Mr. Daniel Kovacich, Executive Officer

Shasta County Regional Transportation Planning Agency (RTPA) 1855 Placer Street

Redding, California 96001

Dear Mr. Kovacich:

SUBJECT: Shasta County RTPA Draft 2004/05 OWP Comments

We have completed our review of the Shasta County RTPA draft Overall Work Program (OWP) transmitted to us on March 10, 2004. Based on our review we offer the following comments/suggestions for consideration as you develop the final OWP for FY 2004/05.

Planning Emphasis Areas

The FHWA and the FTA identify Planning Emphasis Areas (PEAS) annually to promote priority themes for consideration in transportation planning efforts. For FY 2004, we are continuing with the five PEAS from last year. Thank you for mentioning the PEAS on pages 15 to 17 of your draft OWP, and for documenting how the OWP considers the PEAS in the planning process, and in specific work elements.

Intelligent Transportation Systems (ITS)

We appreciate your involvement with the California-Oregon Advanced Transportation System (COATS) Strategic Deployment Plan over the past years. We note that in June of 2001,

the COATS ITS Steering Committee completed requirements related to establishing a Regional ITS Architecture consistent with 23 CFR 940.9 (d). However, the Regional ITS Architecture report was approved in December 2000, before the Final Rule and needs to be updated. We would suggest adding a work element or task to include resources to update the Regional ITS Architecture.

In addition, the requirement to establish a maintenance plan with procedures and responsibilities for maintaining a Regional ITS Architecture per 23 CFR 940.9 (f) has not yet been met. We suggest adding a work element or task to include resources for the development of a maintenance plan. This Work Element should reflect the work needed to re-group stakeholders and establish the Regional ITS Architecture's maintenance plan to meet the April 8, 2005, deadline in 23 CFR 940.9 (f). Shasta County RTPA along with the other RTPA partners need to recognize the importance of updating and maintaining their regional ITS architecture. Without this commitment, Shasta County RTPA and others risk the potential loss of federal funds for ITS system deployment.

In December 2002, the FHWA and Caltrans signed a new "Project Approval and Oversight Letter of Agreement" (Stewardship) that states, "FHWA will be consulted prior to beginning Systems Engineering Analysis and Design to determine if FHWA approval of the Systems Engineering Analysis is required." To start this consultation early, we ask that you provide an indication (e.g., flag or separate listing) of major ITS projects included with your FTIP submittal. Major ITS projects are defined as: 1) multi-modal, 2) multi jurisdictional, or 3) having significant regional impact. We are flexible in how this information is presented. This will facilitate early FHWA education and technical assistance to project sponsors in the application of the Systems Engineering process and avoid unnecessary project delay.

Financial Planning/Financial Constraint

In consideration of the state's late find estimate, the federal agencies will not hold California MPOs to the April, 2004, deadline for developing or updating financial plans that was included as a corrective action for approval of the current FSTIP. However, we will be expecting compliance with financial planning requirements listed in 23 CFR 450.324(e) to be demonstrated with submission of your 2004/05 FTIP to Caltrans.

We appreciate that you have included a task under Work Element 706.00 to update your financial plan for the FTIP. As a reminder, financial plan requirements and financial constraint are applicable to both the FTIP and RTP, so the MPO financial plan should be a document that demonstrates and responds to financial constraint requirements for a timeframe covering the current FTIP through the current RTP planning horizon. In consideration of these requirements, the FHWA recommends that Shasta RTPA consider explicitly identifying financial plan development or updating activities in the OWP as a separate work element, or as a task under both Work Element 701.00 - Preparation and Administration of the Regional Transportation Plan, and Work Element 706.00 - Preparation and Administration of the Regional Transportation Improvement Program (RTIP) and the Federal Transportation Improvement Program (FTIP).

Annual Listing of Projects

The FHWA reminds Shasta RTPA that per requirements listed in Title 23, Chapter 1, Subchapter I, Section 134, (h)(7)(B), you are required to publish an annual listing of projects for which federal funds were obligated in the preceding year. If you have not yet published your FY 2003 annual listing of projects, we would like to discuss this further at the IPG meeting.

Air Quality Conformity

The most recent information that FHWA has received from EPA indicates that Shasta County will not be designated as a new non-attainment area under the 8-hour standard for ozone. We expect EPA to provide final information on the new 8-hour ozone area designations on April 15, 2004. The FHWA would thus encourage Shasta RTPA to consider re-directing some of the resources in the draft OWP that are currently provided for air quality conformity activities, developing and monitoring the CMAQ process, etc.

Public Involvement and Title VI/Environmental Justice

While the narrative in Section I of the OWP provides a broad discussion of public involvement and Title VI/environmental justice-related efforts, we. find that in your work elements, the documentation is more limited, and much that is related to public involvement and Title VI/environmental justice, is concentrated under Work Element 709.00 - Interagency Coordination and Development of the Overall Work Program. We recommend that you include the Section 1 and Work Element 709.00 efforts, and others as appropriate, in a consolidated, separate work element for public involvement and Title VI/environmental justice, or possibly as part of Work Element 701.00 - Preparation And Administration Of The Regional Transportation Plan.

Please provide an. update, at the IPG meeting, on your efforts to initiate formal consultation and dialogue on transportation issues with the Redding Rancheria and Pit River Tribal Council.

Other Comments on Specific Work Elements/OWP Sections Congestion And Air Quality, Page 8

The last sentence regarding the 8-hour ozone standard needs clarification. As discussed above, the narrative under this heading could be modified based on the most recent 8-hour ozone information that the FHWA has received from the EPA.

Work Element 702.00, Task 702.09 - Safety management of the road network with officials, Page 25

It appears that this task consists of activities that may be more operational than planning-related, and may be ineligible for FHWA PL funds.

Work Element 704.00, Task 704.01 - Implement non-motorized element of the RTP, Page 29

It appears that this task consists of activities that may be more related to project implementation, rather than planning, and may be ineligible for FHWA PL funds.

Work Element 705.00 Aviation, Pages 31-32

Tasks under this work element do not involve surface transportation, and are not eligible for FHWA PL funding.

Work Element 707.00 - Transportation Development Act (TDA) Administration

As written, it appears that many of the tasks under this work element may be ineligible for FHWA PL funding. The FHWA requests that Shasta County RTPA clarify what specific tasks and activities listed under this work element will be accomplished with FHWA PL funds.

Work Element 710.00 - Special Proiects

There are numerous projects, tasks, and activities lumped together under this work element. However, as written, the purpose is not sufficient to provide a complete understanding of everything that is to be accomplished. We suggest that Shasta RTPA consider breaking these projects down into separate work elements.

Thank you for the opportunity to review your draft OWP. We are looking forward to the IPG meeting scheduled for Tuesday, April 13, 2004, at 8:30am. If you have any questions, or need further explanation of these comments, please contact Leigh Levine at (916) 498-5034.

Sincerely,

Gene K. Fong

Division Administrator