve their community outreach and public relations. In Pittsburgh, the Downtown Business Association became a project sponsor and worked successfully with the MPO to start a pilot car-sharing program with seed funding from the CMAQ program.

State DOT Involvement

State DOTs play an important role in shaping CMAQ program development at the MPO level, taking different approaches in their type and level of involvement. The relationship between a State DOT and each of the MPOs eligible for CMAQ funding within that State is a critical factor in shaping how regional CMAQ programs function. State DOTs' approach to CMAQ influences the development of regional CMAQ programs in a number of ways:

State DOTs Suballocate CMAQ Funds to MPOs

The Federal-Aid Highway Program apportions CMAQ funds to States on a formula based on the size of nonattainment area populations and the severity of air quality deficiencies. Each State has the flexibility to suballocate funds among eligible MPO regions as it chooses. How States decide to suballocate funds among their MPOs can differ significantly from one State to another. Many States distribute all of the CMAQ funds directly to MPOs for programming. The allocation of CMAQ funds in Colorado, for example, is based on State legislation that requires 100 percent of funds to be given directly to MPOs for programming. In California, Caltrans (the State DOT) devolves programming control of nearly 100 percent of CMAQ funds directly to MPOs16 around the State on the basis of a formula that accounts for population size and the severity of air quality nonattainment in their air basins; a small portion of the overall funds for the five non-MPO areas around the State are reserved for those that are in nonattainment and therefore are eligible to receive CMAQ dollars.

The Massachusetts Statewide CMAQ program includes the following programs:

  • School Bus Retrofit ($15 million in total)
  • MassRides ($2.5 million annually)
  • Enhanced Inspection and Maintenance (I&M)
  • Alternative Fuels for Statewide Fleets pilot program
  • Hybrid Vehicles Plug-in demonstration project
  • Safe Routes to School program

While many States treat CMAQ as an automatic pass-through that is distributed directly to MPOs, some take a more hands-on approach, retaining a pool of funds "off the top" for Statewide initiatives and splitting funds between regional and Statewide projects. For example, the Massachusetts Executive Office of Transportation (EOT) retains about $12.5 million a year for Statewide CMAQ projects and allocates the remaining funds directly to MPO regions. Maintaining a CMAQ program at the State level allows Massachusetts to achieve economies of scale and to take on projects that might be harder to develop if MPOs were working on them in isolation. For example, rather than distributing funds to the State's 13 MPOs for individual rideshare and other TDM programs, EOT uses State CMAQ money to fund the MassRides program, a one-stop shop for commuter information and ride-sharing across the State. EOT believes that MassRides creates Statewide brand recognition for rideshare and other commuter alternatives and that it is able to address complex commuting patterns, which are rarely confined to MPO planning boundaries, in a more cost-effective manner than MPO-specific programs would be capable of doing. Having a pool of CMAQ funds at the State level also provides EOT with the opportunity to collaborate with State-level air quality, public health, and environmental agencies, thereby building new relationships that can be leveraged in other aspects of planning and policy work and enabling innovative, nontraditional transportation projects, most of which would not qualify for State transportation funds.

Whether the State DOT distributes funds directly to the MPOs by formula or retains some of the money for a Statewide program of its own, CMAQ funding suballocations can be contentious as MPOs vie with one another–and with the State itself, when a Statewide CMAQ program exists–for larger portions of the overall CMAQ allocation. When States revisit and update their allocation formulas, the funding impact is that some MPOs "win" and others "lose." For example, when Oregon DOT (ODOT) recently updated its regional CMAQ allocation formula; the Medford MPO went from receiving just 5.5 percent of CMAQ funds Statewide to 13 percent, more than doubling the size of its CMAQ program. Since 1991, the Birmingham MPO is the only area in Alabama that is eligible for CMAQ funding. But currently, the State anticipates three new areas in Alabama soon be redesignated as nonattainment. This would have a dramatic impact on how the CMAQ program is operated in Birmingham, since ALDOT would be suballocating CMAQ funds to four areas around the state instead of just one.

State DOTs Can Be a Source of Technical Support and Capacity-Building for MPOs

States can serve in an important advisory role on technical capacity issues for MPOs that are struggling to meet complex reporting requirements or develop effective methods for estimating emissions reductions across nontraditional transportation project proposals, especially for smaller and midsized MPOs. PennDOT has taken a leadership role in helping to streamline CMAQ project calculations across planning regions by hiring a consulting firm to develop standardized spreadsheets to estimate the emissions benefits for a variety of air-quality-type projects. This work has resulted in a stand-alone software package that small and large MPOs alike can use to evaluate potential projects. PennDOT keeps the consultant on contract to provide services on an as-needed basis, thus helping MPOs as challenges arise when new types of proposed CMAQ projects cannot be matched up with existing spreadsheets17. This approach saves MPOs the cost of reinventing the wheel each time a new methodology needs to be developed. It also ensures that calculations are more robust and consistent across Pennsylvania, which increases the meaningfulness and integrity of the results. It may also help less traditional projects to compete more effectively within the transportation funding process. For example, when the Pittsburgh Downtown Partnership (PDP) came to SPC, the Pittsburgh MPO, with a proposal to fund a demonstration car-share program with CMAQ money, SPC was able to utilize the emissions spreadsheets developed by PennDOT's consultant for a car-share program that was already in existence in Philadelphia and to make a case for funding it. PennDOT also helps to build self-sufficiency for MPOs by convening a Statewide working group that meets quarterly to discuss issues and challenges faced by different MPOs statewide and discuss strategies for overcoming shared challenges.

State DOTs Sit on Committees Determining CMAQ Eligibility or Project Prioritization

States may play a role in determining project eligibility for CMAQ as well as in prioritizing and even selecting projects. Representatives of State DOTs commonly sit on MPO boards, which make the final determinations of which projects ultimately receive funding. Sometimes they also sit on the MPO subcommittees that oversee the technical analysis of projects and make recommendations to the MPO board on how projects should be prioritized and selected from the applicant pool. Some States also convene a Statewide interagency committee to make CMAQ eligibility determinations for proposed projects and to seek input on prioritization. (Sometimes it is the same group that meets to make conformity determinations.) In Massachusetts, EOT convenes a statewide CMAQ eligibility committee, including the Department of Environmental Protection (MassDEP), which meets annually to determine which project proposals qualify for CMAQ funding. In many cases, State DOTs are project sponsors for CMAQ projects, working with the MPO to program projects. PennDOT districts, for example, commonly submit CMAQ project proposals to the MPOs for funding consideration.

Air Quality Agency Involvement

The U.S. Code Title 23, Section 149, states "the Secretary shall encourage States and Metropolitan Planning Organizations to consult with State and local air quality agencies in nonattainment and maintenance areas on the estimated emission reductions from proposed congestion mitigation and air quality improvement programs and projects."18 FHWA guidance echoes this, stating that State DOTs and MPOs should consult with State and local air quality agencies to develop and program projects that have the greatest impact on air quality.19 There is no uniform National model for how air quality and transportation organizations should work together on the CMAQ program, however. Specific approaches and structures are determined locally, producing a variety of models of interaction. There are two main ways in which air quality agencies at the seven site locations are consulted on the CMAQ program:

Interviewees from the site visits noted that the CMAQ program has played a role by shifting this dynamic and providing an opportunity for air quality and other environmental agencies to build stronger working relationships with MPOs and State DOTs. Serving on CMAQ committees and/or proposing CMAQ projects enabled air quality and environmental agencies to engage in the transportation planning process as partners and participants. However, some interviewees acknowledged that barriers to full engagement and consideration of air-quality impacts still exist. If the role of the air quality agency is too narrowly defined, some important information about a project's emission reduction potential could be missed. For example, greater involvement by the air quality agency could help inform project selection by providing information about the relative magnitude of the emission reductions or the effectiveness of reducing a particular pollutant.

Air Quality Agencies Serve as Members of Transportation Boards

In each of the locations visited, the air quality agency was a member of a board or committee that dealt with the transportation and air quality interface. In the San Francisco Bay area, the MPO does not have a stand-alone CMAQ program. It instead integrates air quality issues throughout its planning process. Both the Bay Area Air Quality Management District (BAAQMD) and the San Francisco Bay Conservation and Development Commission (SFBCDC) serve as voting members of the MTC Joint Policy Committee, which sets the overall vision and policy for the MPO. Similarly, in Denver, the Colorado Regional Air Quality Council (RAQC) is a member of the Regional Transportation Committee, which provides overall policy direction for the MPO. More typically, the air quality agency is a member of a committee that reviews, evaluates, and selects projects for CMAQ funding. In Fort Collins, the CDPHE is a voting member of the CMAQ Evaluation Committee, which reviews and ranks all CMAQ proposals and then makes recommendations to the MPO policy board. Pittsburgh is similar to Fort Collins, with the Pennsylvania DEP and the Allegheny County Health Department sharing a role as a voting member of the CMAQ Evaluation Committee. In Massachusetts, CMAQ projects are not evaluated independently from the TIP evaluation process. Instead, the State has a CMAQ Eligibility Committee on which MassDEP is a voting member. The committee determines if a proposed project is eligible for consideration for CMAQ funding. All projects are then programmed in the TIP and approved by the MPO policy board.

Air Quality Agencies Serve as Project Sponsors

The CMAQ program has provided the air quality agencies with the opportunity to utilize CMAQ funds to help further their transportation-related air quality initiatives. In some cases, the air quality agency is able to utilize local funds or private investment to leverage Federal CMAQ dollars. The air quality agencies in each of the seven MPOs visited have sponsored CMAQ projects.

In Massachusetts, MassDEP utilizes CMAQ funding to modernize the Statewide Vehicle Inspection and Maintenance (I&M) program and the retrofitting of all eligible school buses, among other initiatives. In Pittsburgh, the Allegheny County Health Department serves as a project sponsor on behalf of local municipalities. During the last round of CMAQ funding, the Health Department used fines that it collected from stationary-source air quality violations within the region to pay the local match for a series of diesel retrofits for public works vehicles for a consortium of 12 municipalities. In Birmingham, the Alabama Department of Environmental Management (ADEM) is a member of the Clean Air Alliance, which includes private-sector firms. For the ADEM truck stop electrification project completed in 2006, CMAQ funds were only 11 percent of the total cost. The private sector contributed the remaining 89 percent. In Denver, the RAQC received more than $1.6 million over a 2-year period to support its ozone reduction program. In San Francisco, the BAAQMD used CMAQ funds to support its Spare the Air campaign, and in Medford, Oregon, the State's lead air quality agency, the Oregon Department of Environmental Quality (ODEQ), sponsored the region's first PPP, a diesel retrofit to allow Rogue Disposal & Recycling Company's fleet to burn cleaner fuels.

Data and Analysis Requirements

Many of the MPO and State DOT staff interviewed expressed support for the documentation of project benefits required for CMAQ eligibility because they felt it led to the selection of higher-quality projects overall. In Birmingham, for example, MPO staff expressed greater confidence in justifying CMAQ projects to the public than other Federally funded projects because of the analysis that CMAQ projects must withstand in order to be selected. A number of agency staff felt that the CMAQ program raises the bar for other projects competing in the Federal-Aid funding process and suggested that the program be used as a model for other Federal-Aid programs, noting that if all Federally funded projects had to meet the same standards as CMAQ, better projects would be built across the board.

At the same time, one MPO noted that the data requirements associated with determining CMAQ eligibility can add to project costs. For example, one agency noted that a major project such as a bridge rehabilitation using Federal funds requires less justification of benefits derived than does a relatively small bicycle project using CMAQ funds. Similarly, an intersection improvement project would require different levels of analysis depending upon whether CMAQ funding would be used to support the project or not.

In addition to the quantification of benefits, CMAQ funds are tied to other requirements that limit eligibility for project proposals. For example, Federal guidance recommends a 3-year cap on the use of CMAQ funds for operating expenses.20 Agencies differ in how they think about additional requirements such as this. Some agencies felt that this places an unnecessary restriction on projects whose air quality benefits may improve over time; however, in Boston, this restriction was turned into an advantage by requiring an increasing local match each year for operations projects. The belief was that only projects that are increasingly self-reliant should be sustained with funding after Year 1 or 2.

Some agencies asked why additional requirements are applied to CMAQ when it is such a small percentage of the overall FHWA funding program, as this may cause agencies to devote a disproportionately high amount of staff time and resources to administer CMAQ funds and oversee projects in order to meet the requirements. As one staff member noted, CMAQ represents about 4 percent of the TIP program yet can consume about 20 percent of staff time. Since the CMAQ program itself does not include funding for agency administration and oversight, agencies must use their Federal planning funds to cover these costs.

Many agencies agreed that CMAQ's additional requirements can be seen as positive at a broad level since more analysis should lead to higher-quality projects being supported, but they noted that it was a challenge to allocate the increased level of staff time required for administering CMAQ to a funding source that represents such a small portion of their overall transportation budgets. Some staff noted that if increased planning funding were included to cover additional administrative, reporting, and evaluation costs, the additional CMAQ evaluation requirements might serve as an excellent model for how all Federal funding categories could be run more effectively. Under this scenario, the best projects will rise to the top under more rigorous analysis and with a clearer delineation of expected benefits.

Updated: 2/24/2012
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