Statement of Interest for Major Project Management Plans and Annual Financial Plans

OHIO DEPARTMENT OF TRANSPORTATION
CENTRAL OFFICE
1 9 8 0 WEST BROAD STREET
COLUMBUS, OH 43223
JOHN R. KASICH, GOVERNOR
JERRY WRAY, DIRECTOR

November 1, 2018

Ms. Laura S. Leffler, Division Administrator
Federal Highway Administration - Ohio Division
200 North High Street, Room 328
Columbus, Ohio 43215

RE: Statement of Interest - New Special Experimental Project (SEP-16) to Evaluate Proposals for Delegation of Certain Program-wide FHWA Responsibilities to States

Major Project Management Plans and Annual Financial Plans

Dear Ms. Leffler:

In accordance with 23 U.S.C 101, the Ohio Department of Transportation (ODOT) hereby notifies the Federal Highway Administration (FHWA) of our interest in participating in the New Experimental Project (SEP-16) to Evaluate Proposals for Delegation of Certain Program-wide FHWA Responsibilities to States. This project, announced by FHWA on September 19, 2018, document number 2018-20347, is to test and evaluate the delegation of program-level responsibilities of the Federal-Aid Highway Program (FAHP) to States, including the appropriate steps States should take to request to exercise delegated authority.

Summary of Proposal

ODOT proposes to seek authority under 23 USC 106(h) to prepare and approve Major Project Management Plans and Annual Financial Plans as described in 23 USC 106(h)(1)(A)-(B).

Reasoning for Proposal

Current Major Project Guidance prohibits FHWA from authorizing construction funds for a project or project phase if the total project cost estimate is greater than $1 00M until a Financial Plan is prepared and filed for the work subject to authorization. The Financial Plan must be updated annually until project construction is complete. The plans and updates must be certified by the ODOT Director (or designee), filed and made available for FHWA review upon request.

Financial Plans and updates for projects greater than $500M include an additional step. These Financial Plans must be submitted to FHWA for review and approval and usually require that ODOT make revisions to address FHWA comments. The extended time for FHWA review usually takes about 4-6 months and sometimes longer.

ODOT is considering this program as a time savings to this process. The level of effort to prepare the documents will remain unchanged. Over the years, ODOT has demonstrated that internal processes, policies and controls (like the PDP Process for instance) assure that the intent of the federal law requiring the plans and updates are met.

Anticipated Resulting Improvement to ODOT's Project Delivery

ODOT would save time and money by eliminating the 4-6-month FHWA review and comment period.

Experience with Project-Level Delegation

ODOT has been preparing Financial Plans and updates since 2007. In those 11 plus years ODOT has never had a significant issue with cost overruns or schedule delays other than for inclement weather. Nothing related to NEPA, design, right-of-way, constructability, change orders, contractor claims, etc. The processes and polices ODOT has in place provide effective controls over these matters and ODOT has demonstrated that there are no issues with project management and delivery.

ODOT looks forward to working closely with FHWA during the application process for this exciting experimental project.

Respectfully,

Jerry Wray, Director

Copies - Director, L. Macadam, J. Townley, T. Hill

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