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Report to the Ranking Member, Committee on Environment and Public 
Works, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

September 2009: 

Metropolitan Planning Organizations: 

Options Exist to Enhance Transportation Planning Capacity and Federal 
Oversight: 

GAO-09-868: 

GAO Highlights: 

Highlights of GAO-09-868, a report to the Ranking Member, Committee on 
Environment and Public Works, U.S. Senate. 

Why GAO Did This Study: 

Metropolitan planning organizations (MPO) are responsible for 
transportation planning in metropolitan areas; however, little is known 
about what has been achieved by the planning efforts. This 
congressionally requested report describes (1) the characteristics and 
responsibilities of MPOs, (2) the challenges that MPOs face in carrying 
out their responsibilities, (3) how the U.S. Department of 
Transportation (DOT) provides oversight for MPOs and the extent to 
which this improves transportation planning, and (4) the options that 
have been proposed to enhance transportation planning. To address these 
objectives, GAO surveyed all 381 MPOs (with an 86 percent response 
rate) and conducted case studies of eight metropolitan areas and 
conducted a survey of program managers. 

What GAO Found: 

MPOs vary greatly in terms of capacity and responsibilities. Some MPOs 
are supported by one or two staff, while others have over 100 staff. 
While half of MPOs represent populations of less than 200,000, some 
represent millions. MPOs are typically housed within a regional 
planning council or a city or county government agency, but also may 
operate as independent agencies. Most MPOs receive the majority of 
their planning funds from federal sources, but also receive funds from 
other sources such as states or localities. The technical capacity of 
MPOs also varies significantly, both in terms of the type of model used 
to develop travel demand forecasts and the number of staff available to 
perform such forecasts. Some MPOs have acquired additional 
responsibilities, such as project implementation, beyond federal 
requirements. 

MPOs cited many challenges in our survey and interviews, primarily 
related to funding and staffing, authority, and technical capacity. 
About 85 percent of all MPOs responding to our survey cited the lack of 
transportation planning funding as a challenge to transportation 
planning. About half of our survey respondents stated that the lack of 
flexibility for using federal planning funds inhibits them from 
conducting comprehensive transportation planning. Staffing constraints, 
such as limited number of staff and lack of trained staff, also impact 
MPOs’ ability to conduct transportation planning. Finally, according to 
our survey and interviews, some MPOs lack the technical capacity and 
data necessary to conduct the type of complex transportation modeling 
required to meet their planning needs. 

DOT’s Federal Transit Administration (FTA) and Federal Highway 
Administration (FHWA) work together to oversee MPOs, but given the 
process-oriented approach of the oversight, it is difficult to 
determine whether their oversight is improving transportation planning. 
MPOs representing more than 200,000 in population are subject to 
federal certification reviews. The certification reviews focus on 
procedural compliance with planning requirements, not transportation 
outcomes. MPOs generally view this federal process as pro forma in 
nature and place a greater value on informal assistance provided by 
both federal and state governments. 

Several proposals have been developed by government and industry 
associations that could address some of the resource, authority, and 
technical challenges facing MPOs. For example, 

* allowing the use of transportation planning funds for more activities 
could better meet the needs of some metropolitan areas; 

* varying MPOs’ planning requirements and authority or changing the 
legal definition of MPOs could address varying capacity and planning 
needs; 

* increasing federal investment in modeling and data gathering could 
improve the technical capability of MPOs and bring a greater degree of 
reliability and consistency across MPOs to travel demand forecasting; 
and; 

* making the planning process more performance-based could allow FTA 
and FHWA to better assess MPOs’ progress in achieving specific results. 

What GAO Recommends: 

GAO suggests that Congress consider making MPO transportation planning 
more performance based by, for example, identifying specific 
transportation outcomes for transportation planning and charging DOT 
with assessing MPOs’ progress in achieving these outcomes in the 
certification review process. GAO also recommends, among other things, 
that DOT develop a strategy to improve data gathering and modeling at 
the MPO level. DOT agreed to consider the report’s recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-09-868] or key 
components. For more information, contact Phillip R. Herr at (202) 512-
2834 or herrp@gao.gov. To view the e-supplement online, click on 
[hyperlink, http://www.gao.gov/products/GAO-09-867SP]. 

[End of section] 

Contents: 

Letter: 

Background: 

MPOs Vary Considerably in Terms of Capacity, Responsibilities, and 
Range of Activities: 

MPOs Face Resource, Authority, and Technical Challenges That Impact 
Their Ability to Conduct Transportation Planning: 

The Extent to Which MPO Oversight Mechanisms Improve Transportation 
Planning Is Unclear: 

MPO, Government, and Industry Officials Have Developed Options to 
Enhance Transportation Planning: 

Conclusions: 

Matter for Congressional Consideration: 

Recommendations: 

Agency Comments: 

Appendix I: Scope and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Mean and Median Number of Staff at MPOs: 

Table 2: Metropolitan Regions Selected for Case Study: 

Figures: 

Figure 1: Number of MPOs by Population Represented: 

Figure 2: Transportation Planning Processes: 

Figure 3: Apportionments of FHWA and FTA Metropolitan Planning Funds, 
Fiscal Year 1996 through Fiscal Year 2009: 

Abbreviations: 

3-C: continuing, cooperative, and comprehensive: 

AASHTO: American Association of State Highway and Transportation 
Officials: 

AMPO: Association of Metropolitan Planning Organizations: 

APTA: American Public Transportation Association: 

CMAQ: Congestion Mitigation and Air Quality Improvement Program: 

CMP: Congestion Management Process: 

DOT: Department of Transportation: 

FHWA: Federal Highway Administration: 

FTA: Federal Transit Administration: 

MPO: Metropolitan Planning Organization: 

SAFETEA-LU: Safe, Accountable, Flexible, Efficient Transportation 
Equity Act: A Legacy for Users: 

STIP: Statewide Transportation Improvement Program: 

TIP: Transportation Improvement Program: 

TMA: Transportation Management Area: 

TRB: Transportation Research Board: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

September 9, 2009: 

The Honorable James Inhofe: 
Ranking Member: 
Committee on Environment and Public Works: 
United States Senate: 

Dear Senator Inhofe: 

Metropolitan areas are the centers of much social and economic activity 
in the United States. The largest 100 of these areas house more than 65 
percent of our population and produce 75 percent of our national 
economic output. They are also where most seaport tonnage arrives and 
departs, transit miles are ridden, and rail and air passengers board. 
However, the productivity of these economic centers, and as a result 
the economic vitality of the United States, is being threatened by a 
number of transportation challenges, such as increasing levels of 
congestion. These challenges are significantly affected by decisions on 
how federal transportation funds are invested and these decisions are 
shaped by the transportation planning efforts undertaken by the 381 
metropolitan planning organizations (MPO). 

To encourage the development of efficient and effective transportation 
systems, the Federal-Aid Highway Act of 1962 required urban 
transportation planning as a condition for receiving federal-aid 
transportation funds in urban areas. The act also provided funding for 
regional transportation planning. To reflect the growing sense that 
local elected officials and citizens should be given a larger role in 
this regional transportation decision-making process, the Federal-Aid 
Highway Act of 1973 required the designation of MPOs in urban areas 
with populations of more than 50,000 people to carry out a continuing, 
cooperative, and comprehensive (3-C) planning process. Recognizing the 
importance of metropolitan areas and the need to fully integrate these 
areas into transportation investment decisions, the Intermodal Surface 
Transportation Efficiency Act of 1991[Footnote 1] devolved greater 
responsibility for planning and implementation of transportation 
projects to MPOs. Subsequently, in 2005, the Safe, Accountable, 
Flexible, Efficient Transportation Equity Act: A Legacy for Users 
(SAFETEA-LU), the current surface transportation program authorization 
act, added additional transportation planning requirements to MPOs' 
responsibilities, while also providing additional time for MPOs to make 
updates to their plans and programs and increasing federal funding to 
MPOs to respond to such responsibilities.[Footnote 2] Little is known, 
though, about what has been achieved by the federal government's 
investment in metropolitan transportation planning. As the September 
2009 expiration of SAFETEA-LU approaches, more complete information on 
the effectiveness of MPOs' transportation planning activities is 
needed, especially in light of government and industry associations' 
proposals for increasing or modifying MPOs' authority, 
responsibilities, and funding. Accordingly, you asked us to examine (1) 
the characteristics and responsibilities of MPOs; (2) the challenges 
that MPOs face in carrying out their responsibilities; (3) how the U.S. 
Department of Transportation (DOT) provides oversight for MPOs and the 
extent to which this improves transportation planning; and (4) the 
options that have been proposed to enhance transportation planning. 

To address these objectives, we reviewed existing legislation, 
regulations, and program guidance concerning MPOs' transportation 
planning responsibilities and the federal certification process; 
reviewed proposals to change or reform current MPO planning 
responsibilities; interviewed Federal Transit Administration (FTA) and 
Federal Highway Administration (FHWA) officials and representatives 
from industry associations such as the Association of Metropolitan 
Planning Organizations and the Transportation Research Board (TRB), as 
well as state departments of transportation, to obtain their 
perspectives on MPOs' planning activities, variations among MPOs, the 
federal certification process, and proposals to improve the current 
planning process. We also conducted case studies of eight MPOs in four 
states that we selected based on population and structure, among other 
things, which included reviewing the MPOs' transportation plans and 
interviewing MPO officials, the state departments of transportation, 
the relevant FHWA division office and FTA regional office, transit 
agencies, and other regional associations. In addition, we observed an 
FHWA-FTA MPO certification review; and surveyed all 381 legally 
designated MPOs to gain information on their varying roles, 
responsibilities, capacity, the challenges they face in meeting their 
planning responsibilities, and options to improve the transportation 
planning process.[Footnote 3] The results of our survey can be found at 
GAO-09-867SP. To determine the various options to address MPOs' 
challenges, we reviewed proposals from the Association of Metropolitan 
Planning Organizations (AMPO), the American Association of State 
Highway and Transportation officials (AASHTO), the American Public 
Transportation Association (APTA), the Brookings Institution, the 
previous and current DOT administrations, and the June 2009 House 
Transportation and Infrastructure Committee blueprint for the surface 
transportation reauthorization. We also discussed suggestions for 
improving the planning process with federal and state officials, as 
well as the eight MPOs we interviewed. 

For the purposes of this report, we refer to MPOs representing 
populations of less than 200,000 as "small MPOs," MPOs representing 
populations between 200,000 and 1 million as "medium MPOs," and MPOs 
representing populations above 1 million as "large MPOs." Appendix I 
contains additional information about our scope and methodology. We 
conducted this performance audit from September 2008 to September 2009 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

We provided a copy of this report to DOT for their review and comment. 
DOT agreed to consider our recommendations and provided technical 
comments which we incorporated into the report, as appropriate. 

Background: 

MPOs, representing local governments and working in coordination with 
state departments of transportation and major providers of 
transportation services, have responsibility for the regional 
transportation planning processes in urbanized areas.[Footnote 4] (See 
figure 2 for a summary of these processes.) A core function of MPOs is 
to establish and manage a fair and impartial setting for effective 
transportation decision making in an urbanized area. To receive federal 
transportation funding, any project in an urbanized area must emerge 
from the relevant MPO and state department of transportation planning 
process. MPOs, which generally have a governing policy board consisting 
of local elected officials and appropriate state and public 
transportation officials, facilitate decision making on regional 
transportation issues including major capital investment projects and 
priorities. MPOs also generally have a technical advisory committee 
(including engineers, planners, and other local staff); citizen's 
advisory committee; and additional committees, such as a bicycle and 
pedestrian committee or a freight advisory committee. MPO staff assist 
the MPO board by preparing documents, fostering interagency 
coordination, facilitating public input and feedback, and managing the 
planning process. Staff may also provide committees with technical 
assessments and evaluations of proposed transportation initiatives. 
Created to carry out a federally mandated transportation planning 
process, MPOs' core membership is spelled out in law, but the 
organizational structure and staff arrangements were designed to be 
determined by agreement between local officials and the state. 

The size of the populations represented by individual MPOs varies. For 
instance, about 52 percent of the 381 MPOs represent populations of 
fewer than 200,000 people; 36 percent of MPOs represent populations of 
200,000 to 999,999 people; and 11 percent of MPOs represent populations 
of 1 million or more people. However, the largest MPOs--those 
representing more than 1 million people--represent about 49 percent of 
the country. (See figure 1 for a summary of MPO sizes.) 

Figure 1: Number of MPOs by Population Represented: 

[Refer to PDF for image: pie-chart] 

Small (population of 50,000-199,999) 199 MPOs: 53%; 
Medium (population of 200,000-999,999) 139 MPOs: 36%; 
Large (population of 1 million and above) 43 MPOs: 11%. 

Source: GAO analysis of Census data. 

Note: Percentages do not add to 100 due to rounding. 

[End of figure] 

All MPOs have the same basic planning requirements. Specifically, all 
MPOs are required to produce the following: 

* long-range (20-year) transportation plans;[Footnote 5] 

* short-range (4-year) Transportation Improvement Programs; 

* annual statements of planning priorities and activities (generally 
called a Unified Planning Work Program or UPWP); and: 

* public participation plans.[Footnote 6] 

Transportation improvement programs (TIP), based on the long-range 
plan, should be designed to achieve the area's transportation goals 
using spending, operating, management, and financial tools. The area's 
transportation goals are determined by the MPO's policy board, 
including representatives from relevant jurisdictions and 
transportation operators, through interactions between stakeholders and 
the public for the purpose of identifying visions for the community's 
future. This process allows the region as a whole to determine how it 
should allocate its limited transportation resources among the various 
capital and operating needs of the area, based on local and regional 
priorities. Both the TIP and the long-range plan must be fiscally 
constrained--that is, the total estimated cost of the planned 
transportation improvements cannot exceed anticipated levels of 
funding.[Footnote 7] MPOs must develop these plans and programs in 
cooperation with their state department of transportation as well as 
local transit operators, land-use entities, and environmental resource 
agencies.[Footnote 8] Where they exist in their region, MPOs also 
consult with tribal governments, airports, Amtrak, or freight rail 
interests during the planning process. (See figure 2 for a summary of 
the role of the MPO, state, and federal government in developing the 
long-range plan and TIP.) 

Figure 2: Transportation Planning Processes: 

[See PDF for image: illustration] 

Short-range programs[A]: 

* Plan time frame: at least 4 years; 
* Updated at least every 4 years. 

Metropolitan planning: 
Metropolitan transportation improvement program (TIP): 
* Identifies proposed federally supported transportation projects or 
phases of a project; 
* Financially constrained–includes a financial plan to demonstrate 
current and proposed revenue sources; 
* Identifies the criteria and process for prioritizing implementation 
of transportation plan elements; 
* MPOs and states approve the program. 

Statewide planning: 
State transportation improvement program (STIP): 
* Covers the MPO regions and all other state areas; 
* Contains descriptions of all capital and noncapital transportation 
projects, with some exceptions; 
* Financially constrained–demonstrates current and proposed federal, 
state, and local revenue sources. 

Federal Highway Administration/Federal Transit Administration: 
STIP approval: 
* Requires joint approval by FHWA/FTA at least once every 4 years; 
* Certifies that the transportation planning process is carried out in 
accordance with applicable federal requirements; 
* MPO self-certification with each submission of the proposed TIP to 
FHWA/FTA as part of the STIP approval, at least once every 4 years. 

Long-range plans[B]: 
* Plan time frame: at least 20 years; 
* Updated every 4 years (MPOs) or as appropriate (states). 

Metropolitan planning: 
Metropolitan long-range transportation plan: 
* Identifies projected transportation demand and congestion management 
strategies; 
* Assesses capital investments and the existing transportation system; 
* Reflects social, economic, environmental, and energy conservation 
goals and objectives; 
* Includes a financial plan to demonstrate revenue sources for 
transportation investments. 

Statewide planning: 
Statewide long-range transportation plan: 
* Intermodal and statewide in scope; 
* Coordination with metropolitan long-range plans; 
* References planning studies and reports significant to the 
development of the plan; 
* Summarizes availability of financial and other resources needed to 
carry out the plan (optional). 

Federal Highway Administration/Federal Transit Administration: 
MPO and state planning process certification: 
* State shall certify that the planning process is being carried out in 
accordance with all applicable requirements of 23 U.S.C. 134 and 135 at 
the time the entire proposed STIP is submitted to FHWA/FTA for 
approval, at least every 4 years; 
* FHWA/FTA conducts certification reviews for all MPOs representing 
populations greater than 200,000 to ensure that the planning process is 
conducted in accordance with applicable federal requirements. 

Source: GAO analysis of federal regulations governing metropolitan and 
statewide transportation planning. 

[A] Short-range programs, called Transportation Improvement Programs, 
are based on the long-range plan and are required to achieve the area's 
transportation goals using spending, operating, management, and 
financial tools. 

[B] Long-range plans, generally called Metropolitan Transportation 
Plans, are intended to foster mobility and access for people and goods, 
efficient transportation system performance and preservation, and good 
quality of life. 

[C] MPOs are required to review and update the transportation plan at 
least every 4 years in air quality nonattainment and maintenance areas 
and at least every 5 years in attainment areas. An air quality 
nonattainment area is a region that the Environmental Protection Agency 
has designated as not meeting federal air quality standards. An air 
quality maintenance area is a region previously designated 
nonattainment. 

[End of figure] 

Beyond the requirements common to all MPOs, some MPOs have additional 
planning requirements. For example, MPOs serving urbanized areas with 
populations of over 200,000 people, which are referred to as 
transportation management areas (TMA), are required to develop a 
Congestion Management Process (CMP) that identifies actions and 
strategies to reduce congestion.[Footnote 9] In addition, MPOs 
containing areas that do not conform to federal air quality standards 
(i.e., nonattainment areas) or areas that have recently come into 
conformance with the standards (i.e., maintenance areas) are required 
to ensure that planned transportation improvements will not cause new 
air quality violations, worsen existing violations, or delay timely 
attainment of the standards. To ensure that such plans will not 
negatively affect regional air quality, MPOs must conduct what is 
termed "conformity analysis" for proposed transportation improvements. 
[Footnote 10] 

To create these transportation plans and programs, MPOs consider a 
variety of factors, including local travel forecasts and federal 
considerations. For example, MPOs forecast future travel with the 
assistance of computerized travel-demand models. These models provide 
information on how urban growth and proposed facility and operational 
investments will affect the operation of the transportation system. 
Such models are complex and require as inputs extensive current 
information on roadway and transit system characteristics and 
operations, as well as current and forecast demographic information. 
Creating and operating the models requires a high degree of technical 
training and expertise. Additionally, when developing these plans and 
programs, MPOs must consider specific statutorily defined planning 
factors. These factors require that the metropolitan planning process 
provide for consideration of projects and strategies that will: 

* support the economic vitality of the metropolitan area, especially by 
enabling global competitiveness, productivity, and efficiency; 

* increase the safety of the transportation system for motorized and 
nonmotorized users; 

* increase the security of the transportation system for motorized and 
nonmotorized users; 

* increase the accessibility and mobility of people and freight; 

* protect and enhance the environment, promote energy conservation, 
improve the quality of life, and promote consistency between 
transportation improvements and state and local planned growth and 
economic development patterns; 

* enhance the integration and connectivity of the transportation 
system, across and between modes, for people and freight; 

* promote efficient system management and operation; and: 

* emphasize the preservation of the existing transportation system. 

To carry out this regional planning process, 1.25 percent of federal- 
aid highway funding from the Interstate Maintenance, National Highway 
System, Bridge, Surface Transportation Program, and Congestion 
Mitigation and Air Quality (CMAQ) programs is apportioned to the states 
as metropolitan planning funds. 

Federal legislation has maintained, and periodically increased, the 
funding for MPO activities over time. (See figure 3.) These federal 
funds are distributed to states based on population. Generally states 
then provide each of their MPOs with baseline funding and distribute 
any remaining balance according to a formula. While the states can use 
a range of factors in their formulas, such as congestion levels, they 
are required to take population into account. Federal planning dollars 
must also be matched by state and local governments. Specifically, 
state and local governments must provide at least 20 percent of 
metropolitan planning funds, although some state and local governments 
have to provide more than 20 percent in funding to perform all of their 
necessary planning activities. 

Figure 3: Apportionments of FHWA and FTA Metropolitan Planning Funds, 
Fiscal Year 1996 through Fiscal Year 2009: 

[See PDF for image: stacked vertical bar graph] 

Fiscal year: 1996; 
FHWA: $136.8 million; 
FTA: $39.5 million. 

Fiscal year: 1997; 
FHWA: $157.1 million; 
FTA: $40.2 million. 

Fiscal year: 1998; 
FHWA: $162.3 million; 
FTA: $39.6 million. 

Fiscal year: 1999; 
FHWA: $162.3 million; 
FTA: $43.9 million. 

Fiscal year: 2000; 
FHWA: $188.8 million; 
FTA: $49.6 million. 

Fiscal year: 2001; 
FHWA: $192.5 million; 
FTA: $52.3 million. 

Fiscal year: 2002; 
FHWA: $195.5 million; 
FTA: $55.7 million. 

Fiscal year: 2003; 
FHWA: $194.8 million; 
FTA: $60.4 million. 

Fiscal year: 2004; 
FHWA: $238.6 million; 
FTA: $61.5 million. 

Fiscal year: 2005; 
FHWA: $293.9 million; 
FTA: $60.6 million. 

Fiscal year: 2006; 
FHWA: $289.8 million; 
FTA: $77.4 million. 

Fiscal year: 2007; 
FHWA: $294.5 million; 
FTA: $82.4 million. 

Fiscal year: 2008; 
FHWA: $299.2 million; 
FTA: $88.2 million. 

Fiscal year: 2009; 
FHWA: $303.9 million; 
FTA: $93.6 million. 

Source: U.S. Department of Transportation. 

[End of figure] 

Federal and state governments oversee this regional planning process. 
At the federal level, FTA and FHWA work together to perform federal 
certification reviews--certifying that each TMA has carried out its 
planning according to the applicable federal statutes. More 
specifically, the certification review requires that the federal 
government assess TMAs every 4 years to determine how well they are 
working with the transportation-related organizations, local 
governments, public transportation operators, and citizens in their 
area, as well as with the state departments of transportation, to meet 
the many statutory and regulatory requirements applicable to the 
planning process. Additionally, the certification review assesses the 
quality of the required planning documents. The certification review 
includes a desk review of the MPO's plans and a site visit, among other 
things. Additionally, all MPOs, including both TMAs and non-TMAs, must 
also self-certify that their planning process meets the federal 
requirements. States also participate in the regional planning process 
by, for example, reviewing and approving the MPO's TIP. If the state 
approves the TIP, the state must incorporate the TIP, without change, 
into the statewide transportation improvement program (STIP).[Footnote 
11] If the state does not approve the TIP, the MPO and the projects 
included in the TIP are not eligible for federal funding. This 
requirement compels states to coordinate with MPOs and vice versa. 

MPOs Vary Considerably in Terms of Capacity, Responsibilities, and 
Range of Activities: 

The Staffing, Financial, and Technical Capacity of MPOs Varies 
Significantly: 

The staff size and structure of MPOs vary significantly. Some MPOs are 
supported by one or two staff, while a few have over 100 full or part- 
time staff. Most MPOs have a relatively small staff, with a median of 
four full-time staff per MPO, based on our survey. (See table 1 for a 
summary of the number of staff by size of MPO.) The type and structure 
of the organizations housing MPOs also vary across the country. The 
structure of an MPO is determined by agreement between relevant local 
governments and the state, and therefore the extent to which these 
local governments or other regional organizations support MPO 
activities varies. These organizations can support MPOs by housing 
staff within their organization, which can include providing the 
personnel and facilities necessary for MPO activities. Some MPOs are 
housed and staffed by a local jurisdiction (such as a city or county 
government) within its boundaries, others by a regional planning 
council, and still others operate independently. According to our 
survey respondents, 71 percent of MPOs are a part of agencies such as 
regional councils and city, county, or state governments. Eighteen 
percent of MPOs report that they operate independently.[Footnote 12] 

Table 1: Mean and Median Number of Staff at MPOs: 

MPO size: Small (population of less than 200,000); 
Mean number of full-time staff: 3.19; 
Mean number of part-time staff: 1.43; 
Median number of full-time staff: 2.00; 
Median number of part-time staff: 1.00. 

MPO size: Medium (population of 200,000-999,999); 
Mean number of full-time staff: 8.19; 
Mean number of part-time staff: 1.50; 
Median number of full-time staff: 7.00; 
Median number of part-time staff: 1.00. 

MPO size: Large (population of 1 million and above); 
Mean number of full-time staff: 49.27; 
Mean number of part-time staff: 3.90; 
Median number of full-time staff: 31.00; 
Median number of part-time staff: 1.00. 

MPO size: All MPOs; 
Mean number of full-time staff: 10.96; 
Mean number of part-time staff: 1.77; 
Median number of full-time staff: 4.00; 
Median number of part-time staff: 1.00. 

Source: GAO analysis of MPO survey responses. 

[End of table] 

Beyond their staff and structure, MPOs also vary in terms of their 
funding sources and amounts. Federal planning funds--FHWA PL funds and 
FTA Section 5303 funds--generally make up a large portion of the MPO 
budget for conducting necessary studies and developing transportation 
plans, programs, and other documents. According to our survey 
respondents, about 80 percent of MPOs receive a majority of their 
planning funds from these federal sources. The amount of matching funds 
provided by state and local sources also varies considerably by MPO. 
For example, officials from one state department of transportation we 
spoke to said that the small MPOs receive considerably more than the 
required 20 percent of state and local matching funds for 
transportation planning. Officials from another state told us that 
although they only receive the required 20 percent match, they also 
provide technical support to some MPOs. In addition to federal planning 
funds and the required state and local match, some MPOs receive and use 
other funds, such as dedicated local taxes and transit fare box 
revenue. Finally, according to FTA, while most federal transit funds 
designated for urban areas are apportioned directly from FTA to the 
transit operator, some funds are apportioned to MPOs, which then 
allocate those funds themselves.[Footnote 13] 

The technical capacity of MPOs to develop travel demand forecasts--a 
crucial component of the long-range plans--also varies. Some MPOs-- 
about 45 percent of all our survey respondents--use their own models to 
develop most, if not all, of their forecasts, while 51 percent rely on 
consultants or their state department of transportation to conduct 
their modeling. Small MPOs are less likely to conduct their own travel 
demand forecasts, with only 30 percent reporting that they have their 
own modeling, according to our survey. Further, the federal government 
gives local transportation planning agencies, including MPOs, the 
flexibility to choose their own transportation models without being 
subject to minimum standards or guidelines. As a result, the type of 
model used by MPOs also varies. Of the MPOs that reported in our survey 
that they use a model to conduct their travel demand forecasts, a large 
majority said that they use a four-step model, which uses survey and 
other data to estimate future trips and assign those trips to different 
modes. Seven survey respondents indicated that they use activity-based 
models, which are tied more closely to household and traveler 
characteristics and behavior and therefore should, in concept, permit 
MPOs to address policy questions that cannot be treated with the 
conventional four-step models. For example, four-step models are not 
suited to estimating the emissions effects of small transportation 
projects or linking these effects to air quality; more advanced 
modeling techniques, such as activity-based models, are needed to 
estimate such effects. The Transportation Research Board (TRB) also 
noted that although the four-step process is common, there are 
considerable variations in the completeness and complexity of the 
models and data employed.[Footnote 14] Further, they reported that MPOs 
vary significantly in the number of staff devoted to travel 
forecasting. 

The Responsibilities and Activities of Some MPOs Have Expanded beyond 
Transportation Planning: 

Through our survey and interviews, we also found that many MPOs have 
additional responsibilities that are not federally required, many of 
which extend beyond transportation planning. For some MPOs, these 
additional responsibilities and activities are required by their state, 
while other MPOs have taken on these responsibilities over time, based 
on regional needs. 

* Land-use planning. According to our survey respondents, many MPOs 
conduct all or a portion of their region's land-use planning, and for 
some this is a state requirement. Specifically, 70 percent of MPOs have 
some land-use planning responsibilities, with the larger MPOs generally 
reporting that they have more of these planning responsibilities than 
small MPOs. Eleven percent of survey respondents specifically said that 
their land-use responsibilities are required by their state. In 
practice, some MPOs integrate land-use planning into their 
transportation planning process by considering potential land-use 
scenarios along with proposed projects. Some MPOs have also led public 
processes to develop an integrated transportation and land-use "vision" 
for a region and to evaluate future transportation and land-use 
scenarios. Similarly, for a number of MPOs, various forms of land-use 
models are now part of the process for analyzing the growth of the 
region and studying the land-use impacts of alternative transportation 
investment programs. Generally, though, MPOs do not have authority to 
make land-use decisions. Rather, local jurisdictions typically have the 
authority to make such zoning and other decisions. 

* Project selection. By determining which projects are to be included 
in TIPs, all MPOs have a role in determining which projects will 
ultimately be funded. However, only certain MPOs have the authority to 
select--from a list of projects in an approved TIP--which projects are 
to be implemented in the most immediate time frame, using federal funds 
available to a metropolitan planning area. In areas designated as TMAs, 
the MPO, in consultation with the state and public transportation 
operators, selects from an approved TIP all projects that are to be 
implemented using funding under Title 23 or under Chapter 53 of Title 
49 of the U.S. Code (excluding projects on the National Highway System 
and projects funded under the Bridge, Interstate Maintenance, and 
Federal Lands Highway programs). Furthermore, MPOs in air quality 
nonattainment areas also have the ability to use CMAQ funds.[Footnote 
15] Additionally, in California, regional organizations have project 
selection authority for 75 percent of their region's portion of the 
state's TIP funds (which includes both federal and state highway 
money). 

* Project implementation. Some MPOs also have the responsibility for 
implementing transportation projects. Generally, MPOs do not take the 
lead in implementing transportation projects; rather, they play a 
coordinating role in planning and programming funds for projects and 
operations. Usually, local jurisdictions, transit operators, or state 
governments take the lead in implementing projects. However, 37 percent 
of survey respondents--representing MPOs of all sizes--said that they 
implement projects. For example, one large MPO we spoke with utilizes 
its local, state, and federal funds to implement projects by leveraging 
this money with regional partners to construct large-scale 
transportation projects. Toward this end, the MPO established a program 
aimed at quickly reducing congestion in particular areas. This 
initiative uses small-scale projects, such as traffic signal 
optimization, for congested corridors--which can be implemented within 
2 years and are largely funded and carried out by the MPO. 

* Transit operations. Sixteen percent of MPOs responded in our survey 
that they have some responsibility for operating all or a portion of 
their regional transit system. For example, one western MPO is both the 
transit authority--providing mass transit that connects throughout the 
region--and the transportation-planning agency for the greater 
metropolitan area. Another MPO noted in our survey that rather than 
operating the transit system, it serves as the planning staff for both 
the region's MPO and the transit agency. 

* Environmental planning. Twenty-one percent of MPOs responding to our 
survey said that they conduct air quality or emissions analysis, beyond 
the federally required conformity process. Further, 32 percent of MPOs 
responding to our survey said that they conduct additional 
environmental or water quality planning. For example, one state we 
visited requires its MPOs to consider how their long-range 
transportation plan increases water and energy conservation and 
efficiency. 

MPOs Face Resource, Authority, and Technical Challenges That Impact 
Their Ability to Conduct Transportation Planning: 

MPOs Report Funding and Staffing Limitations: 

MPOs we surveyed and interviewed cited several funding challenges that 
impact their ability to conduct transportation planning. About 85 
percent of all MPOs responding to our survey cited the lack of 
transportation planning funding as a challenge to transportation 
planning.[Footnote 16] MPOs we surveyed and interviewed also cited 
challenges related to the lack of flexibility of transportation 
planning funds. Specifically, about half of all MPOs responding to our 
survey cited the lack of flexibility of funding as a challenge. While 
FTA allows planning funds to be used for a broad range of planning 
activities, FHWA is more prescriptive in how planning funds can be 
spent. For example, FHWA guidance precludes using planning funds for 
projects' environmental analyses that definitively go beyond 
transportation planning.[Footnote 17] Furthermore, officials at a few 
MPOs we spoke with stated that it is unclear which activities can be 
undertaken with planning funds, particularly in terms of the FHWA 
planning funds, and that such definitions inhibit them from conducting 
comprehensive planning by not allowing them to use transportation 
planning dollars for other uses where necessary. DOT officials we spoke 
with agreed that the eligibility for FHWA planning funds is fairly 
narrow, but noted that Surface Transportation Program funds can be used 
for metropolitan planning and are more flexible. 

MPOs also cited a few other funding-related challenges. First, many 
MPOs reported having difficulty securing local matching funds for 
federal transportation planning dollars. About 66 percent of survey 
respondents overall cited this as a challenge. For example, one MPO we 
spoke with has been unable to utilize all of the federal planning funds 
it has been allocated because the MPO cannot meet its local matching 
requirements. As a result, the MPO has not been able to hire needed 
staff. Second, MPOs also had mixed opinions regarding the fiscal 
constraint requirement--that MPOs develop plans that correspond to 
reliable revenue projections. About 84 percent of survey respondents 
cited the fiscal constraint requirement as a challenge. One MPO 
official told us that this is a challenge because the MPO has to submit 
its TIP without full knowledge of the state's available funding; this 
makes creating a realistic fiscally constrained TIP difficult. A 
previous GAO report found similar concerns. In particular, for MPOs in 
some urban areas, financially constraining the transportation 
improvement program meant abandoning proposed projects because of a 
lack of projected revenue.[Footnote 18] Although developing a fiscally 
constrained plan can be difficult, we have also previously reported 
that the fiscal constraint requirement has been largely beneficial to 
the planning process because it has led MPOs to obtain more reliable 
revenue projections from state departments of transportation and 
transit agencies and to exclude those projects that could not be 
financed within budget constraints. Third, beyond funding challenges 
related to planning, officials at a few small MPOs we spoke with often 
stated that their region had insufficient funding to keep pace with the 
transportation projects needed. In fact, at one small MPO, an official 
estimated that the region received about 10 percent of the funding 
needed to construct necessary projects. This lack of funding could 
potentially limit the effectiveness of MPO planning because fewer 
projects from the TIP can be implemented. 

MPOs also cited staffing constraints, to a lesser extent, as a 
challenge that impacts their ability to conduct transportation 
planning. Some MPOs stated that staffing affects their ability to 
fulfill its planning requirements. For example, one small MPO told us 
that with only one or two staff members, it is very difficult to 
satisfy all the federal requirements for MPOs such as creating and 
updating the TIP and long-range plan and holding public meetings. MPOs 
also mentioned a lack of trained staff as a challenge to transportation 
planning. About half of the survey respondents cited lack of trained 
staff as a challenge in carrying out the federal requirements for 
transportation planning. Lack of trained staff is also a challenge for 
small MPOs, according to our survey. For example, officials from 
several MPOs stated that retaining staff trained to conduct the travel 
forecasting is difficult because there are few people with the 
expertise to conduct such technical analyses and consulting firms can 
often pay modelers a higher salary than an MPO. In addition, officials 
from one MPO told us that the challenges of having limited staff 
resources is compounded by requirements to ensure public participation, 
noting that much of their time is spent carrying out the public 
participation requirements for the planning process relative to other 
activities. Concerns about meeting the public participation 
requirements were consistent across most of the MPOs we surveyed. In 
particular, 79 percent of survey respondents stated that they have 
difficulty obtaining the public participation needed to meet their 
transportation planning requirements. A few MPOs we interviewed stated 
that it was difficult to generate public participation in the planning 
process, in part because few people actually understand what an MPO is 
or what it does. 

Most MPOs function as part of another planning or governing body, such 
as a council of governments. According to a few MPOs we interviewed, 
this arrangement can address staffing and funding limitations by 
allowing an MPO the ability to cut costs by sharing resources such as a 
space in which to operate and, in some cases, facilitates coordination 
between the MPO and other planners or transportation stakeholders. 
However, this arrangement can also create some challenges. In 
particular, a few MPOs housed within city governments or other entities 
connected with a specific jurisdiction said that this arrangement 
causes them to be viewed as less impartial than MPOs that are stand- 
alone entities, and that these perceptions can affect their consensus- 
building efforts. Additionally, 71 percent of small MPO survey 
respondents cited competing priorities between transportation planning 
and other tasks related to the council of governments as a challenge. 

Most MPOs Report That Limitations to Their Authority Presents 
Challenges: 

MPOs we surveyed and interviewed also cited the lack of authority as a 
challenge to effective transportation planning. About 80 percent of all 
MPOs responding to our survey indicated that the lack of authority to 
implement the plans they develop is a challenge. The majority of MPOs 
that responded to our survey do not implement any of the projects 
contained in the plans that they create. Rather, they rely on other 
agents such as cities, counties, and state departments of 
transportation to carry out their plans. Similarly, although many 
survey respondents reported that they conduct land-use planning for 
their region, MPOs generally lack the authority to make land-use 
decisions. Instead, this authority generally rests with state and local 
jurisdictions. As a result, MPOs indicated that they have difficulty 
anticipating and integrating land-use decisions into their 
transportation planning.[Footnote 19] For example, in one region we 
visited, local jurisdictions are often reluctant to make land-use 
planning decisions in-line with the MPO's regional transportation plan. 
In part, the official stated that this occurs because local 
jurisdictions have a difficult time making land-use decisions that 
benefit the region as a whole as opposed to their individual community. 
If land-use decisions do not correspond with an MPO's plans, the MPO's 
proposed transportation improvements may not be as effective. Our past 
work has documented that integrating land-use and transportation 
investments--including accurately modeling future land-use changes--is 
important but challenging.[Footnote 20] 

MPOs we interviewed also cited their lack of authority in determining 
which projects will be implemented as a challenge. Although MPOs help 
determine which projects are eligible for funding and which ones have 
priority through the development of the TIP, whether a project will be 
funded and the amount of funds made available for the project are 
determined by federal, state, and local policymakers. Moreover, 
according to our survey, the availability of funding and public support 
are more important drivers of transportation investment decisions than 
the analysis conducted by MPOs. This is consistent with our previous 
work regarding transportation decision making, which indicated that 
even when economic analyses are performed, the results are not 
necessarily the most important factor considered in terms of which 
projects to fund; rather, a number of factors, such as public support 
or the availability of funding, drive transportation investment 
decisions.[Footnote 21] 

Although MPOs in the survey cited lack of authority as a challenge, the 
MPOs we interviewed had mixed opinions regarding the extent to which 
they felt being granted additional authority would improve 
transportation planning. Some of the MPOs we spoke with emphasized that 
having project implementation and land-use decision-making authority 
would improve transportation planning. For example, one large MPO told 
us that although they have developed a close working relationship over 
the years with transit operators and other transportation stakeholders 
to make their planning processes successful, they need land-use 
authority to more comprehensively address critical transportation 
issues. Another MPO we interviewed, however, suggested that giving MPOs 
project implementation or land-use authority may not improve 
transportation planning. Specifically, one MPO official stated that 
such additional authorities may actually hamper MPOs' ability to 
conduct transportation planning, since some of their current ability to 
generate consensus results from the fact that they do not have a stake 
in building or operating the transportation plans. 

Lack of Technical Capacity Makes It Difficult for MPOs to Meet 
Increasingly Complex Requirements: 

MPOs also face technical challenges, in part because the travel demand 
modeling required to forecast future growth and needs has become more 
complicated. MPOs today face a much broader and more complex set of 
requirements and needs in their travel modeling than they did in the 
1960s and 1970s, when the primary concern was evaluating highway and 
transit system capacity expansions.[Footnote 22] New requirements-- 
such as determining motor vehicle emissions and changes in land use-- 
have created additional data needs to account for the increasing 
complexity of the transportation system. For example, about half of our 
survey respondents indicated that their MPOs include a nonattainment or 
maintenance area and, thus, are required to conduct air quality 
conformity analyses. An even larger percentage of medium-and large- 
sized MPOs--66 percent and 76 percent, respectively--indicated that 
they have such areas within their MPO boundaries. As planning 
organizations, much of the value of MPOs lies in their ability to 
forecast and analyze an increasingly complex and growing set of 
transportation needs. If MPOs' technical capabilities cannot account 
for the increasing complexities facing regional transportation systems, 
MPOs' contributions to transportation planning may be compromised, 
which could lead to planning failures and poor investment decisions. 

Although some MPOs are taking steps to meet the challenges presented by 
the increasing complexity of the transportation system, MPOs still face 
modeling challenges. About half of MPOs report that they face 
challenges related to their limited modeling capacity. Some MPOs have 
had success updating their travel forecasting techniques to accommodate 
new requirements. For example, officials at one MPO told us the transit 
agency in their region is developing a travel demand model specifically 
for transit, though it has not yet been incorporated into the MPO's 
travel models. Some MPOs we interviewed, however, told us that they 
lack the resources to improve their modeling capabilities. In fact, MPO 
officials expressed concern in interviews that current models, 
including the four-step models most MPOs use, do not necessarily 
produce forecasts that can adequately account for the increasing 
complexities of transportation planning, such as predicting future land-
use patterns and transit's effect on travel behavior. TRB also found 
similar challenges--that is, they found inherent weaknesses in current 
models that are generally unable to address new policy concerns raised 
by the growing complexity of the transportation system. TRB notes that 
when the detail required to address a transportation issue increases, 
the complexity of the analytical techniques should increase as well. 
For example, a small metropolitan area experiencing minimal growth, 
with little transit and no air quality problems, will likely be able to 
use a simple model to determine the area's needs. Thus no single 
approach is appropriate for all MPOs. 

Although modeling presents challenges, according to our survey, the 
most predominant technical challenge was related to acquiring quality 
data to use in planning models. Over 70 percent of survey respondents 
cited data limitations as a challenge. Data reflecting current travel 
patterns in a metropolitan area are important because models that are 
supplied with inaccurate or out-of-date data may produce inadequate 
forecasts that contribute to poor planning. In addition, having robust 
data to support proposed transportation plans helps to keep planning 
more objective and lends credibility to the plans developed by MPOs. 
However, conducting a household travel survey--a survey of random 
households in a metropolitan area that gathers trip-related data, such 
as mode of transportation, duration, distance and purpose of trip--to 
collect updated data is both expensive and time-consuming.[Footnote 23] 
For example, officials at one large MPO we interviewed stated that they 
need to update their household survey but are having difficulty finding 
the estimated $1.5 million needed to do so. As we mentioned earlier, 
funding shortages and the lack of staff trained with such technical 
expertise make increasing technical capacity a challenge for many MPOs, 
particularly small ones. TRB's study also found that many MPOs had 
inadequate data to support their modeling processes. 

The Extent to Which MPO Oversight Mechanisms Improve Transportation 
Planning Is Unclear: 

The federal certification review is an important mechanism that FTA and 
FHWA use to oversee the MPO planning process. Although all MPOs are 
required to self-certify that they have met the federal transportation 
planning requirements, SAFETEA-LU also requires DOT to certify the 
metropolitan planning process of the 155 TMAs every 4 years.[Footnote 
24] To conduct a certification review, FTA and FHWA assemble a team 
which typically consists of FTA and FHWA field staff, but may also 
include FHWA or FTA headquarters community planners, EPA officials, 
other subject matter experts, or experts from DOT's Volpe National 
Transportation Systems Center. FHWA division office personnel generally 
take the lead in these reviews, which typically take 6 to 9 months and 
include (1) an initial desk review, which includes verifying compliance 
with basic regulatory requirements, among other things; (2) an 
evaluation of the MPO's written response to a series of questions; (3) 
a 2 to 4 day site visit during which the team gathers additional 
information; and (4) a meeting to inform the public about planning 
requirements and provide an opportunity for the public to express 
concerns about how the process is meeting the needs of the area. After 
the site visit, the team prepares a final report including review 
findings and recommendations, which incorporates public comments on the 
planning process. 

Consistent with federal law, the federal certification review is 
process-oriented and conducted without regard to transportation 
planning outcomes. Specifically, through certification reviews, DOT 
ensures that the metropolitan planning process of an MPO serving a TMA 
is carried out in accordance with applicable provisions of federal law-
-for example, by ascertaining whether or not the MPO has adhered to its 
public participation plan. Oversight also provides a mechanism through 
which the federal government can ensure that its funds are being used 
to achieve its intended goals. The current process-oriented approach 
toward certification generally focuses on procedural requirements as 
opposed to performance. FTA and FHWA can withhold apportioned federal 
highway and transit funds if they determine an MPO is in noncompliance 
with federal requirements. However, FTA and FHWA officials were unaware 
of any instance in which an MPO was not certified due to noncompliance 
during the last 10 years. Furthermore, FTA and FHWA officials noted 
that the process is meant to be collaborative in nature. Therefore, a 
finding of noncompliance is as much of a failure on the part of DOT as 
the MPO, according to a DOT official. 

Because the federal certification is focused on compliance, not 
outcomes, it is difficult to determine whether federal oversight is 
improving transportation planning. GAO has previously recommended 
[Footnote 25] to DOT, as well as to Congress, that adopting performance 
measures and goals for programs can aid in evaluating and measuring the 
success of the programs, which can lead to better decisions about 
transportation investments.[Footnote 26] The procedural focus of the 
federal certification, and the fact that, according to DOT officials' 
knowledge, no MPO has failed to be certified as a result of a 
certification review also makes it difficult to use the certification 
results as a performance indicator for MPOs. According to FHWA and FTA 
officials, certification reviews examine the quality of the MPO 
planning process by, for example, identifying corrective actions where 
there is noncompliance with statute or regulations and recommendations 
for areas needing improvement. Corrective actions are set with 
milestone dates to rectify the noncompliance and require a status 
report and re-evaluation of the process. Commendations for the use of 
noteworthy practices are also identified. However, FTA and FHWA do not 
assess the progress of the MPO in achieving the goals outlined in the 
plans. According to FTA and FHWA officials, states may, but are not 
required to, monitor the progress of MPOs in meeting their goals. 
Furthermore, an FHWA official noted that the elements that are reviewed 
through certification serve as proxies for good planning--for example, 
the resulting plans will be better if the MPO is regularly soliciting 
and incorporating public input. 

Most MPOs we interviewed generally view the federal certification 
reviews as pro forma in nature and place a greater value on informal 
assistance from the federal government. Officials in one state said 
that the most important oversight is the "give and take" between 
agencies on the various transportation plans they create. This informal 
interaction allows the oversight agencies to identify issues prior to 
the formal reviews. Likewise, many federal officials with whom we spoke 
view informal interactions--such as regular meetings, technical 
assistance, and review of air quality conformity analyses--as an 
important aspect of oversight. One FHWA division official we 
interviewed stated that the benefit of ongoing communication is that 
problems are identified as they arise and can be addressed well before 
the certification review or self certification is conducted. 

MPOs also reported that the assistance provided by their states is more 
important than the federal certification reviews. Although the level of 
participation of states in the planning process varies, MPOs reported 
in our survey that state department of transportation officials 
generally play a greater oversight role than DOT for certain 
activities. For example, around 80 percent of survey respondents 
reported that state department of transportation officials are involved 
in MPO boards and committees, while over 55 percent and 70 percent 
reported similar participation from federal officials on MPO boards and 
committees, respectively. This may be due, in part, to the limited 
number of staff at FHWA and FTA. 

MPO, Government, and Industry Officials Have Developed Options to 
Enhance Transportation Planning: 

With the pending expiration of the current surface transportation 
authorizing legislation, MPO, government, and industry officials have 
developed various formal and informal proposals to improve or change 
the current transportation planning process. We reviewed proposals from 
AMPO, AASHTO, APTA, the Brookings Institution, the previous and current 
DOT administrations, and the June 2009 House Transportation and 
Infrastructure Committee blueprint for the surface transportation 
reauthorization. We also discussed suggestions for improving 
transportation planning with MPO, federal, and state officials. In 
reviewing these proposals or suggestions, we identified several 
recurring changes, or options, that could address some of the resource, 
authority, and technical challenges facing MPOs. Most of the options 
have both advantages and disadvantages, and implementing any of the 
options will require policy trade-offs. 

Increasing Flexibility in Use of Federal Funds: 

Creating an expanded or clarified definition of eligibility for the use 
of transportation planning funds could allow MPOs to utilize planning 
funds in ways that best meet the needs of the area. Most of the MPOs we 
surveyed and many of the MPOs we interviewed suggested that having 
additional flexibility regarding the types of activities that are 
eligible to be completed using planning funds would improve the 
planning process. Currently, FHWA guidance precludes using planning 
funds for projects' environmental analyses that "clearly extends beyond 
transportation planning." As we mentioned previously, officials at a 
few MPOs we spoke with stated that they are unclear about what 
environmental activities are eligible under that definition, which 
makes it difficult to conduct comprehensive transportation planning. 
According to many of the MPOs we interviewed and 90 percent of the MPOs 
responding to our survey, creating more flexibility in how the planning 
funds can be spent would improve the effectiveness of the planning 
process and allow MPOs to be more efficient by prioritizing their 
limited resources to the most critical planning activities. However, 
providing such flexibility in federal transportation funds could result 
in less transparency and accountability. In particular, when funds can 
be flexed across different activities, there is less ability to assess 
the impact of particular funding streams--such as transportation 
planning funds--on the achievement of key goals. 

Creating Greater Variation in Planning Requirements: 

A number of the proposals for improving the MPO planning process 
include creating further variation--in addition to the TMA and non-TMA 
distinction--in MPOs' planning requirements and authority to account 
for the wide variation in capacity of MPOs across the country. For 
example, creating additional variations in MPOs' planning requirements 
could include the development of abbreviated planning requirements for 
MPOs. SAFETEA-LU allows that the Secretary of Transportation may permit 
MPOs that are not designated as TMAs or are not in nonattainment for 
ozone or carbon monoxide to develop abbreviated metropolitan 
transportation plans or TIPs. In so doing, the Secretary must take into 
account the complexity of transportation problems in the area.[Footnote 
27] MPOs in small metropolitan areas--where transportation needs are 
often less complex--could benefit from abbreviated planning 
requirements. To date, no MPOs have applied for the abbreviated 
planning requirements, according to DOT officials. 

Other proposals suggest that MPOs that have exhibited increased 
capacity--e.g., those that are conducting additional activities beyond 
the current planning requirements--could be allowed additional 
implementation authority to oversee the development of certain 
projects. Likewise, an MPO could be granted expanded authority to plan 
and fund a metropolitan area's transportation projects--focusing 
available transportation funds on projects that will benefit a region 
the most, regardless of mode. A large majority of the survey 
respondents--79 percent--stated that additional project implementation 
authority would improve effectiveness of the MPO planning process. 
[Footnote 28] 

However, granting additional authorities to MPOs or reducing the 
requirements could result in some additional challenges for MPOs and 
DOT. Additional federal and state oversight may be needed for (1) MPOs 
that take on new, traditionally non-MPO responsibilities, such as 
project implementation or (2) MPOs that reduce their planning 
requirements in order to ensure that the abbreviated process adequately 
accounts for the transportation needs of the area. Additionally, over 
half of the survey respondents reported that they do not have the 
capacity to undertake additional project implementation authorities, 
despite the fact that a large majority of MPOs stated increased 
implementation authority would improve the effectiveness of their 
planning process. 

Other proposals include changing the legal definition of MPOs to 
realign the MPO planning process with current capacity and planning 
needs. In particular, one option calls for an increase in the 
population threshold for mandatory MPO creation. Requiring the 
formation of MPOs at a larger population threshold could ease the 
burden of the previously mentioned resource constraints affecting small 
MPOs, including funding and staffing shortages. Specifically, one of 
the state departments of transportation we interviewed--one that 
contains more rural areas--noted that the current population threshold 
of 50,000 can create a situation in which a relatively small, rural 
area with less complex transportation needs is given MPO 
responsibilities. In these situations, MPOs may have difficulty funding 
an adequate number of positions--or filling them with qualified 
individuals--to do the work needed to meet federal and state 
requirements. Raising the population threshold could raise the 
likelihood that MPO efforts are limited to urban areas with more 
advanced transportation needs. However, about 73 percent of survey 
respondents from small MPOs reported that raising the threshold would 
not be an appropriate way to improve the planning process. An official 
from a small MPO we interviewed noted that any reduction in 
responsibilities for small MPOs must be a contextual decision based on 
the complexity of the transportation needs in the area, such as 
proximity to a large metropolitan area that is expected to grow in the 
future. 

Increasing Federal Investment in Modeling Efforts: 

With regard to technical constraints, improving technical capabilities 
across MPOs will likely require additional investment in modeling, data 
gathering, or both. As noted previously, current models are not well 
suited to representing travelers' responses to the complex range of 
policies such as freight movement and motor vehicle emissions. Of 
particular concern is that many MPOs have inadequate data to support 
their modeling processes, even for traditional travel demand forecasts. 
Eighty-seven percent of MPOs surveyed said that greater federal support 
for transportation research and data would improve their effectiveness. 
Moreover, many of the MPOs we interviewed agreed that federal 
government investment in modeling and data gathering is necessary to 
ensure greater reliability in travel demand forecasting across MPOs and 
to help account for the increasing complexity of transportation 
forecasting and data needs in urban areas. Furthermore, without such an 
investment, policymakers may lack the information needed to make 
informed decisions on investments related to the transportation system. 

Toward this end, TRB's Special Report 288 recommended the development 
and implementation of new modeling approaches to travel demand 
forecasting that are better suited to providing reliable information. 
These new modeling approaches include such applications as multimodal 
investment analyses, environmental assessments, evaluations of a wide 
range of policy alternatives, and meeting federal and state regulatory 
requirements. TRB also made various recommendations for improvements, 
including increasing DOT support and funding for incremental 
improvements to models in settings appropriate for their use, and the 
continued development, demonstration, and implementation of advanced 
modeling approaches.[Footnote 29] Additionally, TRB encouraged DOT 
collaboration with MPOs and states to examine data collection needs, 
including data requirements for validating current travel forecasting 
models and meeting regulatory requirements. Most recently, in July 
2009, when DOT announced its principles for an 18-month extension of 
federal highway, transit, and highway and trucking safety programs, it 
called for an investment of $300 million to build state and MPO 
planning capacity for the collection and analysis of data on 
transportation goals. Additionally, DOT's 18-month extension proposal 
suggests an investment of $10 million to build MPOs' informational and 
analytic capacity to refine assessment tools at the federal level, 
among other things. 

Making the Planning Process More Performance-Based: 

Currently there are no requirements to attain explicit performance 
thresholds, such as reducing congestion or improving highway safety, 
built into the federal planning requirements for MPOs.[Footnote 30] 
MPOs and industry representatives we interviewed recognized the value 
of making the planning process more performance-based, noting that 
focusing on outcomes could improve transportation investment decision 
making. In addition, DOT's recently released principles for an 18-month 
extension of certain federal surface transportation programs also calls 
for stronger requirements for tracking and reporting on the projected 
and actual outcomes of transportation investments that use federal 
dollars. Using performance measures could help hold MPOs accountable 
for carrying out a 3-C transportation planning process that encourages 
and promotes a safe and efficient surface transportation system. 
According to our survey, most MPOs already report using performance 
measures to some extent to assess results achieved. However, MPOs 
generally reported using output-based measures, such as compliance with 
state and federal transportation planning rules, rather than outcome- 
based measures, such as improved safety. Further, some DOT officials we 
spoke with maintained that the wide variety of needs and capacities 
among regions would make it difficult to establish national performance 
measures. To overcome the challenge of creating such measures for all 
MPOs, some officials said that broader performance goals could be 
established at the national level, while more specific measures and 
targets could be left for states and regions to establish. 

Establishing outcome-based measures for all MPOs would also require DOT 
to expand its oversight so that it can assess the progress of MPOs in 
achieving specific results, rather than focusing on compliance with 
existing statutes and rules. However, a few MPOs and the DOT officials 
we spoke to noted that it would not be appropriate to hold MPOs 
accountable for specific outcomes because they do not have the 
authority to implement their plans. Indeed, it is often up to local 
jurisdictions and the state to carry out MPO plans, and they do not 
always have the same priorities and goals as the MPOs. Some MPO 
stakeholders we spoke to noted that reconciling the needs of the region 
with the priorities of individual jurisdictions is a significant 
challenge. Nevertheless, other officials we spoke to noted that the 
purpose of MPOs is to establish a consensus on a region's long-term 
transportation goals and that it would be appropriate to link those 
goals with specific outcomes. 

Conclusions: 

Our survey shows a pattern of variations and challenges that could 
increasingly compromise the quality of regional transportation 
planning, potentially allowing transportation problems--such as 
increasing congestion--to inhibit economic activity in the United 
States. For example: 

* MPOs' roles and responsibilities are not commensurate with their 
requirements. Under the current system, a small MPO with a simple 
transportation mission and limited technical capacity is generally 
accountable to the same planning and program requirements and oversight 
as a large MPO with a complex, multimodal transportation system, 
raising questions as to whether the federal government is appropriately 
targeting its oversight resources. SAFETEA-LU allows MPOs to seek 
permission to use a more abbreviated planning process. MPOs may not be 
universally aware of this option since, to date, no MPOs have utilized 
it. 

* The quality of MPOs' computerized travel demand models and the data 
used to support the process is often insufficient or unreliable. As 
planning organizations, one of the important functions of MPOs is the 
ability to forecast and analyze an increasingly complex and growing set 
of environmental, transportation, and social trends. Thus if MPOs are 
not able to keep pace with the increasing complexity of this task, 
their contribution to transportation planning may be compromised. 
However, on a cautionary note, effective forecasting requires both 
quality computer models and accurate data, such that investing in one 
without improving the other may waste resources. DOT's July 2009 18- 
month extension proposal calls for additional resources for the 
collection and analysis of data on transportation goals to help build 
transportation planning capacity. Adopting TRB's modeling and data 
gathering recommendations is an example of how the additional resources 
could be invested. 

* Finally, because the oversight mechanisms for MPOs are focused on 
process, rather than outcomes, it is unclear what impact regional 
transportation planning is having on transportation outcomes. Despite 
over 30 years of a federally mandated and funded transportation 
planning process and billions spent on roads, bridges, and transit 
projects, there is not enough information for policymakers to determine 
whether the planning process is addressing critical transportation 
challenges facing the United States. However, shifting to a more 
performance-based oversight approach will require legislative changes. 

Addressing these variations and challenges is particularly important 
given some proposed reforms that would increase the ability of 
metropolitan and local governments to access additional federal 
transportation funds. The upcoming reauthorization of federal surface 
transportation programs provides Congress and DOT an opportunity to 
address these challenges and enhance regional transportation planning. 
For example, Congress and DOT could examine what is being invested in 
the federal oversight process, what the return for this investment is, 
and how it may be improved. 

Matter for Congressional Consideration: 

Congress should consider making MPO transportation planning more 
performance-based--for example, by identifying specific transportation 
outcomes for transportation planning and charging the U.S. Department 
of Transportation with assessing MPOs' progress in achieving these 
outcomes in the certification review process. 

Recommendations: 

To improve the transportation planning process, we are recommending 
that the Secretary of Transportation take the following two actions: 

1. Direct the Administrators of the Federal Highway Administration and 
the Federal Transit Administration to establish guidelines for MPOs to 
apply for, and implement, the abbreviated planning clause for small 
MPOs, and share these guidelines with existing MPOs. 

2. Develop a strategy to improve data gathering and modeling efforts 
among MPOs, including establishing a timeline for implementing the 
modeling and data recommendations for the federal government in the 
Transportation Research Board's Special Report 288. 

Agency Comments: 

We provided a draft of this report to DOT for review and comment. DOT 
agreed to consider the report's recommendations. DOT also provided 
technical comments, which we incorporated as appropriate. 

We are sending copies of this report to interested congressional 
committees and the Secretary of Transportation. In addition, this 
report will be available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-2834 or herrp@gao.gov. Contact points for our 
Offices of Congressional Relations and Public Affairs may be found on 
the last page of this report. GAO staff who made major contributions to 
this report are listed in appendix II. 

Sincerely yours, 

Signed by: 

Phillip R. Herr: 
Director: 
Physical Infrastructure Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

To identify and assess the characteristics and responsibilities of 
metropolitan planning organizations (MPO) we reviewed current and 
previous federal statutes and regulations governing MPOs. We also 
reviewed relevant academic, industry association, GAO, and U.S. 
Department of Transportation (DOT) research and publications to 
understand MPOs' transportation planning responsibilities, the ways 
MPOs vary, and the challenges MPOs face in carrying out their 
responsibilities. Additionally, we interviewed representatives from 
industry associations, as well as MPO, Federal Transit Administration 
(FTA), Federal Highway Administration (FHWA), and DOT officials to 
clarify MPO planning responsibilities, identify transportation planning 
challenges, and assess how DOT provides oversight for MPOs and the 
extent to which this improves transportation planning. To further 
examine the role of state departments of transportation in metropolitan 
planning and assess the potential impact of various changes to MPOs, we 
contacted 11 additional state departments of transportation by e-mail 
and received responses from 6. We also attended and observed a DOT on- 
site certification review in Savannah, Georgia, to further understand 
the federal oversight of transportation management areas (TMA). 

To determine the various options for improving regional transportation 
planning, we reviewed federal surface transportation program 
reauthorization proposals from the Association of Metropolitan Planning 
Organizations (AMPO), American Association of State Highway and 
Transportation officials, American Public Transportation Association, 
Brookings Institution, the previous and current DOT administrations, 
and the current House Transportation and Infrastructure Committee 
blueprint for reauthorization. We also discussed informal proposals or 
suggestions for improving the planning process with MPO, federal, and 
state officials. 

To gather in-depth information on the roles and responsibilities of 
MPOs, the extent to which federal oversight improves transportation 
planning, and possible ways to improve regional transportation 
planning, we conducted a Web-based survey of all 381 MPOs. This survey 
was conducted from February 3 to April 1, 2009. To prepare the 
questionnaire, we pretested potential questions with MPOs of different 
sizes and from different FTA regions to ensure that (1) the questions 
and possible responses were clear and thorough, (2) terminology was 
used correctly, (3) questions did not place an undue burden on the 
respondents, (4) the information was feasible to obtain, and (5) the 
questionnaire was comprehensive and unbiased. On the basis of feedback 
from the seven pretests we conducted, we made changes to the content 
and format of some survey questions. The results of our survey can be 
found at GAO-09-867SP. 

To identify MPOs to survey, we obtained MPO contact information from 
DOT and AMPO; any inconsistencies between the two lists were reconciled 
with phone calls to the relevant MPO. We also contacted all of the MPOs 
in advance, by e-mail, to ensure that we had identified the correct 
respondents and to request their completion of the questionnaire. After 
the survey had been available for 2 weeks, and again after 4 and 6 
weeks, we used e-mail and telephone calls to contact MPOs who had not 
completed their questionnaires. Using these procedures, we obtained an 
86 percent response rate. Because this was not a sample survey, there 
are no sampling errors. However, the practical difficulties of 
conducting any survey may introduce errors, commonly referred to as 
nonsampling errors. For example, difficulties in how a particular 
question is interpreted, in the sources of information that are 
available to respondents, or in how the data are entered into a 
database or were analyzed can introduce unwanted variability into the 
survey results. We took steps in the development of the questionnaire, 
the data collection, and the data analysis to minimize these 
nonsampling errors. For instance, a survey specialist designed the 
questionnaire in collaboration with GAO staff who have subject-matter 
expertise. Further, the draft questionnaire was pretested with a number 
of MPOs to ensure that the questions were relevant, clearly stated, and 
easy to comprehend. When the data were analyzed, a second, independent 
analyst checked all computer programs. Finally, nonresponding MPOs were 
distributed among different states and sizes of MPOs in a way that did 
not show evidence of bias. 

To gather additional information on the roles and responsibilities of 
MPOs, the extent to which federal oversight improves transportation 
planning, and possible ways to improve regional transportation 
planning, we conducted case studies in eight metropolitan areas. Each 
case study involved interviews with the designated MPO for that 
metropolitan area, as well as the state department of transportation, 
transit operators, and other relevant regional organizations. We 
selected MPOs to visit and examine based on the following criteria: 

* population (based on whether or not the MPO is in a designated TMA); 

* location (based on the FTA region); 

* air quality (based on whether the MPO is located in an air quality 
nonattainment area); 

* structure of the MPO (based on whether the MPO is an independent 
agency or housed within another organization or jurisdiction); and: 

* recommendations from internal stakeholders, experts, associations, 
and federal DOT officials we consulted. 

Although using these criteria allowed us, in our view, to obtain 
information from a diverse mix of MPOs, the findings from our case 
studies cannot be generalized to all MPOs because they were selected as 
part of a nonprobability sample.[Footnote 31] Table 2 lists the region 
and relevant MPOs where we conducted case studies. 

Table 2: Metropolitan Regions Selected for Case Study: 

Metropolitan area: Albuquerque, New Mexico; 
Designated MPO: Mid-Region Council of Governments. 

Metropolitan area: Dallas-Ft. Worth, Texas; 
Designated MPO: North Central Texas Council of Governments. 

Metropolitan area: Gainesville, Florida; 
Designated MPO: North Central Florida Regional Planning Council. 

Metropolitan area: Jacksonville, Florida; 
Designated MPO: North Florida Transportation Planning Organization. 

Metropolitan area: Sacramento, California; 
Designated MPO: Sacramento Area Council of Governments. 

Metropolitan area: San Francisco, California; 
Designated MPO: Metropolitan Transportation Commission. 

Metropolitan area: Santa Fe, New Mexico; 
Designated MPO: Santa Fe Metropolitan Planning Organization. 

Metropolitan area: Sherman, Texas; 
Designated MPO: Sherman-Dennison Metropolitan Planning Organization. 

Source: GAO. 

[End of table] 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Phillip R. Herr, (202) 512-2834 or herrp@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, A. Nicole Clowers, Acting 
Director; Kyle Browning; F. Chase Cook; Kathleen Gilhooly; Cathy 
Hurley; Stu Kaufman; Sara Ann Moessbaeur; Josh Ormond; Stephanie 
Purcell; Amy Rosewarne; Jay Smale; and Susan Zimmerman made key 
contributions to this report. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 102-240. 

[2] Pub. L. No. 109-59. 

[3] To establish this list of MPOs, we obtained contact information 
from the U.S. Department of Transportation and the Association of 
Metropolitan Planning Organizations. Any inconsistencies between the 
two lists were reconciled with phone calls to the relevant MPO in 
January 2009. We received completed questionnaires from 328 (86 
percent) of the MPOs. Nonresponding MPOs were distributed among 
different states and sizes of MPOs in a way that did not show evidence 
of bias. 

[4] Planning organizations are not required for rural areas. As part of 
the statewide planning process, the state department of transportation 
consults with local officials in nonurban areas and determines the 
projects in those areas to which the state will direct resources. 
However, some states have Rural Planning Organizations to plan for the 
expenditure of federal and state transportation funds in their area. 

[5] These long-range plans are generally called metropolitan 
transportation plans. 

[6] In providing interested parties "a reasonable opportunity to 
comment on the transportation plan," 23 U.S.C. § 134(i)(5)(C) and 49 
U.S.C. § 5303 (i)(5)(C) require an MPO "to the maximum extent 
practicable...hold any public meetings at convenient and accessible 
locations and times." 

[7] The long-range plan and TIP must include information on how the MPO 
reasonably expects to fund the projects included in the plan, including 
anticipated revenues from FHWA and FTA, state government, regional or 
local sources, the private sector, and user charges. The long-range 
plan must also demonstrate that there is a balance between the expected 
revenue sources for transportation investments and the estimated costs 
of the projects and programs described in the plan. 

[8] With respect to environmental resource agencies, SAFETEA-LU 
requires that long-range transportation plans be developed in 
consultation with state and local agencies responsible for land-use 
management, natural resources, environmental protection, conservation, 
and historic preservation, and that state conservation plans or maps 
and inventories of natural or historic resources be consulted, if 
available. 

[9] The CMP is a process for monitoring transportation system 
performance that involves data collection, performance measurement and 
monitoring, and the identification of strategies and projects to manage 
congestion. 

[10] This transportation conformity analysis requires MPOs to use 
forecasts for their long-range plan to estimate traffic volumes and 
speeds, which become inputs to the Environmental Protection Agency's 
(EPA) MOBILE model. That model, in turn, provides estimates of future 
motor vehicle source emissions. These emissions estimates are used to 
determine whether the proposed transportation plan and programs will 
result in motor vehicle emission levels that conform to those 
established in state air quality plans and approved by EPA. Under 
federal conformity requirements, if the estimated emissions that result 
from future vehicle travel exceed budgets established in the state 
implementation plan, which is required by EPA, and transportation 
conformity cannot be determined, projects and programs must be delayed, 
except for projects determined to be exempt from air quality 
conformity. 

[11] The STIP is similar to the TIP in that it identifies 4 years of 
transportation project priorities and must be fiscally constrained. 
STIPs must be approved by both FHWA and FTA. 

[12] Eleven percent of survey respondents specified "other" as the MPO 
structure. 

[13] Transit funds for rural areas are administered by the state 
department of transportation. 

[14] TRB, Metropolitan Travel Forecasting: Current Practice and Future 
Direction, Special Report 288 (2007). TRB is one of six major divisions 
of the National Research Council--a private, nonprofit institution that 
is the principal operating agency of the National Academies in 
providing services to the government, the public, and the scientific 
and engineering communities. TRB provides leadership in transportation 
innovation and progress through research and information exchange, 
conducted within a setting that is objective, interdisciplinary, and 
multimodal. 

[15] The CMAQ program, jointly administered by the FHWA and FTA, 
provides funds to state departments of transportation, MPOs, and 
transit agencies to invest in projects that reduce criteria air 
pollutants regulated from transportation-related sources over a period 
of 5 years. Funding is available for areas that do not meet federal air 
quality standards (nonattainment areas), as well as former 
nonattainment areas that are now in compliance (maintenance areas). The 
formula for distribution of funds--which considers an area's population 
by county and the severity of its ozone and carbon monoxide problems 
within the nonattainment or maintenance area, with greater weight given 
to areas that are both carbon monoxide and ozone nonattainment and 
maintenance areas--is continued. 

[16] For questions where we asked about the challenges that MPOs face, 
we used a five-point scale to measure the extent of the challenge: very 
great challenge, great challenge, moderate challenge, some or little 
challenge, and no challenge. For the purposes of this report, we 
combined the responses for moderate challenge, great challenge, and 
very great challenge to describe the challenges MPOs identified. 

[17] Specifically, under 23 CFR Part 420 FHWA funding programs, once a 
general travel corridor or specific project has progressed to a point 
in the preliminary/engineering National Environmental Policy Act phase 
that clearly extends beyond transportation planning, additional in- 
depth environmental studies must be funded through the program category 
for which the ultimate project qualifies (e.g., National Highway 
System, Interstate Maintenance, or Bridge Programs), rather than 
metropolitan planning or statewide planning and research funds. 

[18] GAO, Urban Transportation: Metropolitan Planning Organizations' 
Efforts to Meet Federal Planning Requirements, [hyperlink, 
http://www.gao.gov/products/GAO/RCED-96-200] (Washington, D.C.: Sept. 
17, 1996). 

[19] Current transportation demand models are also unable to predict 
the effect of a transportation investment on land-use patterns and 
development. 

[20] GAO, Highway and Transit Investments: Options for Improving 
Information on Projects' Benefits and Costs and Increasing 
Accountability for Results, [hyperlink, 
http://www.gao.gov/products/GAO-05-172] (Washington, D.C.: Jan. 24, 
2005). 

[21] [hyperlink, http://www.gao.gov/products/GAO-05-172]. 

[22] TRB, Metropolitan Travel Forecasting: Current Practice and Future 
Direction, Special Report 288 (2007). 

[23] The National Household Travel Survey is a DOT effort sponsored by 
the Bureau of Transportation Statistics and FHWA to collect data on 
both long-distance and local travel by the American public. The joint 
survey gathers trip-related data, such as mode of transportation, 
duration, distance, and purpose of trip. MPOs also conduct household 
travel surveys to collect data on local travel in their respective 
metropolitan areas. 

[24] According to DOT's MPO database, 155 MPOs have at least one part 
of their designated boundary within a TMA. 

[25] GAO, Rail Transit: Additional Federal Leadership Would Enhance 
FTA's State Safety Oversight Program, [hyperlink, 
http://www.gao.gov/products/GAO-06-821] (Washington, D.C.: July 26, 
2006) and GAO, Surface Transportation: Restructured Federal Approach 
Needed for More Focused, Performance-Based, and Sustainable Programs, 
[hyperlink, http://www.gao.gov/products/GAO-08-400] (Washington, D.C.: 
Mar. 6, 2008). 

[26] DOT officials generally agreed with our recommendations and stated 
that, although they do have some performance measures in place for 
certain programs, additional performance measures could be beneficial. 

[27] SAFETEA-LU 23 U.S.C. § 134(l); 49 U.S.C. § 5303(l). 

[28] For questions where we asked about the options that would improve 
the effectiveness of the MPO planning process, we used a five-point 
scale to measure extent: very great extent, great extent, moderate 
extent, some or little extent, and no extent. For the purposes of this 
report, we combined the responses for moderate extent, great extent, 
and very great extent to report the percentage of responses that 
indicated an option would improve the effectiveness of the planning 
process. 

[29] Advanced travel models are based on a more comprehensive 
understanding of the activities of households; that is, they reflect 
the full range of trade-offs that affect whether to make a trip, what 
time a trip is made, the destinations visited, the modes used, and the 
paths selected. 

[30] The CMP requires that TMAs monitor congestion and consider 
potential congestion relief measures in formulating long-range plans. 

[31] Results from nonprobability samples cannot be used to make 
inferences about a population because, in a nonprobability sample, some 
elements of the population being studied have no chance or an unknown 
chance of being selected as part of the sample. 

[End of section] 

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